BRITISH VETERINARY POULTRY ASSOCIATION RESPONSE TO THE MAFF INDEPENDENT REVIEW GROUP ON DISPENSING BY VETERINARY SURGEONS
PREPARED BY Stephen Lister, BSc, BVetMed, CertPMP, MRCVS ON BEHALF OF BVPA
1. Introduction
1.1. British Veterinary Poultry Association (BVPA) welcomes the opportunity to contribute comments to the review team. At the outset it is the view of our members that we are unaware of evidence of dissatisfaction from our clients, the poultry producers, with respect to the status quo. Indeed, there is clear evidence of customer satisfaction with the current situation.
1.2. Whilst many of the points raised in this submission may apply equally to a range of animal species, our comments will relate to aspects specific to poultry producers and BVPA members.
2. BVPA
2.1 British Veterinary Poultry Association (BVPA) is a
specialist
"species" division of BVA and our membership consists
predominantly of veterinary surgeons serving the poultry industry;
Ø As private practitioners specialising in poultry species
within a more general farm practice,
Ø specialist sole poultry practices,
Ø company veterinarians in poultry companies,
Ø veterinary advisers to pharmaceutical and biological companies
Ø veterinarians involved with poultry veterinary research.
2.2 The BVPA constitution identifies that the object of the Association "shall be to facilitate discussion and exchange of ideas amongst those engaged in the veterinary aspects of poultry disease and husbandry". As suggested in these objectives, our members are appreciative of the link between poultry disease, husbandry and management.
3. The current situation
3.1 One significant factor in disease control and maintenance of health and welfare of the birds under our care is the ability to prescribe and dispense promptly a range of veterinary medicinal products and Prescription Only Medicine (POM) vaccines.
3.2 The current system has served the profession, our clients and their birds well ever since the sustained development of the UK poultry industry started some 40 years ago. Indeed the success of the UK Poultry industry has been directly related to the ability to treat and control significant disease. As well as ensuring the health and welfare of the birds under our care, such expertise has ensured the control of diseases and pathogens of public health significance.
3.3 During this time the Medicines Act of 1968 has enabled alternative dispensing options in terms of classification of products (e.g. G, GSL, PML, P) and source of products. Pharmacists have been able to dispense POM products to poultry (and indeed other species) under veterinary prescription. Pharmacist and animal health merchants are also able to supply directly to the poultry farmer a complete range of non-prescription veterinary products. The fact that this seldom occurs in practice and that many non-prescription products are sold to clients by their veterinary surgeons, suggests that the current system has served the poultry industry well.
4. Consequences of change?
4.1 Any change to the current system would have to be able to
demonstrate improvements in a number of areas.
In the view of BVPA these must include:
Ø Reduction in direct (purchase) and indirect (administration)
costs to the end user
Ø Improve, or at the least prevent a deterioration in, animal
health and welfare
Ø Improve or maintain public health
5. Reducing costs to the end user
5.1 It should be recognised that although only a small number of veterinarians supply veterinary services to the UK poultry industry, there exists a range of methods by which veterinary medicinal products are supplied, whilst still satisfying all relevant legislation and ethical considerations.
5.2 Some veterinarians act as dedicated poultry practices, others as poultry specialists within general practices, whilst some poultry companies directly employ their own veterinarian. This offers choice without monopoly, as poultry producers are free to "shop around" for their veterinary services.
5.3 The choice of the supplier of veterinary services is seldom, if ever, based on unit costs of veterinary medicinal products. Poultry owners will always seek "added value" and a level of service that includes advice on disease control and treatment, animal welfare and strategies to maintain bird health. As veterinarians advising a food production industry such expertise must also extend to advice on public health. Any perceived reduction in unit cost of medicines needs to be tempered by this added value provided by the prescribing veterinarian.
5.4 Currently, a situation already exists whereby medication can be supplied by a feed compounder in feed against a medicated feedingstuffs (MFS) prescription as a cost effective, efficient and safe route for supply and administration of a veterinary medicinal product to animals under the care of the veterinarian and owner.
5.5 Most owners seek water soluble medications and vaccines through their veterinarian as a further cost effective treatment strategy. This is accompanied by advice and assistance direct from the veterinarian making the diagnosis and under whose care such animals are held. Rarely is prescribing and dispensing done in isolation under the current situation.
5.6 In poultry production individual birds are seldom treated, but the flock/house is usually treated as a "population", i.e. treating the whole "at risk" population. Treatment requires careful consideration of necessary management changes that might be required in feed and water provision and presentation. Individual farms and houses may have different feeder and drinker systems which may need to be adjusted according to the type of system, brand of medication used etc. In addition other management adjustments may need to be made to improve the response to treatment e.g. alterations to ventilation, temperature and litter (bedding) conditions.
5.7 Accurate and focused veterinary treatment also necessitates a detailed knowledge of the style and quality of stockmanship on specific farms as well as details on previous or concurrent treatments, disease history and responses to other treatments.
5.8 A two stop strategy of diagnosis and then supply of medicines risks losing the necessary holistic approach to poultry health management.
5.9 Changes in the distribution channel will be more likely to increase delays in treatment and will be more likely to increase rather than reduce costs. Recent Government legislation requiring batch number recording of medicines supplied has added costs to the supply chain. Any further layers in the distribution system would substantially affect the logistics and costs of the supply of veterinary medicinal products.
5.10 In addition, the current system allows the veterinarian who has made a diagnosis in a group of animals under his care to understand the economics of this group and the wider farm enterprise in terms of treating the animals for a particular disease condition under a specific circumstance. This would not be possible if veterinary medicinal product costs and supply were no longer under that veterinarians control.
5.11 Veterinary practices clearly earn revenue from the sale
of veterinary medicinal products but this must be set against a
number of overheads as in any business offering consumers a range
of services and products. Any money earned must be set against:
Ø The costs of stock held on the shelf
Ø Loss of out of date product and other wastage
Ø Bad debt provision
Ø Storage facilities
Ø Stock control and recording
Ø Continuing professional development in relation to disease
diagnosis, medicine availability, usage and administration
Ø General practice facilities (cofunded by veterinary fees)
Ø Provision of other services (cofunded by veterinary fees)
5.12 The recent Office of Fair Trading (OFT) review of veterinary "mark ups" or working margins appears to have exonerated veterinary practitioners, suggesting that pricing structures represent a realistic policy by veterinarians. In fact such margins in products supplied to the poultry industry have historically been generally low reflecting the low margins the whole poultry industry works on from production through to sale of finished products to the consumer.
5.13 Clearly, no action should be taken which would reduce the number of options for the general provision of veterinary services and medicines which are currently available to the poultry industry.
6. Improving animal health and welfare
6.1 The current RCVS guide to professional conduct only allows veterinary surgeons to dispense POM veterinary medicinal products and vaccines, and other medicinal categories to "animals under the care" of that veterinary surgeon.
6.2 These guidelines are not there to benefit the veterinary surgeon, but to ensure that in all circumstances products are supplied appropriately for the benefit of the birds, their owners and the consumer.
6.3 Veterinary prescribing is on efficacy and safety in specific situations and disease conditions and not on price.
6.4 The majority of treatment requirements in relation to poultry disease are in response to acute sudden onset and rapidly spreading disease. Delays in treatment by only a few hours can cause significant increases in morbidity, mortality and unnecessary suffering. A two stop strategy for diagnosis and prescribing followed by supply from a second source (especially "after hours") could have a considerable effect on health and welfare, if delays occurred, and may in fact necessitate an increase in the amount of antibiotic then needed to control disease.
6.5 The veterinary surgeon responsible for animals under his care would have a working knowledge of requirements in terms of the range and quantity of various treatments required to be held in a dispensary. Would other providers simply selling veterinary medicinal products against veterinary prescriptions "cherry pick" and only stock items with high turnover?
6.6 This can have specific and important repercussions for the treatment of so called "minor" species. Poultry are not just one species. They include broiler meat chickens, commercial layers (housed and free range), broiler breeders, layer breeders, turkeys (meat and breeders), ducks (meat and breeders), geese (meat and breeders), guinea fowl, pheasants and partridges. Veterinary medicinal products are licenced specifically in relation to bird type. A number of minor species (which includes the substantial UK turkey and duck industries) have little or no licenced medicinal products. Where no licenced product is available for a specific condition, another product may be prescribed "off label" under the cascade. This requires detailed knowledge of all such species requirements to safeguard animal and public health.
6.7 Whose responsibility would animal health and welfare be on the basis of the non-availability of products prescribed in good faith by the veterinary surgeon?
6.8 Monitoring of success or otherwise of treatment would be more difficult if the veterinary surgeon was not closely involved with the selection and application of the medication.
6.9 Who would be responsible for reporting adverse reactions under the Veterinary medicines Directorate (VMD) Suspected Adverse Reactions Surveillance Scheme (SARSS)? The veterinary surgeon would be disadvantaged if he did not have a detailed knowledge of exactly what was supplied.
7. Improving or protecting public health
7.1 Concerns over the role of treatment of food animals in
terms of hazards and risks to human health are related to:
Ø monitoring, diagnosis, treatment and control of zoonotic
disease
Ø prevention of transmissible antibiotic resistance
Ø prevention of residues of medicines in food products
7.2 As indicated above, the privilege to dispense veterinary medicinal products by veterinary surgeons to the animals under his care, enables focused, targeted and immediate treatment regimes to be undertaken which ensure prompt and effective control of disease and pathogens. This applies equally to pathogens of public health significance as those affecting animal health and welfare. Any additional tiers of control within the distribution chain would be likely to have an adverse effect on the ability to control zoonotic diseases and pathogens.
7.3 In relation to reducing the adverse effects of transmissible antibiotic resistance it is well accepted by human medical and veterinary experts that the key aspects centre on responsible use of human and veterinary medicinal products.
7.4 BVPA was a founder stakeholder in the RUMA (Responsible Use of Medicines in Agriculture) Alliance, a coalition of organisations including agricultural, veterinary, pharmaceutical and retail interests. The aim of the Alliance was to review the use of antimicrobials and to establish practical strategies to enable farmers to reduce the need for their use. BVPA members were active in formulating the poultry guidelines and continue to support this initiative, which has been recognised by Government and medical advisers.
7.5 The current farm assurance audit systems operating widely in the poultry industry have the veterinary surgeon as a key figure in the focused, targeted and audited use of veterinary medicinal products, their on farm storage, administration and usage recording. Dispensing by a third party will make the audit trail far more difficult to maintain.
7.6 Further to these aspects is the allied theoretical possibility of residues of veterinary medicinal products in poultrymeat, products and eggs. In fact, scrutiny of the current system confirms the excellent record of food animals in the UK. The results of residue testing are a matter of public record, with such results indicating that in excess of 99% of meat, meat products and eggs are consistently free of residues of the veterinary medicinal products prescribed and dispensed by veterinary surgeons.
7.7 Interestingly, one residue that has given some cause for concern in recent years is the presence of traces of the chemical nicarbazin (a drug used for the control of coccidiosis in broilers) in eggs. In fact this product is incorporated in animal feed as a zootechnical feed additive (ZFA) which is totally out of veterinary control under current legislation.
8. Classification of veterinary medicinal products
8.1 BVPA considers that the POM category for antimicrobial veterinary medicinal products should be retained. Any deregulation would take these products outside veterinary control, which would have serious implications for public health, animal health and welfare. The pivotal role of the veterinarian in promoting and safeguarding responsible medicine use is well recognised and acknowledged by Government and medical authorities.
8.2 Similar benefits are gained by veterinary control of the administration of a range of non-antibiotic veterinary medicinal products and biologicals/vaccines in terms of safeguarding animal health and welfare. This applies especially to novel products where application methods and strategies often have to be developed as the new products are used in a "field rather than laboratory situation".
9. CONCLUSIONS
9.1 UK veterinary surgeons serving the poultry industry are well aware of the privilege and responsibility given to them in the dispensing of veterinary medicinal products to animals under their care.
9.2 The current system is able to demonstrate responsible use of such products to ensure cost effective treatment and prevention of infectious disease leading to assurances on animal health and welfare and protection of public health.
9.3 An effective treatment and prevention strategy such as this will also by definition lead to an overall reduction in the amount of veterinary medicinal products prescribed.
9.4 This structure has evolved and adapted to meet the needs of the poultry industry such that veterinary surgeons are an integral part of all farm assurance schemes.
9.5 Whilst improvements can always be made, there is no evidence that a change in the current dispensing system for poultry veterinary medicinal products would be to the benefit of the poultry industry, producers, retail chain or the end consumer of poultry products. Indeed an additional layer in the distribution system would be likely to increase costs to poultry producers.
9.6 BVPA would be happy to give oral evidence to the
Independent Review Group to clarify or expand on any aspects of
this submission.