Frequently Asked Questions

GENERAL

The RMTC is a consortium of stakeholders in the horse racing industry. Its mission is to provide an
independent voice for uniform rules, policies, and testing standards through research based
recommendations. The goal of these recommendations is to ensure the integrity of horseracing and
protection of the welfare of horses and other participants.
Its 23 member organizations represent horsemen’s groups, breed registries, racetracks, racing regulators,
industry associations and veterinarians. To see all of RMTC’s member organizations, please visit the Who We Are section of our homepage.

The RMTC SAC is comprised of experienced and knowledgeable racing regulatory veterinarians, veterinary pharmacologists, veterinarians in racetrack practice, and analytical chemists. Collectively they represent over 300 years of experience in the horse racing industry.
The SAC identifies tactical research needs, develops medication control strategies, solicits and monitors research projects, reviews data and formulates recommendations for regulatory thresholds and corresponding withdrawal guidance. The SAC also supports the development of new or improved testing methods, the sharing of laboratory information, and conducts workshops for chemists in the application of analytical methods.

The National Uniform Medication Program (NUMP) is a four-part program consisting of:

1. A Schedule of Controlled Therapeutic Substances (CTS);
2. Third-party Lasix administration;
3. A Multiple Medication Violation (MMV) program; and
4. RMTC Laboratory Accreditation.

Each portion of the NUMP was initially developed through subcommittees of the RMTC. The goal was to develop a comprehensive uniform program for the regulation of medications in horseracing. Each portion of the NUMP was approved by the RMTC Board and the Association of Racing Commissioners International (RCI). Each of these provisions is being used in numerous racing jurisdictions across the country. The goal is uniform implementation of all four aspects of the program in every racing state nationwide.

CTS

Early in the process, a survey was sent to racetrack practitioners through the AAEP to determine which medications they felt were necessary to practice in a racing environment. That list was prioritized by the importance placed on the drugs by veterinarians and the frequency of positive drug violations. A number of the medications were removed as they were not available or no longer appropriate for use in horse racing (e.g., dipyrone and anabolic steroids). And some medications were added, such as firocoxib, because it was approved by the FDA for use in horses. The final list was developed by the SAC with further input from the AAEP, analytical chemists, veterinary pharmacologists, and regulatory veterinarians in conjunction with the RCI.

While the list is not inclusive of all potential medications that can be used in a horse, every effort was made to provide representative medications necessary to treat the common ailments of horses in training. Subsequent to the development of the initial list, additional medications have been added at the request of both the USTA and AAEP veterinarians. Furthermore, the RMTC has a formal process for considering additional medications for inclusion on the CTS list as new medications become available or as research funding becomes available.
A copy of the CTS list is available at: Controlled Therapeutic Substances May 2020

No. Medications not on the CTS may be used in accordance with any applicable state and federal law. But the RMTC will not provide withdrawal guidance on these medications. Also, bear in mind that medications on the CTS list are subject to lesser penalties under the Multiple Medication Violation Penalty system. Moreover, non-scheduled medications may be regulated differently by various jurisdictions – with some having internal laboratory screening limits and others testing to the Limit of Detection (LOD). To the point, there is no national uniformity with drugs not on the CTS list.

Some of the thresholds are based upon historical data and research (e.g., phenylbutazone, flunixin meglumine, and furosemide). The majority of the thresholds, however, were developed using research studies funded by the RMTC or studies shared with the RMTC from similar international studies. In the majority of the RMTC studies, between 16 and 22 horses were used. First, the subject medication was administered at clinically relevant dosages based on either manufacturer’s recommendations or input from clinicians and/or veterinary pharmacologists. Once a medication was administered researchers collected blood, and in some cases urine, at predetermined times post administration. After the samples were collected the analytic laboratory analyzed the samples using a validated method and provided their results to the RMTC. Most of these studies have been published or are in the process of being published in peer reviewed journals.

For non-historical thresholds, RMTC then used that data and applied a 95/95 tolerance interval calculation to the data. The 95/95 tolerance interval is a robust statistical analysis used by the European Agency for the Evaluation of Medicinal Products. It accounts for the variability of the data as well as the number of horses used in the study. A full explanation of the analysis can be found here.

The withdrawal guidelines do not guarantee that a positive finding will not occur. There is always the possibility of an outlier – a horse that for some reason metabolizes medication more slowly than others – but the statistical analysis used in determining the thresholds is very robust and designed to minimize that risk. Moreover, if dosing guidelines for the medication or administration routes recommended are not followed, there is an increased chance of a positive finding.

Furthermore, the experiments performed to set these thresholds do have limitations. The experiments were performed using a specific dose of each medication and did not account for concurrent administration of other medications or other substances – which could affect the length of time required for the medication or its metabolite to fall below the regulatory threshold. Trainers and veterinarians are encouraged to perform their own risk assessment based upon the characteristics of the medication, its rate of clearance, and the dose and route of administration as well as the treatment of the horse with other substances. The use of compounded medications can also cause unintentional overages – even if the recommended dose is used based on label concentration – because in some cases compounded medications do not contain the label concentration of the active ingredient.

The RMTC withdrawal recommendations use the best information available at the time, but ultimately it is the responsibility of the trainer in consultation with his or her veterinarian to do the appropriate risk analysis based on the numerous factors that can effect drug elimination. Drug formulation, route of administration, multiple drug interactions, horse health, size, exercise activity, fitness and many other factors can impact drug eliminations and need to be considered when drugs are used in racing.

The only regulated antibiotic is procaine penicillin. This is because procaine penicillin contains procaine which is, a numbing agent better known as Novocain™. All other antibiotics and vaccines are permitted to be used under the guidance of a veterinarian. Additionally, all dewormers may be used with the exception of levamisole which is metabolized to aminorex (a stimulant) in the horse. There are no thresholds for antibiotics and dewormers that do not act on the mammalian organ systems and RMTC-accredited laboratories are not reporting these substances to regulatory authorities.

There is no prohibition against using any of the corticosteroids on the CTS list IM, SQ, or in the sacroiliac space. However, corticosteroids formulated as fat soluble esters (e.g., methylprednisolone acetate) take an extremely long time (up to several months) to fall below the regulatory threshold after certain routes of administration. Corticosteroids without an ester (e.g., isoflupredone) or those formulated as highly water soluble esters (e.g., dexamethasone sodium phosphate) will take less time – but will still likely take more than the recommended withdrawal time for an intra-articular (IA) or intravenous (IV) dose. Similarly, an IA injection that inadvertently ends up outside of the articular space can take longer to clear than the withdrawal guidelines suggest.

When using corticosteroids IM, SQ or in the sacroilliac space – the veterinarian and trainer are encouraged to perform a risk assessment regarding the time recommended for withdrawal based upon the dose and formulation of corticosteroid used. The appropriate time will be largely dependent upon dose, location, and corticosteroid of choice. There are published research articles regarding methylprednisolone acetate and triamcinolone acetonide that should assist the veterinarian in determining what may be an appropriate withdrawal time. Furthermore, there is an RMTC recommended time for SQ use of isoflupredone when injected into the high suspensory.

The research that was done to establish corticosteroid thresholds is based upon administration of corticosteroids into a single joint at a specific dose. Nonetheless, there are many practitioners who have been injecting multiple joints with corticosteroids since the advent of the NUMP. Based upon the dose injected, the veterinarian will have to determine whether the withdrawal time will vary from the single dose. Results from clinical cases have been collected in Minnesota, Kentucky, and California where multiple joints have been injected with corticosteroids and concentrations in samples from horses have been below the regulatory thresholds at the time of sampling.

The veterinarian should be aware, however, that simply injecting different IA spaces with different corticosteroids at the recommended dose will not necessarily ensure compliance with the thresholds. Veterinarians need to be aware of the clearance mechanism for various medications – those with the same clearance mechanism may interact and thereby extend the time for one or more medications to fall below threshold concentrations if administered close in time to one another. Moreover, the practitioner should not assume that because a specific protocol fell below the regulatory threshold in one horse that it will in all horses.

For flat and jumps racing there is a 14 day stand down period for all intra-articular (IA) injections. A horse that races less than 14 days post-IA injection is in violation of the rule. A determination that a horse was in violation can be made by drug testing, but also by review of treatment records, out of competition testing, or other credible means. For harness racing, corticosteroids are regulated solely by serum thresholds; 7 days is the withdrawal guidance to facilitate compliance with the threshold.

For all flat and jumps racing, intra-articular (IA) injections are prohibited within 14 days of a race. Evidence that a horse received an IA injection at less than 14 days to a race constitutes a violation. For harness racing, corticosteroids are regulated solely by serum thresholds; 7 days is the withdrawal guidance to facilitate compliance with the threshold. It is not a violation to perform an IA injection at less than 7 days as long as the corticosteroid is detected below the regulatory threshold.

Withdrawal Guidance is a recommendation that corresponds to a specific drug, dose, dosing schedule, and route of administration in order to avoid a post-race concentration in excess of a regulatory threshold. Veterinarians are able to use alternative doses, routes of administration, and administration schedules as long as the regulatory threshold is not exceeded in a horse’s post-race sample.
Restricted Administration Times (RAT) prescribe an interval prior to a race during which the administration of a specified medication is prohibited—at any dose and by any route of administration. RATs can be enforced by drug testing, but also by review of medical records or treatment reports, out of competition testing, or surveillance. The 4-hour treatment interval for race day Salix is an example of a RAT. Salix administration at less than 4 hours to post time is specifically prohibited. This prohibition can be enforced by drug testing, but also by surveillance. If an individual is observed administering Salix at less than 4 hours to post time for the race in which the horse is entered, there is evidence that the rule has been violated.

Withdrawal Guidance is provided for a specific drug, dose, dosing schedule, and route of administration. It is determined through a review of administration study data and scientific literature and incorporates a risk analysis that adds a safety margin to provide additional protection against a medication being present above the threshold in a post-race sample.
A Detection Time is the first time point after a substance is administered that it is not detected in any of the samples from the study horses. It does not include any risk analysis nor probability calculation based on the limited sample size. When Detection Times are published the reference also notes the medication, dose, route of administration, dosing schedule, number of horses in the study as can be seen on the International Federation of Horseracing Authorities website: https://www.ifhaonline.org/resources/DetectionTimes.pdf. IFHA detection times are for analysis in urine unless otherwise noted. It is the responsibility of the veterinarian, in consultation with the trainer and in consideration of their knowledge of the horse’s health to determine a withdrawal interval that is longer than the Detection Time.

While the research based withdrawal guidelines were developed based upon careful research, there is always a possibility that a horse is an outlier and metabolizes medication more slowly than others. Additionally, the combination of medications, use of compounded medications, variation of route, variation of dose, variation of formulation, failure to ensure that all medication is injected into an articular space, or failure to dose a horse by its weight can all account for differences in withdrawal times. Depending on drug, especially oral preparations, there is always the possibility a horse was mistakenly treated or not all drug treatments were recorded.

Veterinarians and trainers are permitted to use more than one medication on a horse – whether the medications are on the CTS list or not. For those on the CTS list, however, it is important to note that the withdrawal guideline is based upon a single medication administration. While it may not be true in all cases, there is the potential that the administration of multiple drugs simultaneously may cause a medication to be eliminated more slowly than if a drug is administered alone. If administering more than one medication, the veterinarian is encouraged to determine whether the potential for drug/drug interactions exists and to adjust the dose or withdrawal time accordingly. Furthermore, phenylbutazone, ketoprofen and flunixin have secondary thresholds that restrict stacking of those medications.

The RMTC has attempted to regulate as many CTS as possible in blood. Picogram/ml concentrations in blood are pharmacologically active for many drugs. The same is true for some drugs when found in urine. For this reason, several medications are regulated at concentrations expressed in pg/mL in the horse. While pg/mL concentrations may seem small, the concentration of each of these medications falls below nanograms/mL in blood quickly. In fact, in every case where medications are regulated at thresholds expressed at pg/mL in blood, the concentration of each was below 1 ng/mL at 24 hours in research studies. These include substances such as corticosteroids which we know have effects that last months in the joint. Therefore, regulation at pg/mL is the only appropriate way to control the use of these medications in the racing environment.

It should also be recognized that many of the thresholds for substances on the CTS are in blood rather than urine. The concentration of a drug in blood is almost always much less than the corresponding concentration of the drug in urine so the switch from urine to blood often necessitates use of a much lower threshold in order to regulate race day or longer use of the drug.

Veterinarians are free to use any drug they are otherwise legally able to use within their jurisdiction. However, the NUMP does not provide uniform thresholds for those drugs nor does the NUMP provide withdrawal time information. Further, if a horse tests positive for a medication not on the CTS in a jurisdiction following the MMV, the violation will result in the assignment of twice the points of any medication on the CTS in the same penalty class.

For example – if a horse tests positive for a medication on the CTS list that carries a class C penalty – that violation is a 1 point penalty. If the medication is not on the CTS list and carries a C penalty – the violation is twice the points or a 2 point penalty.

A list of the published research regarding the medications on the CTS can be found at Controlled Therapeutic Substances page. You are encouraged to review this document frequently as it is continually updated.

Medications will continue to be considered as proposed by RMTC board members – particularly the AAEP Racing Committee.

THIRD PARTY LASIX ADMINISTRATION

RMTC encourages the third party administration of Lasix by veterinarians under the supervision of the racing commission.

Many of the inappropriate substances that can be given at the time of Lasix administration are not detectable through the best testing procedures. Therefore, the easiest way to prevent the administration of prohibited substances on race day is to restrict access to the horse on race-day.

No. The only race day medication permitted under the NUMP is Lasix. Adjuncts are prohibited.

LABORATORY ACCREDITATION

Two laboratory accreditations are available to horse racing laboratories in the United States. The first is ISO 17025 Accreditation. The second is RMTC Laboratory Accreditation (RMTC Lab Accreditation). Accreditation generally ensures that laboratories are performing work following consistent and effective methods that are repeatable, are fit for purpose, and produce appropriate results. Absent accreditation, the laboratory may be performing its testing appropriately but there is no independent agency to verify that information.

ISO (which stands for International Standards Organization) 17025 accreditation is a great first step for a racing laboratory. An ISO accredited laboratory is required to demonstrate that it is performing testing in accordance with Standard Operating Procedures (SOPs). ISO 17025 accreditation is available to all testing laboratories (horse racing and other).

RMTC Lab Accreditation goes further because it is designed specifically for horse racing laboratories. RMTC lab accreditation is based on the World Anti-Doping Agency (WADA) laboratory accreditation program. RMTC Lab Accreditation examines the laboratory from the time of sample receipt through final reporting of results to see whether the laboratory uses appropriate testing and methods that will provide defensible results if challenged in court. Additionally, there is a special focus on items of concern to the racing industry such as chain of custody, validation of methods to RCI approved thresholds, and appropriate determination of the measurement of uncertainty. Most importantly, RMTC Lab Accreditation relies on a robust proficiency testing program to test the lab’s ongoing ability to detect and report prohibited substances.

ISO Accreditation is required for all RMTC applicant laboratories. In addition, the RMTC’s independent consultants review the laboratory’s application and perform a 2 day site inspection at the laboratory. Every RMTC-accredited laboratory is subjected to twice yearly proficiency sample testing to ensure that the laboratory can identify and, where appropriate, quantify substances of interest in horse racing. Also, RMTC accredited laboratories are required to have a research program and to share the results of their research with other RMTC accredited laboratories.

Currently, the RMTC covers all application and External Quality Assurance Program costs for every laboratory in the program through a grant from The Jockey Club. The RMTC will continue to cover those costs as long as funding is available.

MULTIPLE MEDICATION VIOLATION PROGRAM

The MMV represents an industry-wide plan to provide appropriate penalties for serious or accumulated violations of medication regulations. The MMV is designed to address trainers who habitually violate drug and medication regulations.

The MMV program assigns points to each medication violation based upon the penalty class (A-D). The less severe the medication violation, the fewer points assigned. Trainers are subject to MMV penalties when they exceed a specific number of penalty points within a specific timeframe.

Points (with the exception of those for class A violations) can be expunged at the request of the trainer after the requisite time has elapsed.

The model MMV rule is available online here (pg. 64)

The MMV program only addresses the violation of regulations related to drugs and medication. Other state racing regulatory violations are not subject to the MMV at this time.

The MMV is designed to address trainers who habitually violate drug and medication regulations. Research has shown that a small percentage of trainers account for a large portion of all medication violations. Trainers who commit one medication violation are more likely to commit a second and even a third violation. The MMV was designed to deter this repeat behavior.

The MMV penalties are issued in addition to and not instead of any penalty proscribed for an underlying drug or medication violation. The MMV penalties are limited to suspensions ranging for 30 to 360 days. The length of the suspension is based upon the number of points that the trainer has accrued.

The MMV suspension runs consecutively with any suspension for the underlying medication violation.

A careful review of trainers with current violations has demonstrated no relationship between the size of the stable and the number of violations that a trainer incurs In fact, most of the largest stables in the United States would not have been subjected to MMV penalties at any time in the past 10 years had the program been in effect.