When Regulations Forget the Patient: Winstrol, Critical Care, and the Cost of One-Size-Fits-All Oversight

At Western Justice, we defend those who work tirelessly to support our American way of life. This is the case especially when expanding federal regulations ignore the real-world needs of animal owners, farmers and ranchers and veterinarians and their patients alike. In 2023, sweeping changes to federal guidelines governing veterinary medications including the use of Winstrol (stanozolol), created unintended consequences that veterinarians who practice in critical care are still fighting to navigate. Now, Dr. Josh Harvey and his team at Outlaw Equine Veterinary Hospital are under fire for doing what they've always done: putting patient care first.

Terms That Matter: Before Judgment, Understand the Words

To understand what’s at stake, it’s important to start with clear definitions:

• Extra-label drug use (ELDU): The use of an FDA-approved drug in a way not specifically listed on the label, often essential in veterinary medicine when treating non-standard or critical cases. ELDU is legal under the Animal Medicinal Drug Use Clarification Act (AMDUCA) when based on a valid veterinarian-client-patient relationship and professional judgment.

• Patient care: The process of diagnosing, treating, and supporting an animal in a way that prioritizes health outcomes, comfort, and survival, especially in emergencies and ICU contexts.

• Egregious: Shockingly bad or flagrant overreach. It is a term that must often be applied to regulatory changes that take place without proper consideration of their overarching impact.

• Compounding: The preparation of a drug that is not commercially available, often necessary when FDA-approved options are either discontinued or insufficient. Governed by evolving FDA guidance, including GFI #256.

• ICU and Critical Care: Veterinary critical care focuses on providing intensive medical attention to animals facing life-threatening conditions or severe injuries. These include illnesses, trauma, poisoning, and post-surgical complications. For critically ill animals, veterinary professionals make every effort to maximize the animals’ chances of survival and recovery. This most often involves round-the-clock care, continuous monitoring, and the use of advanced medications, treatments, procedures, and technology.

• Will to Live: Assessing an animal's “will to live” in a veterinary hospital setting involves observing a combination of physical, behavioral, and emotional cues. It takes into consideration their response to treatment and overall quality of life. These key indicators include willingness to eat and drink, even if it is in small amounts, the ability to pass urine and feces, the ability and willingness to move, positive responses to pain medication, fluids, and other medications.

Winstrol Saves Lives, When It’s Allowed To

Winstrol, also known as stanozolol, has long been used in veterinary medicine to boost appetite, increase strength, and aid recovery in small animals and horses suffering from severe illness, weight loss, or long-term hospitalization. In ICU settings, it has proven invaluable. VCA Animal Hospitals describes its utility in increasing appetite and energy in horses, dogs, and cats recovering from trauma or chronic illness. It's not a magic bullet; it’s a lifeline.

Yet in 2023, new federal rules, many aimed at the horse racing industry, dramatically limited access to Winstrol for all patients, regardless of need. These changes emerged from:

• HISA (Horseracing Integrity and Safety Authority) banning all anabolic steroids in racing or training horses. HISA in itself is an egregious NGO oversight committee and set of regulations which is intentionally damaging the horse racing industry, but that’s a topic for another initiative.

• The FDA’s GFI #256, which restricts how veterinarians and compounding pharmacies

access and prepare medications like Winstrol from bulk drug substances.

Veterinarians treating horses in the ICU suddenly found themselves boxed into a regulatory corner. And those who attempted to follow the rules in good faith, including Dr. Harvey, were left without clear guidance, or worse, punished after the fact for using professional judgment to save lives.

A System That Punishes Compassionate Care

Let us be clear: Dr. Harvey is not alone. At least five other veterinarians are under scrutiny for how they navigated these confusing new mandates while still prioritizing their patients. During a 2024 DEA inspection, Dr. Harvey and his team were told directly that their method of ordering and tracking Winstrol usage, due to the fact that it commonly takes 10 days for the drug to arrive (which is then pointless if you have a critical patient in ICU), was appropriate. Only later, after shifting interpretations and an inspection a year later, were they informed that the previous approval from the last inspector was incorrect and they were subsequently accused of wrongdoing.

Along with Outlaw Equine several other equine hospitals using similar protocols have already been sanctioned not because of misconduct, but because regulations were not clear, consistent, or, most importantly, realistic.

Misguided Oversight: Does the Regulator Understand the Reality?

One of the voices questioning Dr. Harvey’s use of Winstrol is Dr. Lynn Criner, a member of the Texas Board of Veterinary Medical Examiners. But here’s the problem: Dr. Criner’s expertise is not in ICU medicine, emergency critical care, or referral hospital operations. Her practice, Texas Equine and Pet, is a mobile ambulatory clinic offering holistic and preventative care.

Dr. Criner herself acknowledges referring complex cases to specialists, so how can she confidently pass judgment on life-saving ICU protocols developed and used at one of Texas’ busiest equine hospitals?

Winstrol is not some secret performance drug. It has been used for decades to help animals recover from devastating illness. In fact, VCA Animal Hospitals has a page dedicated to describing the use of the drug on its website. Veterinarians across the country, from mixed-animal clinics to large referral centers, have used it legally and ethically for therapeutic purposes for decades. To suggest otherwise is not only inaccurate, it’s disrespectful to the thousands of horses that owe their lives to veterinarians who made bold, informed choices under pressure.

Bureaucracy Over Biology: What Happens When Government Doesn’t Listen

The fundamental problem is this: federal regulators and the HISA group wrote rules for racehorses without considering the needs of equine hospital patients. What was banned to stop cheating in competitions has now endangered lives in ICU stalls.

• The original FDA-approved Winstrol is no longer available, so veterinarians turned to compounded versions, prepared under rigorous standards.

• The new guidelines discourage office stock and impose ordering and recordkeeping burdens that are nearly impossible to meet in fast-moving critical care situations.

• Delays and shortages from compounding pharmacies have left horses without needed medications, and veterinarians left to choose between following rules or following their oath.

The bottom line is that this is not responsible governance, it certainly does not take the lives of animals into consideration. As far as we are concerned, we need to get together with lawmakers and change this circumstance for the benefit of horses and other domestic animals across the country.

Winstrol Has Additional Beneficial Uses for Equine Patients Outside the ICU

While the focus of this article is the fact that the overreaching new regulations regarding the use of Winstrol have put veterinarians who treat critical care cases in an untenable position, we also must point out that it has many other therapeutic uses, where an extended waiting period is not in the best interest of the patient, nor, is it practical, for example if a client has traveled a great distance for diagnosis and treatment of their horse. Here are just a few examples of how Winstrol can be used to the benefit of equine patients outside the ICU:

Equine Protozoa Myeloencephalitis (EPM)

Equine Protozoal Myeloencephalitis (EPM) is a neurological disease in horses caused by the protozoan Sarcocystis neurona. It affects the central nervous system (brain and spinal cord) and can lead to a variety of clinical signs, ranging from mild lameness to severe ataxia and paralysis. In the Central Southwest, recent veterinary studies have shown that EPM is now considered ubiquitous - meaning that it is everywhere. Based on the findings of the study, it is not unreasonable to consider that almost every horse in the region has been exposed to it. How their bodies respond to the exposure is a key factor in whether or not a horse survives the infection or ends up being euthanized due to its potential for devastating neurological effects. In years past, when a horse with an EPM infection showed clinical signs, it almost always meant a death sentence; now, today’s practitioners in the region have more innovative and proven methods of treatment, ranging from antiparasitics that attack the parasite, to rehabilitation therapies, the use of supportive medications, and natural therapies.

EPM often causes asymmetrical muscle atrophy and weakness. Winstrol, by promoting muscle growth, helps rebuild lost muscle mass and improve strength in affected horses. By improving muscle condition, Winstrol contributes to the horse's overall recovery and ability to participate in physical therapy designed to regain balance, coordination, and strength.

Supporting Equine Athletes

It is important to note that Dr. Harvey and his team at OE care for some of the top performance horses in the country. In the cases of many of these horses, they are doing much more than just performing; they are helping their human counterparts make a living. In essence, top rodeo and western performance horses are the foundation for the entire western performance horse industry, including providing jobs for all of the ancillary businesses associated with them, from trucks and trailers manufacturing and sales, to feed and nutrition companies, to trainers and enthusiasts, veterinarians, pharmaceutical companies, medical equipment, facilities builders and more. The list of ancillary benefits from the western performance horse industry is endless.

As many of our followers and members know, it takes years to develop and season top western performance horses, and in most cases, a lot of the top rodeo horses today have some years on them. Therefore, it is imperative to keep them in top shape and feeling good. The use of Winstrol as preventive medicine has helped keep those athletes, strong, feeling good, and performing well. In addition to preventive care for older athletes, Winstrol has been used to help mitigate the impact of osteoarthritis in horses, from joints in the legs to the spinal column. In fact, at the 2023 American Association of Equine Practitioners annual convention, Dr. Scott McClure, veterinarian at Midwest Equine Surgery and Sports Medicine, presented an overview of the drug’s use intra-articularly for certain types of joint conditions.

The American Association of Equine Practitioner’s Statement on Anabolic Steroids

We would be remiss if we did not include the AAEP’s own statement about the beneficial use of

anabolic steroids, like Winstrol in horses. Their website states:

“Anabolic steroids have specific indications in the therapeutic treatment of medical conditions of horses."

Indications for Use

Indications for use: Anabolic steroids are primarily effective when the objective is to improve appetite, repair tissue, promote weight gain, and accelerate recovery from disease. In horses, anabolic steroids may stimulate appetite and increase muscle mass, particularly when there has been marked tissue breakdown associated with disease, prolonged anorexia, stress, or surgery.”

Justice, Not Agendas

At Western Justice, we’ve had enough. It’s time to stop using selective enforcement and anonymous complaints as weapons against veterinarians doing everything they can for their patients. It’s time to recognize that compassionate, competent care is not egregious—it’s essential. We stand with Dr. Josh Harvey, his ICU team, and every veterinarian who refuses to sacrifice patient outcomes to satisfy an inflexible rulebook.

It is not justice to publicly shame and punish professionals without giving them the opportunity to respond, explain, or be heard. We demand better. Not just for Dr. Harvey, but for every veterinarian caught in the crosshairs of regulatory overreach. The allegations against Dr. Harvey were published on a public website without his ability to respond and challenge the allegations, many if not most of which are untrue and unproven.

Western Justice will be publishing additional updates regarding the Texas Board of Veterinary Medical Examiners’ actions against Outlaw Equine. Follow the full story at westernjustice.info.

Because at the end of the day, facts matter. Outcomes matter. And justice is truth in action.