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.
1. INTRODUCTION
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.
2. INTERPRETATION
OF THE
REGULATION
— 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.
3. HEALTH STATUS
AND CURRENT
PRACTICE
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.
4. SUMMARY
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.
5. RECOMMENDATIONS
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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