Letter to Baroness Hayman, Minister of
State, MAFF, from the Director, National Office of Animal Health
Ltd
OP SHEEP DIPS
Further to my fax of 24 December, I am now writing
to express industry concerns over both the content and handling
of the MAFF announcement on 20 December, to request an urgent
meeting involving all those who will have to live with the consequences
of the announcement and, pending that meeting to request that
your announcement is itself suspended so that a proper dialogue
can commence and a jointly agreed programme be put in place.
The MAFF decision could have serious consequences
for animal health and welfare, disease control, environmental
pollution and the economics of sheep farming in the UK, although
we note that none of these points were referred to in MAFF's press
release.
HISTORICAL BACKGROUND
May I remind you of two previous decisions taken
by MAFF which also seemed to be taken without Ministers being
advised of the wider consequences and which have undoubtedly laid
the foundation for the mess we all find ourselves in today.
Prior to 1984 the dominant insecticide used
in sheep dips was HCH (Lindane)—highly successful both in
its control of sheep parasites and its persistence, giving long
term protection to sheep, it also had low human toxicity. However
in 1984 the French government were looking for excuses to block
British sheep exports (plus ca change?) and latched on to the
British use of HCH Dips. To appease the French, MAFF officials
spoke individually to each sheep dip manufacturer, telling each
that "everyone else" had agreed to a voluntary ban.
This manoeuvre succeeded and HCH dips were withdrawn from the
British market. (It subsequently emerged that the French had outsmarted
our officials and that HCH dips continued to be used in France
for many years!) This was also the first recorded case of British
officials preferring to impose decisions on UK farmers without
taking the trouble to find out what was really happening on the
other side of the Channel. As a result of MAFF's appeasement of
Paris, within 12 months 95 per cent of the UK market was taken
by OP dips.
During the late 80's two themes emerged; campaigners
started to focus on OP's, while the Conservative government was
looking for things to de-regulate and money to save. In the late
80's it seems that officials advised Ministers that these two
challenges could be solved at once; and end to compulsory dipping
would disarm the critics of OPs while at the same time reducing
bureaucracy and government costs. The officials counselled an
approach of stealth—firstly the compulsory dipping regime
was steadily slackened, then, when sheep scab numbers started
to rise the regime could be scrapped altogether as being ineffective.
Finally, to cover up the inevitable consequences, the notifiable
status of scab was ended, so that there would be no official figures
to embarrass MAFF by recording the massive explosion of disease
which sheep vets rightly forecast.
MAFF's files will confirm the considerable protests
which arose from all parts of the sheep community. Much as farmers
and industry hate bureaucracy, this was one of the few pieces
of red tape which had the support of many farmers, merchants,
vets and manufacturers because of its success in keeping scab
under control and the very great fear of this devastating disease.
Nevertheless the official view prevailed, compulsory dipping was
scrapped and not only is Scab now endemic throughout Great Britain,
but many minor parasites which were virtually extinct have also
re-emerged.
I apologise for the lengthy introduction, but
it is important that you understand the background, both to the
present situation on the farm and the reasons for the industry's
widespread distrust of officials on the subject.
THE CONSEQUENCES
Returning to 20 December, a number of concerns
have emerged which extend far beyond the simple question of operator
safety:
1. Animal Health and Welfare
UK sheep are prey to a wide range of debilitating
and potentially life threatening parasites. Following the previous
government's disastrous decision to end compulsory treatment,
sheep scab is now endemic throughout Great Britain. Afflicted
sheep are so damaged by the irritation of the parasite that they
can stop feeding, lose condition, fertility falls and in extreme
cases animals may die or be destroyed.
Blowfly strike, where maggots literally eat
the sheep alive, can take hold in a few days, animals die of toxic
shock or have to be destroyed. Other parasites, once rare, such
as lice and keds, have increased since the end of compulsory dipping.
OP sheep dips have the widest range of efficacy
against ectoparasites affecting sheep.
While a wide range of alternative products have
been developed by the industry in recent years, none have the
breadth of activity of OP insecticides.
2. Disease Control and Resistance
The success of first HCH and then OP dips was
not only to reduce the number of scab outbreaks to a minimum,
they also reduced a number of minor parasites to the point where
many veterinary surgeons only knew of them from text books. Since
the end of compulsory dipping and the introduction of a wide range
of highly effective, but more specific, alternatives not only
scab but many other parasites are also on the increase.
According to the NFU (Farming Today 22
December) resistance to both synthetic pyrethroids and to the
avermectin family of endectocides already seems to be emerging
on British farms. Removal of the OP products, which currently
serve 50 per cent of the British market, can only force a greater
reliance on the remaining scab treatments and an inevitable acceleration
in the spread of resistance. Was this pointed out to you by officials?
3. Environmental Pollution
It is important to remember why OP products
came into use for dipping—they were seen as "kind"
to the environment when HCH dips were withdrawn in the mid 1980's.
Now there is more choice for farmers, but every product has its
advantages and disadvantages and SP dips, for example, have been
cited as being a potentially greater environmental hazard if disposal
instructions are not followed properly.
We discovered on Tuesday 21 December that the
relevant experts in the Environment Agency and the Scottish Environmental
Protection Agency were totally unaware of MAFF's announcement
and expressed to us their grave concern that the removal of OPs
from the market would inevitably lead to farmers, who traditionally
prefer dipping, switching to SP dips. Did your officials tell
you of environmental concerns about SPs, and that the Environment
agencies had not been party to their advice?
4. Farm Costs and the Right to Choose
The ability of the farmer to choose the most
appropriate product for his or her own particular circumstances
is vital. At this critical time for sheep farming, OP dips are
perceived by many farmers as being the most cost effective for
them. The products' broad spectrum can lead to "added value":
by also killing parasites of minor clinical importance, the sheep
skins will be of better quality and increase the value of the
animals.
Farmers still choose OP dips—15,000 have
chosen to undertake the certificate of competence to dip, and,
despite 10 years of bad publicity about OPs, the proportion of
OP dips in all sheep ectoparasite sales is now rising, currently
standing at 27 per cent by value, 50 per cent by usage. This rise
in OP usage is significant as it demonstrates the continuing faith
of farmers in the products to protect the health and welfare of
their flocks.
No one has ever been forced to use OPs, and,
before this news, there was a very wide choice of products available.
Farmers, like all consumers, should have the right to make an
informed choice of the right product for them and their animals.
5. Future Supplies of OP Sheep Dips
We were extremely pleased to note from your
press release that it contained no criticism of the product itself,
and noted you belief that OP dips in new packaging would be back
on the market in time for the next dipping season. While we welcome
your confidence and support, it would seem that here too you have
been very badly advised.
(i) As explained in my fax of 24 December,
no company heard the VPC's judgement until 20 December and even
now have not been permitted to discuss with VPC what is expected
of them or what "Best Industry Practice" means;
(ii) I am told that VMD rules require 12
month stability testing for new packaging—even if VMD bend
their own rules to extricate themselves, six months seems likely
to be the minimum accepted and first the VPC have to approve the
companies' outline proposals. Once the new packaging is approved
packs will have to be manufactured, filling lines modified etc.
A massive investment in time and money which, in my experience,
means that it would be prudent to assume 12 months without OP
dips in new packs.
It would also be prudent for you to check with
each company whether they intend to proceed with the packaging
project.
THE WAY
FORWARD
Finally, may I turn to the announcement on 20
December to suspend licences and demand that companies withdraw
all products from farms before 31 January 2000:
(i) We have Leading Counsel's opinion that
VMD have no authority to require product to be withdrawn from
farms;
(ii) We question the need for this to be
done by 31 January. As the main dipping season will not commence
until April, three months notice would have allowed all concerned
proper time to discuss and agree a plan of action;
(iii) Companies have been reminded that they
have three months in which to appeal—supposing their appeal
is successful, will MAFF re-imburse companies for the needless
expense involved in unnecessarily gathering up product from the
market? (And farms).
Logic would indicate that the deadline for collection
should be move to 31 March to allow proper time for dialogue and
for those companies who wish to appeal.
We understand that the reasoning behind the
decision to suspend licenses is because of fears that farmers
using existing cans could become contaminated while filling or
replenishing the dip bath.
(i) We agree that this is potentially the
most hazardous task in the dipping operation. It has been known
for decades that contact with the concentrate was the most likely
cause of OP poisoning. For this reason dip labels have, for over
20 years, contained advice on the use of extra protective clothing
"when handling the concentrate". In this respect the
IoM report said nothing new;
Interestingly, following VPC advice in February
1997 that labelling should be reviewed, in August 1998 VMD put
forward proposals which had been modified so that there was no
longer any distinction between the warnings on handling of concentrate
and diluted dip. NOAH urged them to revise this so that the warnings
on concentrate were more prominent, reflecting the greater risks
in handling concentrate (followed up in writing on 13 August 1998).
Sixteen months later there is still no news from
VMD/VPC on revised labelling for sheep dips.
(ii) While agreeing with the theory, we note
that in real life the number of adverse reactions reported to
be linked to contact with the concentrate are very low. This would
appear to indicate that farmers are conscious of the dangers and
are taking precautions, thus demonstrating that the Certificate
of Competence and other education methods are working;
(iii) In spite of this good record, in July,
following IOM/VPC advice and a proposal from AMTRA, VMD called
a meeting of all interested parties and proposed a "plain
language" plastic card should be sent to all sheep farmers.
The wording was agreed and 40,000 copies were sent out in November.
Not only was this a great expense to VMD (and hence the tax payer)
but there were also considerable costs to those organisations
such as AMTRA and RSPGB who voluntarily assisted with the distribution
(AMTRA alone spent over £1,000);
(iv) One peculiar aspect of this recent saga
is that we understand that VPC are intent on requiring companies
to introduce a "closed transfer system" ie some mechanisms
which will link the can to the dip bath. We were interested to
read in the MAFF press release that the remit of the VPC specifically
excludes "instrument, apparatus or appliance". Thus
it would appear that, in insisting on a closed transfer system
and in ruling on the suitability of company proposals the VPC
were acting without authority;
(v) This pressure on companies, as explained
to them by officials, to introduce "closed transfer systems"
is even more peculiar as the VPC report of November 1999 make
no mention of "closed transfer systems".
The Report does recommend "more caution"
in the handling of concentrated dip (5.3) and we would suggest
that the laminated notice positively noted in the Report (6.9)
goes a long way to achieve this.
Compared to the recommendation for withdrawing
current packaging the VPC report is remarkably mild. . . "not
because existing containers are inherently unsafe when used in
accordance with instructions but because we believe that using
them presents difficulties in handling, particularly when wearing
the recommended gloves . . ."
Logic would indicate that there is no specific
need to suspend the current packaging on operator safety grounds.
Operators are well trained, advice on handling concentrate has
been issued for many years. New advice was issued in November
and adverse reaction reports are very low.
As outlined above, the summary removal of products
which currently supply 50 per cent of the market will have inevitable
consequences for animal health and welfare, disease control and
farm economies.
We do recognise the need to improve packaging
but cannot comply until VMD/VPC have explained what is required
of companies. In the meantime there is likely to be a period of
up to 12 months before new packs emerge.
For all the above reasons we believe that the
advice you have been given is seriously flawed. Therefore the
suspension of licences should be lifted and these useful farming
tools should be allowed to remain on the market for an agreed
period so the transition to new packs can be conducted in an orderly
and trouble free way.
Finally we request that you convene an urgent
meeting involving the relevant farming, veterinary and distribution
groups so the widespread concerns can be explained to you at first
hand.
7 January 2000
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