NOAH Responds to Organic Lobby Report

The authors of the latest Soil Association report clearly do not understand the poultry disease coccidiosis or the stringent system for authorising and monitoring the use of coccidiostats in poultry production, says the National Office of Animal Health. The report 'Too Hard to Swallow', published on 4 June, is alarmist, confused and misleading. Its use of NOAH quotations shows it to be extremely selective in what information it chooses to make its case.

"The Soil Association is a lobbying organisation. It exists to promote the interests of organic farmers and therefore has a vested interest in denigrating conventional food, on which the vast majority of the public, especially those with limited incomes, rely," says NOAH.

It is vital that people are not misled so they can make choices about the food they eat based on sound knowledge. NOAH welcomes reports that the Food Standards Agency is to convene a meeting on this subject. "We will continue to work with the UK and EU authorities, and alongside colleagues in the UK food production chain, to ensure minimal residues in animal produce while also ensuring the continued availability of the animal health products essential to ensure farm animal health and welfare," NOAH says.

The report wrongly states that the three highlighted substances (nicarbazin, lasalocid and dimetridazole) "have never been properly evaluated". Substances such as these are fully regulated, under EU Directive 70/524, as zootechnical feed additives (not "veterinary medicines"). They are not allowed to be used anywhere in the EU unless approved by the relevant EU Commission experts who must determine that they do "not endanger animal or human health nor harm the consumer of livestock produce".

NOAH fully supports residue testing of all animal produce, whether UK produced or imported. To ensure public confidence the test results must be publicly reported. It is ironic that it is only the VMD's openness in publicising test results, for many years, which has enabled the Soil Association to produce this report.

Although testing of poultry meat and eggs has only been a statutory requirement in the EU since 1998, the UK has done this voluntarily (but to the same high standards) for many years. "They deserve congratulations not criticism," says NOAH.

The report also quotes results from Government residue testing schemes, without attempting to put them into context. For example, 102 kilograms of chicken would need to be eaten each and every day to exceed the EU safe limit on lasalocid or over 2000 eggs would have to be consumed each day to surpass the internationally agreed safe nicarbazin level.

"NOAH is confident that current testing procedures prevent unacceptable residues entering the food chain. Furthermore, thanks to the advances in residue testing, the majority of the minute residues detected, highlighted by the Soil Association, are well below the safety levels set by the EU or UK authorities. These themselves include huge safety margins," NOAH says.

NOAH condemns any usage of a product outside the clear rules set out for all livestock medicines and zootechnical feed additives, which are designed to prevent any unacceptable levels occurring in livestock, produce. To assist farmers and vets, NOAH regularly publishes its easy reference booklet "Withdrawal Periods for Animal Medicines", which is sent free of charge to all farm vets.

5 June 2001

Notes for Editors

1. For further information contact Roger Cook or Alison Glennon at NOAH, tel. +44 (0)20 8367 3131, or visit the NOAH website.
   
2. The National Office of Animal Health was formed on 1 January 1986 to represent the UK companies which research, develop, manufacture and market licensed animal health products. The association has 37 corporate members and 10 associate members. In 2000 NOAH's members accounted for around 95% of the £357 million UK animal health market, with additional valuable exports.
   
3. The testing regime and the setting of Maximum Residue Limits have huge safety factors built on top of the mathematical calculation. MRLs are based on the Acceptable Daily Intake (ADI) for a substance - this ADI is between 100 and 1000 times lower than the No Observable Effect Level (NOEL) for a substance and indicates a safe level of consumption for a person consuming the substance every day of their life.

   A further numerical example is that of nicarbazin and chicken liver.

   The ADI for nicarbazin is 0.4mg/kg bodyweight. A standard 'EU human' weighs 60kg. The highest level of nicarbazin ever detected (and this was a one-off) is 7.2mg/kg chicken liver. This means that a person would have to consume 3.3kg of chicken liver at that exceptionally high residue level every day of their life to reach this limit. Take out the huge safety factor - in this case 500X - and to reach the calculated NOEL that person would have to eat 1.66 tonnes of chicken liver every day.

4. The Soil Association report 'Too Hard to Swallow' by Richard Young and Alison Craig was published on 4 June.