APPENDIX 21
Supplementary Memorandum submitted by
the National Office of Animal Health Ltd (B 24)
On 11 April the Committee interviewed Baroness
Hayman, Professor Aitken and Mr Anderson of MAFF. The internet
transcript raises a number of points which we believe require
further clarification or comment and, as we understand the Committee
will not be asking us to give oral evidence, we set them out below
using the paragraph numbers of the transcript for reference.
(A) HANDLING
THE CONCENTRATE—THE
NEED FOR
URGENCY?
In paragraphs 2-13 there are a number of references
to the need for additional care when handling the concentrate.
However, neither Committee members nor MAFF make the point, emphasised
in our earlier document, that the need for this extra care is
not a new revelation, but has been included in the advice on levels
of OP sheep dip and MAFF/HSE leaflets since the mid '80s.
This is highly relevant to Mr Austin Mitchell's
very pertinent question in Paragraph 14: "What I want to
know is why so suddenly?". A question at the core of the
whole issue.
Members will recall, for example, that the concerns
over current containers and the risk of contamination when
handling them to dispense concentrate was first highlighted by
IOM in their 1996 on-farm survey—IOM did not, apparently,
think it of urgent importance, but simply included it in their
1999 report to MAFF (a two and a half year delay). MAFF in turn
did not take immediate action on receipt of that report, but allowed
those containers to remain in use throughout the second half of
1999—even though, it will be remembered, Mr Jeff Rooker,
MP, summoned sheep dip companies to MAFF to express concern in
July 1999.
A further complication arising from the IOM
report is that, with their farm enquiries taking place in 1996,
it is unclear whether the containers they criticised were those
updated by companies in 1995 following VPC discussions, or whether
some of them were old stock, pre-dating those changes.
All subsequent comments by VPC, CoT etc,
on pack design are based on IOM's 1996 survey.
(B) ALTERNATIVE
FORMULATIONS
In paragraph 35 Professor Aitken comments on
the possibility of using new developments in crop spraying technology,
such as water soluble sachets. Without wishing to go into great
technical detail, it should be recognised that there is a considerable
difference between the relatively simple task of formulating a
weed-killer or insecticide for application to leaves or soil,
and the great challenge of formulating an ectoparasiticide so
it can penetrate several inches of greasy wool to reach the parasites
living at skin level. (The sheep's coat has evolved to very effectively
repel water—which is why they can survive in the British
climate). To achieve this task requires the inclusion of solvents
and emulsifiers in the dip formulation. Unfortunately these same
chemicals have serious effects on conventional plastic containers,
water soluble sachets etc. May we assure the Committee that sheep
dip companies, many of which are also involved with crop spraying,
would have switched to such packaging technology many years ago
if it had been a practical proposition (not least because current
sheep dip cans are more expensive than the plastic alternatives).
This explanation is also relevant to Mr Anderson's
incorrect statement (paragraph 89) that sheep dip formulations
have not been tested in polyethylene containers.
(C) COMMUNICATION
WITH COMPANIES
In paragraphs 51 and 52 there is discussion
on Mr Drew's enquiry about when companies knew of the suspension
decision. While it is true that Mr Rooker warned companies in
July of the potential for a suspension, as Baroness Hayman explained,
this was dependent on their failure "to come up with alternative
solutions". During summer and autumn 1999 companies developed
alternative proposals which they believed met MAFF's requirements.
These proposals were presented, in good faith, to VPC at their
November meeting. However, it was not until 20 December that companies
were told of VPC's rejection of those proposals.
Up until 20 December companies had every reason
to believe that their proposals would be accepted. The "shock"
on 20 December was thus in three parts:
— that the proposals had been rejected,
— that there was no offer of further
discussions on how to improve the proposals,
— that instead an immediate suspension
was introduced.
While Baroness Hayman is correct (paragraph
52) in stating that she met with industry representatives and
subsequently arranged further meetings, her reply might have been
more complete if she had explained that her meeting with industry
was not until 10 February and followed a number of letters and
faxes from NOAH and others requesting an urgent meeting.
(D) HSC INTERVENTION
In paragraphs 80 and 125 there is reference
to a letter to VPC from the Chairman of the Health and Safety
Commission. As indicated in our earlier memorandum we had no prior
knowledge of this letter, nor indeed, that HSC were discussing
the topic. It must be a matter of great concern both to natural
justice and the current drive for "transparency" that
the HSC did not consult affected parties before formulating their
advice to VPC, nor have we, even now, been allowed to see the
full letter.
VMD did, on our behalf, ask HSC if we could
be shown the letter, but were only permitted to release extracts.
(E) MARKET SHARE
OF OPS
In paragraph 91 and elsewhere Professor Aitken
discusses NOAH's estimate that 50 per cent of sheep were treated
with an OP dip. For clarification I should explain that our estimate
is that of all UK sheep treated with some form of ectoparasiticide,
50 per cent were treated with an OP dip—the remaining 50
per cent being divided among a wide variety of treatments—SP
and other dips, injectables, pour-ons etc. Most of these have
a much narrower spectrum than OPs and most are ineffective against
all three of the major parasites—scab, blowfly and (of growing
importance) lice, unlike OPs. It would therefore be wrong to imply
that the switch from OPs to products making up the other 50 per
cent would be easy or without negative implications.
(F) Finally, may we welcome the news (paragraph
93) that the State Veterinary Service is to look at welfare issues
affecting sheep in general and the monitoring of sheep scab in
particular. This is very good news and I have written separately
to the Chief Veterinary Officer offering our assistance.
We hope the Committee will find these additional
comments of assistance and would be very pleased to provide further
information if that would be of assistance.
3 May 2000
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