APPENDICES TO THE MINUTES OF EVIDENCE
APPENDIX 1
Memorandum submitted by the Secretary
General, Animal Health Distributors Association (UK) Ltd (B 1)
Thank you for your letter of 3 March. I am pleased
that the committee is going to look into the issue, however, in
my view, this should be on a constructive basis, ie where do we
go from here, and how do we get there. I would be totally opposed
to a witch hunt in respect of the decision of 20 December and
what went before, despite my belief that it could have been handled
much more satisfactorily from all sides. However, it may be helpful
if the Committee were to recommend that if a similar situation
were to arise in future government should bring together manufacturers,
distributors and users immediately before the announcement is
made, to work out the least damaging and most effective means
of recall and an appropriate and practical timetable.
Turning to the future, I can do no better than
repeat extracts from my letter to the Minister, of 11 February,
of which you have a copy—indeed whether because of the letter,
or coincidentally with it, most of the suggestions contained in
it seem to be happening—last week, this week and next week.
Thus I hope this constructive phase is permanent.
As I said to the Minister on 11 February:
"The first problem is that without OP dips
the sheep industry faces an increasingly serious disease and animal
welfare problem—alternative dips will be overused and as
was said by their own manufacturer yesterday, may become ineffective
in large parts of the UK by the end of this year. Injections of
endecticide will not and cannot solve the problem on a nationwide
basis. The second problem is that it is politically impossible,
I fully recognise this, for you to reject advice received from
a regulatory committee such as the VPC, or to have second thoughts
after lobbying from industry and tell them to change their advice
to you!"
I went on to emphasise the vital aspects of
the VPC's advice on which the 20 December announcement was based:
"Point 8.3.2.I is the key. VPC remind you
that they requested urgent design changes in July 1999. They then
go on to say that they have seen plans from manufacturers for
changes, but that they `advise that remaining marketing authorisations
should be suspended until the design of containers is improved
to minimise the risk of exposure to OP concentrate and/or clear
plans are in place to effect the necessary improvements'. By using
the `and/or' this advice leaves it to you to decide whether to
wait until changes are in place, or to end the suspension when
the plans alone are in place—ie the suspensions could be
ended from a specific future date on the basis that product is
marketed in accordance with the plans submitted and agreed."
I went on to conclude:
"Therefore the issue is for the VPC to be
satisfied that the `necessary improvements' have been `effected'.
Would it not be possible following yesterday's meeting, for you
to write to the VPC, informing them of the extreme risk of an
animal welfare crisis of which you have been advised, following
your adoption of their advice on OPs, and asking them for a further
report, by 31 March 2000, on the progress that is being made by
marketing authorisation holders in developing plans, acceptable
to them, the VPC, that would `effect the necessary improvements',
so that the suspension of market authorisations could be lifted
on or before 31 May 2000. Such a request of VPC could encourage
them to cut through some of the unnecessary traditional bureaucracy
and formal appeal procedures associated with market authorisations,
which would in this case waste time we do not have. It would persuade
them to actually discuss with market authorisation holders what
is possible in order to meet their requirements—which are,
we must remember, to `minimise' and not, however desirable to
HSE, to `eliminate' the risk, which is impossible."
"I also suggest that as part of the package
for ending the suspension of market authorisations, the idea which
was put over at the meeting, that it be made a specific legal
requirement that only the Certificate of Competence holder is
allowed to handle concentrated OP dip—something that AHDA
pressed for when the C of C was first introduced."
Finally, I mention to you the final point of
my letter to the Minister—point 8.3.3.1 of the VPC's regulatory
advice. This stated that "Ministers should re-emphasise to
merchants the importance of ensuring that purchasers of sheep
dips are fully aware of the potential hazard of exposure to sheep
dip". It was not made clear earlier in the VPC advice (point
6.9) that it was AHDA, representing most of those supplying dips
to farmers, who first proposed that this laminated A4 sheet should
be produced and distributed. Indeed, the original AHDA proposal
was that this A4 laminated sheet should be made legally part of
the required labelling of each dip container, so that it was a
legal requirement that one was handed over with every container
of dip purchased. We proposed this so that it was not necessary
for a farmer to lift a container of dip (possibly open) to head
height in order to be able to read the safety advice. Unfortunately
this proposal, which would have been far more effective than that
which was eventually adopted, was watered down as being impractical
by others prior to the distribution route by AMTRA and NPTC being
agreed. I return to this idea and suggest that when the suspensions
are lifted, these A4 sheets are made a legal part of the labelling
requirements to be handed over with each sale of dip.
6 March 2000
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