Veterinary Medicines (Amendment etc.) Regulations 2024

Baroness Bennett of Manor Castle Excerpts

Thursday 18th April 2024 Grand Committee

[Baroness McIntosh of Pickering (Con)]

My Lords, I thank my noble friend for presenting the regulations before us this afternoon, which are very welcome. I have one issue to raise with him. I declare my interest as an honorary associate of the British Veterinary Association.

The British Veterinary Association’s response to the original consultation touches a little on the demands being made on veterinary practices in the context of the regulations, which the noble Lord, Lord Trees, referred to. It responded on the requirement to provide information that, essentially, the Government should be mindful of the pressures on smaller practices that have limited administrative resources and that while vets are willing and happy to provide information, the cost and administrative burdens need to be taken into account. I hope that is something that my noble friend will give me some reassurance on in the Committee this afternoon. We learn from paragraphs 12.1 of the Explanatory Memorandum that the annual net direct cost to business of the regulations is expected to be £2.5 million. Paragraph 12.3 states that as the level of impact is less than £5 million, it was agreed to carry out a de minimis assessment not a full impact assessment. What assessment has the department made of the pressure on small practices, in particular, in applying the new provisions in the regulations? Who will end up paying the ultimate price for this?

I am grateful to the Secondary Legislation Scrutiny Committee for its analysis of the regulations. It also refers to the fact that the direct cost to business will be £2.5 million per year and asks whether this will lead to higher prices for veterinary medicines. What impact do my noble friend and the department think this will have on the end user, in particular, either the small pet owner or, more specifically, the farmer, bearing in mind that farmers, particularly since 2001, have faced an increase in other on-costs? They are under great pressure, and many of them, particularly smaller and mixed farmers and those who specialise in livestock production, are going to find it very difficult to fund this.

We are speaking at a very happy time of year when we see lots of lambs and calves being born, but there are veterinary costs associated with that. I am mindful of this, having recently sat next to a local farmer who called out the vet for a stillborn calf and obviously had to pay all the veterinary costs. The mother survived, but they lost the calf. I would be grateful if my noble friend could respond on those two specific points: whether small practices have been considered when it comes to bearing the costs and whether farmers are expected to carry the additional cost of £2.5 million per year going forward.

[Baroness Bennett of Manor Castle (GP)]

My Lords, in rising fairly briefly, I should declare the support I receive from the British Society for Antimicrobial Chemotherapy, as set out in the register. I join the noble Lord, Lord Trees, in welcoming further restrictions on antibiotic use in that context. I do a great deal of work with BSAC on antimicrobial resistance. I remain concerned about any exception for prophylactic use. We are talking in a context where factory farming organisations have said that they need to keep using antibiotics because their operations cannot operate without them. I have a direct question for the Minister. We are coming up to the refresh of the national action plan on antimicrobial resistance after its five years in operation since 2019. Are the Government prepared and thinking about how, working with that plan, there may need to be further restrictions, particularly on the use of antibiotics in veterinary medicine in the light of the threat that antimicrobial resistance presents? This is reflected in the fact that the General Assembly is having a high-level meeting in September on antimicrobial resistance. It is a huge global issue. I acknowledge that the UK has been leading on this. None the less, it is still very clear that we are not anywhere near where we need to be to save the antibiotics that we desperately need for human health. We have to approach all this from a One Health perspective thinking of human, animal and environmental health all going together.

In the light of that, there are a couple of things that I particularly want to raise. One is anthelmintics and their impact on environmental health, particularly insect life in streams and rivers and indeed in the soil, dung beetles being the obvious example here. I do not know whether the Minister will be able to comment on any steps that the Government are planning to take to address that One Health issue.

The other issue that is fast rising up the agenda is spot on flea and tick treatments, which are a significant source of pesticide pollution in rivers. I can cite a recent study from the University of Sussex and Imperial College published in Science of The Total Environment, looking in particular at fipronil and imidacloprid—forgive my pronunciation—both of which have been banned from outdoor agriculture but are still used in spot on flea and tick treatments. This study and others found significant wastewater that had passed through sewage treatment works and was extremely harmful to wildlife; these are potent neurotoxic insecticides. One study found fipronil in 98% and the other chemical in 66% of fresh water. I am aware that the British Medical Association has brought out some new guidelines and is seeking at least to reduce somewhat the usage of these treatments but, given that we have about 2.2 million dogs and cats in the UK, are the Government really looking into this?

Finally, I also reflect the concern expressed by the noble Lord, Lord Trees. We all know now that we are in a global market for everything through the internet. Are the Government looking at and monitoring the extent to which veterinary medicines that should not come into the UK, or should not be used without proper supervision in the UK, are coming in through that potential internet back door?

[Lord de Clifford (CB)]

I draw your Lordships’ attention to my entry in the register, as I work for a large independent vet group with both companion animal and production animal vets. The vets I work with generally welcome this timely update of the Veterinary Medicines Regulations. They acknowledge that they have been listened too during the consultation process and that changes have been made to update the regulations. Some are disappointed that the regulations have moved further away from the EU regulations. Others have commented that, although the EU regulations appear to be more restrictive, they will be interpreted in very different ways over the 27 countries, and we would have interpreted them in some ways, too.

Some have also commented that we have possibly missed an opportunity to update the regulations with regard to the impact of drugs on the environment, to echo the noble Baroness, Lady Bennett. That refers not only to the relationships between the individual vets prescribing the drugs but to the end-user of the drug and how this impacts on the environment. I reiterate the comments regarding spot on treatments and the result in watercourses. I will not try to pronounce the names of the drugs.

Concern remains regarding the amendment to paragraph 19 on the prescribing of medical products contained within feeds, which the noble Lord, Lord Trees, mentioned. The regulation states that

“the time between a prescription being issued and the course of treatment starting must be no more than five working days”.

This has been changed from the original regulation, which is appreciated, but there is still concern that manufacturers have no control over when the treatment starts, and the logistical challenges that the noble Lord, Lord Trees, mentioned of manufacturing feedstuffs, transporting them to the farms and feeding them to the animals. It is in farmers’ interests to feed this medicated feed to their animals as quickly as possible to treat the respective infection, but it seems unreasonable to create a situation where a manufacturer of feeds could be in breach of the regulations simply because a feed has not been fed to the animal within five working days. A feed manufacturer should certainly be held to account if a feed has not been distributed to the farmer within five working days. Therefore, could the Minister relook at amending the wording to say, for example, “distributed to final location” or “left the manufacturing premises within five working days”?

The second area of concern is new paragraph 7A, which relates to

“Duties in relation to prescribing of antibiotic veterinary medicinal products”


for prophylactic purpose. For some, the wording of this new paragraph does not go far enough; they would have liked a total ban of the prescribing of antibiotics. I know from discussions that other veterinary surgeons in the production animal sector accept that the wording is reasonable in this new paragraph to protect animal health and welfare, but concerns have been raised about how it will be interpreted and set out in the guidelines that will follow the implementation of this statutory instrument, with special reference to the words “exceptional circumstances” and what will be allowed. There are many interpretations of what “exceptional” means, both by individuals and by organisations. This could lead to veterinary surgeons breaking regulations when all they are trying to do is protect animal health and welfare and comply with their professional code of conduct.