This thread has already identified others blissfully unaware that they needed a medicines record for their chosen livestock, or that (no matter how arbitrary) expiry dates MUST be complied with - any problem down the line and the proverbial would hit the fan come investigation by the powers that be.
That's the medicines legislation, agree entirely. However the grey area here is what is, or is not, medicine. That creates some anomalies that don't appear to have been anticipated. Take a few scenarios:
- Keeper A treats with a proprietary "hive cleaner" containing thymol and some other essential oils. No records needed, it's not registered by VMD.
- Keeper B treats with Apiguard. Bought last year but still works, doesn't record the batch or pack dates.
- Keeper C treats with Apiguard and records the full details, including the pack dates which are a few months over.
As it stands, all three have the same active ingredient in the hive. Keeper A has done nothing wrong. Keeper B could be prosecuted for not keeping records, but I'm not aware of any prosecutions of small scale beekeepers. Asking around I'm guessing 80% or more of UK beekeepers are actually in Keeper B's position, many are surprised if you point out there is an expiry date. Keeper C can be prosecuted because there is evidence that they broke the rules. There are precedents for prosecutions under the legislation, but the publicised cases are all far more serious such as knowingly changing dates before selling expired medicine.
As it stands there is a perverse incentive to either not keep records or avoid registered medicines; the legal consequences and penalties are likely to be absent or at any rate much less severe. I'm not disagreeing with what the legislation says or that it's far more rigorously enforced in human treatment. Recent clenbuterol cases question how rigorous enforcement is in the commercial food chain. I'm actually writing here as one of the few I know who does write treatments down. I'm just pointing out that the reality is that treatment recording is widely ignored by beekeepers, just as it is by backyard poultry keepers for that matter.
As Margaret Elizabeth says, she's going to treat with essential oils - unregulated, untested, no expiry dates - because they're not medicine. I'm not criticising that, it's perfectly legal and an entirely logical consequence of the way the legislation applies to treatments. Used with caution it can be safe, and I'm not having a go at any individual who makes the choice. However, a cocktail of oils with little or no established concentration, dose or efficacy is permitted, yet using a pack of apiguard one day past the pack date could be prosecuted. I'll look at any reports to the contrary but I just don't believe a prosecution would ever clear the hurdles of the prosecution authorities and judges without being thrown out.