Thank you for the opportunity to contribute
to the BVA response to the Draft UKROFS Standards for Organic
Livestock and Livestock Products. With the increasing consumer
interest I organic production of food, these standards are extremely
important and need to be carefully addressed if the welfare of
animals on organic units is to be protected and the credibility
of the organic movement enhanced.
BCVA is in the process of forming an Organic
Working Group to address organic issues that affect our members
and the clients they serve. The Group will comprise of both BCVA
Council members and non-Council members with a special interest
in the organic industry. This reply has been drafted after consultation
with some of those who have been invited to serve on the group.
Your letter invites comments particularly with
reference to the use of medicines on organic units, however, the
draft standards contain many other aspects relating to livestock
health and welfare that should also be addressed.
The comments are numbered according to the relevant
section of the draft document and not necessarily in order of
SECTION 3: ORIGIN
Para 3.1. The restriction for animals
to be derived only from herds that have not had a BSE case prior
to August 1996 shows a lack of understanding of the epidemiology
of BSE and the legislation introduced to control it in the UK
and EC. The wording used would allow livestock to be acquired
from a herd having a case of BSE born after August 1996, a potentially
serious incident as this is after the withdrawal of MBM, but requires
the removal of all animals that are derived from a herd that has
had BSE at any time in its history requiring the culling of a
huge proportion of the national organic herd. It appears that
the Date Based Export Scheme has been used as a basis for this
rule, but the whole importance of the said scheme has been missed.
There are two suggestions to correct this:
(i) leave the old regulation in place, requiring
animals to be derived from herds not having had a case of BSE
in the last six years;
(ii) apply the DBES accurately. Bought in
animals would need to be born after 1 August 1996, be at least
six months old, be clearly identified with full record of movement,
and the seller would have to provide proof of dam survival six
months after the birth of the said animals and that she did not
Para 3.13. This Paragraph implies that
animals derived from organic sources do not pose the same disease
risk as animals obtained from units not complying with the Standards.
This is patently not the case. Biosecurity is an important issue
for all types of farm and the establishment of good herd health
security practices is not emphasised in the Standards. Acquired
animals are a risk to the health of any herd, and the importance
of quarantine in association with various other preventive strategies
is often underestimated. BCVA have produced a Quarantine Procedure
paper as part of its work for the TB Forum. This paper has been
well accepted as a standard to be achieved and contains measures
that would help control other diseases in addition to TB. A copy
of this paper has previously been forwarded to BVA, and it is
also available on the MAFF TB website.
SECTION 4: FEED
Para 4.16. Many areas of the country
are seriously deficient in trace elements, for example copper,
selenium and iodine. Supplementation of the diet is required in
these areas to ensure animal health. The permitted substances
for use are mostly the simple salts of minerals, and in many instances
these might not be the appropriate form of supplementation. More
complex mineral preparations, such as the chelated products, should
be permitted in these circumstances.
Para 4.17. There should be derogation
for the use of in-feed medicines to treat disease or for strategic
SECTION 5: DISEASE
Para 5.1.1. The adoption of a herd health
plan is a very important step toward ensuring the health and welfare
of the animals on a given unit. Identification of the partnership
between farmer and veterinary surgeon in the development of a
dedicated plan is welcomed. The application of such a plan should
lead to the improved health status of animals on the unit and
thus result in the long-term reduction of all medicine use, naturally
derived and allopathic.
The detailed description of the records that
are needed as part of a herd health plan should be included in
this section rather than being buried in the Inspection Requirements,
Annex III. There should also be provision for the assessment of
herd health plans, some formal ones that have been adopted in
the past have been of little use in truly tackling health and
welfare on the farm. Whereas endorsement of particular plans may
cause some difficulties, there may be a need to recognise suitable
plans to ensure credibility.
One of the first tasks of the BCVA Organic Group
will be to adapt the BCVA Herd Health Plan to organic dairy units.
This plan was devised in association with the National Dairy Farm
Assurance Scheme and is currently being applied on a large number
of UK dairy farms.
Para 5.4a. By what process is a naturally
derived product deemed to be effective? A recognised licensing
system is required to prove efficacy of a given naturally derived
product, or, by application of the Standards themselves, such
products should not be used. Records of use of alternative therapies
are therefore highly important so that efficacy levels can be
assessed on a given unit.
Para 5.4b. Allopathic medicines should
be used in these circumstances.
Para 5.4c. A distinction should be drawn
between true preventive medicine usage, or prophylactic use, and
strategic dosing regimes such as metaphylaxis. Strategic dosing,
in the face of diagnosed disease in the group, can prevent suffering
by inhibiting infection in those unaffected but in contact. Similarly,
strategic dosing for seasonal diseases such as fluke must be allowed,
when to wait for a diagnosis might be too late to prevent suffering
in the animals concerned.
The wording in the first sentence would effectively
ban blanket dry cow therapy, one of the major points of the NIRD
5-point plan originally introduced to reduce the incidence of
mastitis in the UK. The success of this practice has reduced the
number of therapeutic interventions for clinical mastitis during
lactation, when milk is being produced for human consumption,
and has reduced the pain suffered by cows with high somatic cell
counts associated with sub-clinical infections of the udder.
A suitable wording might therefore be "The
use of chemically synthesised allopathic veterinary medicinal
products or antibiotics for preventive treatment, other than in
a justified strategic therapeutic programme, is prohibited."
The sentence regarding vaccine composition should
be removed as it is unhelpful. Is a "four-in-one" vaccine
not a "multiple vaccine"? The veterinary surgeon should
have the freedom to advise any vaccination regime, providing the
choice can be justified. After all, appropriately designed vaccination
programmes reduce the incidence of clinical disease and reduce
the number of therapeutic interventions required.
Para 5.5.a The wording in the draft BVA
response is an excellent suggestion.
Para 5.5.c Some wound powder preparations
contain an organophosphate to prevent the establishment of blowfly
strike at a wound site. The small amount of such product used
in each instance means that residue levels in the animal are negligible
if not undetectable. Such products should be regarded separately
from dedicated OP products.
Para 5.6 All treatments should be recorded,
including phytotherapeutic and homeopathic.
Para 5.7 The tone of the BVA draft should
possibly be changed. The justification for the extended withdrawal
times is that the scientifically derived withdrawal is based on
an MRL, and so by definition, some product could still be present
below the MRL. This logic is difficult to question. A further
multiplication factor is probably as justified as some of the
multiplication factors used in the original MRL calculations!
However, logic must be applied throughout. If
twice the legal withhold is to be the rule, then so be it; so
nil withdrawal is nil, and standard withdrawal for off-label use
should be 14 days. If applied as currently written; vaccines with
nil milk withdrawal should have milk withheld for 48 hours; this
will dissuade vaccine use or encourage the Standards to be flouted.
The paragraph also implies that naturally derived
products do not require withdrawal periods to be applied. This
is not the case! The use of any natural product in food producing
animals that makes a therapeutic claim requires an MRL to have
been calculated and a suitable withhold period derived, otherwise
a standard withhold should be applied.
Para 5.8 The "three strikes and
out" rule! The implications of this standard are far reaching
and should be fully explored. The wording certainly needs to be
changed to remove ambiguity; "more than two or a maximum
This regulation will provide a direct deterrent
for farmers to treat sick animals or record such treatments. What
of the animal that has received two treatments and then is threatened
with removal due to an ailment such as foul in the foot, which
would readily be treated by a short course of antimicrobial? Will
she remain lame for a much longer period of time, hoping for a
natural resolution? Will she be treated but not recorded?
There is also the possibility of larger farmers
running two herds. The organic herd exists to attract the premium
product, but has a high replacement rate, with cows being transferred
out to the commercial herd if they are more prone to illness or
reduced fertility. There is then little incentive for that farmer
to improve the lot for the organic herd and reduce overall treatments.
This is already happening on several units.
Such restriction should be avoided in the interests
of animal welfare and consumer perception.
SECTION 6; HUSBANDRY
Para 6.1.2 It is presumed that routine
disbudding in cattle is allowed to prevent future welfare problems,
but not routine dehorning when calves are older. It is difficult
to see why routine castration should be freely allowed, but the
removal of horns be restricted if this is not the case. There
are sound welfare reasons for performing both techniques at an
Para 6.1.4 To approach the certification
body each time a veterinary surgeon requires an animal to be tethered
for treatment or isolation will prove impractical.
SECTION 8; FREE
Para 8.3.7 Our understanding of the requirements
is that calves must have tactile contact with other calves; this
does not preclude individual boxes, but restricts the type of
division that can be used.
ANNEX III A 2; INSPECTION
There is no reference to the existence of an
audit process. There must be an effective, transparent, consistent
audit process by which organic producers and the certifying bodies
are monitored. This is the only way that the credibility of the
organic industry can be maintained. The standards, at national
and certifying body level must be consistent, justifiable and
capable of being monitored. If this is not so, this could be the
achilles heal of the whole organic industry.
The length of this response shows how far reaching
these Standards are livestock on organic farms. The implications
for health and welfare extend beyond the consideration of merely
medicine issues. I hope you find the comments of use, and I thank
you for sight of the draft BVA response to which I have referred.
In line with our previous arrangements, please
could you forward a copy of the final BVA submission to the BCVA
Office for our files.
Hon Sec BCVA