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O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 1 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
Brexit – Veterinary Fact File Updated 24th October 2016
Contents 1. EU legislation ................................................................................................................................... 1
2. Workforce ....................................................................................................................................... 3
3. RCVS impacts................................................................................................................................... 5
4. Drugs ............................................................................................................................................... 5
5. Surveillance and biosecurity ........................................................................................................... 6
6. Animal Welfare ............................................................................................................................... 7
7. Food and farming ............................................................................................................................ 8
8. Research .......................................................................................................................................... 9
1. EU legislation 1.1 Areas currently subject to EU legislation include: 1
• Veterinary medicines • Livestock and food chain traceability • Food labelling • Livestock identification and record keeping • Food safety • Disease prevention, control, eradication and outbreaks • Surveillance • Control and disposal of animal by-products • Official animal welfare checks • Welfare at slaughter • Animal welfare standards for different species • Welfare in transport • Controls on food products and livestock at ports • Pet travel • Commercial movement of animals • Use of animals for research
1 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Campaigns/eu-referendum-uk-veterinary-profession.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 2 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
1.2 Future EU legislation:
EU Animal Health Law (Rules on Transmissible Animal diseases) was passed by all EU institutions in
April 2016 and will apply in the EU from April 2021.
EU medicated feed and veterinary medicinal products regulations. Draft legislation produced,
European Parliament finalised position March 2016. European Council progress very slow (currently
considered 57/150 articles in vet med products regulation (July 2016). Medicated Feed regulations
have not been considered for several months to allow Vet Med Products to “catch up”. Council not
finalised its views on either so neither has entered trilogue. Current guess is that trilogue will start in
mid-2017, legislation may be finalised by the end of 2018 and come into effect 2020 or 20212.
Medicated feed proposal:
Replace the current directive with regulation to harmonise rules on production, marketing and use of medicated feed in EU.
Allow for medicated feed to be used in non-food animals (i.e. pets)
Reduce risks of antimicrobial resistance by: o restricting preventative use of medicated feed o setting limits for the amount of active substance permitted to be present in non-
target feed (“carry over”).
Allow for “anticipated production” where medicated feed is made in advance of a prescription
Set criteria for homogeneity in feed Veterinary Medicinal Products proposal:
Introduce ability for commission to reserve use of certain antimicrobials for humans only (via implementing acts)
Ban routine prophylactic usage of antimicrobials
Restrict metaphylactic usage to use in clinically ill animals or individual animals identified as high risk Ban the internet sales of antimicrobials, psychotropic and biological or immunological veterinary medicines.
Restrict veterinarians to only be able to sell antimicrobials for animals under their immediate care and only in the amount required for the treatment concerned.
Facilitate R&D to create new antimicrobials by extending the periods of protection of new products
2 D. Murphy, NOAH, pers. comm. July 2016
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 3 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
2. Workforce Source: Adapted from RCVS Facts 2008 and 2014
FIGURE 1: RCVS new registrations 2002-2014
2.1 Lack of experienced vets for clinical veterinary roles
BVA Voice of the Veterinary Profession survey 20153: Two thirds of vet practices took over
three months to fill a vacancy in the last year with 1 in 10 taking over 6 months. Particularly
bad in companion animal sector – a quarter took 6 months and 20% of ads were withdrawn
due to lack of suitable candidates. The majority of those that struggled to recruit were
looking for vets with at least one year experience (91%) with 49% looking for vets with over
three years of experience
Three months is over three times the national average (April 2016) of 29 days4
2.2 Uncertainty for non-UK EU vets currently working in the UK
Rights of EU vets to live and work in the UK – currently subject to negotiations. EU directive 2005/36/EC on mutual recognition of professional qualifications – could be revised
during negotiations.
BVA position calls for the working rights of non-UK EU vets/veterinary nurses (VNs) currently
working and studying in the UK, and for British vets/VNs working in the EU, to be maintained with no
time limit and to consider inclusion of veterinary medicine on the Shortage Occupation List.5
3 https://www.bva.co.uk/News-campaigns-and-policy/Newsroom/News-releases/Struggling-to-recruit--you-are-not-alone/ 4 http://dhihiringindicators.com/wp-content/uploads/2016/07/2016-06-DHI-Hiring-Indicators-FINAL.pdf 5 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Policies/BVA-principles-for-negotiating-Brexit.pdf
2002/03
2003/04
2004/05
2005/06
2006/07
2007/08
2008/09
2009/10
2010/11
2011/12
2012/13
2013/14
Overseas non-EU/EAA 299 249 346 228 218 190 155 146 142 126 122 135
Overseras EU/EAA 355 258 362 579 519 493 454 369 435 456 603 701
UK 493 493 587 565 569 628 630 736 708 815 807 795
0
200
400
600
800
1000
1200
1400
1600
1800
Nu
mb
er o
f n
ew r
egis
trat
ion
s
UK Overseras EU/EAA Overseas non-EU/EAA
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 4 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
2.3 Reliance of current vet businesses and vet teaching/research on non -UK vets.
TABLE 1: PROPORTION OF NON-UK EU NATIONALS ACADEMIC STAFF MEMBERS IN UK VETERINARY
SCHOOLS (JULY 2016)6
RCVS – in recent years almost 50% of veterinary surgeons registering in the UK qualified
from Non-UK EU vet schools7 (Figure 1).
APHA – 90% of meat inspection OVs are non-UK EU citizens
2.4 Uncertainty over the future employment of non-UK vets
Opportunity to allow more selectivity in choice of registered vets?
Current European standard provided by European Association of Establishments for Veterinary Education (EAEVE)
RCVS may wish to develop own accreditation scheme Likely to make it more difficult to employ vets from EU
May follow current model for employment of non-EU vets – i.e. subject to UK Visa sponsorship license requirements
Possibility to make it easier to employ vets from outside EU
May be possible to remove requirement to advertise posts within the EU prior to employing from non-EU countries.
Possible repeal of regulations implementing the EU Working Time Directive – remove legal limits on working time (currently set at 48 hours per week). 8
6 Vet Schools Council et al. Pers. Comm., July 2016 7 RCVS Facts 2014 and 2008 reports 8 Vet Times report July 2016 “Good for employers, bad for employees” James Cronin (Eight Legal – UK’s only vet specific HR and employment law service).
VETERINARY SCHOOL
% NON-UK EU STAFF
BRISTOL 13%
NOTTINGHAM 11%
RVC 28%
EDINBURGH 21%
GLASGOW 11%
LIVERPOOL 40%
CAMBRIDGE 14%
TOTAL 22%
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 5 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
3. RCVS impacts Financial impact on the college from drop in registrations
There is likely to be a requirement to amend the Veterinary Surgeons Act 1966. Opening up the Act
may offer the opportunity for changes - e.g. introduce stricter language controls and to review
Schedule 3.9
BVA position is for the RCVS to have the power to determine recognition of veterinary qualifications
and language competency requirements.10
4. Drugs EU legislation: The Veterinary Medicinal Products Directive 2001/82/EC (as amended) sets out the
controls on the manufacture, authorisation, marketing, distribution and post-authorisation
surveillance of veterinary medicines.
New EU legislation on veterinary medicinal products and veterinary medicated feeds proposed but
still several years from being finalised and implemented (likely after 2020).
EU has applied pressure in the past to remove SQP drug category. This has been resisted in the UK. If
UK loses negotiating position then restriction may be applied across EU with minimal opposition. UK
may choose to mirror this regulation to facilitate access to drug markets.
There has also been pressure from EU countries to decouple the right to prescribe from the right to
dispense veterinary drugs. This is not in the current Veterinary Medical Products Proposal but could
change between now and new laws being implemented.
VMD response to Brexit – Currently business as usual until article 50 is triggered. Continues to
participate in meetings with EU regulators.
NOAH have stated post Brexit that they “would we do not want to miss the opportunity presented
by new veterinary medicines legislation with the benefits of reduced administrative burden and
stimulating investment and innovation in our sector. Indeed the prospect of an improved EU single
market can be a benefit whether we are in the EU or not. NOAH will be calling for the UK to mirror
EU regulations where possible – such as licensing procedures and product packaging – to avoid
barriers to trade or additional cost of complying with a dual UK:EU regulatory system.” 11
BVA position (2013) supports a harmonised approach on authorisation and distribution of veterinary
products across the EU and on harmonisation of data collection on drug sales/usage.
BVA position (2016) calls for the UK to retain access to veterinary medicines licensed in the EU and
for the veterinary medicines cascade to be maintained and, if possible, simplified.12
9 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Campaigns/eu-referendum-uk-veterinary-profession.pdf 10 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Policies/BVA-principles-for-negotiating-Brexit.pdf 11 http://www.noah.co.uk/supporting-noah-members-brexit-negotiations-blog-ceo-dawn-howard/ 12 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Policies/BVA-principles-for-negotiating-Brexit.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 6 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
5. Surveillance and biosecurity 5.1 Legislation
Future requirements for pet travel may change
Opportunity to introduce stricter controls e.g. tick treatment
5.2 Funding
EU typically provides up to 50% of national government cost for eradication, control and surveillance of animal diseases.
e.g. 50% of the funding for the UK’s Bovine TB eradication programme comes from EU. In
2014 the EU made the single largest allocation to a Member state’s animal disease
eradication programme (£25 million allocated) (Source – BVA briefing document “EU
referendum and UK vet profession”)
In 2011, over 1.4 million Euros were allocated to UK-based EU reference laboratories researching
major animal diseases including AHVLA, Pirbright Institute and the Centre for Environment, Fisheries
and Aquaculture Science (Cefas).
5.3 Collaboration:
BVA’s Veterinary Policy Group agreed that UK should be considered within the epidemiological unit
of Europe for disease control
EU Disease Eradication Task Force facilitated rapid action response to FMD outbreaks in 2001 and
2007
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 7 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
6. Animal Welfare13 Around 80% of UK animal welfare legislation originates from the EU via 44 EU animal welfare laws
13 are directives and are therefore already implemented in UK legislation
31 are regulations/decisions which are currently directly applicable in UK law but may cease to apply
once the UK exits Europe.
Laws cover:
Farm animals (17 laws)
o rearing and production methods (5 laws)
o species specific laws for laying hens, veal calves, meat chickens and pigs
o consumer
information, such as mandatory labelling of the provenance of eggs and meat
o Rules on the live transport of animals
o Rules on killing and slaughtering of animals
Wildlife (11 laws)
o Prohibits import of wild-caught birds, ban on seal products, regulates hunting and
trapping wildlife (including ban on certain types of trap), bans use of driftnets for
fishing
Animals in research (9 laws)
o Breeding, husbandry, transport and use. Includes ban on cosmetic products testing
on animals
Companion animals (4 laws)
o Pet travel scheme and ban on import of products made from dog or cat fur
Some aspects of EU animal welfare law (particularly in relation to wildlife) ratify existing
international treaties of which the UK is a member. The UK will continue to be bound by these
treaties post-Brexit:
CITIES – Regulates trade in endangered species
International Whaling Commission – Limits commercial hunting of whales
OIE (World Animal Health Organisation) – 13 guidelines on animal welfare
Council of Europe Conventions – International transport, slaughter of farm animals, keeping
of farm animals, ‘protection’ of animals used in scientific procedures and the conservation of
European wildlife and natural habitats.
A sixth Convention “The Pet Convention” has not been ratified by the UK or EU.
BVA position is for there to be no dilution of existing animal welfare standards in the UK as a result
of Brexit and for the UK to seek opportunities to improve animal welfare, for example in relation to
the export/import of live animals, mandatory method of production labelling and the labelling of
non-stun slaughter.14
13 https://blogs.rspca.org.uk/insights/2016/07/07/brexit-animal-welfare/#.V-zWRPkrKUl 14 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Policies/BVA-principles-for-negotiating-Brexit.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 8 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
7. Food and farming National Farmers Union did not actively campaign in the referendum but stated that on the balance
of existing evidence “the interest of farmers are best served by our continuing membership of the
European Union”
BVA position is that any public money used to replace the EU Common Agricultural Policy (CAP)
should be used to support and incentivise public goods encompassing at least animal health and
welfare, disease surveillance, biodiversity and environmental stewardship.15
The majority of food and non-alcoholic drink exports from the UK are currently traded with the EU
(Figure 2). This includes 38% of UK lamb production.16
FIGURE 2: UK FOOD AND DRINK EXPORTS 2004-1417
FIGURE 3: UK FOOD, DRINK AND FEED IMPORTS AND EXPORTS18
15 https://www.bva.co.uk/uploadedFiles/Content/News,_campaigns_and_policies/Policies/BVA-principles-for-negotiating-Brexit.pdf 16 http://www.nfuonline.com/assets/61993?u=wi8fbdrCqqOxx1M5dcGKqA 17 http://www.nfuonline.com/assets/61993?u=wi8fbdrCqqOxx1M5dcGKqA
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 9 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
8. Research 7.1 Funding
FIGURE 4: GROSS AND NET UK CONTROBUTIONS TO EU ANNUAL BUDGET19
The net amount contributed annually by the UK to the EU budget is about £8 – 10 billion (Figure 4)
UK is one of the largest recipients of research funding in the EU and, although national contributions
to the EU budget are not itemised, analyses suggest that the UK receives a greater amount of EU
research funding than it contributes (Figure 5)
18 http://www.nfuonline.com/assets/61993?u=wi8fbdrCqqOxx1M5dcGKqA 19 HM Treasury: European Union Finances 2015: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/483344/EU_finances_2015_final_web_09122015.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 10 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
FIGURE 5: TOTAL EU CONTRIBUTIONS BY THE UK AND EU FUNDING TO THE UK 2007-1320
There are two major routes by which the EU directly funds research in the UK – Framework
Programme funding (e.g. Horizon 2020) and structural funds.
The UK is very successful in attracting Framework Programme funding. It was the second largest
recipient of Framework Programme funding (after Germany) in the last funding cycle (FP7: 2007-
2013) receiving almost 7 billion Euros. The majority of this funding (71%) was allocated to UK
universities.21
20 https://royalsociety.org/~/media/policy/projects/eu-uk-funding/uk-membership-of-eu.pdf 21 https://royalsociety.org/~/media/policy/projects/eu-uk-funding/uk-membership-of-eu.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 11 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
Source: EU membership and UK Science Report – House of Lords Science and Technology Committee
FIGU
RE 6: A
N A
TTEMP
T TO C
AP
TUR
E THE P
RIN
CIP
AL M
ECH
AN
ISMS ESTA
BLISH
ED B
Y THE EU
TO SU
PP
OR
T SCIEN
CE A
ND
RESEA
RC
H
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 12 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
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The UK receives relatively little structural funding, which is largely targeted at building capacity in
the least economically developed regions of the EU.
FIGURE 7: EU EXPENDITURE ON RESEARCH, DEVELOPMENT AND INNOVATION 2007-1322
22 https://royalsociety.org/~/media/policy/projects/eu-uk-funding/uk-membership-of-eu.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 13 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
The level of EU funding for research at UK universities increased in recent years while the level of
funding from the government science budget has decreased. In 2013/14 10% university research
income came from the EU.
FIGURE 8: RESEARCH FUNDING OF UK UNIVERSITIES23
23 https://royalsociety.org/~/media/policy/projects/eu-uk-funding/uk-membership-of-eu.pdf
O F F I C E O F L O R D T R E E S
H O U S E O F L O R D S , W E S T M I N S T E R , S W 1 A 0 P W
Page 14 of 14 Parliamentary Veterinary Intern: Anthony Ridge
E-mail: [email protected]
Twitter: @VetPolicy
Web: vprf.wordpress.com
Framework Programme funding from the EU accounts for around 3% of total UK expenditure on UK
research and development (2007-2013)
FIGURE 9: UK EXPENDITURE ON RESEARCH AND DEVELOPMENT BY SOURCE OF FUNDING 2007-1324
7.2 Collaboration
House of Lords Science and Technology Select Committee identified three main roles of the EU in
promoting collaboration:
1. Collaborative funding schemes and programmes
2. Researcher mobility due to freedom of movement
3. Facilitating and fostering participation in shared European research infrastructures
In practice, this enables research to take place into topics where there are difficulties in procuring
funding at national level (e.g. nuclear fusion) or into topics that would be difficult to research in this
country as the sample size is low (e.g. rare diseases).
Using the EU as a platform also helps simplify the process of developing multi-national collaborative
programmes with countries outside of the EU.
24 https://royalsociety.org/~/media/policy/projects/eu-uk-funding/uk-membership-of-eu.pdf