Annex 1
COMMENTS FROM NATIONAL SHEEP ASSOCIATION
(MARCH 2000) TO GOVERNMENT ON ORGANOPHOSPHATE SHEEP DIPS
Copy of letter to Baroness Hayman dated
6 January 2000
GOVERNMENT ANNOUNCEMENT
ON ORGANOPHOSPHATE
DIPS
I am writing to inform you that the announcement
made on 20 December concerning OP dips is considered by my organisation
to be illogical, unreasonable, excessive and against environmental
interests, sheep welfare and the peace of mind of producers. For
these reasons we ask you to reconsider your decision as a matter
of the utmost priority.
We will spell out our thinking as simply as
possible.
1. Against the environmental interests
The alternative chemical used to control ectoparasites
in sheep by the plunge dip method is synthetic pyrethroid. It
is common knowledge that SPs are far less friendly to the environment.
It is equally important to recognise that the general conclusion
of sheep farming organisations* is that the best interests of
sheep farmers are served by the maintenance of a wide armoury
of products which can be deployed in the most appropriate way.
For example, injecticides are suitable for breeding stock and
animals kept for relatively long-term storage periods, but are
not suitable for animals imminently destined for the food chain.
The most effective injecticide having a withdrawal period of some
72 days.
Vitally important to recognise that at this
time of year OPs are the favoured products for dealing with sporadic
outbreaks of sheep scab and heavy lice infestation. Important
also to understand that in disposal of spent dip terms the OP
product is the safest option available especially when groundwater
levels are at their highest.
2. Against sheep welfare
It is common knowledge that the sheep scab mite
(psoroptes ovis) becomes most active during cold weather—ie
this time of year. It is also well known in farming circles that
since the removal of compulsory treatment period for scab that
it has become endemic and even though it is unlikely to be recognised
officially there is anecdotal evidence of quite massive, probably
unprecedented numbers of sheep suffering from scab at the current
time. As many of these animals are destined for relatively imminent
slaughter it will not be suitable to inject them and as the Synthetic
Pyrethroid is not considered by many to be effective the removal
of OPs creates a void which is not filled by any other product
and will result in a potentially serious welfare problem.
3. The peace of mind producers
Several years ago the Certificate of Competence
was instituted with close industry co-operation at all levels.
To date some 16,000 people have been approved which includes a
great number of professional contract dippers. Since its inception
the rules have been tightened and extended—again with the
co-operation of the industry. An important part of the purpose
of the Certificate of Competence was to ensure that people handling
the chemical understood that they were dealing with a product
which could be hazardous to their own health and to ensure they
knew how to deal with it in the most suitable way. The test was
taken by sheep farmers to ensure that they would be able to purchase
and use the product which they considered to be the most suitable
for the purpose of maintaining the welfare standards of the stock
in their care. We take the view that the removal of OPs, even
on a temporary basis, breaks an agreement of faith between users
and Government without there being a suitable and acceptable replacement
and this places enormous mental pressure on producers who consequently
find difficulty in looking after their stock effectively. With
this in mind and with the utmost respect for those who feel that
users should be protected from possible exposure whilst opening
the dip concentrate container we feel that to withdraw the product
for this reason reflects unfairly on the competence of the users.
We would also make the point that as it is impossible to remove
all elements of risk in life that any assessment of risk analysis
associated with container lids should bear this in mind.
4. An illogical and unreasonable decision
We would take the view that the best logical
progression in this issue would have been to allow the process
which had been started to get manufacturers to redesign containers
to come to fruition. We understand that one company had provided
a suitable system so it would have been far more reasonable in
our view to have allowed that company to supply product in its
new containers and give time for the other companies to come up
to the same standard. The fact that in spite of this company having
come up with a suitable design but was not given an immediate
green light, smacks to us of a Government bent on imposing its
will on an industry which has worked consistently and constructively
to achieve an equitable result. Note must be taken of the fact
that whichever way we look at it the product used to kill ectoparasites
on sheep is likely to be a poison. It is equally a truism that
all poisons will have a downside. We submit that OPs on balance
would seem to have as much benefit as any other currently available
and to have least cumulative, negative side effects.
We conclude that the removal of OPs from the
market at this time provides no benefit to sheep farmers and is
positively harmful, a serious disbenefit to the welfare of sheep
and the potential for an added problem to be visited on the environment.
We implore you therefore to reconsider this ill-thought decision,
arrange an urgent meeting with the entire industry and re-establish
a proper dialogue which takes us forward in a positive way.
*[NSA represents over 80 such incorporated groups
throughout UK covering around 15,000 people as well as 11,000
individual farming families.]
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