Delivering the strategies
37. The Outline of an animal health and welfare
strategy for Great Britain and veterinary surveillance strategy
provide a clear statement from Defra of what it expects to be
delivered. This provides a starting point in evaluating the amount
of private and public sector veterinary input they will require.
But the first step in delivering either of these strategies, and
implementing farm-level food safety rules, is knowledge of the
location of every animal in the country. Further steps include
the securing of livestock keepers' and vets' participation in
the strategies, and a determination of what resources will be
required to ensure that the strategies achieve their objectives.
Each is considered in turn below.
Licensing or registering livestock keepers
38. One of the revelations of foot and mouth disease
was that it is impossible to know where all livestock is at all
times; it may not even be possible to know with complete accuracy
the whereabouts of all livestock holdings. As a result support
has been expressed for a system or licensing or at least registering
all keepers of livestock. Indeed in its report following the outbreak
the Royal Society recommended that all livestock keepers were
licensed, with one of the conditions of the licence being an annual
health plan.[102] The
proposal has been endorsed by the Government's Chief Scientific
Adviser.[103] When
we commented on the opposition of some farmers to licensing, he
argued that "those sections of the farming community that
would like to avoid a 2001 type epidemic ever occurring again
might welcome it".[104]
39. In his evidence to us Mr Morley told us that
Defra was considering a licensing scheme.[105]
But at the launch of the Outline of an animal health and welfare
strategy for Great Britain, the new animal health and welfare
Minister made clear that licensing was not on the agenda - for
now. He said that "the theme of the strategy is that keeping
animals is a privilege not a right, animal keepers must meet their
responsibilities as set out in the strategy. If they can not fulfil
their obligations, sanctions may have to be considered, including
the possibility of licensing or permits for farm livestock".[106]
We believe that equating the introduction of licensing for
livestock farmers with putting 'sanctions' on them is not helpful.
It is conceivable that a system of licensing might one day have
to be introduced but for rather more positive reasons than as
a way to 'punish' errant farmers.
40. That said, there are substantial obstacles to
the introduction of a system of licensing for livestock keepers,
as Mr Morley pointed out in his evidence.[107]
The first, and most obvious, is cost. Although no assessment seems
to have been made of the full cost, simply creating and maintaining
a list of all livestock keepers will require some resources; if
a licence is subject to conditions, and thus inspections of compliance
are required, the scheme will be much more expensive. Second,
the burden imposed on small or hobby farmers, with relatively
few animals, would be disproportionate. The RCVS reminded us that
the Royal Society inquiry had addressed this point, and had said
that all types of "livestock keepers were equally at risk
of [their animals] contracting an exotic disease".[108]
Clearly, then, any form of licensing system must apply at the
very least to all keepers of cattle, sheep and pigs; and the difficulties
of smaller or hobby farmers will have to be dealt with..
41. Third, a number of witnesses sought to link the
idea of licensing to the payment of subsidy under the Common Agricultural
Policy, using cross-compliance. However, as Mr Morley pointed
out, the pig and poultry sectors are unsupported, and therefore
could not be subject to cross-compliance rules.[109]
Therefore it seems apparent that, if it is to be introduced,
livestock keepers will have to meet the cost of licensing themselves.
42. Notwithstanding these obstacles, pressure for
licensing - or at least registration - may become irresistible.
The Food Standards Agency told us about changes to European legislation
governing the production of food. The new legislation will apply
from 2005 at the earliest, and, inter alia, will place
new requirements on farms as food businesses. Coupled with those
new requirements will be a full range of official control activities
including inspection, audit, monitoring, surveillance, and sampling
and analysis.[110]
Defra told us that the new rules, "which are nearing final
agreement", would "require livestock producers to be
registered as food businesses".[111]
The notion of registration of livestock keepers (without
the conditions assumed to be associated with full licensing) met
with approval from the RCVS in particular. It said that "all
keepers of livestock - whether it is pet goats, pet sheep, pet
cows, pet pigs, whatever - should be registered on a Defra database,
and they should have registered the name of a veterinary surgeon,
and they should submit some form of health plan at least once
a year".[112]
The introduction of some form of scheme of registration of
livestock keepers is probably now inevitable. A database listing
the location of all such keepers would of course be immensely
valuable in combating animal disease. We recommend that Defra
develop one without delay - and we note that we recommended such
a database nearly two years ago in the aftermath of foot and mouth.[113]
It may be that a registration scheme might in future evolve into
a licensing scheme, but before that we recommend that Defra undertake
an analysis of licensing, looking at the conditions which might
be attached to a licence, the cost, particularly for smaller or
hobby farmers, and the likely benefits..
Participation and implementation
43. In the Outline of an animal health and welfare
strategy for Great Britain, Defra quoted a stakeholder who
said that "animal health plans are the way forward".
Defra then commented that farm health planning could help livestock
keepers fulfil their responsibilities to prevent disease spread
and maintain healthy animals. It described the process of farm
health planning and identified a need to develop guidance and
training in the preparation of farm health plans. It also committed
itself to "facilitate the production of the required tools
for encouraging farm health planning". However, Defra argued
that stakeholder groups need to champion this issue themselves.[114]
The NFU wanted vets to sell animal health plans to farmers but
said that vets seemed to be more comfortable with 'fire brigade'
work than with the "developing philosophy" of herd health
planning.[115] Defra
noted that it required "a cultural change in some farmer
groups to adopt these beneficial practices".[116]
If Defra wants herd health planning to succeed, it will have to
take the lead in bringing about that cultural change. Changes
to the CAP, especially the requirement for stricter cross-compliance,
may provide Defra with both the 'carrot and stick' it needs to
encourage universal adoption of animal health planning. But it
will also have to provide guidance and support to the veterinary
profession to ensure that any statutory requirements are consistently
implemented and enforced. If Defra is determined to proceed
without a licensing system, it should now detail how it envisages
a herd health planning scheme could operate. It should also say
whether it intends animal health plans to cover all livestock,
including all pets, or restrict them to commercially-farmed livestock.
Defra should undertake a cost benefit analysis of a compulsory
herd health planning programme for all livestock keepers.
44. In terms of veterinary surveillance, protocols
need to be developed to allow information to get to the central
database, and then to be cascaded back down to vets and farmers.
Professor Brownlie highlighted the huge amount of information
that does not reach the SVS,[117]
although the issue of confidentiality may be the cause in some
cases.[118] Defra
has outlined its ideas on partnerships: it needs to consider how
it can ensure that these are developed between vets and all livestock
farmers, especially those who, in the past, have not called the
vet out. The Chief Scientific Adviser's suggestion of random checks
may need to be considered. If it is not, Defra, farmers and vets
will need to work together to determine how surveillance data
is collected. They will need to address the following questions:
- Can vets collect surveillance
data when invited to a farm or should it be the subject of a specific
pre-announced visit?
- In both cases, how and who should the vet
charge for this activity?
- How should evolving international disease
risks which have implications for British farmers be communicated
to vets and farmers?
45. The animal health and welfare strategy, the veterinary
surveillance strategy and the forthcoming food safety rules have
much in common. They all require knowledge of where animals are
(the registration requirements of the new European Union food
safety rules could achieve this). They all require vets' presence
on farms. They all require the support of the farming industry.
They all have the potential to bring benefits to both farmers
and wider society. Defra should examine with farmers and vets
the extent to which the animal health and welfare strategy, the
veterinary surveillance strategy, and the requirements of the
food safety rules can be 'rolled-up' to bring the benefits to
farmers and society without causing too much inconvenience to
farmers or placing too heavy a burden on large animal vets.
Resources
46. We have listed above the new demands that will
be placed on large animal vets in implementing the animal health
and welfare strategy, the veterinary surveillance strategy, and
forthcoming farm-level food safety rules. It is clear to us that
more large animal vets will be needed if Defra is to deliver these
strategies. We have already recommended that an assessment of
the number of vets required to undertake current tasks is completed.
But Mr Morley told us that "we clearly have to evaluate capacity
as part of any animal health and welfare strategy - both in relation
to ourselves and also within the private sector".[119]
Using the results of the assessment we have proposed, Defra
should determine how many additional large animal vets are needed
to deliver its animal health and welfare and veterinary surveillance
strategies. It should also assess the veterinary input that will
be required to implement farm-level food safety rules and any
consequent reduction on the requirement for vets in slaughterhouses.
47. One area in which the Government can usefully
intervene to ensure that the supply of large animal vets is increased
is in education and training. Efforts are needed to overcome current
difficulties in attracting new graduates to large animal
work. We urge the Government to invest in education to make
large animal work more attractive to students. Some of the initiatives
that Mr Scudamore mentioned are a start but more would be needed.
It is imperative that the Government is proactive.
48. Professor Brownlie outlined the importance of
research to the teaching of veterinary science. He argued that
role models who would "impress upon the students that livestock
farming is a worthwhile and very important career" had to
be actively engaged in research work.[120]
But he later expressed the concern that "it is extremely
difficult to get funding for endemic livestock disease",[121]
that short term funding programmes would not make "a real
impact" on disease, and that funding was "fragmented".[122]
We recommend that, in conjunction with the veterinary colleges
and farming organisations, Defra and other sponsors of veterinary
research should review veterinary research programmes, in the
light of data gathered by the surveillance programme, to ensure
they reflect the health and welfare problems faced by the industry.
If a disease levy is introduced, one 'dividend' from it could
be additional funding for research into the diseases it covers.
49. If indirect intervention does not encourage veterinary
students to enter large animal practice, Defra and the veterinary
colleges may need to consider more fundamental changes to the
recruitment and training of students. One approach would be to
allow undergraduate students to distinguish between veterinary
science (farm livestock) or veterinary science (small animal)
degrees on their enrolment. Course sizes could be determined on
the basis of the need for practitioners and, if necessary, entry
grade requirements could be differentiated to reflect demand for
and availability of places on courses.
50. In the shorter term, Defra may still be able
to stimulate interest in large animal practice. Offering extramural
placements, an important element of veterinary training, to students
would be a clear way of Defra demonstrating its commitment to
partnership with the industry. We recommend that Defra explore
with the veterinary schools and the RCVS not only how such placements
might work but also the possibility of staff exchanges and secondments
to provide opportunities for continuing professional development
for both teachers and Government vets. Finally, given the
additional responsibilities that the strategies will place on
practising veterinary surgeons and the additional costs they will
place on farmers, Defra may need to intervene directly in the
market to ensure that veterinary practitioners are paid appropriately
for the services they provide, and that all livestock keepers
are within the ambit of the strategies.
Competition Commission report
on prescription-only veterinary medicines