h. Medicines (dart guns)

When veterinary surgeons receive requests to prescribe medicinal compounds for use in dart guns they should consider carefully every aspect of the request. The medicines supplied for use in dart guns, such as Large Animal Immobilon are very potent. If they are not fully confident of their grounds in prescribing, they should refer the request to a more knowledgeable colleague.

Veterinary surgeons should take great care to ensure that any Large Animal Immobilon they prescribe or use is not administered to deer, or any other animals, which may subsequently be killed or slaughtered for meat production.  The same position applies to the use of any other medicine not licensed for use in food-producing animals.

Veterinary surgeons administering Large Animal Immobilon, or any other immobilising medicine not licensed for use in a food-producing animal, must mark permanently, with an appropriate tag (see 1 below) in each ear, any deer (farmed or wild), or if relevant dispose of the carcass, to ensure, so far as practicable, that such animals will not enter the human food chain. 

Before any supply is made a written agreement to supply should be signed by both the dart gun licence holder and veterinary surgeon. This should include the following points, which as appropriate should be adhered to by both parties to the agreement:

1. Details of the dart gun licence holder's firearms licence with expiry date. (Generally a separate Home Office licence will not be required [see 2 below].)
2. Recognition that a veterinary surgeon cannot supply medicines to a dart gun licence holder per se, but can supply only for animals under the veterinary surgeon's care.
3. Recognition that medicines will be supplied only to the dart gun licence holder in person, and only in sufficient quantities for immediate use.
4. Confirmation that only the dart gun licence holder will handle the medicines after he or she has received them and when not being used will be kept in a nominated locked place.
5. That the veterinary surgeon will require a signed receipt for each supply of medicines used for restraint, such as Immobilon. The signed receipt to be retained together with the written agreement for at least two years from the date of the last supply.
6. Arrangements for the veterinary surgeon to visit the area where the animals are kept to check on their general health and condition and ensure appropriate numbers of animals are marked permanently.
7. Confirmation that the dart gun licence holder has been instructed in the use of the gun and medicines (see 3 below).
8. Confirmation that the dart gun licence holder has been told what to do in an emergency e.g. a person being struck by a dart. There should be details in the written agreement on the use of specified antagonists to the tranquilliser and on appropriate resuscitative and first aid measures. Where a specific antagonist is available the veterinary surgeon should also ensure that the antagonist is available for use by the dart gun licence holder in an emergency.
9. Confirmation that the dart gun licence holder after administering Large Animal Immobilon, or any other immobilising medicine not licensed for use in a food-producing animal, will mark permanently, with an appropriate tag (see 1 below) in each ear, any deer (farmed or wild), or if relevant dispose of the carcass, to ensure, so far as practicable, that such animals will not enter the human food chain. 
10. Confirmation that the dart gun licence holder will keep records of medicines used for each identifiable animal and that at least yearly these records will be reviewed by the veterinary surgeon.
11. That a written copy of the Food Standards Agency's advice on the use of Large Animal Immobilon in deer (and general advice on medicines not licensed for use in food-producing animals) (Veterinary Director, Food Standards Agency letter in the Veterinary Record, December 6, 2003 [see 4 below]) is part of the agreement and has been explained to the dart gun licence holder by the prescribing veterinary surgeon.
12. Confirmation that the dart gun licence holder will provide, in writing, the number of animals of each species, on each holding (see 5 below), administered with medicines not licensed for food-producing animals, such written records to be retained by the veterinary surgeon.
13. Confirmation that the owner (who may not be the client) of an animal administered a medicine not licensed for use in a food-producing animal, will be advised by the dart gun licence holder that the animal must not be allowed to enter the food chain at any time in the future.

Notes

1. The tags are Ketchum tags stating 'EAT NOT' and are available from the Veterinary Deer Society by contacting Mr J Peters MRCVS at julian@arthurlodge.co.uk. 

2.  Section 8 of the Firearms (Amendment) Act 1997 states: -

"The authority of the Secretary of State[or the Scottish Ministers (by virtue of the provision made under Section 63 of the Scotland Act 1998]  is not required by virtue of subsection (1)(a), (b) or (c) of Section 5 of the 1968 Act for a person to have in his possession, or to purchase or acquire, or to sell or transfer, any firearm, weapon or ammunition designed or adapted for the purpose of tranquillising or otherwise treating any animal, if he is authorised by a firearm certificate to possess, or to purchase or acquire, the firearm, weapon or ammunition subject to a condition restricting its use to use in connection with the treatment of animals."

3. The Veterinary Medicines Regulations 2005 requires that a veterinary surgeon who prescribes and supplies a POM-V, must:

a. prescribe for animals under his or her care;

b. prescribe after having carried out a clinical assessment of the animals;

c. prescribe the minimum amount for the treatment;

d. on supply, always advise on the safe administration of the veterinary medicinal product;

e. on supply, advise as necessary on any warnings or contra-indications on the label or package leaflet; and,

f. on supply, be satisfied that the person who will use the product is competent to use it safely, and intends to use it for which it is authorised.   

4.  SIR - The Food Standards Agency issued a warning in October against consuming venison from deer potentially exposed to Immobilon.  This resulted from an incident in which deer, confined in a park, were tranquillised with etorphine (Large Animal Immobilon; Novartis Animal Health UK) so that they could be transported for release into the wild and shot, primarily for sport, although their carcases were subsequently supplied to game dealers. 

A number of ethical issues arise.  However, the Agency's concern was the very real risk that meat containing residues of the active ingredients contained in Immobilon could have found their way into the food chain.  It would appear from this incident that the legal position with regard to the prescription and use of medicines not authorised for food animal species, such as Immobilon, needs clarifying.  The Royal College of Veterinary Surgeons' Guide to Professional Conduct, in its Annex on Prescribing of Medicines, paragraph 24, advises that anaesthetics and analgesics should not be administered to food animals unless it is necessary for the health and welfare of the animals in circumstances where there is no viable alternative authorised product and where the imposition of the statutory withdrawal period would protect consumers.  This is to conform with the Medicines (Restrictions on the Administration of Veterinary Medicinal Products) Regulations 1994 (SI 1994 No 2987).

[NB: SI 1994 2987 revoked by the Veterinary Medicines Regulations 2005 - See VMD Guidance Note No 15 Controls on the Administration of Veterinary Medicines]

Immobilon is authorised for use in deer, but is not authorised for use in food animals.  No maximum residue limit (MRL) has been established for the active ingredients of Immobilon and, thus, an appropriate withdrawal period cannot be set.  Immobilon cannot, therefore, be authorised for use in food-producing animals and the legislation prohibits its administration to such animals.  Immobilon must not, therefore, be administered to animals which might enter the food chain at any time in the future. 

Veterinary surgeons should take great care to ensure that any Immobilon they prescribe or use is not administered to deer, or any animals, which may subsequently be killed or slaughtered for meat production.  The same position applies to the use of any other medicine not licenced for use in food animal species.

Veterinary Director, Food Standards Agency, Aviation House, 125 Kingsway, London WC2B 6NH   (6 December 2003)

5.  If the owner of the holding is not the owner of the animal, the owner of the animal should also be specified.

Professional Conduct Department, 18 May 2005 revised February 2006