Select Committee on Agriculture Appendices to the Minutes of Evidence

Annex B

  Dear Mr Keatinge

  Thank you for the letter you sent to Mr Peter Orpin, President of BCVA, regarding EU Organic Regulation 1804/1999. Mr Orpin forwarded the letter to me for a reply.

  The British Cattle Veterinary Association is a professional group comprising veterinary surgeons and others who have a particular interest in cattle medicine. We provide scientific meetings and other services for our members.

  BCVA has recognised the growing interest in organic enterprises and has several concerns regarding the future of the organic cattle industry. These concerns include the movement's speed of development, the apparent variation in scheme rules, the attraction of more business minded farmers to premium organic prices, and the risk that a combination of these factors poses to organic food credibility and consumer perceptions. Our particular interest stems from the direct involvement of our members at farm level who have both converted and converting clients that need specific veterinary services. Our role is to provide those members with sufficient information so that they may safeguard the welfare of both animals and clients to the best of their ability.

  In our aim to fulfil this role we have been in contact with Malla Hovi MRCVS at Reading in order to discuss ways in which sound practical guidelines can be developed to help veterinary practitioners and their clients adopt organic principles for their stock management. Malla has been very helpful in this regard, and I am due to reply to her within the next few days.

  The document you circulated for consultation focuses upon the major areas of importance, and it is a good starting point for a paper that will help deal with some of the apparent inconsistencies that exist in the organic regulations. I have divided my comments into headings relating to the numbered sections in the paper.


  BCVA is pleased to hear that the NAHWOA has recognised the so-called "three strikes and out" rule as an issue of priority. BCVA also feels that this rule could have serious effects on animal welfare and organic credibility if the situation is not addressed. We therefore welcome any discussion regarding this issue and give our full support to aid in the development of a pragmatic solution.


    —  The farming methods required to fulfil the general principles laid out in 5.1 and 5.2 are nothing new in that they were methods used before many of the medicines commonly used today became available. The differences lie within modern-day expected production levels and the stocking densities required to achieve these.

    —  The commentary to 5.4a describes the definitions well; I may have misunderstood, but shouldn't the last paragraph suggest that "herbal remedies and plant extracts may be allopathic . . ."? In this way it would be a natural allopathic treatment and not a chemically-synthesised one, and so acceptable for use. The inclusion of Phytotherapeutics as a separate category would help with interpretation.

    —  5.4b is essential to allow the veterinary surgeon final discretion as to the advised therapeutic protocol in a given situation in order to safeguard animal health and welfare. The lack of specificity allows for this discretion to be applied and should be retained.

  Vaccines are likely to form the greatest proportion of genetically modified veterinary products. Vaccines are essential in many circumstances to control the incidence of a particular disease. This is an area where we have experienced illogical interpretation of the requirements by individual associations, with a genetically modified BVD vaccine being acceptable so long as it was monovalant; two different monovalant vaccines could have been used, but not one combined one!

  Whereas it is true that phytotherapeutics in particular are outside the licensing scheme, it is only the case if there are no medicinal claims made for the product. If such claims are made, a medicinal license must have been granted. Homeopathic treatments are covered by their own specific EU legislation.

  In all member states, the use of prescription only medicines must be under the direction of a veterinary surgeon under whose care the animals have been placed; this care being regarded as real and not nominal. This creates a number of problems at the moment. There are few food-animal veterinary surgeons with extensive organic/homeopathic experience in the UK, and there is potential for advice to be given almost by correspondence. Some veterinary surgeons providing this advice are such converts to the philosophy that communications with local veterinary surgeons become difficult due to a reluctance to consider conventional medicine as a possibility. Measures must be taken to ensure that the organic bodies do not apply ivory tower conditions restricting the most appropriate therapies for certain diseases. Practical veterinary involvement in the setting of organic livestock standards is essential. In turn the veterinary profession must further educate itself in the application of organic methods.

  Activity regarding the harmonisation of the veterinary medicines legislation has now been re-introduced. Much of the problem lies in the different classification systems for veterinary medicines currently in place in different EU states.

    —  In 5.4c the view that a distinction should be recognised between preventive/prophylactic and strategic treatment/metaphylaxis is supported.

  There is concern over the use of dry cow therapy for the treatment and control of subclinical mastitis and high somatic cell counts. Dry cow therapy is a cornerstone of the NIRD five-point plan and has served the industry well in the reduction of national cell counts and mastitis incidence. To remove it in total is a retrograde step for many herds. Not only is there a welfare issue for which this treatment is indicated, there is also a real possibility that farmers with SCC problems will rely on high culling and replacement rates to maintain the herd below the level set by the clean milk directive. Not an impression that the consumer wants to be presented with.

  The use of vaccines to control disease incidence should also be regarded in a different light, possibly by drawing distinction between acceptable preventive treatments and prophylaxis. It is our understanding that different EU states and their organic associations interpret vaccination in a different manner to the UK associations, allowing the use of more vaccine protocols. It would be useful to discuss the various interpretations to ensure that similar production constraints are being applied.

    —  Section 5.6 requires the inspection of farm treatment records by an inspection authority in order to maintain organic status. This body must be totally independent and transparent in its activity to ensure credibility and engender consumer confidence.

  With the premium prices being attracted for organic produce, there is a great temptation for the farmer to under record disease treatments. A comprehensive audit system must be in place to ensure that the consumer has every confidence in the system, so maintaining credibility. BCVA has recently gained much experience in this area with the development of the National Dairy Farm Assurance Scheme (NDFAS).

    —  The withdrawal periods in 5.7 make a little more sense than those currently in place for the UK. To extend a conventional withdrawal period by a given factor, even though it is arbitrary, at least pays some respect to the science that established the original period. To impose a minimum of 14 days, so equalising a 24 hour product with a seven day product, is ludicrous. This particular ruling has greatest effect on the treatment of mastitis in dairy cattle. Mastitis is a painful condition, and the farmer is seriously discouraged from using an intramammary tube due to the prolonged withdrawal time. Worse still with respect to the regulations, he may be tempted to treat the animal and not record the treatment.

    —  Paragraph 5.8, the "three strikes and out rule"! This is one of the most concerning aspects of the regulations for BCVA. As has been rightly pointed out, the wording needs altering to remove confusion.

  This regulation will provide a direct deterrent for farmers to treat sick animals or record such treatments. What of the animal that has received two treatments and then is threatened with removal due to an ailment such as foul in the foot, which would readily be treated by a short course of antimicrobial? Will she remain lame for a much longer period of time, hoping for a natural resolution? Will she be treated but not recorded?

  There is also the possibility of larger farmers running two herds. The organic herd exists to attract the premium product, but has a high replacement rate, with cows being transferred out to the commercial herd if they are more prone to illness or reduced fertility. There is then little incentive for that farmer to improve the lot for the organic herd and reduce overall treatments. This is already happening on several units.

  As is stated in the commentary, such restriction should be avoided in the interests of animal welfare and consumer perception.


  The need for an assessment of disease levels on organic units as compared to conventional units is supported. Actual estimation of such levels on either type of farm is problematic. Accurate estimates of the incidences of mastitis and lameness for example, can only be gathered as part of a comprehensive recording system applied consistently across a large number of herds. Such a system would need an audit trail to ensure accurate recording. No such scheme has existed in the UK until recently, and voluntary surveys are notoriously inaccurate.

Dairy systems

  The advent of the NDFAS has provided a framework through which such a recording scheme should be possible. The requirement to record incidences of the major production diseases, the introduction of a herd health plan, and regular inspection by independent auditors provide depth and credibility to the system. With the majority of the major milk retailers now committed to the scheme, the true incidence of disease on scheme farms will become known to a unit's individual veterinary surgeon. In this way, accurate comparisons between herds will be possible. Until such time, comparisons will be based on anecdote and selective recording.

  The subject of mastitis, SCCs and DCT has been dealt with above. There may well be less reported antibiotic used on organic units, but whether this is real, or whether the mastitis situation is properly under control, is another matter.

  The second Dairy System paragraph is also inaccurate. Whilst infertility and lameness may well be of lesser importance in terms of incidence, lameness cannot be viewed so. In general, the causes of lameness on organic farms are not widely different to the causes on conventional units. With incidences of 30 per cent being common, greater than this in some herds, this is singularly the most important welfare issue facing the dairy industry at the present time. I therefore question the statement that the overall incidence is low! It is true that the majority of cases can be treated within the existing regulations. This includes digital dermatitis, so there is no need to attract attention to this individual condition. The obvious problem with digital dermatitis is the widespread practice of footbathing the herd in antibiotic to achieve control. There are problems emerging with this practice on conventional farms with the use of unlicensed medicines that makes the distinction between them and organic farms less clear (seven day milk withhold). In any case, cows can be treated as individual cases within the current regulations.

  BVD should be considered as a separate entity. BVD has widespread effects within the herd over and above the association with the respiratory pathogens quoted. Vaccination for this virus is viewed by many as the cornerstone for control of disease on the whole unit. It is not a disease that lends itself readily to control by simple management.

  Lungworm is becoming more prevalent, particularly in adult animals. The use of strategic vaccination and/or anthelmintic programmes are essential for control. Without such control, the health and welfare of animals on organic units will suffer. Vaccination can presumably be instituted on written veterinary advice. Strategic treatment for fluke is a similar issue.

Beef systems

  Many of the problems affecting the dairy cow will also affect the beef suckler, but often to a lesser extent. Scour problems with calves at foot may be more of an issue.

  The major problem with beef units is the incidence of pneumonia in the housed weaned calf. Management can largely deal with this, particularly coupled with vaccination programmes, but many of the management procedures to be employed include investment in infrastructure, investment that is currently in short supply.

  No comment upon the sheep, pig and poultry sections.


  The first paragraph is meaningless. The quality of the information available to make such an assumption is questionable. What constitutes "acceptable levels" of disease incidence? ". . . At least in some instances better than that on conventional farms" suggests that the majority of conventional farms have better incidences than organic farms!

  The use of antimicrobials on organic units might be much less, but this does not mean that the health and welfare of the animals is any better! Indeed, the priority to reduce veterinary input on farm may result in decreased standards for the animals. Whilst a decrease in conventional medicine use is desirable on organic units, the input of the veterinary surgeon in the development of a preventive medicine strategy is arguably more important, so resulting in greater veterinary input to the unit. There are reports from the welfare unit of the VLA that organic units are being over represented in the incidence of disease associated with compromised welfare.

  It is accepted that the veterinary profession has not generally kept pace with the development of organic farming, but this is as much the fault of the organic associations and regulatory bodies for instituting conditions and standards without adequate veterinary input. BCVCA is committed to raising awareness of our membership in organic farming techniques, but to do that, there needs to be a commonality of approach on which to base an education programme.

  The problem of policing restrictive medicine policies is a major one, and one that threatens the credibility of the whole organic movement.

  Fully support a flexible approach to the use of chemically-synthesised allopathic medicines to protect animal health and welfare.

  The NDFAS will provide a framework for herd health plans on dairy farms.


  The institution of herd health plans in association with the veterinary surgeon are vital to protection of animal health and welfare on organic units.

  Comparison of true disease incidence between organic and conventional farms is required to develop specific advice. The incidence of diseases compromising welfare must be further investigated by the MAFF welfare unit.

  The existence of an independent audit authority is essential for the creditability of the organic organisations.

  Do not suggest that the limitation of allopathic treatments might be less problematic, this negates the need to remove the requirement.

  I hope these comments are of use in your aim to formulate the discussion paper. I look forward to seeing further developments.

  As I mentioned earlier, I am about to enter into correspondence with Malla Hovi regarding the whole issue of organic farming as it affects the UK cattle veterinary surgeon. It is hoped that this will lead to meetings with the various organisations to develop the commonality of approach needed to further develop the organic issue within the veterinary profession. It is only by including the veterinary profession that the organic movement will be seen to be considering the health and welfare of the animals on organic units, and therefore protect consumer confidence.

  If we can be of further assistance, please feel free to get in touch.

Carl Padgett, MRCVS

Hon Sec BCVA

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