16th May 2007
PROPOSED CHANGES TO THE AVAILABILI=
TY AND
SUPPLY OF LOCAL ANAESTHETIC FOR USE WITH FARM ANIMALS IN THE REPUBLIC OF
IRELAND
Submission to the Irish Medicines Boa=
rd by
Compassion in World Farming - Ireland
Compassion in World Farming= - Ireland (CIWF) welcomes the decision by the Department of Agriculture and Food (DAF= ) to investigate improved access to a suitable local anaesthetic (LA), e.g. lignocaine, for use during the treatment of food-producing animals (includi= ng cattle, sheep and pigs). We n= ote that the DAF recognises that the current situation is compromising animal welfare. We thank the Irish Medicines Board (IMB) for inviting CIWF to make a submission on this issue.=
Introduction
CIWF is seriously concerned= that, at present, veterinarians in the Republic of Ireland do not have easy acces= s to a LA for use on food-producing animals.&nb= sp; In our view, it is a basic veterinary requirement to have a suitable= LA readily available for use when carrying out potentially painful procedures = on farm animals. In this submiss= ion, we propose that a suitable LA should be authorised for use by veterinarians= on farm animals as a matter of urgency.
Certain routine procedures = that are carried out by farmers without a LA also have the potential to inflict pain= on farm animals. In particular, = CIWF is concerned that farmers carry out disbudding of calves under 14 days old without using a LA (a LA must be used for disbudding calves over 14 days old because this is a legal requirement; therefore, disbudding of older calves = must be carried out by a veterinarian because LAs are for veterinary use only).<= span style=3D'mso-spacerun:yes'> In this submission, we propose that farmers are allowed, under strictly regulated conditions, to use a LA when disbudding calves under 14 days old.
In this submission, we also= outline the situation and experience in the UK, where the LA procaine is accessible= to both veterinarians and farmers for use with farm animals.
Types of local anaesthetic
We note that the IMB’= s letter inviting CIWF’s submission refers to the possible re-evaluation of the supply status of the LA lignocaine. Subsequent information from another source suggests that there may be some doubts about the use of lignocaine on human health grounds, and that t= he LA procaine may instead be under consideration because it has a better safe= ty profile.
CIWF notes that, in the UK, veterinarians originally used lignocaine and found it satisfactory. When a Maximum Residue Limit issue arose, lignocaine was no long permit= ted for use on food-producing animals in the UK. Instead, veterinarians changed to = using procaine. We understand that veterinarians in the UK appear to have found procaine to be an acceptable a= lternative to lignocaine.
From an animal welfare view= point, it appears that either lignocaine or procaine would be an acceptable LA for authorisation in the Republic of Ireland for use with food-producing animals. There may, of course= , be other suitable alternatives.
The necessity for an approved local anaesthetic for use by veter=
inarians
in the Republic of Ireland during the treatment of farm animals
CIWF calls on the IMB to do=
all it
can, as a matter of great urgency, to ensure that a suitable LA is made
available for veterinarians to use in the treatment of food-producing anima=
ls. Our reasons are outlined below.
The use of drugs, including= LAs, on food-producing animals is highly regulated because of possible risks to hum= an health from drug residues in food.
At present in the Republic = of Ireland, there are no authorised LAs available to veterinarians for use with food-producing animals. If a = LA is needed for the treatment of a farm animal, then the only option available to veterinarians is to use a LA that has been authorised for another species of non-food producing animal, under the “cascade” provision.
The “cascade” p= rovision involves a time-consuming procedure of record-keeping. There can be serious consequences = for the veterinarian if an unintended error is made in the “cascade” procedure. It is understandab= le that, because of these difficulties, veterinarians may be reluctant to reso= rt to the “cascade” provision.&nb= sp;
The lack of an authorised L= A for food-producing animals and the problems relating to the use of the “cascade” provision mean that, in effect, there is no readily available LA for veterinarians in the Republic of Ireland to use on farm animals. This situation clear= ly jeopardises the welfare of farm animals and is totally unacceptable.
Suggestion for making a local anaesthetic available to farmers f=
or
use when disbudding young calves
At present, LAs are restric= ted to veterinary use only in the Republic of Ireland. CIWF urges the IMB to change= the supply status of an authorised LA so that farmers can use this during disbudding of calves under 14 days old (with strict regulatory requirements= in place to protect animal welfare and human health and safety). Our reasons are outlined below.
Calf disbudding is a common= ly-used procedure involving the removal of horn buds when the calves are young. It can be carried out using caustic paste, but the more humane method is by use of a heated disbudding iron in conjunction with a LA. (All references to disbudding in this submission relate to heated iron disbuddin= g.)
Legislation governing disbu= dding permits the disbudding of calves under 14 days old without a LA, which means that farmers can disbud such animals. Once calves are over 14 days old, the law requires that a LA is used= . At present, only veterinarians can administer a LA, which means that all disbudding of calves over 14 days old must be carried out by a veterinarian.
Disbudding is a painful pro= cedure, and there is likely to be residual pain afterwards. The 14 day limit in the legislatio= n is arbitrary: there is no eviden= ce that calves under 14 days do not feel pain during disbudding. From an animal welfare perspective= , CIWF believes that all disbudding should be carried out with a LA, including cal= ves under 14 days old.
At present, if a farmer wan= ts a LA used during disbudding of calves under 14 days old, then a veterinarian mus= t be called to administer the LA (because LAs can only be used by a veterinarian). This means that there is a cost is= sue. If farmers were permitted to use a= LA themselves when carrying out disbudding of calves under 14 days old, then t= he extra cost of calling out a veterinarian would be avoided and this disincen= tive would be removed.
Though not a legal requirem= ent, the use of a LA by a farmer when disbudding calves under 14 days old could be p= ut forward as recommended “best practice” in Department of Agricul= ture guidelines etc. The use of a = LA during disbudding of calves under 14 days old would represent a significant animal welfare improvement.
We recognise that there are= animal welfare and human safety issues raised by the use of a LA by farmers (i.e. = by non-veterinarians). However, = we suggest that potential problems could be minimised by:
We stress that under no circumstances should farmers be permitted to carry out adult cattle de-horn= ing, even with a LA. CIWF is total= ly opposed to adult de-horning, other than in exceptional circumstances. Adult de-horning is a major proced= ure that, even if carried out by a veterinarian, causes considerable pain and distr= ess to the animal. CIWF is of the vi= ew that adult de-horning should be made illegal.
[In the longer term, CIWF b= elieves that the use of polled cattle (cattle without horns) is desirable on animal welfare grounds because this negates any need for horn removal.]
In summary, CIWF urges the IMB to:
1.&n= bsp; As a matter of urgency, make readily available to veterinary practitioners a suitable LA for use in food-producing animals, w= hich can be used by veterinarians without them having to resort to the “cascade” provision. &nbs= p;
2.&n= bsp; Make available to farmers, under strictly regulated conditions, a suitable LA that they can use when disbudding calves under 14 days old. This would bring ab= out a significant animal welfare improvement.
Background information on the availability of local anaesthetic =
in
Ireland
At present, the legal situa= tion in the Republic of Ireland is that LA products authorised by the IMB are no= t indicated for use in cattle or other food-producing animals.
In the absence of a LA being authorised for use with food-producing animals, veterinarians carrying out treatment on calves and other farm animals may use a LA that has been authorised for another species, as permitted under the “cascade” provisions of the legislation.
Local anaesthetics in Irela= nd are restricted to use by veterinarians only.
In summary, the current sit= uation is that LAs can only be used on food-producing animals by veterinarians under = the “cascade” provisions of the legislation.
Based
on information from Dr Gabriel Beechinor, Director of Veterinary Medicines,
Irish Medicines Board, May 06.
Background information on the availability of local anaesthetic =
in
the UK
CIWF understands that in th= e UK in the past, lignocaine was the LA used by veterinarians. After a Maximum Residue Limit issue arose, lignocaine was no longer permitted for use in food-producing animals in the UK. An alternative LA, procaine, is no= w used and veterinarians appear to have found this acceptable.
The use of procaine in the = UK is not restricted to veterinarians. Farmers there can purchase and use procaine, but only on their own animals. UK farmers do use pr= ocaine when disbudding calves.
Veterinarians in the UK do = little disbudding now because farmers do it themselves. This saves the farmer money because he/she does not have to pay a veterinarian to come out to the farm. Veterinarians are happy with this situation because it means that farmers can better afford to call out a veterinarian in cases where veterinary intervention is essential.
CIWF understands that there= is no farmer training requirement in the UK for farmers disbudding calves and usi= ng procaine. CIWF understands th= at it is generally believed that there are some minor difficulties for farmers us= ing procaine on their animals, but no major problems.
Based
on information obtained from:
Mary-Anne Bartlett
Director
Compassion in World Farming - Ireland