Select Committee on Agriculture Appendices to the Minutes of Evidence


Supplementary memorandum submitted by the UK Register of Organic Food Standards (UKROFS) (F 72)


1.  Can Livestock Standards be met in all parts of the UK and what reassurance can be given on welfare issues surrounding the use of veterinary medicines?

  1.1  Comments on the animal health aspects of the EC Regulations have centred on the presumption of the Regulation that chemically synthesised allopathic veterinary treatments are to be avoided in organic farming. However the Regulation does allow the use of such treatments where necessary. Further, although the EC Regulation prevents the indiscriminate use of conventional products in a prophylactic manner the UKROFS standards do contain the provision for their use strategically where there is a known disease risk.

  1.2  The UKROFS Standards have gone further than the EC Regulation in placing emphasis on "positive welfare" and the need for a plan drawn up by the farmer, preferably in partnership with a veterinary surgeon, to ensure the development of health building and disease control measures appropriate to the particular circumstances of the individual farm and to allow for the evolution of a farming system which is progressively less dependent on allopathic veterinary medicinal products.

  1.3  There has also been criticism of the so-called "three strikes and you're out" approach to the use of conventional veterinary medicines mentioned at Annex IB paragraph 5.8 of Regulation 2092/91 and reflected in the UKROFS Standards.

  1.4  This sets out that where an animal receives more than three courses of treatment with chemically-synthesised allopathic veterinary medicinal products within one year (or more than one course of treatment if their productive life-cycle is less than one year) the livestock concerned, or produce derived from them, may not be sold as organic and the animal must undergo a conversion period. However, the following features of this requirement are sometimes overlooked.

    (1)  vaccinations, treatments for parasites (which form a large proportion of health problems for stock in the hill areas which have been mentioned) and any compulsory eradication schemes established by Member States are excluded from this requirement;

    (2)  a "course of treatment" is defined in the standards as meaning "all necessary measures taken to restore the animal back to health."

  1.5  Taking these provisions into account UKROFS believes that there is sufficient flexibility to allow the standards to be operated effectively under most UK conditions.

  1.6  UKROFS also believes that these provisions, taken with good stock management and husbandry practised as part of a veterinary plan as detailed above, are sufficient in most cases to ensure the health and welfare of organic stock.

2.  What evidence is there to prove the safety and efficacy of homeopathic remedies allowed under the Regulation?

  2.1  The Regulation provides that such medicines may be used provided that their therapeutic effect is effective for the species of animal, and the condition for which the treatment is intended. The effectiveness of such treatments is for farmers to judge in consultation with their veterinary adviser. Although such medicines are not formally approved under veterinary arrangements and there is relatively little scientifically verified evidence of their effectiveness, farmers using such medicines report beneficial effects. Clearly, however, the welfare of the animal may be compromised if they are ineffective.

3.  Were the competitiveness implications of shorter derogations considered in the decision on how the Regulation should apply to poultry producers?

  3.1  Yes. The Board concluded that the balance of advantage lay in a derogation which—although longer than some would have wished—would encourage the industry to move relatively quickly to the standard set out in the Regulation. High standards are essential for consumer confidence and the competitiveness of the industry.

4.  What procedures have been set up to monitor the effect of the UKROFS Standards, and is research to be commissioned?

  4.1  UKROFS will be putting in place arrangements to monitor the effect of the standards by means of close consultation with the industry.

22 November 2000

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