Environment and Climate Change Committee
Wednesday 10th June 2026
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10:00
10:00
Speaker 2
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Speaker 2
Yeah. Good morning, and thanks for the opportunity to be here. My name is Doctor Liz Merlino. I'm senior vice president of the British Veterinary Association and the BBA officer with responsibility for small animal products, in particular um by trade. I'm a GP vet so I've spent over 30 years in general practice mixed and then small animal. But I'm also a recognised specialist in British Wildlife medicine as well.
10:01
10:01
Speaker 3
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Speaker 3
I'm Doctor Rose Perkins, I'm a vet and a visiting fellow at Imperial College's Grantham Institute. I've been a vet for 20 years. I still see practice as a vet. I should dare declare a conflict of interest that I still work as a vet in practice and do sell parasiticides. I did my PhD on environmental exposure pathways for fipronil and imidacloprid used in pet flea treatments, and that was funded by the Veterinary Medicines Directorate.
10:02
10:02
Speaker 4
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Speaker 4
I'm Doctor Martin Whitehead, also a general practice vet. But I do some referral and zoo work as well. I've been a vet for 27 years. 17 of those running a general practice, 14 of them also owning that practice. I currently am employed by one of the large corporate groups because I sold my practice to them, and if I do see cats and dogs that would need parasiticides, I'd be selling them to make a profit for my employer. Obviously, as all vets do.
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10:03
Speaker 1
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Speaker 1
Thank you very much. So let me start by asking each of you to give us an introduction as to why these chemicals are necessary. What are the main pet parasite products sold in the UK, and where can people buy them?And can you also address how has their use changed over recent years?Who would like to start?
10:03
Speaker 2
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Speaker 2
I'm happy to start with perhaps an overview of how things have changed. So, when certainly myself and Martin graduated, our only way of treating fleas in dogs and cats was to pin the dog down or scruff the cat and spray it with an aerosol insecticide. Um, as a consequence of that, we saw animals with really quite bad flea infestations. And we regularly, I would say several times during an evening surgery, would see pets with flea allergic dermatitis. Those products increasingly also became multivalent, and at the time we were quite excited about this.
They're in people's beds. I'd say people have potentially also become a little bit more risk adverse. Um, initially I think we're talking there about the dogs and cats largely lived outside or in the kitchen. These days. Dogs are on the sofa, they're in people's beds. I'd say people have potentially also become a little bit more risk adverse. Um, initially, I think we're talking there about the parasites, but we might also talk about the environment, you know, going on with that.
And dogs and cats largely lived outside or in the kitchen these days. Dogs are on the sofa. They're in people's beds. I'd say people have potentially also become a little bit more risk adverse. Um, initially, I think we're talking there about the parasites, but we might also talk about the environment, you know, going on with that. And as Martin's maybe also alluded to as part of this perfect storm storm. We've also had corporatisation of the veterinary profession, which has meant that, you know, this reason for regular prevention has become commercialised.
Um, you know, to to some extent. And that's meant that the selling of regular monthly treatments has become the norm. Alongside that, we've also had some change in licensing by VMD. So some of these products are now also very much out of veterinary hands. They're for sale on the internet. Um, and that's led us to where we are. And at the same time, we've obviously realised that some of these products are really environmentally damaging. And we need to backtrack at a rate of knots, which I hope we're beginning to do, but we probably need to do it more quickly than we are doing.
They're in people's beds. I'd say people have potentially also become a little bit more risk adverse. Um, initially I think we're talking there about the dogs and cats largely lived outside or in the kitchen. These days. Dogs are on the sofa, they're in people's beds. I'd say people have potentially also become a little bit more risk adverse. Um, initially, I think we're talking there about the parasites, but we might also talk about the environment, you know, going on with that.
And dogs and cats largely lived outside or in the kitchen these days. Dogs are on the sofa. They're in people's beds. I'd say people have potentially also become a little bit more risk adverse. Um, initially, I think we're talking there about the parasites, but we might also talk about the environment, you know, going on with that. And as Martin's maybe also alluded to as part of this perfect storm storm. We've also had corporatisation of the veterinary profession, which has meant that, you know, this reason for regular prevention has become commercialised.
Um, you know, to to some extent. And that's meant that the selling of regular monthly treatments has become the norm. Alongside that, we've also had some change in licensing by VMD. So some of these products are now also very much out of veterinary hands. They're for sale on the internet. Um, and that's led us to where we are. And at the same time, we've obviously realised that some of these products are really environmentally damaging. And we need to backtrack at a rate of knots, which I hope we're beginning to do, but we probably need to do it more quickly than we are doing.
10:06
10:06
Speaker 3
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Speaker 3
So just to address your question about the different products and market shifts, we don't have very recent sales data for most pet parasiticides, but the data that we have indicates that fipronil, imidacloprid, and fluralaner are the most widely used products. So historically, Fipronil and imidacloprid were, well, they dominated the market. And those are the products that, um, I did my PhD on and for which we have the best evidence of environmental pollution. Um, there has, however, been a marked shift over the last several years towards a new class of flea treatment called the Isoxazolines.
So these are available as tablets.
So these are available as tablets.
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10:06
Speaker 3
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Speaker 3
So there are a variety of reasons. It's um they are, they work in a different way. So they're available as tablets which are primarily given to dogs. So they're very convenient. Um, they're very effective, extremely effective. I would argue researchers are more, more effective than the older products. Um, they are also available as spot on products which tend to be administered to cats. Because cats are seen as difficult to give a tablet to.
Work in a different way and that they're absorbed systemically into the body, um, or proportion of, of them is um, I won't go into the detail of what happens to the rest of it because we don't really know. Um, in terms of sales, we know that imidacloprid sales peaked in around about 2017 and they've slowly been declining since then. Um, so I think it was 4200kg in 2017, the sales data that we have, and it was about 2900 in 2024. I think fipronil sales seem to have been fairly steady over the last several years.
We don't have very good recent data for Isoxazolines, but, um, my, my understanding is that those sales are really increasing. And, um, in terms of distribution routes, Isoxazolines are primarily prescription only medications at the moment. So a lot of the shift has occurred in veterinary practices. So vets are shifting away from footprint on imidacloprid for a variety of reasons, including pollution concerns. Um, so vets are shifting towards these newer isoxazoline products. Um, fipronil and imidacloprid are very easy.
Available. So they are available from supermarkets. They're easily available online. Um, my understanding is that they are primarily sold online at the moment. And as I said, very easily available online. Um, the Isoxazolines are primarily sold by vets, but they are and are prescription only, but they are becoming more accessible. So in the last year or two, some Isoxazole Oxazole isoxazolyl tablets for dogs have been made available in the NFA category, which means that they can be sold with professional advice from a pet shop or online.
Work in a different way and that they're absorbed systemically into the body, um, or proportion of, of them is um, I won't go into the detail of what happens to the rest of it because we don't really know. Um, in terms of sales, we know that imidacloprid sales peaked in around about 2017 and they've slowly been declining since then. Um, so I think it was 4200kg in 2017, the sales data that we have, and it was about 2900 in 2024. I think fipronil sales seem to have been fairly steady over the last several years.
We don't have very good recent data for Isoxazolines, but, um, my, my understanding is that those sales are really increasing. And, um, in terms of distribution routes, Isoxazolines are primarily prescription only medications at the moment. So a lot of the shift has occurred in veterinary practices. So vets are shifting away from footprint on imidacloprid for a variety of reasons, including pollution concerns. Um, so vets are shifting towards these newer isoxazoline products. Um, fipronil and imidacloprid are very easy.
Available. So they are available from supermarkets. They're easily available online. Um, my understanding is that they are primarily sold online at the moment. And as I said, very easily available online. Um, the Isoxazolines are primarily sold by vets, but they are and are prescription only, but they are becoming more accessible. So in the last year or two, some Isoxazole Oxazole isoxazolyl tablets for dogs have been made available in the NFA category, which means that they can be sold with professional advice from a pet shop or online.
10:09
10:09
Speaker 4
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Speaker 4
Um, there are four reasons to sell Parasiticides. One of them is animal health and welfare, and that's the one that probably immediately comes to people's minds preventing flea infestations or worms or such. Uh, one of them is human health concerns. Um, because potentially some of the things that animals get can infect us. Them is what you might call intangible benefits for owners peace of mind not having to think, oh, my cat's got some horrible, yucky parasite inside it, something like that.
Not having to think, oh, maybe I will get a flea infestation one day. Um, and and, and also appearing at responsible owner, the veterinary profession has put a lot of effort, not necessarily deliberately, but they have done so over maybe 20 years or so to convince clients you need to be treating your pet regularly. That's part of responsible ownership. Um, so, and my own view is that the huge majority of the parasiticides that are sold are sold to that intangible benefit market. Um, the fourth is you make a profit from selling them and they are a very large contributor to veterinary professions, uh, income and to anybody else who sells them, obviously.
Um, and I would also point out that part of the reason there's been a shift away from fipronil and towards newer compounds, partly the newer compounds probably are better in the sense of they kill the fleas quicker, maybe more effective at that. But also vets want as businesses, we want to distinguish ourselves from what you can buy in a supermarket or get hold of very easily without a vet. So we can put across the advantages of a oxazolidones and say, it's better than that. Fipronil and imidacloprid stuff you can buy elsewhere.
Not having to think, oh, maybe I will get a flea infestation one day. Um, and and, and also appearing at responsible owner, the veterinary profession has put a lot of effort, not necessarily deliberately, but they have done so over maybe 20 years or so to convince clients you need to be treating your pet regularly. That's part of responsible ownership. Um, so, and my own view is that the huge majority of the parasiticides that are sold are sold to that intangible benefit market. Um, the fourth is you make a profit from selling them and they are a very large contributor to veterinary professions, uh, income and to anybody else who sells them, obviously.
Um, and I would also point out that part of the reason there's been a shift away from fipronil and towards newer compounds, partly the newer compounds probably are better in the sense of they kill the fleas quicker, maybe more effective at that. But also vets want as businesses, we want to distinguish ourselves from what you can buy in a supermarket or get hold of very easily without a vet. So we can put across the advantages of a oxazolidones and say, it's better than that. Fipronil and imidacloprid stuff you can buy elsewhere.
10:10
Speaker 1
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Speaker 1
Thank you. Um, so you've outlined four reasons why these are necessary if you like. Um is but there's growing concern um is that recognised within the veterinary profession. Growing concern. The impact of these very persistent chemicals. We understand from our evidence last week on the environment and their accumulative potential.
10:11
Speaker 2
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Speaker 2
Yes. I mean, I would say probably that realising that concern has taken time, you know, vets are dealing across a whole range of things and it has taken time. But we survey, um, part of our, our membership. So we have about 20,000 members and we survey about 2000 of them on a regular basis. And 93.5% of the people who responded to our recent survey were concerned about the environmental impact of small animal parasiticides. Um, over 70% agreed that any blanket prophylaxis was inappropriate, and nearly 80% agreed that there should be a lot more restrictions on the sale of small animal parasiticides.
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10:12
Speaker 2
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Speaker 2
I think that's yeah. That's all that's our aware of the risks. And I would say that's been part of the shift away from fipronil and imidacloprid. Um, I think obviously the concern there is, do we have any certainty about the environmental risks associated with the alternative products?But there has been a shift. I would agree with Martin, that some of that shift is perhaps also commercial. If you can buy Fipronil online very easily, why would you buy it from your vet?You can go to your vet who's got an alternative product, which is an injection or a tablet, which is maybe easier to give.
The evidence was suggested going to be a little bit better as well. So some of the shift is concern, I'd say, with individual vets, some of the shift perhaps more a vet practice corporate level is is a commercial one as well.
The evidence was suggested going to be a little bit better as well. So some of the shift is concern, I'd say, with individual vets, some of the shift perhaps more a vet practice corporate level is is a commercial one as well.
10:13
10:13
Speaker 2
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Speaker 2
Yeah. I think it has. And, um, I would probably refer you to the competition markets inquiry on this. Um, the CMA have singled out pet health plans where you, you get a range of services but almost always including these drugs. Parasiticides in some form. They've singled that out as being a potential issue where people were making a monthly payment for a package of things. And that wasn't necessarily a value. So one of the CMA's remedies that will go into their order at the end of September will be around transparency in those pet health plans, and also offering price comparison prescription for these products.
I think what vets are doing is moving away from product in pet health plans anyway. Um, but there is I know we'll go on to this. There is a risk if we push people away from vets for buying these products that at the moment they can just go online and buy some of the ones we understand to be the most damaging.
I think what vets are doing is moving away from product in pet health plans anyway. Um, but there is I know we'll go on to this. There is a risk if we push people away from vets for buying these products that at the moment they can just go online and buy some of the ones we understand to be the most damaging.
10:14
10:14
Speaker 3
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Speaker 3
Medicines Directorate has made some of this data available. Um, but it's not monitored in the way that antibiotic use is monitored. I think there's a requirement for antibiotic use to be published every year. Um, but veterinary, um the parasiticide use um is. Much harder to get hold of. So you have to submit a freedom of information requests. And it's usually only data from several years ago.
10:15
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Speaker 3
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Speaker 3
Yes. They have actually published one of the companies has made available some of their sales data. So there's a paper that came out recently which looked at imidacloprid levels in waterways. Um and that was actually funded by one of the market authorisation holders and they made available some of, um, some of their sales data.
10:16
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10:16
Speaker 5
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Speaker 5
Yes, please. Thank you. And thank you for coming and giving us your time. I declare an interest. I'm a veterinary surgeon. I did work for Elanco many years ago, in 1977 to 1980. But before any of these compounds were available anywhere, and I wasn't involved with that. And I have no current involvement with pharmaceutical industry directly. Um, could I just follow up the the segmentation of particularly imidacloprid and fipronil in terms of the marketing authorisation category?I'm interested because, you know, recommendations in future, either from the VMD or from this committee might involve changes to that.
Have you any idea?I know we don't have hard data, but could you give us estimates of the percentages of imidacloprid and fipronil products which are sold GSL or online, and the amounts, if you like as well, compared to that, go through a prescription only route. Any.
Have you any idea?I know we don't have hard data, but could you give us estimates of the percentages of imidacloprid and fipronil products which are sold GSL or online, and the amounts, if you like as well, compared to that, go through a prescription only route. Any.
10:18
Speaker 3
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Speaker 3
We did a survey a few years ago which looked at Parasiticide use in pet owners, and they told us what sort of routes they were purchasing their parasiticides through. And if I remember correctly, it was 80 either 70. No, 70% were purchasing their parasiticides from veterinary practices. And this is from several years ago. It was the study was from 2000. We published it in 2023. So it might have shifted a bit now, but um, 70% bought their parasiticides in veterinary practices, 20% bought them through online channels and 10% bought them through other routes such as pet shops and supermarkets.
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10:19
Speaker 6
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Speaker 6
Yeah. You're on the sort of cross hare between being good guys, treating our pets and animals and the bad guys making lots of money, you know, that's that's the kind of crossover you find that. So, um, how aware are vets of the emerging evidence about how chemicals get into the wider environment?And are you seeing this reflected in how different products are prescribed?I mean, you indicated that you thought they were aware, but I just want to know how widespread that might be.
10:19
Speaker 4
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Speaker 4
They are certainly aware that in my dichloropyridine fipronil are getting into the environment, because that's been published and it's very, very frequently discussed in the Veterinary Record and the Veterinary Times, those sorts of places. Um, I don't know to what extent they're so sure how it's getting into the environment. That information is out there and has also been a little bit discussed. I don't know to what extent, um, they have extrapolated from fipronil and imidacloprid where the research has been done to many of these other newer compounds.
We don't really know what's happening to those compounds, nor did your panelists last week. Um, so obviously it's going to be even harder for a general practice vet to twig that.
We don't really know what's happening to those compounds, nor did your panelists last week. Um, so obviously it's going to be even harder for a general practice vet to twig that.
10:20
10:20
Speaker 4
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Speaker 4
It would affect some vets for sure. So for instance, one of the other large corporate groups actually came up with a policy that they were going to stop using fipronil and imidacloprid because they were aware of the environmental consequences that might certainly their heart's in the right place. It might actually do more harm than good because we don't know what harm the things are switching to are doing.
10:20
Speaker 2
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Speaker 2
But I think there's two parts to this. One is we need to change the way we prescribe. So we're using these products really routinely. And I think if you ask most vets probably what they use with their own pets, we don't treat our own pets in the way that some practices are selling these products. And some of that is about the risk of with our clients, our clients, as Martin alluded to, they don't want fleas in the house, they don't want the cats to have.
And the drug companies have used that as a marketing thread. And it's something we've pushed back on. Um, but we need to change the way we prescribe. I mean, these products are different to antibiotics, but if you go back 20 years, we would give all routine surgery, antibiotics as a preventative in case, you know, there was some nasty infection there. We don't do that anymore. We don't use antibiotics routinely around surgery. It would be considered incredibly bad practice to do that.
So we need to start treating these products in the same way. We need to prescribe them where there's a genuine need. And that genuine need might relate to the pet. In some instances, it could relate to the human beings involved in that household as well. Um, so we need to do something about the way we prescribe, but we also need to look at the products we prescribe. And I think one of the concerns at the moment is that vets knowledge is to these products are really bad for the environment.
Let's stop prescribing them, prescribe something else. But we don't know that there's something. Ulcers are safer and we've got drug companies marketing those products really aggressively. I mean, one six month injection, you know, this is great. Give six months protection, just one injection. Isn't it brilliant?Well, maybe it's not because we don't have the environmental evidence there. So there's two bits we need to know more about the products. But we also do need to change our prescribing habits as vets.
And I hope we're doing that.
And the drug companies have used that as a marketing thread. And it's something we've pushed back on. Um, but we need to change the way we prescribe. I mean, these products are different to antibiotics, but if you go back 20 years, we would give all routine surgery, antibiotics as a preventative in case, you know, there was some nasty infection there. We don't do that anymore. We don't use antibiotics routinely around surgery. It would be considered incredibly bad practice to do that.
So we need to start treating these products in the same way. We need to prescribe them where there's a genuine need. And that genuine need might relate to the pet. In some instances, it could relate to the human beings involved in that household as well. Um, so we need to do something about the way we prescribe, but we also need to look at the products we prescribe. And I think one of the concerns at the moment is that vets knowledge is to these products are really bad for the environment.
Let's stop prescribing them, prescribe something else. But we don't know that there's something. Ulcers are safer and we've got drug companies marketing those products really aggressively. I mean, one six month injection, you know, this is great. Give six months protection, just one injection. Isn't it brilliant?Well, maybe it's not because we don't have the environmental evidence there. So there's two bits we need to know more about the products. But we also do need to change our prescribing habits as vets.
And I hope we're doing that.
10:23
10:23
Speaker 2
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Speaker 2
Bit of both. I mean, that's more of Rose's area than mine, but it is a bit of both. I mean, I think some things like the Songbird Trust's work around, you know, these products being in Bird's Nest, those made the headlines of the veterinary press. And, you know, we we care about animals. You know, we do care about what goes on out in the environment. So those have been really strong messages. So I think there is some real awareness and concern.
And there's the same awareness and concern with some of our clients across section of our clients. Definitely, you know, don't want these products because they've heard they're bad. But the danger then is we move to other products. We don't know any better. And that's why we also need to change the way we actually prescribe.
And there's the same awareness and concern with some of our clients across section of our clients. Definitely, you know, don't want these products because they've heard they're bad. But the danger then is we move to other products. We don't know any better. And that's why we also need to change the way we actually prescribe.
10:24
Speaker 3
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Speaker 3
I can just step in there. I think one of the the challenge that the veterinary challenges that the veterinary profession is facing is that we are, um, the BVA has, has sort of stepped up and, um, advised more judicious use and they've recommended risk based parasite control and the phrase risk based parasite control has become very, very popular, widely used. Um, but the problem is that we don't really have a very clear definition of what risk based parasite control actually means. Um, and there are various potential interpretations of this.
So one interpretation would be that we do risk assessments on individual animals. And we target preventative treatment towards higher risk animals. And we just monitor lower risk animals. And that's the interpretation that's been put forward by organisations like vet sustain. Um but then oh and one example of this just to illustrate how you would apply this would be for fleas. So we know that fleas can occur in any animal. It's very difficult, difficult to completely eliminate the risk of fleas.
Um but there are certain factors that research has shown increase the likelihood of fleas. So they're more likely to occur in summer and autumn. They're much more likely to occur in cats than in dogs. So one potential approach if we adopt this. Interpretation would be to target preventative treatment towards cats in summer and autumn. Um, but then another interpretation and arguably this is the interpretation that's been put forward by industry funded advisory bodies like Escap, which is the parasitology advisory body, um Escap parasitologists have um often recommended year round treatment for cats and dogs.
Um, sort of based on the premise that um, if there's a risk you should treat preventatively. Um, so I would argue that is blanket treatment. Um, and that's exactly what the BVA and the, the Royal College, the Ocvs, which is veterinary regulator, that's exactly what they, they state that we should, we should not be doing. Um, so the problem is that that risk threshold is very subjective. Um, and in my experience, what tends to happen in practice is it just gets put very low.
Vets get very risk averse. Um, and this is certainly incentivised by healthcare plans which do incentivize, incentivize, um, a very cautious approach. So what I think needs to happen is we need a paradigm shift from having routine prevention as the default and perhaps not treating if there's some exceptional circumstances to having no treatment as the default, and then perhaps treating if there's a high risk that's sort of confirmed high risk of infestation. And this is what I do in my own pets. Um, just got a puppy recently.
We've not treated her for fleas, not planning to. Um, that's still a sort of experiment that we've only just started, but I've had a cat for nine years. She's never treated her routinely for fleas. She's had fleas. Once. We picked that up through a flea dirt test, which is a test that all pet owners should be shown how to do. It's a very easy test. It helps you pick up fleas early. It cleared pretty much immediately with a tablet.
Isoxazoline. Um, so yeah, I think, um, this approach of just.
So one interpretation would be that we do risk assessments on individual animals. And we target preventative treatment towards higher risk animals. And we just monitor lower risk animals. And that's the interpretation that's been put forward by organisations like vet sustain. Um but then oh and one example of this just to illustrate how you would apply this would be for fleas. So we know that fleas can occur in any animal. It's very difficult, difficult to completely eliminate the risk of fleas.
Um but there are certain factors that research has shown increase the likelihood of fleas. So they're more likely to occur in summer and autumn. They're much more likely to occur in cats than in dogs. So one potential approach if we adopt this. Interpretation would be to target preventative treatment towards cats in summer and autumn. Um, but then another interpretation and arguably this is the interpretation that's been put forward by industry funded advisory bodies like Escap, which is the parasitology advisory body, um Escap parasitologists have um often recommended year round treatment for cats and dogs.
Um, sort of based on the premise that um, if there's a risk you should treat preventatively. Um, so I would argue that is blanket treatment. Um, and that's exactly what the BVA and the, the Royal College, the Ocvs, which is veterinary regulator, that's exactly what they, they state that we should, we should not be doing. Um, so the problem is that that risk threshold is very subjective. Um, and in my experience, what tends to happen in practice is it just gets put very low.
Vets get very risk averse. Um, and this is certainly incentivised by healthcare plans which do incentivize, incentivize, um, a very cautious approach. So what I think needs to happen is we need a paradigm shift from having routine prevention as the default and perhaps not treating if there's some exceptional circumstances to having no treatment as the default, and then perhaps treating if there's a high risk that's sort of confirmed high risk of infestation. And this is what I do in my own pets. Um, just got a puppy recently.
We've not treated her for fleas, not planning to. Um, that's still a sort of experiment that we've only just started, but I've had a cat for nine years. She's never treated her routinely for fleas. She's had fleas. Once. We picked that up through a flea dirt test, which is a test that all pet owners should be shown how to do. It's a very easy test. It helps you pick up fleas early. It cleared pretty much immediately with a tablet.
Isoxazoline. Um, so yeah, I think, um, this approach of just.
10:28
10:28
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10:28
Speaker 3
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Speaker 3
Yeah. That the active ingredient is lotilaner. And it's a tablet. So that's the product I recommend for, for cats. And I'm not getting commission from, from anyone for that. Um, I'm very much a fan of tablets versus spots. Yeah. I do not like Spartans. Um, and I think this approach is really supported by the evidence. So it's more in line with the way that we use antibiotics.
Um, it's much cheaper. You save a lot of money. Um, and isoxazolines are incredibly effective. So they are half a dozen studies showing that flea infestations clear rapidly with isoxazolines with no need for household flea spray. Um, so it really does weaken the argument for routine prevention. Um.
Um, it's much cheaper. You save a lot of money. Um, and isoxazolines are incredibly effective. So they are half a dozen studies showing that flea infestations clear rapidly with isoxazolines with no need for household flea spray. Um, so it really does weaken the argument for routine prevention. Um.
10:30
10:30
Speaker 3
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Speaker 3
This do the same. Well, absolutely. Vets know what works. That's one reason I think these products should be prescription only. Vets know what works. If people buy them the products elsewhere, they end up getting products that are less effective. So yeah, this is the approach that I recommend to clients and I find that it works very well. Good.
10:30
10:31
Speaker 7
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Speaker 7
Um, thank you very much for your evidence today. I mean, you say vets know what works. I guess the question I wanted to ask you isn't the all the direction from the pharmaceutical companies really to cut vets out of the equation and sell directly to consumers and sell directly online?And you sign up to a 12 month plan and you overdose your pet because that's, that's kind of a way of making profit. And I just wondered first if you agreed with that and to what your thoughts were as veterinarians on that relationship.
That to my mind, you might not agree, is developing between pharmaceutical companies and direct to consumer products and where the environment sits in. Well, there's.
That to my mind, you might not agree, is developing between pharmaceutical companies and direct to consumer products and where the environment sits in. Well, there's.
10:31
Speaker 4
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Speaker 4
Two separate markets. Um, one of them is through vets and I think still the bulk of flea treatment comes that way. Uh, the other one is not through vets. And I'm sure the drug companies would love it if both of those markets did year round flea treatment, because that sells the most parasite and makes the most profit. Um, so they'll be happy to promote that both ways. Um, and I'm fully in agreement with rose and is, and the BVA in the CVS that we should not be doing that.
Uh, almost all the Parasiticides that are preventively applied to pets are unnecessary because the pet wasn't going to get a parasite in the time that, that parasiticide was working anyway. Um, so yes, there is a very strong feed down from above and it's not just the vet, the, the drug companies who are making money, obviously veterinary practices make money from it. And although it's a smaller factor for supermarkets and pet shops, they'll be making some money from it too. So the whole thing and that obviously is a problem with private medicine in humans or animals.
Yeah.
Uh, almost all the Parasiticides that are preventively applied to pets are unnecessary because the pet wasn't going to get a parasite in the time that, that parasiticide was working anyway. Um, so yes, there is a very strong feed down from above and it's not just the vet, the, the drug companies who are making money, obviously veterinary practices make money from it. And although it's a smaller factor for supermarkets and pet shops, they'll be making some money from it too. So the whole thing and that obviously is a problem with private medicine in humans or animals.
Yeah.
10:32
10:32
Speaker 8
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Speaker 8
The question that I was going to put. First of all, could I declare my interest?I'm an honorary fellow or fellow associate of the British Veterinary Association, of which I'm very proud. Um, so we heard from Johnson that the over the counter sales value of the AVM GSL products alone are £100 million. So presumably you are losing out um income if over the sale counters go in place of prescription. If I ask you first, Liz, is that is that the case?
10:33
Speaker 2
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Speaker 2
Yeah. I mean we don't I don't think we have data on exactly which products are being sold in which categories to which people in the right way. Um, so there are a lot of over the counter. I mean, some of it is online, some of it will be in supermarkets. Um, there's things like pet insurance companies that will deliver your flea control to you every month. And that is a GSL product that they're selling the whole time. Certainly the evidence that I've read would suggest that for dogs, the vets are still the main place that people go.
For cats. It's a bit different. A lot of people do have multi-cat households. You know, people have cats, have a few of them. And having them all at the vets is going to be quite costly as well. Obviously the GSL, the prescription only we do have that suitably qualified person category in the middle. And even moving to that would be better than just general sales, because it would give out some advice with that category. Um, veterinary nursing colleagues, actually, very few of them are suitably qualified people because they don't see a benefit of that training.
There could be some advantages to more of these products that GSL coming back to VPS. That it could be sold in veterinary practices in a different way. At the moment, if you've got a dozen cats, you have to take your dogs and cats to the vets. They all have to be individually examined. And then you either get a prescription or you get product supplied. For some households, I think that is a problem. And I was speaking to a colleague who until recently worked for the Dogs Trust, and she said, you know, that is an issue.
And even within their clinics, they were selling GSL products because they were cheaper. So fipronil effectively. So I in an ideal world, these would be prescription only products because they would be then sold with proper advice. Vets would move to using them in the same way we use other antimicrobials. But I do think we need to think about some of the most vulnerable households. I don't want to go back to where I was 30 years ago where, you know, I got houses that were infested with fleas and people with masses of animals that really couldn't cope with that and wouldn't probably be able to cope with the costs of some of the Pom products as they are at the moment.
So we need to shift that market to make things more affordable.
For cats. It's a bit different. A lot of people do have multi-cat households. You know, people have cats, have a few of them. And having them all at the vets is going to be quite costly as well. Obviously the GSL, the prescription only we do have that suitably qualified person category in the middle. And even moving to that would be better than just general sales, because it would give out some advice with that category. Um, veterinary nursing colleagues, actually, very few of them are suitably qualified people because they don't see a benefit of that training.
There could be some advantages to more of these products that GSL coming back to VPS. That it could be sold in veterinary practices in a different way. At the moment, if you've got a dozen cats, you have to take your dogs and cats to the vets. They all have to be individually examined. And then you either get a prescription or you get product supplied. For some households, I think that is a problem. And I was speaking to a colleague who until recently worked for the Dogs Trust, and she said, you know, that is an issue.
And even within their clinics, they were selling GSL products because they were cheaper. So fipronil effectively. So I in an ideal world, these would be prescription only products because they would be then sold with proper advice. Vets would move to using them in the same way we use other antimicrobials. But I do think we need to think about some of the most vulnerable households. I don't want to go back to where I was 30 years ago where, you know, I got houses that were infested with fleas and people with masses of animals that really couldn't cope with that and wouldn't probably be able to cope with the costs of some of the Pom products as they are at the moment.
So we need to shift that market to make things more affordable.
10:36
10:36
Speaker 2
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Speaker 2
Yeah, I mean, it is pharmaceutical companies are definitely doing it. So when Rose was talking about, you know, risk assessment, if you go on, there are some tools for vets to risk assess individual pet and owner combinations. They always result in you needing to treat the animal. I've genuinely gone in and played with them and tried to create the least risky household. They still tell me I need to treat. So that's not at all helpful. Um, we have provided some resources to try and, you know, help.
Vets are professional people. They're also very busy people. And I think the more between us all, we can provide some easier resources. But every household pet combo is a little bit different. So they, they do need to be really easy. Some of the marketing from the pharmaceutical companies, one I particularly did go personally and push back on was it was actually about tapeworms, but it was tapeworms are gross. So not that tapeworms are any health problem for your pet.
They're not any human health risks. They're just gross. And that's the reason. And I was just like, you cannot advertise like that. That's not a reason for us using these chemicals. It's really wrong. And, um, you know, they do push this still very much push monthly, year round, convenient prevention. That's what they're pushing.
Vets are professional people. They're also very busy people. And I think the more between us all, we can provide some easier resources. But every household pet combo is a little bit different. So they, they do need to be really easy. Some of the marketing from the pharmaceutical companies, one I particularly did go personally and push back on was it was actually about tapeworms, but it was tapeworms are gross. So not that tapeworms are any health problem for your pet.
They're not any human health risks. They're just gross. And that's the reason. And I was just like, you cannot advertise like that. That's not a reason for us using these chemicals. It's really wrong. And, um, you know, they do push this still very much push monthly, year round, convenient prevention. That's what they're pushing.
10:38
Speaker 2
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Speaker 2
Yeah, I think there needs to be some. I mean, we had it. If you go back 20 or 30 years, we did actually, some of the drug companies produce things for you to look at what risks were. And they work very, very well. Before we moved into more routine treatment. Um, but yeah, we need to look at the, the owners we need, it's a questionnaire really about number of pets, number of owners. So that's the first thing, which in very many situations, as Rose suggested, would be actually you don't need anything at the moment, but we then need to be in a position where people go in and say, now my cat's got fleas, that we're able to give them the right advice, which again, would involve asking about other pets in the household.
You know, dogs going to doggy day care, getting a proper picture so that we can prescribe the right product in the right way. And I'm saying we, which would be veterinary surgeons. Um, it is possible for that advice to be given by other people. Veterinary nurses would probably be my preference there. But um, suitably qualified people do give this advice for farm animal products and can be trained to do small animal work. Some of them are not, as many of them as to make the products accessible.
I don't think, um, you know, to everybody, not everywhere in the country will have a small animal SQP on the doorstep.
You know, dogs going to doggy day care, getting a proper picture so that we can prescribe the right product in the right way. And I'm saying we, which would be veterinary surgeons. Um, it is possible for that advice to be given by other people. Veterinary nurses would probably be my preference there. But um, suitably qualified people do give this advice for farm animal products and can be trained to do small animal work. Some of them are not, as many of them as to make the products accessible.
I don't think, um, you know, to everybody, not everywhere in the country will have a small animal SQP on the doorstep.
10:40
10:40
Speaker 3
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Speaker 3
Yeah, absolutely. My, my view is that I'm not particularly in favour of making these products NFA. Um, I do appreciate there's an argument for lower income people. Um, but you know, the example of someone with a dozen cats, if the, when the cats need vaccinations because they should be getting vaccinations, they'll need to take them to a vet for that. They'll need to take them to a vet for any other prescription medication for antibiotics. I think all of the factors that justify the requirement for a prescription, um, are present for parasiticides.
So they are hazardous products. Um, we know that they're dangerous for the environment. They're potential risks for human health and the potential risk for resistance, which we haven't touched on yet. But that is a real concern. Um, so I think. If we were to keep them as NFA, I mean, I've, I've done a little bit of research on this. I've gone to my local pet shop, I've spoken to ask about Parasiticides. I had a look online.
Um, the skps that I spoke to weren't aware of the environmental risks around footprint on imidacloprid. I know that Amtrak has been making efforts to, to sort of educate. Um, but none of them were aware of it. Um, they all recommended blanket treatment when I asked what advice they give on, on parasite control, fipronil and imidacloprid are easily available online even when they're in the NFA category. So they are already footprint products sold as NFA. You can buy them easily online.
I don't see how you could get any sort of suitable professional advice when they're primarily being sold online. You can also buy NFA products easily through um subscription schemes. No problem. No barriers whatsoever. So I, I struggle to see how the proposed change is going to affect pollution levels at all. Whereas if we were to make these product prescription only, I'm quite certain that usage would plummet because vets don't use these products. We actually did a.
Well, I've mentioned the survey we did a while ago. One of the interesting findings from from that. And you have to sort of dig into the data to see this, but there are quite a few vets who responded to the survey and told us what they use in their own pets. Vets don't use fipronil. I think we had one vet out of 100 vets who responded to the survey, had used Fipronil in their reported Fipronil as the primary product they were using in their own.
So they are hazardous products. Um, we know that they're dangerous for the environment. They're potential risks for human health and the potential risk for resistance, which we haven't touched on yet. But that is a real concern. Um, so I think. If we were to keep them as NFA, I mean, I've, I've done a little bit of research on this. I've gone to my local pet shop, I've spoken to ask about Parasiticides. I had a look online.
Um, the skps that I spoke to weren't aware of the environmental risks around footprint on imidacloprid. I know that Amtrak has been making efforts to, to sort of educate. Um, but none of them were aware of it. Um, they all recommended blanket treatment when I asked what advice they give on, on parasite control, fipronil and imidacloprid are easily available online even when they're in the NFA category. So they are already footprint products sold as NFA. You can buy them easily online.
I don't see how you could get any sort of suitable professional advice when they're primarily being sold online. You can also buy NFA products easily through um subscription schemes. No problem. No barriers whatsoever. So I, I struggle to see how the proposed change is going to affect pollution levels at all. Whereas if we were to make these product prescription only, I'm quite certain that usage would plummet because vets don't use these products. We actually did a.
Well, I've mentioned the survey we did a while ago. One of the interesting findings from from that. And you have to sort of dig into the data to see this, but there are quite a few vets who responded to the survey and told us what they use in their own pets. Vets don't use fipronil. I think we had one vet out of 100 vets who responded to the survey, had used Fipronil in their reported Fipronil as the primary product they were using in their own.
10:43
10:43
10:43
10:43
10:44
10:44
Speaker 3
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Speaker 3
Have actually I've tried to look into that. I think um it's not clear to me that they are prescription only. I'd have to check that for you. I've been trying to find out for certain about that, but I think there's a very strong argument that these products should all be prescription only. Absolutely.
10:44
10:44
Speaker 4
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Speaker 4
Yes. But if I could first just add to something that Rose just said, um, in the current VMD consultation about changing the products from GSL to NFA. There is. Um, from the VMD, a massive assumption that that would result in useful professional advice to um purchasers of these drugs. And I just don't see that being the case at all. I would say that what the VMD should do is a bit of secret mystery shopping. Um, you know, buy some stuff off the internet, buy from pet shops.
So I think that would be very useful thing to do. Um, as for defining prophylactic, um, if animals come to the vet and they've got an infestation, every vet will be very happy to treat. Obviously I'm dead against prophylactic use and I'm certainly would be treating them if it's a harmful infestation. Like Lee said, if I see a cat with um tapeworm, well, you're treating it because the owner doesn't like it. But for fleas, definitely. If they haven't got them, uh, you've got, you've got to that's where the risk base comes in.
You ask them about their cat. You think about the time of year. Um, so for myself, if somebody comes to me with a dog or a cat in the middle of winter, they're very unlikely to be getting fleas. It's not impossible. And you can ask them, say, well, how many cats do you've got?If they've got six cats that are all going outside and interacting with wildlife, maybe one of them will bring fleas in. But it's, you know, if they've got one cat, very unlikely at that time of year, even in the middle of summer, the probability is that it won't get fleas.
So my advice providing the cat is amenable is just combing a cat every day. Just very briefly. The cat will probably enjoy it. Actually, if you see pleader right, come and get some product and we'll give it to you. And, and it's not just the probability of will the animal get a parasite, it's also the consequences of the animal having a parasite. So some dogs and cats have an allergy to flea bites. Um, and they get really terribly itchy.
So I'd be maybe inclined in the summer if you've got a dog or a cat that, you know, gets this terrible allergy, flea bites, well, maybe let's treat it over the summer, the high risk period when I wouldn't maybe do that for a cat that doesn't. Or maybe if you've got a young cat and the owner has a, you know, a severely immune compromised elderly relative or child living at home, theoretically, younger cats are prone to getting a flea carried infection, a bacterial infection called Bartonella, which can cause serious illness, sometimes very, very rare, in fact, that it can cause illness in immune compromised.
So there's maybe another reason, or perhaps just a blind owner. They're not going to notice fleas building up on their pet. So that's risk based prescribing. That's what we do in our practice.
So I think that would be very useful thing to do. Um, as for defining prophylactic, um, if animals come to the vet and they've got an infestation, every vet will be very happy to treat. Obviously I'm dead against prophylactic use and I'm certainly would be treating them if it's a harmful infestation. Like Lee said, if I see a cat with um tapeworm, well, you're treating it because the owner doesn't like it. But for fleas, definitely. If they haven't got them, uh, you've got, you've got to that's where the risk base comes in.
You ask them about their cat. You think about the time of year. Um, so for myself, if somebody comes to me with a dog or a cat in the middle of winter, they're very unlikely to be getting fleas. It's not impossible. And you can ask them, say, well, how many cats do you've got?If they've got six cats that are all going outside and interacting with wildlife, maybe one of them will bring fleas in. But it's, you know, if they've got one cat, very unlikely at that time of year, even in the middle of summer, the probability is that it won't get fleas.
So my advice providing the cat is amenable is just combing a cat every day. Just very briefly. The cat will probably enjoy it. Actually, if you see pleader right, come and get some product and we'll give it to you. And, and it's not just the probability of will the animal get a parasite, it's also the consequences of the animal having a parasite. So some dogs and cats have an allergy to flea bites. Um, and they get really terribly itchy.
So I'd be maybe inclined in the summer if you've got a dog or a cat that, you know, gets this terrible allergy, flea bites, well, maybe let's treat it over the summer, the high risk period when I wouldn't maybe do that for a cat that doesn't. Or maybe if you've got a young cat and the owner has a, you know, a severely immune compromised elderly relative or child living at home, theoretically, younger cats are prone to getting a flea carried infection, a bacterial infection called Bartonella, which can cause serious illness, sometimes very, very rare, in fact, that it can cause illness in immune compromised.
So there's maybe another reason, or perhaps just a blind owner. They're not going to notice fleas building up on their pet. So that's risk based prescribing. That's what we do in our practice.
10:48
10:48
10:48
Speaker 3
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Speaker 3
Briefly make a point about this, this concept of professional advice. I think one of the sort of underlying premises of, um, providing professional advice alongside sale of the products is that, um, if clients are advised on how to use the products correctly, so how to apply them and how to dispose of pipettes that will address pollution issues. But what our research shows, and this is the research that the VMD itself funded, is that pollution is occurring through correct use. So there's actually no evidence that incorrect application or incorrect disposal of the products is a source of pollution.
Even if it is, it's not going to resolve the problem if we address that, because we know that the major routes to the environment are routine. Um, activities like washing your hands for weeks after treating your.
Even if it is, it's not going to resolve the problem if we address that, because we know that the major routes to the environment are routine. Um, activities like washing your hands for weeks after treating your.
10:48
10:49
10:49
10:49
Speaker 1
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Speaker 1
And before we move on, I just want to pursue the same point a little bit further. I just want to completely understand you said that vets would not be prescribing these medicines in the volumes that we're seeing at the moment. Um, who sets a vet's practice and to what degree do vets have autonomy in their decision making?
10:49
Speaker 3
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Speaker 3
Yes, that's a really good question. So, um, guidance on responsible parasiticide use comes, I would say primarily from Escap, which stands for European Scientific Council companion Animal parasites. Um, and to a lesser degree from Rheumacin, which um. Provides guidance on responsible use of medicines. Both of these organisations are funded by the pharmaceutical industry. Um escape advice. I think I've mentioned this before um representatives have largely continued to promote routine year round treatment for cats and dogs.
Um even though in my view this is blanket treatment and it goes against veterinary authority guidance. Rheumacin haven't really said much about this. They've issued a very vague statement saying that we should use medicines responsibly, but there are too many knowledge gaps to know what to do about the pollution. So sort of implying that we should carry on as we are. Um, I would just point out that both of these organisations have really obvious and substantial conflicts of interest. And I would also say that the conflicts of interest around Parasiticides are particularly acute.
So we know they're highly polluting products and we know they're also highly profitable products. So that's quite a dangerous combination. And there's a huge incentive to to keep selling these products. I think in human medicine. Um, the, the importance of managing conflicts of interest when it comes to developing guidelines on responsible medicine use, um, is well recognised. So the scientific bodies that develop guidelines on, on medicine use have really stringent measures in place to, to manage conflicts of interest.
So there'll be things like requirement that the chair of a panel has no funding from pharmaceutical industry or has no conflicts of interest. Most of the panel members should not have conflicts of interest, that sort of thing. Complete transparency. Um, and also they'll have really rigorous methods for developing guidelines on medicine use. So ways that we assess the body of evidence and we do systematic reviews of the evidence. And we come up with balanced evidence based guidelines. But there's actually very little of that in the veterinary profession.
Um, and I think there's a lack of appreciation in the veterinary profession of the gravity of the conflicts of interest surrounding the guidance that we get on Parasiticides and that we are passing on to pet owners. And the potential bias that this introduces into the advice that we are giving to pet owners.
Um even though in my view this is blanket treatment and it goes against veterinary authority guidance. Rheumacin haven't really said much about this. They've issued a very vague statement saying that we should use medicines responsibly, but there are too many knowledge gaps to know what to do about the pollution. So sort of implying that we should carry on as we are. Um, I would just point out that both of these organisations have really obvious and substantial conflicts of interest. And I would also say that the conflicts of interest around Parasiticides are particularly acute.
So we know they're highly polluting products and we know they're also highly profitable products. So that's quite a dangerous combination. And there's a huge incentive to to keep selling these products. I think in human medicine. Um, the, the importance of managing conflicts of interest when it comes to developing guidelines on responsible medicine use, um, is well recognised. So the scientific bodies that develop guidelines on, on medicine use have really stringent measures in place to, to manage conflicts of interest.
So there'll be things like requirement that the chair of a panel has no funding from pharmaceutical industry or has no conflicts of interest. Most of the panel members should not have conflicts of interest, that sort of thing. Complete transparency. Um, and also they'll have really rigorous methods for developing guidelines on medicine use. So ways that we assess the body of evidence and we do systematic reviews of the evidence. And we come up with balanced evidence based guidelines. But there's actually very little of that in the veterinary profession.
Um, and I think there's a lack of appreciation in the veterinary profession of the gravity of the conflicts of interest surrounding the guidance that we get on Parasiticides and that we are passing on to pet owners. And the potential bias that this introduces into the advice that we are giving to pet owners.
10:52
10:52
10:53
10:53
10:53
10:53
Speaker 3
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Speaker 3
Um, that data should absolutely be, be part of the environmental risk assessment. But I suppose if we're talking specifically about the development of guidelines and who should be providing guidance, it's a separate issue from their environmental risk assessment. Of course, that should feed into the environmental risk assessment. I suppose the problem at the moment, um, is that these well, scalp in particular, um as far as I'm aware, last time I checked they have absolutely no mention in their official guidance of environmental risks. Even though we know that there are environmental risks.
10:54
10:54
10:54
10:54
10:55
10:55
Speaker 3
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Speaker 3
What responsibility they are. Absolutely. They do provide guidance as well. So, um, there are lots of promotional activities. So pharmaceutical companies provide continual professional development activities. They sponsored talks at um at Congresses. Um, but my view is that there should be an independent um scientific body that sets the standard at the moment. It's being set by organisations that have huge conflicts of interest. There needs to be an independent body that sets the standards and that is disseminated by.
10:56
10:56
10:56
10:56
Speaker 3
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Speaker 3
Provide detailed guidance on medicines. Use they. What tends to happen in the veterinary profession is they. They collaborate with other organisations. So um, they are involved with rumour. They're involved with Scop. So all of the organizations that provide guidance on parasiticide use, um, tend to have the VMD sort of collaborating with NOAA, which is the pharmaceutical trade organisation and does a lot of lobbying for the pharmaceutical industry. They're heavily involved in the guidance that's developed for vets.
Um, so it tends to all be very influenced, in my view, by the pharmaceutical industry. And there will be some independent vets as well. But thank you.
Um, so it tends to all be very influenced, in my view, by the pharmaceutical industry. And there will be some independent vets as well. But thank you.
10:57
10:57
Speaker 3
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Speaker 3
Uh, pharmaceutical companies are actually involved to some extent in the guidance. So if you look at Rheumacin, um, their treasure. Treasurer is the chief executive of NOAA, which is the trade organisation. So basically with rumour, you've got the, the person effectively holding the purse strings for the organisation providing guidance on medicine use. Um is the chief executive of an organisation which lobbies for the pharmaceutical industry. The chief executive of an organisation which lobbies for the pharmaceutical industry. And this is considered normal in the veterinary.
10:58
Speaker 1
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Speaker 1
Profession. Will do a whole session on. A whole question on policy implications. So I think we'll park this discussion just here, but just on a few factual points on this issue. Um, can you say definitively which category do fipronil imidacloprid come under where the newer products sit in those distribution categories?And where would you like them to sit?
10:59
Speaker 4
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Speaker 4
Um, obviously fipronil and imidacloprid are on the general sales list. That's what they call off the shelf. Um, the most of the parasiticides and especially most of the newer ones, including this group of compounds called isoxazolines, pyrazoles are prescription only medicine veterinary. So they need a prescription sold by a vet or be given a prescription and order.
10:59
10:59
11:00
Speaker 4
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Speaker 4
Yeah. So there's POMV and which is by a vet. And then there's POMVP which is vet pharmacists who I suspect sell relatively little of it. And then the S is for the suitably qualified person. So most of those products are in there. Um the um a few of the Isoxazoline products are in that NFA s category. Um so you can go and buy those. I forget the precise names.
11:00
Speaker 1
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Speaker 1
The other quick question I would like an answer to is what is the price difference between prescription?Uh, you know, by getting something, by going to see your vet, what's a consultation fee and how much are you going to pay for the medication as opposed to buying it off the shelf?Because that will be a key consideration for, for people with pets.
11:01
Speaker 3
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Speaker 3
Yeah. So, um, in my experience, what tends to happen in veterinary practice is that when animals come in for their annual vaccination, um, then a, quite often a script will be put up for whatever parasiticides are considered necessary. Um, often they won't necessarily be, uh, handed out. At that point, but if the animal needs a parasiticide at some point over the next 12 months, it's usually a 12 month script. They can just ring and get it. So there's no need to come back for a consultation.
Um, in terms of cost, um, I think they probably are cheaper if they're bought online. So fipronil and imidacloprid are generally cheaper. Um, the one of the issues that was raised by the CMA was the fact that um veterinary practices were quite heavily marking up parasiticides if they were not sold through the health care plans, which sort of helps to um um, argue. That the health care plans are very good value for money because there's so much cheaper than the alternatives that aren't provided through the health care plans.
But if you buy them through independent pharmacies with a written prescription, there are a lot cheaper. So that written prescription would cost money. It's usually about £28. That's what costed my practice. So there is an additional fee for prescription products. Um, in my view, it's absolutely.
Um, in terms of cost, um, I think they probably are cheaper if they're bought online. So fipronil and imidacloprid are generally cheaper. Um, the one of the issues that was raised by the CMA was the fact that um veterinary practices were quite heavily marking up parasiticides if they were not sold through the health care plans, which sort of helps to um um, argue. That the health care plans are very good value for money because there's so much cheaper than the alternatives that aren't provided through the health care plans.
But if you buy them through independent pharmacies with a written prescription, there are a lot cheaper. So that written prescription would cost money. It's usually about £28. That's what costed my practice. So there is an additional fee for prescription products. Um, in my view, it's absolutely.
11:02
11:02
11:03
Speaker 9
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Speaker 9
Thank you very much, Lord chair, thank you to our witnesses for being here. Um, I want to ask a bit about the prevalence of pet infections from parasites. So we've been given various figures. The group at Imperial College, which you're associated with, said the largest published survey of veterinary consultants identified fleas in 1 in 400 dogs and 1 in 85 cats, and ticks in 1 in 150 dogs and one in every 625 cats. On the other hand. Noah has told us that 1 in 4 cats have fleas and 1 in 6 dogs have fleas.
Um, so we've got very divergent views. So my first part of my question is, can you give us some insight into which of those estimates is more accurate?But importantly, if we changed from prophylactic to reactive prescription, presumably, or well, a question to you, would the flea and tick population in companion animals go up?So the fact that, um, you know, at the moment you. Rose said she doesn't treat her pets. Routinely. And they rarely, if ever, get fleas or ticks.
But maybe if everybody else stopped treating their pets routinely, the flea population would would blossom. So what is the best estimate of the prevalence and how would that prevalence change if we went from, uh. Phylactic reactive prescription to.
Um, so we've got very divergent views. So my first part of my question is, can you give us some insight into which of those estimates is more accurate?But importantly, if we changed from prophylactic to reactive prescription, presumably, or well, a question to you, would the flea and tick population in companion animals go up?So the fact that, um, you know, at the moment you. Rose said she doesn't treat her pets. Routinely. And they rarely, if ever, get fleas or ticks.
But maybe if everybody else stopped treating their pets routinely, the flea population would would blossom. So what is the best estimate of the prevalence and how would that prevalence change if we went from, uh. Phylactic reactive prescription to.
11:04
Speaker 2
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Speaker 2
I have those same figures that you just quoted. That was the, the best data that I could find. Which one?The 1 in 400 dogs. And, um, but of course that's against a background of us currently treating prophylactically. Um, so I don't think it's that straightforward in that the flea population waxes and wanes according to temperature. So we get some years that really warm. The fleas kind of go crazy. One of the arguments for using all year round flea treatment, would you get the same issue when you put your central heating on?So we probably will see more fleas.
But I think when I open the session talking about how we used to treat fleas, we didn't have terribly effective methods of treating them. We now have some really, really good products that if somebody comes in with a dog that's really hoochie in fleas, we can get rid of those really, quite, really fast. Compared with the products we used to be able to use to sort of sprays and things, I think there would have to be some increased awareness as to how you look for fleas. You know, I've got a black dog.
It's not that easy to spot fleas on them, but that can be part of what let's teach owners right from the beginning with puppy and kitten consultations. You know, instead of saying, and of course, you'll need to use this product every month, we teach them some skills to be able to recognize parasites in their pets, know when to come and see us, when we need to intervene. So it's a little bit of re-education, but I think that's really useful. And anything that encourages conversations with our clients is a good thing.
So the actual figures probably are somewhere between those, but they'll also wax and wane over the year. Different households, you know, if you've got half a dozen cats, a flea problem quite quickly is going to get significant in your house. Whereas if you've just got one dog, you might never see a flea from years to years. Um, I treat my dog once a year when in the tick season and that's, that's all I do. So, but she's a single dog, isn't in contact with other dogs.
That might be really different for other people in other situations.
But I think when I open the session talking about how we used to treat fleas, we didn't have terribly effective methods of treating them. We now have some really, really good products that if somebody comes in with a dog that's really hoochie in fleas, we can get rid of those really, quite, really fast. Compared with the products we used to be able to use to sort of sprays and things, I think there would have to be some increased awareness as to how you look for fleas. You know, I've got a black dog.
It's not that easy to spot fleas on them, but that can be part of what let's teach owners right from the beginning with puppy and kitten consultations. You know, instead of saying, and of course, you'll need to use this product every month, we teach them some skills to be able to recognize parasites in their pets, know when to come and see us, when we need to intervene. So it's a little bit of re-education, but I think that's really useful. And anything that encourages conversations with our clients is a good thing.
So the actual figures probably are somewhere between those, but they'll also wax and wane over the year. Different households, you know, if you've got half a dozen cats, a flea problem quite quickly is going to get significant in your house. Whereas if you've just got one dog, you might never see a flea from years to years. Um, I treat my dog once a year when in the tick season and that's, that's all I do. So, but she's a single dog, isn't in contact with other dogs.
That might be really different for other people in other situations.
11:07
Speaker 3
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Speaker 3
So looking at those studies that you mentioned, um, the, the first one with the much lower prevalence was a study from Sean Farrell at the University of Liverpool. So that looked at veterinary electronic health data. So they collect vets notes, um, across millions of practices. So I think that study had about 6 million cats and dogs in.
11:07
11:07
Speaker 3
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Speaker 3
So that's the figure of 1 in 400 cats and 1 in 85 dogs. So, um, a couple of things to say about that study. So every study will have pros and cons and drawbacks. Um, it's possible that that prevalence was slightly, um. Underestimated because not all pet owners are aware that their animals have fleas and there was no um, not all animals would have been checked for fleas. These were just routine consults. And if vets happened to identify fleas, they made a note of it.
Um, but on the other hand, you could say that animals are perhaps a little bit more likely to present at the vets if they have fleas and animals from the general population, because some people do take their pet to the vet if they have fleas, um, the, the other study, there's a bit more to say about it. That's the Abdullah study. It's from 2019. This is the one that's very often cited by industry and had a far higher prevalence than the study. It was 1 in 20 8% of cats apparently were reported to have fleas, and 14% of dogs.
That was a much smaller study. I think there were 800 cats and 600 dogs involved in that study. And in that study, they did get vets to check animals to do a sort of flea prevalence check. Um, but the there are some problems with that prevalence figure. So, um, the first issue is that there are actually no randomisation protocols in that study. They do say animals were randomised but the protocols are not described. And there was another study done a few years previously which used exactly the same methodology.
And they looked at ticks. And in that study they found a prevalence of 30% of dogs having ticks. And the authors of that study did explicitly say that their method of participant recruitment was likely to have inflated the prevalence values. And I've checked with the authors, it was exactly the same recruitment method. Um, and I actually, I worked in a practice that participated in that study and the instructions that filtered down to me as a practising vet were if you see a tick, collect it and fill in the form.
So there was no, um, there was no randomisation and I'm sure there was a quite a lot of selection bias in that study and I don't, I find that figure very difficult to square with what I see in practice. So 1 in 4 cats having fleas, I challenge anyone to go out and do a random flea comb on any cats they come across and find that 1 in 4 have fleas. In practice, it's much more normal. I would say. I've been in practice for 20 years around the country at sort of worst case scenario would be in a middle of summer, in a place that is prone to fleas, and you'd probably see a few fleas a week, but it's very normal in practice to go for weeks without seeing fleas.
I would just note that they say roughly 50% of owners are unaware that their pet has fleas. So yeah. Are missing some.
Um, but on the other hand, you could say that animals are perhaps a little bit more likely to present at the vets if they have fleas and animals from the general population, because some people do take their pet to the vet if they have fleas, um, the, the other study, there's a bit more to say about it. That's the Abdullah study. It's from 2019. This is the one that's very often cited by industry and had a far higher prevalence than the study. It was 1 in 20 8% of cats apparently were reported to have fleas, and 14% of dogs.
That was a much smaller study. I think there were 800 cats and 600 dogs involved in that study. And in that study, they did get vets to check animals to do a sort of flea prevalence check. Um, but the there are some problems with that prevalence figure. So, um, the first issue is that there are actually no randomisation protocols in that study. They do say animals were randomised but the protocols are not described. And there was another study done a few years previously which used exactly the same methodology.
And they looked at ticks. And in that study they found a prevalence of 30% of dogs having ticks. And the authors of that study did explicitly say that their method of participant recruitment was likely to have inflated the prevalence values. And I've checked with the authors, it was exactly the same recruitment method. Um, and I actually, I worked in a practice that participated in that study and the instructions that filtered down to me as a practising vet were if you see a tick, collect it and fill in the form.
So there was no, um, there was no randomisation and I'm sure there was a quite a lot of selection bias in that study and I don't, I find that figure very difficult to square with what I see in practice. So 1 in 4 cats having fleas, I challenge anyone to go out and do a random flea comb on any cats they come across and find that 1 in 4 have fleas. In practice, it's much more normal. I would say. I've been in practice for 20 years around the country at sort of worst case scenario would be in a middle of summer, in a place that is prone to fleas, and you'd probably see a few fleas a week, but it's very normal in practice to go for weeks without seeing fleas.
I would just note that they say roughly 50% of owners are unaware that their pet has fleas. So yeah. Are missing some.
11:10
11:10
Speaker 4
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Speaker 4
Yeah, we have no idea what the prevalence of fleas is, is the way I would put it. Um, the Abdullah study I would say was funded by industry and there are some severe defects in, in that, uh, one of the, one of my favourites was they specifically asked people not to count dogs who came in dogs and cats who came in with fleas, but they said doing do include free flea checks, which obviously is where people bring their dogs in for us. So yeah, there were biases in that study very much to increase the prevalence of fleas.
But the truth is, we absolutely don't know the prevalence of fleas. And it varies a lot from year to year. It varies from north to south, up and down the country probably varies from city to countryside as well.
But the truth is, we absolutely don't know the prevalence of fleas. And it varies a lot from year to year. It varies from north to south, up and down the country probably varies from city to countryside as well.
11:11
Speaker 9
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Speaker 9
If I may ask a supplementary question, that's very helpful answers to my main question. Do we have a similar degree of uncertainty about how many cases there are of humans?A contracting zoonotic diseases through companion animals?Because there's a whole, you know, VMD lists a whole lot of alarming things that you can catch from fleas and ticks. Um, yeah. Um, we have any idea how much of that comes from companion animals. What the prevalence.
11:11
Speaker 4
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Speaker 4
Is very little. Um, the, the main, um. Zoonosis from fleas is the Bartonella bacterium that I mentioned earlier. Um there hasn't been a huge study done in England in the US which has more fleas, especially in the southern states. Um there was a insurance data private. Well in America, so your workplace health insurance that their nearest equivalent to our NHS. Um the researchers looked at 280 million person years of data trying to find evidence of bartonellosis.
Um, I think the figures were about 45 cases per million, uh, of which two per million were serious enough for hospitalisation. The average hospitalisation time was three days. There were no fatalities. This is a very, very mild disease. In the vast majority of cases, the nearest data we have in the UK is from the UK Health and Safety Authority used to be Public Health England. Um they publish a zoonotic zoonosis report. They don't even include Bartonella because basically it's not either common or serious enough to be included.
And the NHS England. Um, publish, uh, basically lists of all the diagnoses of hospitalized patients. And over the period from 22 to 24, um, there were basically ten cases of Bartonella diagnosed in hospital a year in England. So what's that?Maybe 60 million people. So looking at 1 in 6,000,000 people, this is incredibly rare. And although there are case reports of people with severe other illnesses being badly affected by Bartonella, uh, it's not clear that you need to treat, uh, tens of millions of pets dozens of times a year in order to reduce that risk.
Um, I think the figures were about 45 cases per million, uh, of which two per million were serious enough for hospitalisation. The average hospitalisation time was three days. There were no fatalities. This is a very, very mild disease. In the vast majority of cases, the nearest data we have in the UK is from the UK Health and Safety Authority used to be Public Health England. Um they publish a zoonotic zoonosis report. They don't even include Bartonella because basically it's not either common or serious enough to be included.
And the NHS England. Um, publish, uh, basically lists of all the diagnoses of hospitalized patients. And over the period from 22 to 24, um, there were basically ten cases of Bartonella diagnosed in hospital a year in England. So what's that?Maybe 60 million people. So looking at 1 in 6,000,000 people, this is incredibly rare. And although there are case reports of people with severe other illnesses being badly affected by Bartonella, uh, it's not clear that you need to treat, uh, tens of millions of pets dozens of times a year in order to reduce that risk.
11:13
Speaker 3
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Speaker 3
If I can just add, um, what I find quite interesting about that NHS data is that they, they include diagnoses of bartonellosis, but they don't actually specify what kind of Bartonella it is. And there are other forms of Bartonella. And one of those interestingly is Bartonella Quintana, which also occurs in the UK, but that's not spread by fleas that spread by lice. So if we were to apply this logic to to kids, then we should be applying insecticides to our kids all year round to prevent a rare disease.
11:14
11:15
11:15
11:15
11:16
Speaker 9
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Speaker 9
Very quickly. In light of the shortness of time. You've talked about flea borne diseases and you mentioned Bartonella. Um, also VMD mentions Rickettsia mycoplasma dipylidium. So there are others, but I assume those are also equally rare. But I just wanted to check on tick borne diseases, particularly Lyme disease and tick borne viral enceph. Myelitis encephalitis. Uh, is there any evidence that humans contract Lyme disease or tick borne encephalitis from companion animals?
11:16
Speaker 4
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Speaker 4
As far as I'm aware, owning a dog. Um, it's you don't catch it off the tick, particularly the most common ticks in the UK. Sound Lord has taught me parasitology. So I will um. The the once, once a year, once a year they jump on an animal, have dinner, disappear off, jump on another animal a year later. So that's not a sort of procedure where you're likely to get illness. Having a dog does make you go places where you're more likely to pick up ticks from deer and sheep.
So there is a sort of risk association, but you're not getting it from your dog. So no, you don't generally get Lyme disease from your dog.
So there is a sort of risk association, but you're not getting it from your dog. So no, you don't generally get Lyme disease from your dog.
11:17
11:17
11:17
Speaker 3
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Speaker 3
I just wanted to speak to the question of whether we'd see an increase in diseases if we decreased our level of parasiticide use. Um, and my, my view is that we have an incredibly or extremely low occurrence of human zoonoses. As far as we know, all the data shows that the prevalence is extremely low. And we know that coverage of the pet population with Parasiticides, even though we are widely treating routinely, is not complete. So we don't have good data. But for argument's sake, if we say that roughly percent of pets are being treated routinely, if we had if we stopped that and just treated, um, reactively and we had a proportional increase of infestations in zoonoses, then arguably we would have a doubling proportional increase of the occurrence of those diseases, but doubling an incredibly rare disease still gives you an extremely rare prevalence of extremely low prevalence.
So um, yeah. And you would have an enormous decrease in pollution and human exposure to these chemicals. And in resistance risks.
So um, yeah. And you would have an enormous decrease in pollution and human exposure to these chemicals. And in resistance risks.
11:18
11:18
11:19
11:19
Speaker 5
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Speaker 5
Thanks very much. Could I just follow up, though, on the clinical, uh, prevalence or incidence in, in the pets themselves of these parasites, as you well know, I'm sure that generally it's more animals get parasite or quite a lot of animals are population will get parasites, but only a few of them will suffer clinically. Um, do we have any secular data?For example, on um flea allergic dermatitis in. Relation to the introduction of these as products, particularly in mitochondria and fipronil and and and during the time that has been used, has there been a diminution of those clinical presentations or do we have any data on that?
11:20
Speaker 2
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Speaker 2
I think there might be some stuff from organisations like Safenet. Um, I don't have it and we could have a look and see if we can find that for you. But I mean, Martin's right, if you're as old as us, um, you know, you would see a couple of consults every night that would flea allergic dermatitis. We would sell a lot of steroids and related products. We don't sell those at all anymore. But part of that is about the efficacy of the products we were using.
We didn't have great treatments. So even when we were treating, we weren't doing it very well. I think now, you know, if we we see those cases, which is actually rare to see them in the way we used to, it's very easy to treat them. We've got very effective, easy to give products we can give them in a variety of, of ways. So if you think you've got a compliance issue with a patient, it's very easy to administer the things themselves.
So I don't imagine we will drift back to the bad old days simply because we're not using these products all the time. Um, we would if we went back to using the same chemicals we were using, but I think we're in a much better position to be able to treat when we have to treat. But that doesn't mean we need to prevent in the way we have been doing.
We didn't have great treatments. So even when we were treating, we weren't doing it very well. I think now, you know, if we we see those cases, which is actually rare to see them in the way we used to, it's very easy to treat them. We've got very effective, easy to give products we can give them in a variety of, of ways. So if you think you've got a compliance issue with a patient, it's very easy to administer the things themselves.
So I don't imagine we will drift back to the bad old days simply because we're not using these products all the time. Um, we would if we went back to using the same chemicals we were using, but I think we're in a much better position to be able to treat when we have to treat. But that doesn't mean we need to prevent in the way we have been doing.
11:21
11:21
11:22
11:22
Speaker 4
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Speaker 4
Nobody in the UK monitors that, um, and I'm not sure anybody's really monitoring it. Uh, worldwide, there used to be a scheme for monitoring imidacloprid resistance. They didn't find any, but I don't know if that's still ongoing. There is very, very strong anecdotal view among the veterinary profession that is backed up by a survey that has been published that fipronil, I'll put it, lacks efficacy. That's not the same as there's definitely is resistance. I would also point out that resistance is the only isn't the only thing you've got to worry about.
Um, in say, cytostome in worms, in horses, it's been shown that if you very frequently worm, um the time after the wormer works, but at the time after the worms, until the eggs appear showing there's a new infestation greatly shortens. You're selecting the parasites just to be more efficient. Uh, even though they're not resistant, we might well be doing that with all the fleas and worms in this country. The way, the irresponsible way we're using parasites. Um, but again, there's no evidence of that because nobody looks.
Um, in say, cytostome in worms, in horses, it's been shown that if you very frequently worm, um the time after the wormer works, but at the time after the worms, until the eggs appear showing there's a new infestation greatly shortens. You're selecting the parasites just to be more efficient. Uh, even though they're not resistant, we might well be doing that with all the fleas and worms in this country. The way, the irresponsible way we're using parasites. Um, but again, there's no evidence of that because nobody looks.
11:23
11:23
Speaker 2
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Speaker 2
Yeah. There is some evidence that there may be some resistance to fipronil, but that it's very localized. It's not widespread problem. And it's unlikely to be a big issue. We don't have the data though. We need to record this. And this does come down to vets reporting. You know it as an adverse reaction that the product seems to not be working, but it is quite hard to judge because compliance is definitely an issue.
The person that comes in and says, you know, the fipronil is not working anymore. Well, how are they applying it?Are they using it all to on all their pets?Do the pets go to doggy daycare?What's going on there?So there's kind of a lot to unpick, but as a profession, certainly at BVA, we've been promoting it. If you think there's an issue with resistance, you shouldn't just be selling an alternative product because that's probably not what we don't want to be changing between products unless we've got good reason to be doing that.
Um, and we should be reporting that suspicion of, of any resistance.
The person that comes in and says, you know, the fipronil is not working anymore. Well, how are they applying it?Are they using it all to on all their pets?Do the pets go to doggy daycare?What's going on there?So there's kind of a lot to unpick, but as a profession, certainly at BVA, we've been promoting it. If you think there's an issue with resistance, you shouldn't just be selling an alternative product because that's probably not what we don't want to be changing between products unless we've got good reason to be doing that.
Um, and we should be reporting that suspicion of, of any resistance.
11:25
11:25
11:26
Speaker 4
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Speaker 4
Don't think anybody's looked to see if there's acquired resistance. There is huge variability in the natural resistance level. Yes. And I probably should clarify for fipronil. There's no question that there is our fipronil resistant strains of flea. They've been taken out of the the field out of the wild and put in labs and studied. But the thing is, if you have a cat and you have a resistant strain of flea and you treat it with fipronil, it doesn't get better.
You nip down the vets, you just get one of any of the other products and you clear it. So it's not so much. Is there resistance?It's is there resistance that's causing a problem across the country?And that's difficult to tell when you're using many different products.
You nip down the vets, you just get one of any of the other products and you clear it. So it's not so much. Is there resistance?It's is there resistance that's causing a problem across the country?And that's difficult to tell when you're using many different products.
11:27
11:27
11:27
Speaker 3
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Speaker 3
Um, I would just point out that I do see treatment failure for footprint and practice on quite a regular basis. So, um, my practice doesn't cell footprint, but a lot of people who bring their pets in, if they suspect a flea infestation or they have a skin condition, they would have tried it. Um, so that's not uncommon at all. And that's not just my experience. I think, as Martin said, um, this is very common knowledge in the veterinary profession. There is a study which showed very widespread treatment failure for fipronil.
So Cooper et al showed that 62% of cats that had been treated with fipronil, that presented at a veterinary practice still had fleas. And 45% of dogs treated with footprint still had fleas. Um, I think there's every reason to think that resistance might be out there. We know that resistance has developed to fleas and fleas to other parasiticides or organophosphates carbamates pyrethroids. As Martin said, resistant strains have been demonstrated in the lab. There's just no active surveillance. So without looking, we can't know what level of resistance is out there.
And regulators at the moment depend on passive pharmacovigilance. So they rely on the end user to report treatment failure. Um, and as far as I know, they've not flagged up in issues, which to me shows that that system is not working because we know treatment failures out there, either it's not being reported or it's not being flagged up by the system. But this absolutely is a priority for research. We should absolutely be looking at this. And it is important because resistance, I think, drives increased parasiticide use.
So if you have a resistant infestation, you'll be treating for longer. You'll be using more products. They're more likely to spread it to, to other animals. And it also, I think, drives the perception that, um, flea infestations are difficult to resolve. Um, which fuels this narrative that we, they should be prevented at any cost. And that routine prophylaxis is appropriate. Thank you.
So Cooper et al showed that 62% of cats that had been treated with fipronil, that presented at a veterinary practice still had fleas. And 45% of dogs treated with footprint still had fleas. Um, I think there's every reason to think that resistance might be out there. We know that resistance has developed to fleas and fleas to other parasiticides or organophosphates carbamates pyrethroids. As Martin said, resistant strains have been demonstrated in the lab. There's just no active surveillance. So without looking, we can't know what level of resistance is out there.
And regulators at the moment depend on passive pharmacovigilance. So they rely on the end user to report treatment failure. Um, and as far as I know, they've not flagged up in issues, which to me shows that that system is not working because we know treatment failures out there, either it's not being reported or it's not being flagged up by the system. But this absolutely is a priority for research. We should absolutely be looking at this. And it is important because resistance, I think, drives increased parasiticide use.
So if you have a resistant infestation, you'll be treating for longer. You'll be using more products. They're more likely to spread it to, to other animals. And it also, I think, drives the perception that, um, flea infestations are difficult to resolve. Um, which fuels this narrative that we, they should be prevented at any cost. And that routine prophylaxis is appropriate. Thank you.
11:30
11:30
Speaker 5
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Speaker 5
Thanks chair. Um yeah. The next question is about awareness. Guidance, the advice that's available to pet owners. The VMD have launched an awareness campaign about appropriate usage. We've had a bit of discussion about this earlier, but do you think the advice available to pet owners is is adequate?Do you think the the advice on packaging, given that a significant proportion of pet owners will buy over the counter, so is the advice given with the products on the on the products adequate?And particularly one example that we've already been made aware of by others is the don't let your dog go swimming for two days after treatment, which seems to be very inadequate.
So could you comment about the advice available to pet owners?
So could you comment about the advice available to pet owners?
11:31
11:31
Speaker 2
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Speaker 2
The aim behind it, but yeah, we have the same concerns that you do about some of the advice. And, you know, it seems to not go far enough. I mean, I think dogs having spot on products shouldn't swim at all. You know, if your dog swims or it's bath regularly or something like that, you shouldn't be using a spot on product. And VMD have obviously stopped short of saying that. And there's also inconsistency in some of the messaging we've seen.
Some of it is two days. Some is four days. Um, it's really variable. And the scientific evidence suggests we'd have washed off, you know, beyond way beyond two and four days. Um, there's more that could be done and it's coming back to a little bit to what Rose was referring to about, you know, how independent of BMD of the drug companies, you know, if they're trying to support everybody's products, then that's not independent enough. They, they need to be able to give independent advice that is correct across all the products.
And then the manufacturers need to be labelling things accordingly. I think there could be much more visual labelling, you know, that do not use this if your dog swims, you know, if you've got swimming dog and a big red cross through it. So I think more could be done. And you know, it's been based on the data sheet advice and it probably needs to be more independent than that. The data sheets themselves. I mean, how many of us read a whole data sheet when we take a medication or use one for our pets?You the highlights of that data sheet need to be in a really usable, accessible way.
You know, that's easy for everybody to read. And even when people are certainly at the moment, we've got GSL products and people are making those choices themselves. It needs to be really clear what products are appropriate for their pet and what are ones that aren't.
Some of it is two days. Some is four days. Um, it's really variable. And the scientific evidence suggests we'd have washed off, you know, beyond way beyond two and four days. Um, there's more that could be done and it's coming back to a little bit to what Rose was referring to about, you know, how independent of BMD of the drug companies, you know, if they're trying to support everybody's products, then that's not independent enough. They, they need to be able to give independent advice that is correct across all the products.
And then the manufacturers need to be labelling things accordingly. I think there could be much more visual labelling, you know, that do not use this if your dog swims, you know, if you've got swimming dog and a big red cross through it. So I think more could be done. And you know, it's been based on the data sheet advice and it probably needs to be more independent than that. The data sheets themselves. I mean, how many of us read a whole data sheet when we take a medication or use one for our pets?You the highlights of that data sheet need to be in a really usable, accessible way.
You know, that's easy for everybody to read. And even when people are certainly at the moment, we've got GSL products and people are making those choices themselves. It needs to be really clear what products are appropriate for their pet and what are ones that aren't.
11:33
Speaker 3
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Speaker 3
Yeah. So our research, which is the VMD research, did show that these products are washing off through correct use. And as I said before, there's actually no evidence that significant amounts are going, um, getting into waterways through incorrect applications. So, um, the sort of new campaign that they've launched and also the, um, proposal to, to change the distribution category does seem to be based on the premise that if we provide advice and if the products are applied correctly, then we'll resolve the issue. But I don't think that's an evidence based assumption.
Um, in fact, on their recent campaign, they actually state that the products are safe and effective when used correctly. And that's, that's just not true. The products are not safe when used correctly. Their own research shows that they're not safe for the environment. They're very serious questions about their safety to, to human health or potential um, risk to human health. And there are concerns around resistance. So I would actually argue that's, that's quite misleading communication.
It's misleading the public about the safety of the products.
Um, in fact, on their recent campaign, they actually state that the products are safe and effective when used correctly. And that's, that's just not true. The products are not safe when used correctly. Their own research shows that they're not safe for the environment. They're very serious questions about their safety to, to human health or potential um, risk to human health. And there are concerns around resistance. So I would actually argue that's, that's quite misleading communication.
It's misleading the public about the safety of the products.
11:34
11:35
11:35
Speaker 12
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Speaker 12
Focus again on human health, not as induced by the parasites, but by the treatments, this doesn't seem to be terribly conclusive evidence. So can you say what assessments have been made of the human health risk of pet parasite medications, particularly exposure in the home, and I would therefore include the waterways, drinking water, and also, of course, in the workplace for the the the vet themselves.
11:35
Speaker 3
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Speaker 3
Yes. I would say that the, um, this whole field is quite poorly understood. And the research on human exposure and health risks from pet parasiticides is quite limited. And it is quite inferential. Um, we know that these chemicals are selective for invertebrates. They are insecticides, but they can have effects on people. So they are both fipronil and imidacloprid are classified as moderately hazardous to human health by the World Health Organization. They are examples of fatalities from poisoning from from these insecticides.
But the real concern is not so much obvious poisoning, um, but more subtle long term health effects through prolonged exposure. Um, so we know that they disseminate widely in the home after Spartans are applied to pets. Um, we, my, our research group at Imperial recently did a study looking at dust and mop water in the home. And we showed high levels of imidacloprid in that in the homes of treated pets. Um, so we know that residues, um, we know from our previous research that residues are constantly present on the, the hands of pet owners for weeks after applying the product.
So we know that a. Long term skin exposure is occurring. And there are very few studies looking at internal absorption. So seeing how much actually gets absorbed into the system and what the potential impacts of that might be. Um, but there are emerging concerns around these chemicals. It takes a very long time, quite often for the full sort of implications for any sort of hazardous chemical to be fully understood, not just the environmental risks, but also the human health risks.
And it's very difficult to fully assess their risks in any sort of risk assessment. But there are there is new evidence that's coming through, um, regarding these, these chemicals. So, um, one particular concern is the potential to act as endocrine disrupting chemicals. So these are chemicals that can affect hormone levels in the body. And they can have effects even at extremely low doses and potentially affect things like fertility and neurodevelopment. Um, we know well the um. Fipronil and its toxic breakdown product footprint or sulphone have been identified as potential thyroid disrupting chemicals.
So, um, one particular concern is around pregnancy and early life exposure. So we know that fetal neurodevelopment is extremely sensitive to thyroid hormone disruption at critical periods of development. And there is a study which um, found. That, uh, for. General exposure in mothers was correlated to lower levels of certain hormones in newborns and also with lower Apgar scores, which is a standard measure of newborn condition. Exposure sources weren't investigated in that study. They don't know where the footprint was coming from, but there was actually a report on fipronil health risks from California's Department of Pesticide Regulation.
But the real concern is not so much obvious poisoning, um, but more subtle long term health effects through prolonged exposure. Um, so we know that they disseminate widely in the home after Spartans are applied to pets. Um, we, my, our research group at Imperial recently did a study looking at dust and mop water in the home. And we showed high levels of imidacloprid in that in the homes of treated pets. Um, so we know that residues, um, we know from our previous research that residues are constantly present on the, the hands of pet owners for weeks after applying the product.
So we know that a. Long term skin exposure is occurring. And there are very few studies looking at internal absorption. So seeing how much actually gets absorbed into the system and what the potential impacts of that might be. Um, but there are emerging concerns around these chemicals. It takes a very long time, quite often for the full sort of implications for any sort of hazardous chemical to be fully understood, not just the environmental risks, but also the human health risks.
And it's very difficult to fully assess their risks in any sort of risk assessment. But there are there is new evidence that's coming through, um, regarding these, these chemicals. So, um, one particular concern is the potential to act as endocrine disrupting chemicals. So these are chemicals that can affect hormone levels in the body. And they can have effects even at extremely low doses and potentially affect things like fertility and neurodevelopment. Um, we know well the um. Fipronil and its toxic breakdown product footprint or sulphone have been identified as potential thyroid disrupting chemicals.
So, um, one particular concern is around pregnancy and early life exposure. So we know that fetal neurodevelopment is extremely sensitive to thyroid hormone disruption at critical periods of development. And there is a study which um, found. That, uh, for. General exposure in mothers was correlated to lower levels of certain hormones in newborns and also with lower Apgar scores, which is a standard measure of newborn condition. Exposure sources weren't investigated in that study. They don't know where the footprint was coming from, but there was actually a report on fipronil health risks from California's Department of Pesticide Regulation.
11:38
11:38
Speaker 3
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Speaker 3
Well, yeah. It's a correlation. And also the exposure sources weren't identified. But there was a report from the California Department of Pesticide Regulation a few years ago, which looked at health risks from fipronil. They found negligible health risks from dietary exposure. But they did find a potential risk through exposure to flea products, particularly sprays and spot ons to pitch owners and also children, and also to occupational users. So in that study, they looked at groomers.
They didn't look at vets. Um, I'm not aware of any um. User safety assessments for the products that have actually done occupational exposures for vets, vets. I think the exposure is likely to be quite similar to groomers. We can easily touch ten, 20, 30 animals a day. The only exposure assessment I could find in the veterinary literature was an assessment for fipronil based product. Um, and that was for groomers. And the assumption in that exposure assessment was that basically PPE was worn.
So it included gloves and protective clothing. Time, the user safety risk assessments are quite opaque, a lot of detail, um, is not available to the public. So it's quite difficult to see what sort of risk assessments have been done.
They didn't look at vets. Um, I'm not aware of any um. User safety assessments for the products that have actually done occupational exposures for vets, vets. I think the exposure is likely to be quite similar to groomers. We can easily touch ten, 20, 30 animals a day. The only exposure assessment I could find in the veterinary literature was an assessment for fipronil based product. Um, and that was for groomers. And the assumption in that exposure assessment was that basically PPE was worn.
So it included gloves and protective clothing. Time, the user safety risk assessments are quite opaque, a lot of detail, um, is not available to the public. So it's quite difficult to see what sort of risk assessments have been done.
11:40
Speaker 12
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Speaker 12
It would be helpful if you give us in writing afterwards the the WHO references why they consider it moderately hazardous. And indeed all the references. So we can have a look. Could I just um we did have. Some evidence um about the possibility of autism and Johnson instant having heard this evidence, wrote to us and said no, no, no, no such thing. Now, I know autism has many fathers, but and um, I imagine this was a correlation again, if, if anything.
But have you heard anything about that.
But have you heard anything about that.
11:41
Speaker 3
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Speaker 3
Um I can respond to that. So um there are a couple of studies there. Not many, but there are a couple of studies that have looked at this and have found some potentially concerning results. So there was a study from 2014 which looked at, um, maternally reported use of imidacloprid spot-on. And they found that mothers of children with autism spectrum disorder were more likely, slightly more likely, not enormously more, but there was a slightly increased odds of them having used imidacloprid when they were pregnant.
Um, and that um, association strengthened the likelihood of them having the children developing that um issue. Were more likely if they'd used the product very, very regularly. Um and there was another study from last year, I think by Goodrich which looked at um flea treatment exposure in the home. And they, I can't remember the details of that study, but they did find an association between. correlation again. Yes, a correlation between um, flea treatment exposure during pregnancy and early life.
And I think they, their, the significant findings were for the older products. So it was things like um powders and shampoos. Some of the older um parasiticides that were associated with an increased risk of um neurodevelopmental or that was neuro cognitive issues in children that had, um, autism spectrum disorder, I think it wasn't with autism itself, but issues in children who had autism.
Um, and that um, association strengthened the likelihood of them having the children developing that um issue. Were more likely if they'd used the product very, very regularly. Um and there was another study from last year, I think by Goodrich which looked at um flea treatment exposure in the home. And they, I can't remember the details of that study, but they did find an association between. correlation again. Yes, a correlation between um, flea treatment exposure during pregnancy and early life.
And I think they, their, the significant findings were for the older products. So it was things like um powders and shampoos. Some of the older um parasiticides that were associated with an increased risk of um neurodevelopmental or that was neuro cognitive issues in children that had, um, autism spectrum disorder, I think it wasn't with autism itself, but issues in children who had autism.
11:42
11:42
Speaker 2
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Speaker 2
Yeah, maybe just on that point. I mean, when we've gone through this, we've ended up with a long, long list of research requests, things we'd like to be looked into, you know, and there's masses of it. But the reality is that research like that doesn't always get funding. And it is a very broad, but it feels like, you know, the drug companies have been told that until there is really good data, these products are fine to use. And I would like us to flip that around.
You know, I think we need to have a confidence that these products are safe, you know, within a reasonable limits if we're going to use them. And I think vets are very naively, you know, we all knew neonicotinoids were an issue for bees, but we kind of thought putting these products on dogs was okay. And the reason we thought that is we had confidence that these products were safe. And I think we've learned that they're not. And that's what we need to flip around because I don't think we're ever going to have all the evidence to prove that the problematic across humans and environment.
But we need to take a precautionary approach. And that needs to start with the pharmaceutical companies showing us that these products within reasonable limits are actually safe, and then we can use them with confidence because we are using them in people's homes, and we're using them with pets that are increasingly very close to physically. And that's an issue.
You know, I think we need to have a confidence that these products are safe, you know, within a reasonable limits if we're going to use them. And I think vets are very naively, you know, we all knew neonicotinoids were an issue for bees, but we kind of thought putting these products on dogs was okay. And the reason we thought that is we had confidence that these products were safe. And I think we've learned that they're not. And that's what we need to flip around because I don't think we're ever going to have all the evidence to prove that the problematic across humans and environment.
But we need to take a precautionary approach. And that needs to start with the pharmaceutical companies showing us that these products within reasonable limits are actually safe, and then we can use them with confidence because we are using them in people's homes, and we're using them with pets that are increasingly very close to physically. And that's an issue.
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11:44
Speaker 7
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Speaker 7
My question actually, um, follows on quite nicely from your last comment that really these are um insecticides. So the question I really want to ask you is about the main gaps that you think need to be addressed to determine the comparative benefits of these products to animal and human health versus the potential cost to the environment. And how do we weigh those against the benefits from using these products for animal and human health?
11:44
Speaker 4
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Speaker 4
Well, it is one of these apples and oranges questions. Sorry. We're trying to stop animals getting bad flea infestations and such like. And you're balancing that against not just the natural environment harms, but also the household environment, as Rose has just explained, we're sort of, if you treat your dogs with these things, you're living in a sea of pesticides. Amount of resistance and maybe just making the parasites more efficient. Um, there are all medicines have adverse effects on dogs.
That's unnecessary. And all of those are unquantified. I'm afraid. Where where do you start?Yeah. Let's use that.
That's unnecessary. And all of those are unquantified. I'm afraid. Where where do you start?Yeah. Let's use that.
11:46
11:46
Speaker 3
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Speaker 3
I can expand a little bit on, on that. And we know that they are very toxic, they are very persistent, and we are applying them in quite large quantities, but we don't really know where they're going. I would also say that pet wormers are have been a bit neglected. We use it as a wormer all the time. So, um, I would very much like to know what's happening with that. Wishlist of um, things I would like to research.
They are important products. Um, and then of course, human exposure and health risks, as I said, I think that's, that's very important to look into. One area I think does need to be looked at is lungworm. So that's a research gap.
They are important products. Um, and then of course, human exposure and health risks, as I said, I think that's, that's very important to look into. One area I think does need to be looked at is lungworm. So that's a research gap.
11:47
Speaker 2
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Speaker 2
On a positive note, if we started prescribing in a different way. And you know, whether a product seemed not to work. You know, we don't know which pets are most susceptible, which environments they live in, necessarily what time of year it is. One of the issues is, I mean, you're seeing this, it's an argument between the drug companies and the environmental groups. So some genuinely, you know, independent research that gives us the facts.
11:47
11:47
Speaker 2
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Speaker 2
So there's Vet Compass, which is run by the Royal College of Veterinary Surgeons and the Saxonette, which came out of the University of Liverpool. And there's, you know, six large veterinary corporates. And of course everyone's got a computer system now. And I think it at a practice level is probably the best way of doing that. We've not been able to give you definitive answers on that. You know, that that information should be out there because it needs to be our starting point with this.
11:48
11:48
11:48
Speaker 4
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Speaker 4
Um well it started off as an antibiotic amnesty where practices and some other organisations advertised to the public to say bring your medicines, especially antibiotics back to us. Um and one of the other recommendations I'm sure we'd all say is there should be some scheme for getting rid of these things. But there isn't a veterinary equivalent.
09:59
Speaker 2
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Speaker 2
Things that they've sold. But there's not. I would also say the handling and disposal information around, particularly some of the Spartans, has been really variable. And, you know, you hear dreadful anecdotal things that people washing goats, you know, spot on containers and things. So that needs to be better too, needs to be easier for people.
09:59
09:59
Speaker 2
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Speaker 2
I think there is, but I think we could change the emphasis. So, um, most people who get a puppy and kitten will come into a vet practice and have a consultation with the veterinary nurse, maybe see a vet. And at the moment that will have been talking through which products they might use as preventative. So we need to change that conversation. If you're doing it with a new puppy, sometimes you've you've got a new owner or you've got an owner who's not a puppy for 15 years.
So they're keen to learn. And that learning needs to be different. It doesn't need to be. Or you can use a spot or a tablet. Let's have a conversation about how you recognise these parasites, what you would do if you saw them. You know which products you should be thinking about. So I think we can change those conversations at a practice level.
So they're keen to learn. And that learning needs to be different. It doesn't need to be. Or you can use a spot or a tablet. Let's have a conversation about how you recognise these parasites, what you would do if you saw them. You know which products you should be thinking about. So I think we can change those conversations at a practice level.
10:01
10:01
Speaker 5
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Speaker 5
A quick one about I was disturbed at what you said, Rose, about not understanding the environmental damage. Could you maybe send us a note or any evidence you have for that?You had a bit of anecdotal, but I think that's a bit worrying since Skps have some meant to have some sort of expertise in terms of prescribing, dispensing drugs, like.
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10:02
Speaker 1
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Speaker 1
Thank you. So I'm very sorry that we're, uh, over time, but it's been a really useful session. I think raising awareness of the harm, the enormous harm, I think is what we're hearing. These chemicals in the wider environment and with implications for the food chain as well, is something that we we need to increase awareness of. And I think that that is, uh, that could be a very useful outcome of this. And then hopefully that will lead to better prevention of the issues around fleas and ticks.
Also, thank you all very much. It's been very reassuring hearing from the veterinary professions. Thank you, thank you. And with that.
Also, thank you all very much. It's been very reassuring hearing from the veterinary professions. Thank you, thank you. And with that.
10:03