Friday, March 28, 2014

IHRC 2014 Medication Withdrawal Times (Which Expire On April 30, 2014)

With a revision date of March 21, 2014, the Indiana Horse Racing Commission has posted their 2014 Medication Withdrawal Times. The caveats this year, however, are that the withdrawal times the IHRC has provided are for just 37 medications and they will somehow "Expire April 30, 2014." (Of course, their disclaimer as well as ours is that "Reliance on these guidelines is no guarantee of compliance with Indiana Horse Racing Commission (IHRC) medication rules." In IBOP's view, no withdrawal time should ever be posted without stated dosages.) This year's withdrawal times raise a few questions that we'll try to answer, if that is even possible. The IHRC's current 2014 Medication Withdrawal Times can be found at the following link: http://www.in.gov/hrc/files/Medication_2014_Withdrawal_Times.pdf.

Q. Why are there withdrawal times for only 37 medications? A. Your guess is as good as ours as we have no idea as to why there are 37 medications with withdrawal times. The 2013 Medication Withdrawal Times issued by the IHRC included withdrawal times for 72 medications! (A link to that 2013 document is at the bottom of this article.) At their March 5th meeting, the IHRC was to consider emergency rules that would have established supposed thresholds for 24 controlled therapeutic medications approved by the Association of Racing Commissioners International (ARCI) as recommended by the Racing Medication & Testing Consortium (RMTC). After first hearing testimony from the RMTC's Executive Director, Dr. Dionne Benson, the commissioners, based upon some very weak arguments by Chairman William Diener, decided to table any further public testimony on these medications and thresholds until the next IHRC meeting which is to be scheduled for late April. (This was an unbelievably disrespectful move to the industry groups in attendance that were prepared to provide testimony, but respect for the industry has never been a high priority with the IHRC.)

With any further discussion on adopting the 24 controlled therapeutic medications tabled, IHRC Executive Director Joe Gorajec raised this issue of providing what he felt were appropriate withdrawal times for 2014. Here's what he proposed, "What I would propose and what I would do, unless the Commission instructs me otherwise, is the guidance that we give the veterinarians and the horsemen leading up to the next meeting with regard to withdrawal times would be consistent with the current RMTC proposal." Mr. Gorajec went on to say, "What we do is we work with the lab and based upon the best available science we give horsemen guidance on withdrawal times. That doesn't change." (Official Transcript Page 84, Lines 15 through 23) After some brief discussion, the commissioners voted to approve this proposal which would lead anyone to believe that what the IHRC was going to do was publish the withdrawal times for only those 24 controlled therapeutic medications, not for the 37 medications currently published.

Mr. Gorajec's comment "that doesn't change," leads us to assume that the 72 medication thresholds published in 2013 were established with the "best available science." Yet, if the IHRC was interested in truly preventing medication violations, wouldn't an expanded list of those 72 withdrawal times make sense to the public anyway? Since the IHRC will never use documented compliance with a withdrawal time as a mitigating circumstance to a medication penalty, then why not publish as many withdrawal times as possible? And, if they truly wanted to assist horsemen, why not provide a specific recommended dosage from the best available science along with that withdrawal time! For guidance on dosages for at least the 24 controlled therapeutic medications, perhaps the best idea is to consult the actual ARCI Controlled Therapeutic Medication Schedule - Version 1.0 which can be found at the following link: http://arcicom.businesscatalyst.com/assets/1arci-controlled-therapeutic-medication-schedule---version-1.0.pdf. The IHRC should have considered publishing this document as well.

What we also find interesting is the following comment made by Dr. Benson from the RMTC at the March 5th meeting, "We have no problem with people medicating horses. It's whether they can run on a specific medication. We don't prohibit any appropriate medication from being used or even being kept on the backside of a racetrack. What we are concerned about is the integrity and safety of the horse and whether that horse should actually have that medication and at what level in its system at the time that it actually competes." (Official Transcript Page 52, Lines 10 through 18) In other words, Dr. Benson is saying that medications beyond the RMTC & ARCI's 24 controlled therapeutic medications can be used, but do not have thresholds on race day and their presence would be considered a violation. That's nothing new to Indiana racing. Again, if other medications can be used, wouldn't a responsible commission provide as many medication withdrawal times (and dosages) as possible, especially if in the past they've established withdrawal times with the "best available science" in conjunction with testing labs.

Of the 37 medication withdrawal times published by the IHRC, there are only 21 that were provided by and approved by both the RMTC & ARCI (yes, three RMTC & ARCI recommended medication withdrawal times are missing from the IHRC's current list); two medications, albuterol and isoflupredone, were recently approved by the RMTC, but not the ARCI, for the controlled therapeutic list; another two medications, cimetidine (Tagamet®) and ranitidine (Zantac®), currently have thresholds under Indiana's medication rules, but those race day thresholds would be eliminated as they are not part of the controlled therapeutic medications list; and the other 12 medications are hold overs from prior year's list. Why have these 12 on the list and not the full 72 from 2013?

Q. Why are there no withdrawal times for non-steroidal anti-inflammatory drugs (NSAIDs) flunixin (banamine), ketoprofen, phenylbutazone (bute)? A. Once again, your guess is as good as ours as we have no idea. Below the withdrawal times, the IHRC simply points to the "Regulations regarding administration" of these widely used medications. If you read these regulations you will find their current race day thresholds, but what you won't find is a withdrawal time. So much for guidance. These NSAIDs are the three medication withdrawal times that are missing from the RMTC & ARCI vetted 24. As a service to horsemen, the RMTC recommended dosage and withdrawal times are as follows: a single IV dose of flunixin as Banamine® (flunixin meglumine) at 1.1 mg/kg outside of 24 hours before racing; a single IV dose of ketoprofen as Ketofen® at 2.2 mg/kg outside of 24 hours before racing; and a single IV dose of phenylbutazone at 4.0 mg/kg also outside of 24 hours before racing.

This link will take you to more detail regarding the RMTC recommendation and guidance regarding flunixin:
http://www.rmtcnet.com/resources/Flunixin%20Withdrawal%20Guidance.pdf

Q. Why are there no withdrawal times for boldenone (Equipoise®), nandrolone (Durabolin® and Deca-Durabolin®), stanozolol(Winstrol), and testosterone? A. Here's another head scratcher of a question. Similar to the NSAIDs, these androgenic-anabolic steroids (AAS) have thresholds in the rules of racing in Indiana which means they are legal to use. Yet, the IHRC is providing no guidance, not even a reference to 71 IAC 8.5-1-8 (flat racing) or 71 IAC 8-1-8 (standardbred) that provide details on their thresholds. The IHRC is also considering the ARCI Model Rule for AASs along with their controlled therapeutic medications list. If approved, stanozolol would be eliminated from use In Indiana racing. In addition, so would the use of Equipoise and Durabolin as boldenone, nandrolone, and testosterone would be limited to "endogenous concentrations" which means only concentrations naturally occurring in a horse and no supplements.

Q. Why will the 2014 Medication Withdrawal Times expire on April 30, 2014? A. First of all, how does a withdrawal time expire? Any legal or therapeutic medication, with or without a threshold, has a withdrawal time for race day whether it's published or not. They don't expire unless all medications are banned from being used with race horses both in and out of competition.

Secondly, with a so-called expiration date of April 30th, are these withdrawal times only going to be used for the first month of the Hoosier Park standardbred meet which begins today, March 28th, and not the thoroughbred meet which begins on May 6th? We find that difficult to believe. The suggestion that the withdrawal times for the 24, soon to be 26, controlled therapeutic medications would expire is dumbfounding, or for any other medication for that matter. Assuming that the IHRC does approve the ARCI controlled therapeutic medications at the next IHRC meeting in late April, there would be no logical reason to ever suggest an expiration date for those 24 or 26 medications. Assuming that the IHRC does not approved the ARCI Controlled Therapeutic Medications, which would mean no administrative rule changes from 2013, then it's not logical to suggest that there is any expiration at all of any medication. In fact, in that scenario, logic would dictate going back to guidance on the withdrawal times for the 72 medications from 2013. But, unfortunately, logic has never been a strong suit at the IHRC, and perhaps never will be.

2013 IHRC Medication Withdrawal Times http://www.ai.org/hrc/files/Medication_2013_Withdrawal_Times.pdf

Here's a list of the other medications with a withdrawal time published by the IHRC in 2013, but not in 2014: acebutolol, aminocaprioic acid, atropine, beclomethasone, benzocaine, bupivacaine, cromolyn, dipyrone, dyphyline, ergoloid mesylate, ergonovine, fenoterol, fenspiride, guanabenz, ketorolac, medetonidine, methylprednisolone, pentazocine, pentoxyfyline, phenytoin, polyethylene glycol, procaine HCI, promazine, propantheline, propionylpromazine, propranolol, salmeterol, terbutaline, triamcinolone, trichlormethiazide, and triflupromazine.

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