Select Committee on Agriculture Appendices to the Minutes of Evidence

Annex C

  Dear Richard

  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 importance.


  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 develop BSE.

  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.


  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 dosing regimes.


  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 of three"?

  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.


  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 early age.

  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.


  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.


  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.

C. Padgett
Hon Sec BCVA

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