Page 1 of 32 Report of the Working Group on the Methods of Supply of Companion Animal Antiparasitic Medicines June 2010 Page 2 of 32 Chapter 1. Introduction & preamble 1.1 Introduction [Background to IMB request] 1.2 Preamble [Background to use of antiparasiticides in companion animals] Chapter 2. Background 2.1 Historical Perspective on the Supply of Companion Animal Antiparasiticides in Ireland 2.2 Legal and Regulatory Constraints on the Distribution of Companion Animal Antiparasiticides in Ireland 2.3 Current Situation in Relation to the Distribution of Companion Animal Antiparasiticides in Ireland Chapter 3. Problem Analysis 3.1 Scope 3.1.1 Zoonotic considerations 3.1.2 Resistance 3.1.3 Benefit risk assessment 3.1.4 Internet selling 3.1.5 Advertising 3.2 Position of Other EU Member States 3.3 Additional considerations 3.4 Methodology Used and Feedback Analysis 3.5 Perspective of Interested Parties 3.6 Observations of the Working Group on the Submissions Received Chapter 4. Conclusions, Impact Analysis and Proposed Classification Criteria 4.1 Conclusions 4.2 Proposed Classification Criteria 4.3 Impact Analysis Appendices 1. Terms of Reference of Working Group on Classification of Methods of Supply of Companion Animal Antiparasiticides 2. Membership of the Working Group 3. Original Criteria for allocating veterinary medicines to categories 4 .Routes of Supply for Veterinary Medicines established by Schedule 1, Part 1 of SI No. 786 of 2007 5 .Criteria established by SI No. 786 of 2007 in designating the Route of Supply 6. Draft EMA criteria for exemption of veterinary medicinal products authorised under the centralised system from the requirement for a veterinary prescription. 7. Interested Parties who made Submissions to the Working Group 8. Listing of Companion Animal Antiparasiticides with their Existing and Recommended Routes of Supply Page 3 of 32 Chapter 1, Introduction & Preamble 1.1 Introduction The Working Group (WG) on classification of methods of supply of veterinary antiparasitic products was established by the Board of the Irish Medicines Board (IMB) on 25 June 2009 following an earlier recommendation by the IMB’s independent scientific committee on veterinary medicines, the Advisory Committee for Veterinary Medicines (ACVM). The WG was charged with the tasks of reviewing the current methods of supply of veterinary antiparasitic agents intended for use in companion animals and preparing a guidance document for the IMB on the most appropriate criteria to allocate such products to the various national supply routes available, taking into consideration the effect of national legislative changes in 2007 to the distribution of veterinary medicines as well as the relevant risks and benefits associated with use of the products and any practical considerations. The scope of the review excluded medicines which have been authorised by the EU Commission. The terms of reference of the WG are attached in Appendix 1. The members of the WG are presented in Appendix 2. 1.2 Preamble Veterinary medicines which can treat or control internal and external parasites of dogs and cats offer both animal health and public health benefits. Under Directive 2001/82/EC1 (hereafter referred to as ‘the Directive’) applicant companies must provide data on the quality, safety and efficacy of each medicine so that the conditions under which a product will perform effectively and safely can be ascertained and documented. In relation to the safety assessment, the legislation requires that the risks be identified and characterised and that appropriate risk management measures be applied. Amongst the risk management options available to the IMB as competent authority is that of restricting the distribution of the medicine to professional persons such as veterinary practitioners or pharmacists. The policy of the IMB in allocating a method of supply for veterinary antiparasitic products for dogs and cats pre‐dates the change in national legislation relating to the supply of prescription medicines in 2007. One of the consequences of the change was that certain medicines which were subject to veterinary prescriptions could be dispensed by certain non‐pharmacy outlets (previously veterinary prescriptions could be dispensed only by pharmacies). Many such products which were originally restricted as prescription‐only medicines have maintained this classification since the date of their original authorisation many years ago and despite a long record of safe and effective use in the meantime. Given the impact of the 2007 legislative changes relating to the supply of certain categories of veterinary medicines and following a review of methods of supply of such antiparasitic medicines for dogs and cats in a number of EU Member States it is timely for the IMB to review the suitability of the allocated national methods of supply of the antiparasitic group of veterinary medicines which 1 Consolidated Directive 2001/82/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to veterinary medicinal products as amended by Directive 2004/28/EC Page 4 of 32 are used for routine or prophylactic use for the control of parasites in companion animals (even if only to confirm the suitability of the existing methods of supply). National legislation2 provides that antiparasitic drugs intended for use solely for aquarium fish, caged birds, homing pigeons, terrarium animals, small rodents, ferrets and pet rabbits may, following an application to the IMB, be exempted from the requirement of having an animal remedies authorisation. Therefore, this Report is concerned exclusively with recommendations for supply of antiparasitic medicines to dogs and cats. As with all medicines there are certain risks related to the use of antiparasitic medicines and the IMB must, as the national competent authority, ensure that the risk mitigation measures are appropriate and sufficient. Risk mitigation measures have to take into account the intended target user group for the product and will include such controls as: • The quantity or strength of drug available or amounts to be administered, • The potential user exposure to the drug and the nature of the product container, • The adequacy and prominence of product warnings and instructions, • The adequacy of any literature accompanying the product advising on safe and effective use, • The method of supply of the product to the end user, • The need for professional involvement in their use (e.g. point‐of‐sale advice, need for prior diagnosis, administration). In exercising its role, the IMB must be mindful of the proportionality of any new proposed restrictions, especially in relation to veterinary medicines which have been authorised for several years. However, the rationale for any approach should be clearly set out as the principles will form the basis for future decisions on new products in this sector. It should be noted that all new veterinary medicines are authorised for an initial period of five years. Those that contain a new active substance are required to be restricted to supply on a prescription‐ only basis at the time of initial authorisation3 (see also section 3.3 of this report). After the initial five‐year period, an authorisation may, on application to the IMB and provided the benefit/risk balance underpinning it remains favourable, be renewed indefinitely thereafter. The principles enunciated in this document are expected to be applied at the time of renewal of the marketing authorisations for antiparasitic veterinary medicines for dogs and cats which are authorised nationally. 2 Regulation 3(3)(a)(ii) of the European Communities (Animal Remedies)(No.2) Regulations 2007 [SI No 786 of 2007] 3 Article 67, Directive 2001/82/EC as amended Page 5 of 32 Chapter 2, Background 2.1 Historical Perspective on the Supply of Companion Animal Antiparasiticides in Ireland Until the mid 1980s there were limited controls on the supply of antiparasitic veterinary medicines in Ireland. Those which existed were based on a schedule of active ingredients e.g. the Poisons Regulations, 1983 and the Animal Remedies (Control of Sale) Regulations, 1985. Following the establishment of national legislation governing the authorisation of veterinary medicines in 1986, companion animal antiparasitic medicines were assigned supply routes varying from prescription control to general sale based either on the legal schedules or an evaluation of the risks involved in using the products concerned. In point of fact, many products were not assigned a method of supply by the Irish Medicines Board or its predecessor, the National Drugs Advisory Board, until the late 1990s by which time new legislation, the Animal Remedies Regulations, 1996 came into being. That legislation set out six supply categories as follows: Veterinary Surgeon use Only (VSO), Prescription Only Medicine (POM), Prescription Only Medicine Exempt (POM[E]), Pharmacy Sale (PS), Licensed Merchant (LM) and Companion Animal Medicine (CAM). The criteria applied by the IMB in allocating a suitable method of supply to veterinary medicinal products at that time are provided in Appendix 3. The national legislation has been revised several times since the criteria were set. 2.2 Legal and Regulatory Constraints on the Distribution of Companion Animal Antiparasiticides In Ireland European Union legislative constraints and scientific principles on the supply of veterinary medicinal products are established under Article 67 of the Veterinary Directive4. This states that: “Without prejudice to stricter Community or national rules relating to dispensing veterinary medicinal products and serving to protect human and animal health, a veterinary prescription shall be required for dispensing to the public the following veterinary medicinal products: (a) those products subject to official restrictions on supply or use, (b) those products in respect of which special precautions must be taken by the veterinarian in order to avoid any unnecessary risk to the target species, the person administering the products to the animal and the environment, (c) those products intended for treatments or pathological processes which require a precise prior diagnosis or the use of which may cause effects which impede or interfere with subsequent diagnostic or therapeutic measures. In addition, a prescription shall be required for new veterinary medicinal products containing an active substance that has been authorised for use in veterinary medicinal products for fewer than five years unless, having regard to the information provided by the applicant, or experience acquired in the practical use of the veterinary medicinal product, the competent authorities are satisfied that none of the criteria referred to in (a) to (c) apply”. 4 Directive 2001/82/EC as amended Page 6 of 32 Article 68 of the Veterinary Directive states that Member States shall take all measures necessary to ensure that only persons empowered under their national legislation in force possess or have under their control veterinary medicinal products which have antiparasitic properties. Current national legislation5 sets out seven supply categories for veterinary medicines authorised in Ireland. These are presented in Appendix 4 and the legislative criteria underpinning them are presented in Appendix 5. The IMB is obliged to follow specified criteria outlined in the legislation in designating a suitable route of sale. There are no criteria established by legislation relating to medicines which might be designated Licensed Merchant (LM) or Companion Animal Medicine (CAM). At the time of initial drafting of this Report (April 2010) all antiparasitic products authorised for cats and dogs had been assigned to either POM or CAM routes (53 POMs and 47 CAMs). 2.3 Current Situation in Relation to the Distribution of Antiparasitic Agents for Companion Animals in Ireland The main interested parties involved in the dispensing and supply of antiparasitic products for companion animals in this country are the animal health industry itself, veterinary practitioners (either directly or under prescription for animals under their care), pharmacists (from pharmacies, either by the pharmacist or under the personal supervision of the pharmacist) and those licensed by the Department of Agriculture, Fisheries and Food (DAFF) either to supply animal remedies generally or to supply companion animal medicines specifically. While Licensed Merchants are entitled to supply companion animal medicines such products are typically not supplied through LM outlets. The roles of the interested parties are described below. Animal Health Industry Veterinary manufacturers supply their products to users usually via a network of wholesalers to veterinary practitioners, pharmacists, Licensed Merchants and licensed CAM outlets. The animal health industry is not entitled to advertise prescription‐only medicines to the public. However, it is entitled to promote and advertise antiparasiticides which are not subject to prescription‐control through relevant media to various end users. The distribution of veterinary medicines is governed by legislation and is under the control of the DAFF. A feature of the control exercised is a significant emphasis on record keeping and traceability of medicines from manufacturer through to user. Veterinary Practitioners, Pharmacists and Licensed Merchants are required to keep records of all animal remedies supplied (including those labelled CAM). However, companion animal medicine outlets which are registered with the Department of Agriculture, Fisheries and Food are not required to keep such records. 5 Schedule 1, Part 1 of the European Communities (Animal Remedies) (no. 2) Regulations 2007, (SI No. 786 of 2007) Page 7 of 32 Veterinary Practitioners This group plays a unique role in the control of veterinary medicines. Veterinary practitioners are trained in the control of diseases, in epidemiology and veterinary medicine. They are expected to have first‐hand knowledge of animal diseases including any change in the local prevalence and expression of the disease. They are also expected to be familiar with the animal history and husbandry conditions. They also have knowledge of biosecurity measures and diagnostics as well as available vaccines and therapies and other methods for controlling disease. They are also expected to be in a position to evaluate the understanding and competence of the animal owner to adhere to advice given and to administer medicines. Veterinary practitioners are the profession qualified and authorised6 to conduct a clinical examination of animals. Only veterinary practitioners are entitled to write a veterinary prescription. In accordance with Regulation 28(6) of SI No. 786 of 2007, a veterinary practitioner does not have to write a prescription for companion animals under his care, where an offer to do so has been made but declined. Pending the lifting of a derogation in 2011, Veterinary Practitioners are required to certify the passports of dogs and cats entering the European Union and transiting from the European mainland to Ireland to ensure that such animals have received appropriate treatment for the control of ticks and the tapeworm Echinococcus multilocularis. Veterinary practitioners are subject to annual registration with the Irish Veterinary Council and they must register their practice premises to ensure compliance with minimum standards. Those who fail to abide by the ethical and statutory rules in force or who fail to meet or maintain fitness to practice standards are liable to disciplinary procedures, including removal from the Register with consequential effects for their livelihood. If they fail to conform to the national legislation they may also face prosecution by the courts. In accordance with the applicable legislation, where a prescription is written for a POM designated veterinary medicine, such prescriptions may be dispensed by the veterinary practitioner, by another veterinary practitioner within the same group practice, by a pharmacist or by a licensed merchant. As regards the supply of veterinary medicines which are designated POM, veterinary practitioners may supply such products only in respect of animals entrusted to their care and may not supply them to members of the general public whose animals have not been so entrusted. Veterinary practitioners are not entitled to supply medicines labelled LM to the general public unless the animals concerned have been entrusted to their care or unless an appropriate licence has been obtained from the DAFF. Veterinary practitioners are however entitled to supply antiparasitic products labelled CAM to the general public. Pharmacists Pharmacy undergraduates spend four years reading pharmacy to degree level. On graduation, pharmacists spend a further year under the supervision of a tutor pharmacist further developing their dispensing and advisory skills. All pharmacy graduates in Ireland undergo training in veterinary pharmacy. They are therefore trained and competent to give advice on all medicines and are an easily accessible resource for the public seeking such advice. All pharmacists and pharmacies within 6 Veterinary Practice Act 2005, No. 22 of 2005 Page 8 of 32 the State are now subject to annual registration with the Pharmaceutical Society of Ireland (PSI)7. Pharmacists must undertake continued professional development and are also subject to fitness to practice provisions. Each pharmacy must comply with regulations and standards specified by legislation through adherence to codes of conduct issued by the PSI. Those who fail to abide by the ethical and statutory rules in force or who fail to meet or maintain fitness to practice standards are liable to disciplinary procedures, including removal from the Register with consequential effects for their livelihood. Pharmacists and pharmacies may also be prosecuted in the courts for failing to comply with the legislative requirements. A pharmacist may supply veterinary medicines classified as POM products to the public on foot of a veterinary prescription. A pharmacist may supply veterinary medicines labelled as POM(E) to members of the general public provided that the veterinary medicine in question is dispensed in person by the pharmacist. Veterinary medicines labelled as LM or CAM may be also supplied to the public (with or without prescription) from a pharmacy shop. Veterinary medicines labelled as ‘Pharmacy Sale’ (PS) may also be supplied from a pharmacy shop, although such products need not be dispensed by the pharmacist in person. It is estimated that, at present, the majority of the 1700 registered pharmacies in the State are involved in supplying veterinary medicines for use in companion animals. Licensed Merchants The national legislation provides that endo‐ and ecto‐ parasitic veterinary medicines can be supplied via licensed merchants in two situations: 1. Those which are regulated as CAM or LM products may be supplied to the general public without prescription. 2. Those which are regulated as POMs, provided a veterinary prescription has been issued for the product specified. While licensed merchants typically supply medicines intended for food‐producing animal species, the legislation does not discriminate between antiparasitic medicines for livestock and those intended for dogs and cats. Therefore, such outlets may also dispense antiparasitic medicines labelled POM and intended for dogs and cats (on foot of a valid prescription). Licensed merchants are not entitled to supply medicines labelled as POM(E). The licensed merchant trade is operated both by private merchants and by co‐operative societies. Only those premises which meet specified standards established by the DAFF and where a retail assistant trained and accredited as a ‘responsible person’ is present are deemed to qualify as LM. Persons engaged by licensed merchants to retail antiparasitic medicines are not ordinarily members of a regulated professional body and are not therefore subject to fitness to practice sanctions in the event of lack of conformity with legislative requirements. However, LMs are regulated by the DAFF and as such are subject to inspection by authorised officers of DAFF whereby their licences may be 7 Pharmacy Act 2007, No. 20 of 2007 Page 9 of 32 suspended, varied or revoked by the Minister if necessary. They may also be subject to prosecution in the courts if they fail to uphold their legal requirements. Companion Animal Medicine Sellers The DAFF has registered some 450 CAM sellers. Currently, there is no requirement for any inspections of premises or vetting of applicants. Unlike the position of other retailers and veterinary practitioners supplying companion animal medicines, a CAM seller is not required to keep records of purchases and sales. Persons engaged as CAM sellers of retail veterinary antiparasitic products are not ordinarily members of a regulated professional body and are not therefore subject to fitness to practice sanctions in the event of lack of conformity with legislative requirements. However, CAMs are registered by the DAFF and as such their registrations may be suspended or revoked by the Minister if necessary. They may also be subject to prosecution in the courts if they fail to uphold their legal requirements. Page 10 of 32 Chapter 3, Problem Analysis 3.1 Scope In order to understand the impact of the route of supply category on the benefits and risks associated with use of antiparasitic medicines the WG considered the situation insofar as it might affect animal welfare, as well as the risk implications related to the use of the products, including zoonotic risks and related matters. In the knowledge that any change to the route of supply will have a consequential impact on the wider availability of the products concerned, while restricting products might act as a barrier to remove potentially useful veterinary medicines from the casual reach of the public, the risks are further considered hereunder. 3.1.1 Zoonotic considerations Several parasites of dogs and cats may be transmitted to humans and therefore pose a potential zoonotic risk. These include Toxocara spp. in particular, although infestations with parasites not native to Ireland e.g. Echinococcus spp. might also occur exceptionally. Regular treatment of animals with appropriate medicines is necessary to minimise infestation pressure, while control of the parasitic eggs and larvae in the environment is needed to reduce the zoonotic risks. Such risks are greatest in young children and in immunocompromised individuals. No direct risk to humans from ticks attached to dogs or cats has been reported. Lice are host specific and are not considered to present a zoonotic risk. However, fleas are capable of transferring easily between animals and humans. 3.1.2 Resistance Although anthelmintic resistance is a developing issue in respect of livestock and bloodstock, there have been few documented reports of anthelmintic resistance in dogs and cats8. Concern has been expressed however9 that the use of regular anthelmintic treatments for dogs, regardless of their ages and without any association with a particular parasite or strategy might hasten the appearance of drug resistance. The European Scientific Counsel on Companion Animal Parasites (ESCCAP)10 recommends that treatment strategies for anthelmintics avoid excessive or unnecessary worming and be risk‐based rather than blanket‐based. There have not been any proven cases of resistance or treatment failure concerning the treatment of ticks or insect dwellers in companion animals. However, ESSCAP11 recommends that unnecessary treatments be avoided and rotations between drug classes at intervals of one to two years be considered. 8 Koop, S. 2008. Pyrantel Resistance in the Canine Hookwork, Ancylostoma caninum. PhD Thesis, School of Veterinary Science, University of Queensland. (http://espace.library.uq.edu.au/view/UQ:159784) 9 Thompson R.C.A. and Roberts, M.G. 2001. Does pet helminth prophylaxis increase the rate of selection for drug resistance? Trends in Parasitology, 17 (12), 576‐578. 10 European Scientific Counsel Companion Animal Parasites, Guideline 1, December 2006, (http://www.esccap.org/index.php/fuseaction/download/lrn_file/001‐esccap‐guidelines‐ukfinal.pdf) 11 European Scientific Counsel Companion Animal Parasites, Guideline 3, March 2009, (http://www.esccap.org/index.php/fuseaction/download/lrn_file/esccap‐ecto‐guidelines‐27march09.pdf)
Description: