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News & Reports veterinary medicines
Survey provides insight into prescribing under the cascade More than half of the veterinary surgeons who responded to a survey carried out by the Veterinary Medicines Directorate (VMD) last year agreed that without the flexibility provided by the prescribing cascade, animal welfare would suffer. The VMD has recently published a summary of the responses it received to the survey, which it carried out between April and July 2013 as part of an evidencegathering exercise to help inform the UK’s negotiating position during the ongoing revision of the European directive governing veterinary medicines. The VMD notes that, when the revision process began, the European Commission raised concerns about the use of the prescribing cascade; however, it says, more recent advice from the Commission has indicated that the importance of the prescribing cascade has been recognised, and its existence is unlikely to be questioned. The VMD adds that the UK’s view is that the cascade is essential for animal health and welfare. The VMD reports that it received some 230 responses to the survey, providing ‘some interesting information which will be useful in developing future policy’. Most of the respondents worked in first opinion practice and almost half worked in small animal practice. Many (107) of the vets responding to the survey said that they used the prescribing cascade ‘several times a day’, while 37 said that they used it once a day, 41 that they used it three to four times a week and 20 said they used it once a week. The species and conditions that respondents said they prescribed for under the cascade for ranged from enteric red mouth and sea lice in fish, through bacterial infections and pain relief in exotic species, to diarrhoea in dogs and cats. The main reason given as to why the cascade needed to be used was that there was only a limited number of authorised products available for particular species or conditions. The VMD reports that, when vets were asked what was good about the prescribing cascade, the most common answer was that it provided flexibility to choose the medicine that was most appropriate for the animal
Prescribing cascade Under the provisions of Schedule 4 of the Veterinary Medicines Regulations 2013, the prescribing cascade may only be used exceptionally and only to avoid causing unnecessary suffering to the animals concerned. In the absence of a medicine authorised for a condition in a particular species, the provisions allow a veterinary surgeon to prescribe or administer, in descending order of preference:
n A medicine authorised for use in the same species for a different condition, or for the same condition in a different species; n A medicine authorised for human use, or, a medicine authorised in another member state for use in any animal (in the case of a food-producing animal, it must be a food producing species); n A medicine specially prepared at the time to the veterinary surgeon’s specifications (extemporaneously prepared product). presented, even if that medicine was not authorised for that use. Another positive was that the cascade provided guidance and structure for veterinary surgeons when considering what medicine to prescribe. Responses to a question about what was bad about the cascade included that it was too restrictive, complex and cumbersome and that it impacted negatively on the cost of medicines (with the comment being made that human ‘generic’ medicines were prohibited from being used, even though they might be significantly cheaper than authorised veterinary versions). Respondents felt that a number of improvements could be made to the cascade, including allowing cost to be considered as a factor when selecting what medicine to prescribe. Also, they suggested, human generic medicines should be allowed to be used on cost grounds. Other suggestions included relaxing the provisions for
non-food-producing species and making the provisions less restrictive and bureaucratic. The VMD reports that, when asked what the impact on animal health and welfare might be if the cascade could no longer be used for food-producing animals, almost 41 per cent of respondents felt that the outcome would be ‘very bad’. Comments suggested that the impact on animal welfare would be significantly detrimental, especially for minor species such as goats, gamebirds, turkeys, pheasants and horses. A small percentage of respondents said that the removal of the cascade would allow veterinary surgeons to prescribe without restriction. Over half of those responding to the survey felt that the impact on animal health and welfare in non-foodproducing animals would also be ‘very bad’ if the cascade could no longer be used. Respondents’ comments suggested that there would be inadequate care and treatment of animals for conditions where there were no authorised medicines. A small percentage of respondents said that removal of the cascade would benefit animal welfare by encouraging a greater focus on animal management, nutrition and preventative techniques. When asked for general comments about the cascade, many respondents said that the provisions allowing veterinary surgeons to use treatment options other than authorised medicines must be maintained for animal welfare reasons as there were not enough authorised treatments for every condition. Other comments suggested that respondents believed that the cascade had value in the treatment of food-producing species in terms of preventing residues from treated animals, but that it should be relaxed for pet or companion animals, with treatment options being left to the veterinary surgeon’s professional judgement. n The VMD’s summary of the responses to the survey can be downloaded from www.vmd.defra.gov.uk/public/vmr_review. aspx doi: 10.1136/vr.g3265 May 17, 2014 | Veterinary Record | 489
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