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5. Guidance on the California Equine Medication Rule

ALERT: As of June 1, 2022, the California drug testing fee will now be $14 per horse entered in competition or consigned to a public sale.

Guidance on the California Equine Medication Rule

California law (Food and Agricultural Code Sections 24000-24018) outlines the equine medication rule for equines in public shows, competitions and sales in California. The owner, trainer and consignor have responsibility to ensure full compliance with all elements of the California Equine Medication Rule. Owners, trainers, exhibitors, veterinarians and consignors of equines to public sales must comply with both the California Equine Medication Rule and any sponsoring organization drug and medication rule for an event. The more stringent medication rule applies for the event.

The California Equine Medication Rule prohibits use of certain drugs or drug combinations, yet accommodates specific legitimate therapeutic use of medications within specified parameters. A licensed veterinarian must administer or prescribe the administration of therapeutic prohibited substances and non-steroidal anti-inflammatory drugs (NSAIDs) to horses at public events.

The California Equine Medication Rule defines a therapeutic drug or medicine as a drug or medicine prescribed by a licensed veterinarian for the treatment of a diagnosed illness or injury. All drug and medication use must be for legitimate therapeutic purposes only. Administration of a prohibited substance for non-therapeutic purposes, including but not limited to, clipping, shipping, shoeing, or training, requires that the animal be kept out of competition until the prohibited substance is no longer detectable in equine blood or urine samples. The EMMP advises owners and trainers to contact the EMMP veterinarian to confirm if intended drug use for a particular purpose is therapeutic.

The California Equine Medication Rule allows use of modern therapeutic pharmacologic treatments for illness or injury, unless the treatment

1. Involves use of a prohibited substance and the animal is not withdrawn from competition or sale following treatment,
2. Results in the presence of more than one non-steroidal anti-inflammatory drug (NSAID) in the urine or plasma, or
3. Results in the presence of the substance exceeding the maximum allowable level in blood or urine.

Prohibited Substance

The California Equine Medication Rule classifies drugs as prohibited substances and permissible substances. A prohibited substance is defined as any drug or medication that is a stimulant, a depressant, a tranquilizer, an anesthetic including local anesthetic, an analgesic, an anabolic steroid, a corticosteroid (excluding dexamethasone) and a soring agent. A prohibited substance administered for therapeutic purposes must be withdrawn 24 hours before a public competition or 72 hours before a public sale.

List of common prohibited substance for the California Equine Medication Monitoring Program

Non-steriodal Anti-inflammatory Drugs (NSAIDs)

Common NSAIDs used in horses include are diclofenic Acid (Surpass®), flunixin (Banamine®), firocoxib (Equioxx®), ketoprofen (Ketofen®), meclofenamic acid (Arquel®), naproxen(Naprosyn®) and phenylbutazone (Butazolidin®).  It is acceptable for therapeutic administration of a NSAID to horses prior to and during registered horse shows and competitions, if the dose of NSAID does not exceed the maximum detectable regulatory limits in plasma or urine.  Detection of prohibited substances or NSAID in a horse sold at a public sale is a violation the medication rule.  In addition, the detection of more than one NSAID in the same sample is a violation.

Permissible Substance

A permissible substance is a therapeutic drug or medicine or a drug or medicine found in a sample within the established maximum detectable plasma or urine levels.  There are nine (9) permissible drugs with restriction on the established maximum detectable plasma or urine levels.  The nine (9) permissible medications, not to exceed maximum allowable levels, include: dexamethasone (Azium®), diclofenic acid (Surpass®), firocoxib (Equioxx®), flunixin (Banamine®), ketoprofen (Ketofen®), meclofenamic acid (Arquel®), methocarbamol (Robaxin®), naproxen (Naprosyn®), and phenylbutazone (Butazolidin®).

Nine (9) Permissible Medications with Maximum Allowable Limit Restrictions - Dose and Time Recommendations Table

Permissible Drug Levels in Equines at Equine Competitions

For specific guidance on the therapeutic administration of permissible substances, see the Drugs and Medication Guidelines document.

12 Hour Injectable Rule

The California Equine Medication Rule prohibits the administration of any injectable substance to an equine within twelve (12) hours of competition, except for a veterinarian administering the following:

• A minimum of 1 liter of polyionic fluids per 100 pounds of body within 6-12 hours of competition. (NOTE: Fluids supplemented with concentrated electrolytes, such as magnesium, are prohibited.)
• Antibiotics (NOTE: Procaine Penicillin is prohibited).
• Dexamethasone injection, not to exceed 0.5 milligrams per 100 pounds, exclusively for the treatment of acute urticaria (hives) within 6-12 hours of competition.

The veterinarian must file a Drug Declaration Form (CA Form 76-027 or USEF Form) within 1 hour of administration of these injectable substances

Herbal/Natural Products

Herbal and natural products have the potential to contain prohibited substances.  Food and Drug Administration (FDA) approval is not necessary for manufacturers to produce commercial herbal products; therefore, herbal products are not scientifically tested or regulated as modern medications. When administering a product with an herbal or natural label to an equine, be aware that specific ingredients and quantitative analyses are not known for these products. Contrary to a manufacturer claim, detection of a prohibited substance (positive drug test) may occur after use of herbal products, such as valerian root, kava, chamomile, capsaicin, and devils claw.

Withdrawal of Equine from Event After Administration of Therapeutic Medication

An equine must be withdrawn from competition for a minimum of:

• 24 hours after therapeutic administration of a prohibited substance
• 45 days after the administration of reserpine and fluphenazine
• 90 days after the administration of an anabolic steroid.

An equine must be withdrawn from a public sale for a minimum of:

• 72 hours after therapeutic administration of a prohibited substance
• 72 hours after the administration of a therapeutic NSAID.

Completion of a Drug Declaration Form (Form 76-027)

(CDFA Form 76-027 or US Equestrian Federation Drug and Medication Report Form)

A Drug Declaration Form (CDFA Form 76-027 or USEF Drugs and Medication Report Form) is a legal document that an exhibitor or consignor must complete and file with an event manager for any equine at an event that has received a prohibited substance deemed by a licensed veterinarian as therapeutically necessary for the treatment of an illness or injury. An owner/exhibitor/trainer must complete and file a Drug Declaration Form for any equine that has received a prohibited substance within the three (3) days before the day being shown. A consignor must complete and file a Drug Declaration Form for any equine that has received a prohibited substance or NSAID within the five (5) days before the day of the sale.

The owner/exhibitor/trainer is to submit the completed Drug Declaration Form to the event manager within one (1) hour of administration of the product(s) at the event. If the product administration occurs at a time other than during equine event or sale hours, the owner/exhibitor/trainer is to submit the completed form within one (1) hour after an event manager returns to duty.

Sample Collection

EMMP field personnel receive assignments to randomly select equines competing in or consigned to a registered event for sample collection. ANY equine on an event premises is subject to random selection for sampling and testing.

The California Equine Medication Rule does not require collection of both blood and urine samples. Trained EMMP field personnel will collect urine samples from selected equines when an EMMP-approved California licensed veterinarian is not assigned to the event. When an EMMP-approved California licensed veterinarian is assigned to work with EMMP field staff at an event, ONLY blood samples will be collected from selected equines.

When an equine is selected, the owner, trainer, or designee must maintain control of the selected animal and take it to a location designated by the EMMP representative for sample collection. Once in the designated location, the individual must remove themselves from the immediate proximity of the animal and avoid any activities distractive to the animal. Any activity causing delay of sample collection, including but not limited to, schooling or training, lengthy cooling out period, or bandaging, shall be considered "non-cooperative." Failure to cooperate with EMMP staff or refusal/failure to submit a selected equine for sampling is a violation of the California law and subject to civil penalty of not less than $100 and not more than $10,000.

An EMMP priority is the safety of the public, the equine and EMMP representatives. An EMMP representative may officially release a selected equine without sample collection if the animal poses a safety risk.  If a reasonable attempt to collect a sample is made without successful collection of a sufficient sample volume, EMMP field personnel will document the sample collection attempt and may officially release the selected equine.

Owners, trainers or designees have the option to serve as a witness during the time of sample collection, labeling, and sealing. The witness may sign the record of sample collection acknowledging observation of the collection procedure. A decision to not observe sample collection or to not sign the sample collection document, constitutes a waiver of any objections to the identification of the equine selected and the manner of sample collection, labeling and sealing. Failure to witness the collection procedure is not an acceptable defense for challenging the identity of the equine or sample collection procedures.

Drug Detection Investigations and Violations

EMMP personnel seal collected samples, maintain chain of custody and submit the samples for chemical analysis to the Kenneth L. Maddy Equine Analytical Chemistry Laboratory, Davis, CA. The chemical analysis of blood or urine is positive when a prohibited substance is found to be present in the sample or when a permissible substance is detected above the maximum allowable level. A positive chemical analysis shall be prima facie evidence that the substance was administered in some manner to the equine, whether intentionally or unintentionally, which caused it to be present in the sample at the time of competition or sale. According to the California Equine Medication Rule, the owner, trainer and consignor are responsible and accountable for the equine's condition at the time of sampling.

When the chemical analysis of a blood or urine specimen is positive for detection of a drug or medicine, an EMMP investigation begins. An initial investigatory letter is sent to the owner/exhibitor/trainer or consignor of the equine with the positive sample. Relevant evidence or information about the detected substance must be submitted to the EMMP within a designated timeframe. Submitted information is given consideration by EMMP in determining a violation.

Under the rule, the EMMP staff may take into account relevant factors to determine an appropriate penalty, including but not limited to, the pharmacology of the prohibited substance, past violations of the responsible party, previous penalties in similar cases and reliance on the professional advice of a licensed veterinarian.

EMMP staff will issue a Notice of Violation (NOV) when a rule violation determination is made. Individuals may request an Informal Hearing to contest a Notice of Violation within thirty (30) days of issuance of the Notice of Violation (NOV). The California Department of Food and Agriculture Legal Department assigns a Hearing Officer to the case and coordinates the hearing. The Hearing Officer provides the EMMP and the owner, trainer or consignor the opportunity to present their case. The Hearing Officer has fourteen (14) days to render a decision to release the case, to hold the violation in abeyance or to support the issuance of violation and civil penalty.

The type of drug detection and the background case investigation information are given consideration in the assessment of the civil penalty for violations.

• Civil penalties, of not less than $100 and not more than $10,000 for each offense, will apply to the owner, the trainer, or both the owner and trainer of an equine found to have a chemical analysis with a prohibited substance, more than one NSAID, or detection of a substance above the maximum permissible level in violation of the rule.
• The owner, trainer, or both owner and trainer may receive a suspension from all public shows and competitions for a period of not less than 90 days or more than one year for each violation.
• The owner of an equine found in violation of the rule may have to pay a penalty fee of $50.00 to the public show or competition, where the animal was sampled.
• If an equine sample is found in violation of the rule, the event manager of the public show or competition, where the animal was sampled, may require owner forfeiture of all prize money, sweepstakes, trophies, ribbons and points won, in accordance with event organization by-laws.
• The contract of sale on an equine may be declared void at the buyer’s discretion, if a sample obtained from the animal at a registered public sale is found in violation of the California Equine Medication Rule.

Resources

• Drugs and Medication Guidelines Brochure
• Drug Declaration Form
• List of common prohibited substance for the California Equine Medication Monitoring Program
• Horse Show/ Competition Exhibitor Poster