APPENDIX 19
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.
THE VISION
OF DEFRA
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.
STRUCTURE AND
WEIGHTING OF
THE DEPARTMENT
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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