Passports for all horses? RCVS submits views to DEFRA

untry. For that purpose it would seem sufficient to require a passport to be produced when a horse is presented for slaughter for human consumption. The UK is bound to implement the more elaborate solution laid down by Decision 2000/68, but the aim should nevertheless be to keep the response in proportion to the problem.

Turning to the draft order, Article 11 would prohibit a veterinary surgeon from administering the relevant medicines to a horse in the absence of the passport. A horse could thus be denied the right treatment for lack of a piece of paper. This point was made in the debate in the House of Lords on 2 June, and Lord Whitty is recorded as having said:

"It is necessary to have some understanding with the veterinary organisations as to how they would deal with a horse that did not have that disclaimer. It is not impossible to see that there will be options available to vets in those circumstances rather than simply refusing to use the medicines."

If Lord Whitty was correctly reported, we would be interested to know what he had in mind. It is to be hoped there is no suggestion that veterinary surgeons should turn a blind eye to the law. As the body responsible for overseeing the professional conduct of veterinary surgeons RCVS would be concerned if they were to be placed in the position of choosing between applying the law and giving proper care to their patients.

The drafting of article 11 is also deficient in two respects. First, it refers only to the administration of medicines by veterinary surgeons. The administration of medicines by other persons would need to be covered too. Second, the article refers to "drugs listed in Annexe IV of Council Regulation 2377/90/EEC". That annex does not in fact deal with "drugs" (or, to use preferable terminology, medicines) but with components of medicines, and it does not list them. Instead the Directive provides for the establishment of a list of pharmacologically active substances for which no maximum levels can be fixed. On a practical point, veterinary surgeons would need to know where to find the list.

The Royal College invites the Department to reconsider the proposal that all horses should be registered and to refrain from pursuing the order pending clarification of how veterinary surgeons would be meant to apply it. We would welcome a meeting with you to discuss in detail the part that veterinary surgeons would be expected to play.