Memorandum submitted by the National Office
of Animal Health Ltd (F37)
NOAH represents the manufacturers of animal
medicines in the UK. NOAH's 34 corporate members supply approximately
95 per cent of all the animal medicines sold in the UK, and an
even larger share of those sold for use on farm. Thus we inevitably
regard ourselves as part of the Animal Welfare sector, taking
a particular interest in the livestock sector, which currently
takes about 50 per cent by value of the animal medicines sold
in the UK.
The British countryside is the product of 10,000
years of farming, and current conventional farming techniques
produce affordable, high quality food whilst also minimising the
negative impact on the environment. Conventional farming methods
were developed as a way to solve the problems of earlier farming
generations, but now many of these practices may be rejected in
favour of "organic" production.
While we have no objection to any farmer choosing
to farm in a particular way (laws and standards permitting) we
are most concerned that some proponents of organic farming tend
to promote themselves by attacking the conventional 97 per cent
of farmersaccusing them of abusing animals, poisoning consumers
and the environment.
Organic farming is widely perceived to be a
"Good Thing" and it may be predicted that the majority
of those responding to your enquiry will be supporters of "Alternative"
agriculture who will urge that organic farming should be given
greater political and financial support. We beg to differ, and
to suggest that in four important ways those promoting organic
farming have the potential to do enormous damageindeed
much damage may have been done already:
(1) Public confidence in farming and
in the process of regulation as laid down by Parliament has been
(2) Animal health and welfare could
be jeopardised by restrictions on medicine usage
(3) Misleading the public with claims
that organic food is "healthier", tastes better, is
better for the environment.
(4) Sustainability and the ability
to feed future generations.
(Some of the information in this submission
is based on quotes from researchmore details can be found
in Annex 1).
1. PUBLIC CONFIDENCE
The last decade, or more, has been notable for
a change in public attitude to farmers and farmingfarmers
are no longer seen as providers of the food we need to survive,
but as rapists of the countrysidedestroying the environment,
poisoning wildlife and people, abusing their animalsand
all for "profit". It is no coincidence that this is
the message, the "knocking copy", which has been used
by organic proponents such as the Soil Association to promote
their method of farming, (the fact that organic farmers also make
a profit is seldom mentioned, although for many of the system's
newest recruits it is a major attraction).
Organic organisations have been particularly
harsh in their criticism of agricultural inputs: agrochemicals,
fertilisers and animal medicine. Such criticism ignores the stringent
controls required under EU and UK law, and, in the process, public
distrust of science and of government regulation has also grown.
For over thirty years Animal Medicines have
been regulated, under laws first laid down by the Callaghan Government's
Medicines Act 1968. This law, and its subsequent updating by UK
and EU law, requires a Medicine to be of high quality, effective
and safe to animals, users, the environment and the consumer.
Equivalent laws apply to crop chemicals. However, organic organisations
prefer to pick and choose which products may be usedby
implication rejecting the systems of public protection laid down
by parliament and the expertise of the officials and scientists
appointed, under law, to administer them.
The simple message of organic organisations
is that only they know best, and in so doing they happily and
consciously denigrate the work and ethics of the vast majority
of decent farmers and government employees.
The current crisis of confidence in farming
and Regulation is clear evidence of the success of organic publicists.
2. ANIMAL HEALTH
Veterinary treatment in organic systems raises
some serious animal welfare concerns.
Firstly the use of unregulated homeopathic and
herbal remedies, as opposed to strictly regulated conventional
animal medicines, raises questions over the safety and efficacy
of the product and its likely effects on the animal and the consumer
of the animal treated. Unlike regulated animal medicines, there
is no system for setting withdrawal periods for unlicensed homeopathic,
herbal or other "alternative" remedies.
The requirement in EU and UK Organic regulation
to automatically double withdrawal periods for animal medicines
is illogical, unscientific and a potential threat to animal welfare.
MRLs and withdrawal periods for licensed medicines are based on
rigorous, independent, international scientific standards incorporating
massive safety factors. There is no logic to a "blanket"
doubling which takes no account of the properties of the individual
product. Such additional delay could prompt a farmer to withhold
treatment of an animal near to market (or to cheat).
The organic insistence on using medicines therapeutically
(as opposed to preventatives treatments), means that the animal
has to get sick and suffer before it is treated, whereas preventative
medicines would have prevented the suffering from happening at
all. While symptoms develop there is also an increased risk of
the sick animal passing infection to its fellows, further increasing
suffering and increasing the total volume of medicines used. (See
The banning of genetic modification in any form
by the Soil Association raises serious concerns over the availability
of medicines to treat animals. Many veterinary medicines today
have biotechnology somewhere in their parentageif not in
the active ingredient, then in the excipients. The use of biotechnology
in veterinary medicines allows improvements to existing products,
for example, vaccines, produced with the techniques of biotechnology,
which can replace chemical treatments for internal and external
parasites, offer considerable opportunities for environmental
and operator safety and the reduction of residues. By banning
GMO's in any form farmers and vets are being denied the benefits
of modern medicine developed through biotechnology.
The EU, however, recognises the importance of
genetic modification in the production of veterinary medicines
and therefore has excluded animal medicines from the ban on GMs
in their regulations.
Organic proponents claim that organic food is
healthier, tastes better and is better for the environment. (Annex
1) A MORI survey for the Soil Association (June 1999) showed
that consumers buy organic food because they believe it to be
healthier, free of chemicals, better tasting, GM free and better
for the environment and animal welfare and that half of those
did so because they believed it to be safe and healthy.
There is no conclusive evidence to support these
claims, the organic movement has been further misleading the public
by claiming an exclusivity of virtue on these areas.
Scientific evidence suggests that organic food
is no more nutritious or better tasting than conventionally produced
food and variations depend more on other factors such as soil
type and freshness of the produce. (Annex 1).
The safety of organic food is also questionablerecently
there have been concerns over the use of animal manure which can
lead to increased risk of E. coli 0157. Where chemical methods
are not used to treat pests and diseases, plants under attack
produce their own toxins which may themselves be harmful to humans.
The safety of unlicensed and untested herbal
and homeopathic remedies, listed for organic farming use, is questionable
as they do not comply with EU or UK animal medicine legislation
which is designed to protect consumers, animal users and the environment.
While in general fewer agrochemicals are used
in organic farming some forms of pesticide are used and over 30
additives are allowed.
Imported organic food (70 per cent of organic
food in the UK) may not be GM free as the standards of organic
produce vary from country to country. (Annex 1[6.1])
Not only can the claims not be applied to all
organic farms, but equally, many conventional farms can show the
same benefits, but unburdened by dogma.
Claims that organic farming is better for the
environment than conventional farming is not necessarily true.
While birds and wildlife are a valued adjunct to organic farming,
the use of similar management techniques on conventional farms
can lead to the same benefits. The more extensive methods of organic
farming means it requires more land to produce a given amount
of food than a conventional farm. Thus, to institute organic farming
countrywide to provide the required amounts of food, a large amount
of wilderness, hedges and woodland would have to be utilised.
This questions the sustainability of organic farming. (Annex 1
The fundamental principles of sustainability
are, we believe, clear, and may be summed up as the careful use
of all resources, and in particular on non-renewable resources;
for agriculture this includes both on-farm resources (such as
the land itself) and purchased inputs such as fossil fuels, mineral
fertilisers and equipment, as well as the latest technology. Farming
must be able to sustain itself, to plan and invest for the future,
to change and improve outmoded and outworn equipment, products
and practices. This can only occur if British agriculture is allowed
to remain efficient and profitable.
The use of animal medicines in agriculture not
only reduces suffering, and prolongs useful life, but healthy
animals invariably produce more efficiently and perform better,
so utilising less feed and other resources.
For organic farming to remain sustainable it
must also be profitable. Organic livestock production requires
organic inputs, notably fodder and feed grains. Producers of such
organic crops themselves expect higher premiacan organic
livestock producers continue to produce profitably as produce
prices drop, approaching those for conventional farming, if their
input costs rise?
Organic produce prices cannot avoid the law
of supply and demandas organic production increases, prices
must fallsupermarkets have declared their intention to
supply Organic food at equivalent prices to conventional farming.
These lower prices will inevitably be passed back to organic producers.
Thus organic producers are increasingly being
caught in a pinceron the one hand steady escalation of
standards by organic organisations, for example by increasing
the proportion of organic inputs (which cost more to produce)
on the other hand, increased supplies and supermarket buying powers
will reduce prices receivedthe net result is likely to
be that those who have converted to organic production for commercial
rather than philosophical reasons are likely to be disappointed.
It must also be recognised that today's organic
farms, both livestock and arable, benefit from the eradication
and control, by conventional means of many pests and diseases
over many years. They also benefit from being surrounded by a
"cordon sanitaire" of clean, conventional farms. If
the organically farmed area was to spread, would existing controls
break down and the artificiality of organic disease control methods
Thus we believe that the assertion that organic
farming is "sustainable" should be seriously questioned.
Organic supporters frequently call for special
funding and emphasis to be given to "organic" research.
Such demands would appear to be based on a number of misconceptions.
1. Much of MAFF's research is into "generic"
activities which could apply equally to conventional and organic
2. Similarly, commercial research into agricultural
equipment, conventional breeding of plants and animals, animal
feed etc. is equally applicable to both sectors.
3. Research into animal disease carried
out by universities and other quasi-official institutions is applicable
to both, as is most of the commercial research carried out by
animal medicine companies.
4. MAFF research into animal medicines is
predominantly into methods of public protection, such as residue
testing, which is again of general benefit. Furthermore, much
of this is paid for by levies on industry rather than from the
5. We believe, however, that there is a
case for more research to be devoted to an open-minded investigation
of some of the claims made by organic farming, in order to ensure
proper protection of the public, both as purchasers and consumers.
In the Committee's call for evidence, comment
is invited on assurance schemessuch schemes are increasing
in all sectors of farming and we particularly welcome the launch
of the British farm standard, backed as it is by strict and independently
It could be argued that through such schemes
conventional farming provides most of the elements of "Public
Good" for which the organic movement has tried to claim exclusivityAnimal
welfare, environmental protection, food safety. Assurance schemes
should, we believe, acknowledge and build on the legal controls
and codes which already existMedicine and pesticide licensing,
welfare and performance codessuch as the Code of Practice
for the Responsible use of Medicines on farmlaunched by
Nick Brown last year, and the RUMA (Responsible Use of Medicines
in Agriculture Alliance) Antibiotic guidelines.
We applaud the increasing maturity of Farm and
Food Assurance Schemes; gone are the early problems such as claiming
meat to be "hormone free" (which is biologically impossible,
and also ignored the fact that the use of Growth Promoting hormones
has been illegal throughout the EU since 1986).
We also welcome the ending of competitive and
often meaningless claims that food from a particular scheme is
"healthier" or from "happier animals".
Sadly, the organic sector continue to employ
such negative marketing methods, which are currently the subject
of a complaint to the Advertising Standards Authority.
Under the circumstances outlined above, we cannot
agree with those who argue for additional funding for organic
farming. We believe that public support for agriculture should
be applied equally to all forms of farming, and farm inputs, acceptable
under the law.
We find it a peculiar contradiction of the concept
of "joined-up government" that one part of MAFF is giving
special support to organic farming which, by statement and implication,
denigrates the work of other parts of MAFF which scientifically
licence as "safe, effective and of high quality" animal
medicines, agrochemicals and other farm inputs.
The continuing and unjustified attacks by organic
farming organisations on the vast majority of farmers who use
conventional methods is particularly reprehensible.
In continuing their support for efficient, safe
and sustainable agricultural systems, the member companies of
NOAH do not seek to restrict the farming activities of any particular
sector; they do however support rigorous and fair assessments
made as evidence based decisions with respect to veterinary medicine's
role in agriculture.
13 June 2000