APPENDIX 14
Memorandum submitted by the Scottish Crofters'
Union[3]
(B 15)
The Scottish Crofters Union is very concerned by
the government's December 1999 decision to withdraw all OP sheep
dip from the market, and to recall all stocks, pending the design
and introduction of containers to minimise operator exposure to
OP concentrate. It is the Union's view that the Government did
not take sufficient account in its deliberations of the impact
such immediate action would have on the industry or on sheep welfare,
and that its decision is flawed as a result. This bias is not
surprising given the expertise and perspective of all the parties
involved in drawing up the advice (COT, VPC, ACP, CSM).
We believe that a more appropriate outcome from
the deliberations would have been to set a timescale for the introduction
of new containers such that they would become available before
the old ones were banned—thereby avoiding a damaging break
in the availability of OP dips. The SCU views in more detail:
— we cannot accept that the additional
health risk from continuing to allow approved producers to handle
OP dips, for the possibly short period until new containers are
available, is sufficient to justify the ban. The Government has
already recently introduced a requirement for training and approval
for those handling OP dips which has further reduced the potential
health risk to humans from OP dip concentrate;
— sheep scab has recently become a
severe and escalating problem in many parts of the country since
compulsory dipping was discontinued, and it is clearly a major
and current animal welfare issue. The practical experience of
many crofters to date is that OP dips are the most effective and
practical means of scab control. It is entirely inappropriate
in the SCU's view for the Government to remove one of the most
effective means of controlling scab at such a critical time for
the control of this very unpleasant and highly contagious disease.
Crofters have been left in the unenviable position of having to
embark on scab control initiatives on an unprecedented scale without
the benefit of OP dips, adequate information on the efficacy of
alternatives for their situation, or a likely timescale for the
return of OP dips to the market;
— sheep scab, once introduced, is a
particular challenge to control in many crofting areas featuring
large unfenced common grazings. These allow for the rapid and
widespread transfer of the disease following its introduction,
not only between different flocks on the common, but also across
to flocks on neighbouring common grazings. Eradication therefore
requires an extremely thorough gathering of these vast areas,
and exceptional levels of co-operation between the very many flock
owners concerned;
— dipping sheep is no longer a statutory
requirement, and there are several alternative treatments available.
These facts, taken together with the ample advice available and
the new requirements for the training and testing of operators,
surely mean that Government need not be concerned about public
liability in the event of the misuse of OP dip;
— there are already too many constraints
on crofters' freedom to manage their sheep in the manner best
suited to their own, and their flocks' particular circumstances.
Crofters and farmers are now well informed of the risks of careless
handling of OP dip concentrate, and of the safeguards required,
and the decision on whether or not to use OP dip should be left
to their balance of judgement. The Government's OP decision flies
in the face of its claims to be doing everything it can to reduce
the constraints and regulatory burden on producers;
— the Government's proposals are clearly
unjust on producers who have already been forced by other recent
legislation to incur substantial expenditure in order to continue
to use OP dips. Producers have invested time and money in the
training and certification required by recent Government legislation
for the use of OP dips. Many producers have also spent money on
the approval and registration (and possibly upgrading) of their
spent dip disposal sites in response to the recent Groundwater
Regulations;
— these costs are relatively higher
for crofters with their small flocks, and the withdrawal of OP
dips could mean that this expenditure has been effectively wasted—at
a time of severe economic hardship in the sheep sector;
— there is a possibility that dip manufacturers
and suppliers, themselves currently under severe financial pressure,
may decide to pull out of OP dips altogether, rather than meet
the cost of developing and introducing new containers for a possibly
lower turnover of product. The temporary ban envisaged could therefore
conceivably result in a permanent loss of the product.
The rushed process that led to the Government's
decision on OP dips is of concern. At the very least there should
have been a period of consultation with the industry to ensure
a thorough discussion of all aspects to the debate before any
decision was taken. Such a period of debate would also have allowed
information on the true efficacy of the alternatives to OP dips
to be collated, and an information programme prepared for implementation
in the event of a ban.
We believe therefore that the Government should,
as a priority:
1. review its decision to withdraw OP dips
from use in light of advice from this Commons Agriculture Committee
enquiry;
2. inform producers of the likely timescale
for the re-appearance of OP dip on the market. There has been
absolutely no indication of this, so producers do not know whether
the required container improvements will be readily met this season
or, at the opposite extreme, whether the specification is impossibly
high for manufacturers to meet at a justifiable cost;
3. state clearly its views on the future
use of OP sheep dips, and indicate the type of future research
finding which might cause it to implement a general ban on OPs.
Manufacturers, suppliers and producers are understandably suspicious
that the current proposal is simply a stalling tactic prior to
an ultimate banning of OP dips.
20 March 2000
3 The Scottish Crofters Union has a membership of
c 3,300 located in the most peripheral parts of the Highlands
and Islands of Scotland. The very poor agricultural quality of
their land, the harshness of the climate and shortness of growing
season means that hill livestock rearing is the only agricultural
option open to the vast majority of crofters. Virtually all of
the SCU's crofter members have sheep enterprises, and for most
of them this will be their only agricultural enterprise. The viability
of hill sheep enterprises is therefore critical to crofters' incomes
and to the viability of the many peripheral and economically fragile
crofting communities. Back
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