Importation and use of veterinary medicines under exceptional circumstances
Given the range of species and conditions that exist in veterinary medicine it is not practical to have authorised products available for each situation. EU and national legislation recognise the need for veterinary practitioners to avail of a number of tools to improve the position.
Use of medicines under the ‘cascade’ principles
National and EU legislation recognise the need for veterinary practitioners in exceptional circumstances to be able to use certain medicines off-label (i.e. not strictly in accordance with the conditions of authorisation of the medicine). This is commonly referred to as use under the ‘cascade’ provisions of the legislation, and applies exclusively to vets. The Department of Agriculture, Food & the Marine (DAFM) is the competent authority for giving advice on the use of the cascade provision, including the importation of veterinary medicines from another country where there is no suitable medicine authorised in Ireland (the so-called AR 16 and AR 18 licensing procedures).
Such licences may be granted by the DAFM when there is a particular health situation (e.g. an outbreak of an infectious disease that normally does not occur in Ireland) or where no authorised veterinary medicinal product is available in this country but one is available in another Member State of the European Union.
Supply and use of human medicines in veterinary practice
According to articles 112, 113 and 114 of European Regulation 2019/6 (the so-called ‘cascade’ provisions), when a suitable veterinary medicinal product is not available in this country, veterinary practitioners are entitled to use certain human medicines under particular circumstances. To access these medicines, veterinary practitioners may source them from a retail pharmacy in Ireland, or from an Irish wholesaler authorised to supply human medicines.
Irish wholesalers of human medicines are permitted to supply human medicines to veterinary practitioners in accordance with applicable national legislation. The definition of ‘supply by wholesale’ detailed in regulation 4(1) of the Medicinal Products (Prescription and Control of Supply) Regulations 2003, as amended. It states that
‘supply by wholesale’ means the supply of a medicinal product to a person who obtains the product for one or more of the following purposes:
(a) supply in the course of a pharmaceutical business,
(b) administration in the course of a professional practice, or
(c) for or in connection with a service provided by a hospital.
The HPRA interprets ‘professional practice’ as including professional practice by a registered veterinary practitioner; veterinary practitioners have an ethical and professional responsibility to treat animals in order to relieve or prevent animal suffering.
In accordance with the ‘cascade’ provision in Regulation 2019/6, human medicines that are either authorised centrally (following the recommendation of the European Medicines Agency), or which are authorised in Ireland or in another EU Member State as a medicinal product for humans, can exceptionally be supplied to veterinary practitioners in situations where there is not an authorised veterinary alternative available.
Note that the ‘cascade’ provisions in Regulation 2019/6 do not entitle veterinary practitioners to access or use human medicines which have been supplied into Ireland without a marketing authorisation (e.g. human medicines that are imported under special conditions for specific or compassionate use for human therapy but which do not have marketing authorisations, human medicinal products that are authorised in the UK but are not authorised in Ireland etc.).
The HPRA understands that veterinary practitioners who wish to order human medicines from a human medicines wholesaler in Ireland should not write a prescription (which should only be filled by a retail pharmacy) but that the records should be kept (e.g. in the veterinary practitioner’s order book). It is suggested that veterinary practitioners making such orders should confirm in his/her order that the medicines sought are for use in animals under their care and in accordance with his/her professional practice.
Responsibility for exceptional licensing procedures rests with the DAFM and queries on the application requirements should be directed to them (firstname.lastname@example.org or Lo-call 1890 200 510).
Importation of veterinary medicines for which an equivalent product is already authorised
It is legally possible for a company to import a veterinary medicine that is already authorised in Ireland but is available more cheaply in another EU Member State. This procedure is governed by regulations and requires the applicant to seek authorisation from the HPRA under the so-called ‘parallel veterinary product authorisation procedure’.
There are a number of conditions which attach to such applications, including that the parallel‐distributed product must be the same as that already authorised in Ireland and that the labelling and package insert of the product are based on those approved by us for the existing product. The repackaging must be carried out in a manufacturing facility which has a veterinary manufacturing licence in accordance with Good Manufacturing Practice (GMP). An application fee applies. The product will be allocated a parallel veterinary product authorisation number. For further details please click here.
The appropriate forms are available on the Department’s website. Any further queries should be directed to email@example.com or by telephone on 01 615 7100.