APPENDIX 45
Supplementary memorandum submitted by
the UK Register of Organic Food Standards (UKROFS) (F 72)
RESPONSE TO COMMITTEE'S QUESTIONS ON LIVESTOCK
STANDARDS
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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