NOAH represents the manufacturers of animal medicines in the UK. NOAH's 34 corporate members supply approximately 95 per cent of all the animal medicines sold in the UK, and an even larger share of those sold for use on farm. Thus we inevitably regard ourselves as part of the Animal Welfare sector, taking a particular interest in the livestock sector, which currently takes about 50 per cent by value of the animal medicines sold in the UK.

  The British countryside is the product of 10,000 years of farming, and current conventional farming techniques produce affordable, high quality food whilst also minimising the negative impact on the environment. Conventional farming methods were developed as a way to solve the problems of earlier farming generations, but now many of these practices may be rejected in favour of "organic" production.

  While we have no objection to any farmer choosing to farm in a particular way (laws and standards permitting) we are most concerned that some proponents of organic farming tend to promote themselves by attacking the conventional 97 per cent of farmers—accusing them of abusing animals, poisoning consumers and the environment.

  Organic farming is widely perceived to be a "Good Thing" and it may be predicted that the majority of those responding to your enquiry will be supporters of "Alternative" agriculture who will urge that organic farming should be given greater political and financial support. We beg to differ, and to suggest that in four important ways those promoting organic farming have the potential to do enormous damage—indeed much damage may have been done already:

(1)  Public confidence in farming and in the process of regulation as laid down by Parliament has been undermined.

(2)  Animal health and welfare could be jeopardised by restrictions on medicine usage

(3)  Misleading the public with claims that organic food is "healthier", tastes better, is better for the environment.

(4)  Sustainability and the ability to feed future generations.

  (Some of the information in this submission is based on quotes from research—more details can be found in Annex 1).

1.  PUBLIC CONFIDENCE

  The last decade, or more, has been notable for a change in public attitude to farmers and farming—farmers are no longer seen as providers of the food we need to survive, but as rapists of the countryside—destroying the environment, poisoning wildlife and people, abusing their animals—and all for "profit". It is no coincidence that this is the message, the "knocking copy", which has been used by organic proponents such as the Soil Association to promote their method of farming, (the fact that organic farmers also make a profit is seldom mentioned, although for many of the system's newest recruits it is a major attraction).

  Organic organisations have been particularly harsh in their criticism of agricultural inputs: agrochemicals, fertilisers and animal medicine. Such criticism ignores the stringent controls required under EU and UK law, and, in the process, public distrust of science and of government regulation has also grown.

  For over thirty years Animal Medicines have been regulated, under laws first laid down by the Callaghan Government's Medicines Act 1968. This law, and its subsequent updating by UK and EU law, requires a Medicine to be of high quality, effective and safe to animals, users, the environment and the consumer. Equivalent laws apply to crop chemicals. However, organic organisations prefer to pick and choose which products may be used—by implication rejecting the systems of public protection laid down by parliament and the expertise of the officials and scientists appointed, under law, to administer them.

  The simple message of organic organisations is that only they know best, and in so doing they happily and consciously denigrate the work and ethics of the vast majority of decent farmers and government employees.

  The current crisis of confidence in farming and Regulation is clear evidence of the success of organic publicists.

2.  ANIMAL HEALTH AND WELFARE

  Veterinary treatment in organic systems raises some serious animal welfare concerns.

  Firstly the use of unregulated homeopathic and herbal remedies, as opposed to strictly regulated conventional animal medicines, raises questions over the safety and efficacy of the product and its likely effects on the animal and the consumer of the animal treated. Unlike regulated animal medicines, there is no system for setting withdrawal periods for unlicensed homeopathic, herbal or other "alternative" remedies.

  The requirement in EU and UK Organic regulation to automatically double withdrawal periods for animal medicines is illogical, unscientific and a potential threat to animal welfare. MRLs and withdrawal periods for licensed medicines are based on rigorous, independent, international scientific standards incorporating massive safety factors. There is no logic to a "blanket" doubling which takes no account of the properties of the individual product. Such additional delay could prompt a farmer to withhold treatment of an animal near to market (or to cheat).

  The organic insistence on using medicines therapeutically (as opposed to preventatives treatments), means that the animal has to get sick and suffer before it is treated, whereas preventative medicines would have prevented the suffering from happening at all. While symptoms develop there is also an increased risk of the sick animal passing infection to its fellows, further increasing suffering and increasing the total volume of medicines used. (See Annex 1(8.8)).

  The banning of genetic modification in any form by the Soil Association raises serious concerns over the availability of medicines to treat animals. Many veterinary medicines today have biotechnology somewhere in their parentage—if not in the active ingredient, then in the excipients. The use of biotechnology in veterinary medicines allows improvements to existing products, for example, vaccines, produced with the techniques of biotechnology, which can replace chemical treatments for internal and external parasites, offer considerable opportunities for environmental and operator safety and the reduction of residues. By banning GMO's in any form farmers and vets are being denied the benefits of modern medicine developed through biotechnology.

  The EU, however, recognises the importance of genetic modification in the production of veterinary medicines and therefore has excluded animal medicines from the ban on GMs in their regulations.

3.  MISLEADING THE PUBLIC

  Organic proponents claim that organic food is healthier, tastes better and is better for the environment. (Annex 1[1]) A MORI survey for the Soil Association (June 1999) showed that consumers buy organic food because they believe it to be healthier, free of chemicals, better tasting, GM free and better for the environment and animal welfare and that half of those did so because they believed it to be safe and healthy.

  There is no conclusive evidence to support these claims, the organic movement has been further misleading the public by claiming an exclusivity of virtue on these areas.

  Scientific evidence suggests that organic food is no more nutritious or better tasting than conventionally produced food and variations depend more on other factors such as soil type and freshness of the produce. (Annex 1[2][5]).

  The safety of organic food is also questionable—recently there have been concerns over the use of animal manure which can lead to increased risk of E. coli 0157. Where chemical methods are not used to treat pests and diseases, plants under attack produce their own toxins which may themselves be harmful to humans. (Annex 1[3]).

  The safety of unlicensed and untested herbal and homeopathic remedies, listed for organic farming use, is questionable as they do not comply with EU or UK animal medicine legislation which is designed to protect consumers, animal users and the environment.

  While in general fewer agrochemicals are used in organic farming some forms of pesticide are used and over 30 additives are allowed.

  Imported organic food (70 per cent of organic food in the UK) may not be GM free as the standards of organic produce vary from country to country. (Annex 1[6.1])

  Not only can the claims not be applied to all organic farms, but equally, many conventional farms can show the same benefits, but unburdened by dogma.

  Claims that organic farming is better for the environment than conventional farming is not necessarily true. While birds and wildlife are a valued adjunct to organic farming, the use of similar management techniques on conventional farms can lead to the same benefits. The more extensive methods of organic farming means it requires more land to produce a given amount of food than a conventional farm. Thus, to institute organic farming countrywide to provide the required amounts of food, a large amount of wilderness, hedges and woodland would have to be utilised. This questions the sustainability of organic farming. (Annex 1 [7])

4.  SUSTAINABILITY

  The fundamental principles of sustainability are, we believe, clear, and may be summed up as the careful use of all resources, and in particular on non-renewable resources; for agriculture this includes both on-farm resources (such as the land itself) and purchased inputs such as fossil fuels, mineral fertilisers and equipment, as well as the latest technology. Farming must be able to sustain itself, to plan and invest for the future, to change and improve outmoded and outworn equipment, products and practices. This can only occur if British agriculture is allowed to remain efficient and profitable.

  The use of animal medicines in agriculture not only reduces suffering, and prolongs useful life, but healthy animals invariably produce more efficiently and perform better, so utilising less feed and other resources.

  For organic farming to remain sustainable it must also be profitable. Organic livestock production requires organic inputs, notably fodder and feed grains. Producers of such organic crops themselves expect higher premia—can organic livestock producers continue to produce profitably as produce prices drop, approaching those for conventional farming, if their input costs rise?

  Organic produce prices cannot avoid the law of supply and demand—as organic production increases, prices must fall—supermarkets have declared their intention to supply Organic food at equivalent prices to conventional farming. These lower prices will inevitably be passed back to organic producers.

  Thus organic producers are increasingly being caught in a pincer—on the one hand steady escalation of standards by organic organisations, for example by increasing the proportion of organic inputs (which cost more to produce) on the other hand, increased supplies and supermarket buying powers will reduce prices received—the net result is likely to be that those who have converted to organic production for commercial rather than philosophical reasons are likely to be disappointed.

  It must also be recognised that today's organic farms, both livestock and arable, benefit from the eradication and control, by conventional means of many pests and diseases over many years. They also benefit from being surrounded by a "cordon sanitaire" of clean, conventional farms. If the organically farmed area was to spread, would existing controls break down and the artificiality of organic disease control methods be exposed?

  Thus we believe that the assertion that organic farming is "sustainable" should be seriously questioned.

RESEARCH

  Organic supporters frequently call for special funding and emphasis to be given to "organic" research. Such demands would appear to be based on a number of misconceptions.

  1.  Much of MAFF's research is into "generic" activities which could apply equally to conventional and organic production.

  2.  Similarly, commercial research into agricultural equipment, conventional breeding of plants and animals, animal feed etc. is equally applicable to both sectors.

  3.  Research into animal disease carried out by universities and other quasi-official institutions is applicable to both, as is most of the commercial research carried out by animal medicine companies.

  4.  MAFF research into animal medicines is predominantly into methods of public protection, such as residue testing, which is again of general benefit. Furthermore, much of this is paid for by levies on industry rather than from the taxpayer.

  5.  We believe, however, that there is a case for more research to be devoted to an open-minded investigation of some of the claims made by organic farming, in order to ensure proper protection of the public, both as purchasers and consumers.

ASSURANCE SCHEMES

  In the Committee's call for evidence, comment is invited on assurance schemes—such schemes are increasing in all sectors of farming and we particularly welcome the launch of the British farm standard, backed as it is by strict and independently enforced rules.

  It could be argued that through such schemes conventional farming provides most of the elements of "Public Good" for which the organic movement has tried to claim exclusivity—Animal welfare, environmental protection, food safety. Assurance schemes should, we believe, acknowledge and build on the legal controls and codes which already exist—Medicine and pesticide licensing, welfare and performance codes—such as the Code of Practice for the Responsible use of Medicines on farm—launched by Nick Brown last year, and the RUMA (Responsible Use of Medicines in Agriculture Alliance) Antibiotic guidelines.

  We applaud the increasing maturity of Farm and Food Assurance Schemes; gone are the early problems such as claiming meat to be "hormone free" (which is biologically impossible, and also ignored the fact that the use of Growth Promoting hormones has been illegal throughout the EU since 1986).

  We also welcome the ending of competitive and often meaningless claims that food from a particular scheme is "healthier" or from "happier animals".

  Sadly, the organic sector continue to employ such negative marketing methods, which are currently the subject of a complaint to the Advertising Standards Authority.

CONCLUSION

  Under the circumstances outlined above, we cannot agree with those who argue for additional funding for organic farming. We believe that public support for agriculture should be applied equally to all forms of farming, and farm inputs, acceptable under the law.

  We find it a peculiar contradiction of the concept of "joined-up government" that one part of MAFF is giving special support to organic farming which, by statement and implication, denigrates the work of other parts of MAFF which scientifically licence as "safe, effective and of high quality" animal medicines, agrochemicals and other farm inputs.

  The continuing and unjustified attacks by organic farming organisations on the vast majority of farmers who use conventional methods is particularly reprehensible.

  In continuing their support for efficient, safe and sustainable agricultural systems, the member companies of NOAH do not seek to restrict the farming activities of any particular sector; they do however support rigorous and fair assessments made as evidence based decisions with respect to veterinary medicine's role in agriculture.

13 June 2000