Brussels is expected to adopt new medicated feed regulations in August and it won’t just be compounders who’re affected – home mill-mixers will face new controls too. As Digby Scott writes, however, chapter and verse are still far from clear.
Some countries involved in the current negotiations on the medicated feed regulations want an outright ban on antibiotics in feed, and there’s a fear their lobbying may have influenced European Commission (EC) thinking on the subject. For instance, it believes carry-over of medicated product into the next batch is a significant issue and wants to impose a maximum carry-over of 1% of antibiotic product and 3% of other medications.
But the EC’s perception that carry-over would occur at one percent all the time – so pigs eating the next batch of feed would get one percent of antibiotic product every day – is incorrect. And this is borne out by Veterinary Medicines Directorate (VMD) checks on residue levels in meat, which are very low. In any case, compounders see a 1% limit on carry-over as unachievable, so the NPA will be pressing for the upper figure of 3% for all medicated feed.
It’s difficult to identify 3% of material in a tonne of feed, said the NPA’s chief executive, Zoe Davies, adding: “It would be a struggle to pick up 600g let alone 18g, which is what 3% would be.”
And percentage carry-over would, in any case, be a misleading figure, as it would vary hugely depending on how much of the medication had to be added.
One of the problems regarding the current pressure on in-feed medication is that the British pig industry is not, by and large, geared up to swap to medication in the water supply.
Many farms are unable to use dosage meters as they rely on negative pressure, and simply dumping medication in header tanks isn’t a satisfactory option.
Brussels is also proposing that homogeneity be set at plus or minus 10%, but compounders feel this would be technically difficult to achieve.
Most carry out homogeneity testing every six months, and would find it impractical – and in some cases impossible – to do every time they mix a medicated feed.
Another restriction proposed by Brussels is to make in-feed prescriptions valid for only three weeks but Dr Davies suggested there’s little science behind this idea.
“In fact, there seems to be little evidence supporting any of the numbers they’ve put into the proposed regulation,” she said.
The VMD, which will enforce the new regulations when they’re introduced, has decided that metaphylactic use of antibiotic in feed should be allowed.
That is to say, pigs may be treated if they’re at risk of suffering an outbreak of infectious disease due to exposure to disease agents or extremely unfavourable environmental conditions.
But there are some concerns as to how this will be interpreted. The European Medicines Agency says if an animal is infected, even though there are no clinical signs, it’s reasonable to medicate.
But the VMD believes that at least some animals with clinical signs must be present before a vet agrees treatment. This goes against prevention-better-than-cure principles, so the medicines industry is going to argue the issue be removed from the regulation and be handled by product licence instead.
The VMD also appears to be in favour of requiring medicated feed to be produced to the medicine-standard good manufacturing practices (GMP), despite being told unequivocally that this would increase the cost by 30 to 40%, and is what killed off German in-feed medicine production.
The medicines used are already manufactured to the GMP standard and therefore there’s no need to repeat the process for its inclusion in feed, Dr Davies said.
“Hazard analysis and critical control points (HACCP) should be good enough if properly enforced,” she added.
Nevertheless, VMD appears intent upon producing a paper on the issue, so the jury is still out.
Home mill-mixing takes place on nearly a third of British pig units, and the message to these producers is that although it’s unclear at this stage precisely what the new regulations will look like, and how they’ll be interpreted and enforced by VMD in this country, change is on the way. And for the large part, it’ll make life more complicated.