Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by the National Office of Animal Health (G26)

  NOAH represents the companies that research, develop, manufacture and market animal medicines and zootechnical feed additives in the UK. In 2001, NOAH's members accounted for about 95 per cent (by value) of the £359 million UK animal health market.

  As such, NOAH's comments on DEFRA are brief and specific, reflecting the area in which we operate.


  1.  NOAH agrees with the vision of a sustainable future, and one that recognises the need for rural communities, including farms, to be economically as well as environmentally viable. The vision of rural Britain projected needs farms producing food from British livestock produce. Without the recognition of the need for economic viability, British farming, and the social, environmental and economic fabric that goes with it, will not survive.

  2.  We are pleased to see protection against animal disease as being part of the vision of the Department, and its juxtaposition with the promotion of animal welfare indicates that the two are seen by DEFRA as being inextricably linked. Animal medicines play a key role in keeping Britain's farm animals and pets healthy.

  3.  However, the DEFRA response to the Policy Commission on the Future of Farming and Food's recommendation that research should be directed to low or no-drug farming systems was worrying, as this could be taken to mean there was no place for animal medicines in sustainable farming, and would seem to contradict the inclusion of animal health in DEFRA's vision. (NOAH will be responding to DEFRA's "Sustainable Food and Farming Working Together" document separately.)

  4.  Naturally, NOAH supports initiatives to reduce the need to use medicines. Our work with RUMA, the Responsible Use of Medicines in Agriculture Alliance, is an example of that. Prevention—through good stockmanship and through vaccination and worming—is better than cure, but equally there are times when cures are vital for animal welfare. For example, we hear reports of animals that are farmed organically suffering because a particular medicine could not be used, or because the right therapeutic treatment was withheld until all else had failed.

  5.  Animal sickness does not allow sustainable farming. When animals are sick, or harbouring a sub-clinical infection, their production is affected. Inputs (feed, energy etc) are wasted if an animal—or bird—is not growing or producing: to compound this the animal continues to produce manure, with inevitable greenhouse gas implications. Animal medicines can help with DEFRA's vision on a wider scope than is initially obvious.

  6.  Medicines are part of the solution to provide safe and healthy food, in sustainable systems.


  1.  NOAH welcomed the potential for "joined-up Government" afforded by the formation of DEFRA. It brought together into one department the Veterinary Medicines Directorate (the agency with which NOAH has most direct contact) and the Environment Agency, which has a role in monitoring pollution incidents involving veterinary medicines and also undertakes monitoring for a number of veterinary medicines in environmental waters.

  2.  When the VMD was formed, it brought together the parts of MAFF dealing with animal medicines, to create a unified approach. This was something NOAH strongly supported at the time, and something we continue to believe is the best approach. This "one-stop shop" brings best value for all stakeholders. The VMD is currently being reviewed by DEFRA as part of the Department's review of Executive Agencies, and in our submission to that Review, we state that we believe that the authorisation process, pharmacovigilance, residues monitoring and Policy should remain with VMD. Having these aspects of the overall role of Government in one place is efficient, and leads to consistency of approach, and better understanding of the realities of the veterinary market by those developing policy advice for Ministers.

  3.  We do have concerns about the erosion of the unified approach that DEFRA—and the VMD within DEFRA—have the potential to bring. Although the VMD does have environmental and residues experts assessing authorisation applications, it is of course right that other government agencies and departments should have an input into the authorisation process to ensure that a fully rounded consideration is given to the application. However, when an authorisation is issued by Ministers (including DEFRA Ministers) it is of concern if those other agencies undermine public trust in the authorisation process of which they are part. We would like to see more "joined-up government" within the Department as well as outwith, with agencies such as the EA, FSA, HSE contributing to the authorisation process, and then "buying in" to the approval that is given when products are authorised as safe by government.

  NOAH is pleased to be able to contribute to this Inquiry, and remains happy to answer any specific query related to our field, or to provide oral evidence if so desired.

31 May 2002

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