New Regulations - Feed Additives and Medications
There are still many doubts about the implementation of the above measures even though they came into effect from early May. BVPA has a long list of questions which VMD have not yet answered. However the main effects of this legislation appear to be:
1. Previous PML products cease being considered medicines and are now called "Zootechnical Additives". Anticoccidials and GP's will need to be used in accordance with the listing in the appendix to the EU directive (and cannot be adjusted upwards or downwards by prescription). As far as I can see all applications for commercial poultry match the previous UK license for these products. There is no obligation to use the previously UK-licensed products - generics are legally acceptable (though whether your customers will accept them is another issue). This is a temporary effect since the EU system is being changed so that all products will require individual brand-specific licenses. "Generics" will no longer be permissible once a brand-specific license is issued (unless the supplier also achieves such a license). I attach a listing of products and approvals which is, as far as I can gather, up-to-date. The final listing has yet to be issued.
2. The dose of the above products may take into account on-farm further dilution (e.g. with grain) and this will not require a prescription (unless a prescription only product such as an antibiotic is also included).
3. The MFS Prescription replaces the VWD and contains most of the information the mill is used to but in a different format. We have already implemented this following the format in the directive as closely as possible. Data we hold on previous VWD's remains available in the same data-base which now prints MFS's. The MFS Prescription, though valid for 3 months, may only cover 31 days supply. The 31 days runs from first shipping of feed (not the date on the script) but cannot go beyond 3 months from the date on the script. These requirements will affect your mill recording procedures. There is no effect on ordering prescription medicines or feed additives. This provides us with some extra flexibility but we would not anticipate routinely issuing scripts 1-2 months in advance of their required use date.
4. Opinion is divided as to whether zootechnical additives may/should appear on the MFS Prescription. We are taking the view that it is beneficial to continue to list these products to help prevent accidental compatibility problems.
5. Only 1 medicated premix may be incorporated in a diet (the zootechnical additives do not count!), whether or not wormers count is questionable (they are currently exempted from prescription status pending an EU consultation. There is another exception to this rule (called a 'mini-cascade') but this will not normally be applicable to commercial poultry.
6. Feed mills will have to be licensed under the new regulations - applications need to be in by September. Consult RPSGB for details.\par \par If it is any consolation these regulations have much more severe effects for the game bird industry since many products do not have licenses for game birds under the EU legislation. If any of you are manufacturing game bird feed we would be happy to advise on the implications.
If you have any queries arising from this please do not hesitate to contact one of us.