Preparing for an Animal Health and Welfare Strategy for Great Britain

Background

The National Office of Animal Health (NOAH) represents the UK animal medicines industry whose aim is to provide safe, effective, quality medicines for the treatment and welfare of all animals.

Summary

NOAH fully supports a vision of consistently high standards of animal health and welfare and improved public health in Great Britain.

We believe it is important that not only farm animals are addressed in this strategy - the health and welfare of the nation's horse and companion animal population are important too.

Good preventive medicine, when needed, to stop animals from getting sick - and therapeutic medicines being available to treat animals, are fundamental to any animal health and welfare strategy. The marketing authorisation system for animal medicines protects not only the public, but also the animal. However, regulation should not be unnecessarily restrictive so as to prevent new medicines from reaching the market that would have otherwise been beneficial to animal welfare or existing medicines from being forced off the market because it becomes unviable to retain them. Likewise, while their use should be controlled, they should also be accessible.

Animal medicines are a critical part of the solution for a sustainable animal health and welfare policy. Sick farm animals are not efficient, and feed inputs are wasted. Sick companion animals cannot do their job, whether that be as trusted friend or as assistance dog. We are pleased to see responsible use of veterinary medicines as part of the vision.

The role of an innovative animal health industry is essential for improving animal health but the nature of disease is dynamic and, unless there is a responsive industry addressing new disease challenges, overall health status will decline.

There is much scientific expertise within the animal medicine industry. The people involved with researching the medicines of the future are there, along with those that know how existing medicines can be most effectively used in particular situations to help prevent and cure disease. We would welcome the opportunity to be a real key player in the implementation of a scientific evidence based strategy.

We have always believed animal health and animal welfare are inextricably linked: this is why we welcomed the fact the responsibility came under the remit of one Minister, and latterly, that the VMD (and hence animal medicines) were also seen as part of the same picture.

Specific comments

Section 5 - Scope

The document does focus strongly on farm animals, and although companion animals are covered, they seem to be an add-on. It needs to be ensured their health and welfare is fully addressed, although this may to some extent be by consideration of other legislation currently in draft. Nevertheless, as far as NOAH's view in relation to the important role of animal medicines is concerned, they fit here.

The horse is by current EU definition a food-producing species: there are moves towards identifying individual horses as food producing animals to allow continued access to many medicines for the others - the vast majority of which could be accurately termed 'working' animals. Any strategy for horse welfare must ensure horses have continued access to a full range of animal medicines, including, for those not entering the food chain, those for which a Maximum Residue Limit (MRL) is not established.

Section 9 - Who Does What?

9.1.1 It is also important that animal keepers recognise that animal medicines are licensed, why they are licensed and therefore why it is important that they are used responsibly. We would be happy to work with DEFRA to build on the work already being done in this area.

9.1.2 The role of the veterinarian is very important, and we fully support that. But animal keepers can legally obtain some medicines from other places - from pharmacies, registered merchants, saddlers, and pet shops. Work done by the Animal Medicines Training Regulatory Authority (AMTRA), of which NOAH is a member can help ensure that there are qualified advisors able to help animal keepers here also.

Section 10 - A draft vision

Consistently high standards of animal health and welfare

NOAH fully supports the draft vision of consistently high standards in animal health and welfare. We note that one of the strands to achieve that is that there should be responsible use of veterinary medicines in 10 years time. While we fully agree with that, we would not want this to imply they are being used irresponsibly now.

All animal medicines need a marketing authorisation before they can be put on the market: once there, the route by which they are sold is controlled. For medicines for farm animals, there is a withdrawal period for each medicine used which must be observed: all medicines used in farm animals must be recorded. This is to ensure safety to the consumer of any livestock produce, and the system works: the independent Veterinary Residues Committee (VRC) report published last October, giving residues surveillance figures for 2001, concluded "that no UK authorised use of a veterinary medicinal product resulted in a residue which would give cause for concern for human health". This shows a high level of compliance with safe use of animal medicines is being achieved. NOAH feels DEFRA and other agencies eg Food Standards Agency (FSA) should ensure consumers have greater awareness of this.

Responsible use does not always mean less use: it is a responsible act to use a medicine to stop an animal from getting sick (vaccines for example) and to cure a sick animal. We see preventive medicine for both farm and companion animals as being the way forward in responsible medicine use and thus helping to protect animal health and welfare.

Improved public health

The recent (February 2003) FSA consumer survey showed public concern about food to be dropping: however, they still wished for more information about 'chemicals' in their food. Much information exists - the VRC report mentioned above for example. We would be happy to help publicise this, and the fact that strict controls exist before an animal medicine can reach the market.

A better informed and more effective livestock industry

The industry is not complacent: it is involved with the RUMA (Responsible Use of Medicines in Agriculture) Alliance drawing up species specific guidelines on antibiotic and anthelmintic use. It is involved with the AMTRA training schemes. NOAH has input into the veterinary profession's pharmacy courses. We would welcome continued support for these initiatives, and would like to see them included within the way forward to build on responsible use further.

We also do not think that being better informed is exclusive to the livestock industry. There is the potential, for example, for diseases to be brought in from abroad as companion animals travel more. Pet owners need to be aware of this. Work done by groups such as the Pet Health Council (PHC) and Pet Advisory Committee (PAC) can help spread awareness.

Use of science to ensure…

The last part of the vision deals with the use of science. There is much scientific expertise within the animal medicine industry. The people involved with researching the medicines of the future are there, along with those that know how existing medicines can be most effectively used in particular situations to help prevent and cure disease. We would welcome the opportunity for this expertise to be utilised.

We fully support the policy of evidence based science - this is something that can be usefully applied to ensuring the continued availability of animal medicines.

Section 11 - Themes from Stakeholder meetings

NOAH had not been involved with the stakeholder meetings that developed the themes. Because of the special scientific expertise that representatives from the animal medicine industry can bring, we would very much like to be involved in any future meetings, both to contribute and to listen.

As part of the food chain (and as part of the group working towards responsible pet ownership) NOAH would be happy, and well placed, to assist with improved understanding and improving skill and knowledge. Indeed, NOAH is involved in initiatives along these lines (RUMA proposals on training, AMTRA training schemes, PHC advice on responsible pet ownership etc)

12 Questions to consider

Do you agree that we need a more strategic approach to animal health and welfare in Great Britain? If so what do you think a strategy should cover? Do you have any other views on the reasons for a strategy?

Yes, the development of a strategy is a good thing. It also needs plans on how to implement it, which could include:

a) Where are we now? This should include analysis of the level of disease, the disease challenges and an assessment of risk for the major species (unless you know where you are starting from, a plan is meaningless)

b) How did we get here? This will demonstrate critical trends

c) We do we want to get to? This will include the vision, mission and objectives which should be measurable.

d) How do we get there? This should include key steps and milestones

Is the draft vision set out above (section 10) a desirable future for animal health and welfare in Britain? What is your vision?

We would agree with the vision in principle (see above) but would wish to ensure proper use of licensed animal medicines is seen as an integral part of the solution

What economic, social, environmental and welfare benefits are you looking for from the Strategy? What costs need to be taken into account? And how should these be balanced?

Assuming animal medicines are part of the solution, then barriers to their development and authorisation need to be considered.

Companies recognise the need for regulation and accept that good regulations are an essential pre-condition for competitiveness. Regulations are critical to establishing and maintaining consumer confidence in the safety, quality, and efficacy of the animal health industry's products. They are a "guarantee" of the safety of new products entering the market. And, because they protect investments in intellectual property and facilitate entry into global markets, good regulations also provide a powerful stimulus to innovation. But, according to a 2002 study carried out by Business Decisions Ltd on behalf of the European Federation of Animal Health FEDESA, despite a number of important improvements since the mis-1990's, Europe's regulatory framework continues to exhibit major failings of design, implementation and enforcement. For example, across Europe:

" over the past 10 years the development time for a major food producing species medicine has increased by 4 years, one for a companion animal by 2.5 years. " The development costs for a major new product for food producing species has increased by 113% in real terms, one for companion animals by 84% and for a minor species by 75% " 35% R&D budget is spent on 'defensive R&D' (supporting existing products, leaving less for innovation. While some is justified in the light of increased scientific knowledge and new information, around 50% of the defensive R&D spend is though to be unjustified

Regulations are the biggest obstacle facing companies across Europe when they seek to innovate and exploit existing products - they are a major barrier to getting new products onto the market for the health and welfare of Britain's animals.

The British animal medicines industry needs a level playing field of implementation of EU regulations, same standards for third country imports of livestock produce, continued support in European discussions for UK distribution system and continued recognition for cascade for companion animals.

Can you identify any potential conflicts or risks that might challenge the draft vision?

If the vision is based on consistently high standards of animal health and welfare, and science is used as a basis for the strategy, there should really be no conflict. However, there is the potential for conflicts between perception and science - what if a new TB vaccine was to be produced by biotechnology; would retailers perceive consumers may not wish to eat meat from animals vaccinated against FMD? There is a real need to communicate and inform on issues such as these.

How can we build the new contract and make partnerships with stakeholders work?

Partnerships are already working e.g. AMTRA, RUMA, PHC, PAC - these do not need to be reinvented, but built on. If new stakeholder groups are established, we need to make sure that all sectors, including industry, are included. So to make stakeholder groups work, they need to be inclusive.

What is your most important long-term animal health and welfare priority? Do you agree with the issues and themes from stakeholder meetings? (section 11) Do you have any to add?

NOAH's most important priority is to seek recognition of the benefits of animal medicines to the health and welfare of animals, and to be recognised as a stakeholder with scientific expertise.

Your views are sought on the value of animal health plans: do you think this is something that should be expected from all animal keepers?

While commendable for the farming profession, (and working well through schemes such as the FABBL Farm Assurance Scheme) it is unrealistic for every pet owner to have to have a compulsory animal health plan. Having said that, NOAH is working with the veterinary profession towards greater emphasis on yearly checks for dogs and cats, even if not tied in automatically with a yearly booster vaccination. But it would never be enforceable - there is no government support even for dog registration, let alone any other companion animal!!

Have we set out accurately the roles of Government, the livestock industry, and other stakeholders? Is the current balance of Government intervention right? What are your views as a taxpayer?

It is important that the Veterinary Medicines Directorate, the agency working on behalf of the Government in licensing animal medicines in the UK, is also recognised as a stakeholder.

Do you have views on the scope of the strategy and how far beyond farmed livestock and companion animals it should extend?

There are two aspects to this. One is the environment and impact of farming on it and the animals that live in it - where existing groups like Linking Environment and Farming (LEAF) and Farming and Wildlife Advisory Group (FWAG) can tie in. This is probably outwith the scope of the strategy.

The other is wildlife as a vector for disease - e.g. TB, potentially rabies, and other diseases that could possibly arrive such as West Nile Fever. This is certainly an area an animal health/welfare policy needs to address.

For England and Wales, a commitment was made in the FMD Inquiry response to seek views on the regular reviewing and issuing of progress reports on the state of emergency preparedness : what do you think would be the most appropriate format for these? How often do you think Government should issue them?

We assume emergency procedures does not just refer to FMD. If there is more transparency about emergency procedures, there would be less 'conspiracy theory' about dry runs, enquiries etc. There's been a case of damned if you do, damned if you don't about them - for instance enquiries about wood for pyres prior to the FMD outbreak. But perhaps this is outside NOAH's remit. Information needs to be available, but not necessarily pushed out. For example, PHC and PAC are actively looking to see what provision (if any) is being made for pets in the new 'protect and survive' in the event of terrorist attack.

During the FMD outbreak, the media expressed concerns, claiming to be from consumers, that the public would need the reassurance if animals were vaccinated to protect against FMD. DEFRA needs to tackle this misconception. Numerous vaccines are already used safely in livestock and not only protect animals, but also consumers from zoonoses, therefore FMD vaccination, if included in Government strategy, should similarly be welcomed and not condemned due to insufficient education in the facts.

NOAH 1.4.03