Contact: John Horan, Chief Executive
INTRODUCTION
The Irish Veterinary Union and the Irish Veterinary Association welcome the appointment of the Agri Food 2010 Committee by the Minister for Agriculture & Food. In particular, we have considered the terms of reference for the committee “ to propose a strategy for the development of Irish Agriculture & Food over the next decade, following the agreement on Agenda 2000, and in the light of the changes and challenges which are likely to evolve nationally and internationally over that period”. On the basis that interested organisations have been invited to make submissions to the committee on the issues covered by the terms of reference, IVU/IVA are pleased to present the following matters for consideration by the committee.
Under the common agriculture policy, there has been an era of phenomenal growth in agricultural production matched only by the plethora of European community production regulatory measures. Throughout this era of rapid change and many difficulties, Irish Vets through their round the clock and year round vigilance over the health and welfare of Ireland’s animal population, provided an unstinting service to their farmer clients. If there has been any certainty in farming over these turbulent times, it is that their Vet will always respond to a call for help, irrespective of when the call is made. This has led in turn, to a very close affinity between the Veterinary profession and farmers based on their common interest in the health and welfare of livestock.
Ireland has in the past established its claim to be regarded as the “Food Island” and if this is to be maintained we will have to be ale to substantiate this claim with records that prove that Ireland produces the safest food in Europe.
This submission outlines the current position of the veterinary profession in Ireland and focuses particularly on the role we have been playing in contributing to the establishment of Ireland as the “Food Island”. More importantly, this submission sets out our considered view on how best we can underpin the work of the Irish food industry with robust food safety/quality programmes.
THE VETERINARY PROFESSION
Farm animal practice
In Ireland the greatest number of veterinary surgeons are engaged in farm practice (approx. 800). This is unusual by international standards, but reflects the relatively large numbers of farmed animals and the small human population.
Given the current and projected trends in animal based agriculture, particularly in relation to input cots and product costs, it would seem that improvements in income will only be achieved by increase in scale, or efficiency. These changes will put pressure on service providers to the livestock industry, including veterinary surgeons. The effects will be most severe in the less intensive livestock areas, particularly the North and West of Ireland.
Most of those engaged in farm animal practice also derive a significant proportion of their income from working as Temporary Veterinary Inspectors (TVI) in meat inspection and from disease control work (TB and brucellosis testing). This income may be more than 50% of total income. This dependence on the State may have inhibited the development of practices and services, especially specialization. It is believed that the development of multi-person practices comprising individuals with specialist post-graduate training will be a necessary development in the near future.
Companion animal practice
One of the major changes in practice during the last ten years has been the increased number of practitioners engaged in companion animal practice. This includes both whole-time and part-time work. Most of this whole-time employment is in the larger population centers. Part-time work is usually undertaken as part of farm animal practice, with one or more members of the practice developing the appropriate skills. This development reflects the increased numbers of the animal owning public and their expectation of greatly increased sophistication in animal health care.
The main factors which have triggered this development have been increased wealth, a development of the appreciation of the value of pet ownership, and widely viewed television series. The relatively small human population, even taking account of its expected increase, will not provide unlimited work opportunities in the future. Even a doubling of this work would not provide more than 200 job opportunities in 20 years.
State employment
Much has been written about the “brain drain” – usually out of the public and into the private sector. The reverse seems to be the case here with the State rapidly becoming the larger employer of veterinary expertise. Most of those leaving farm animal practice have taken up employment in the State service. The numbers employed in full-time work is now about 400, or 50% of the numbers engaged in farm practice (who also derive much of their income from the State). This enlargement while it will not continue, is a reflection of the increasing demand for improved animal health control and consumer protection.
Specialisation
There has been an increase in the numbers engaged in specialist practice. This includes equine, pig, poultry, fish specialists, as well as specialization in veterinary techniques, such as fertility and mastitis control, surgery and complementary medicine. In the future the number of consultants with specialized experience and qualifications will provide some new opportunities. In spite of the increased opportunities in these areas, most of those involved will be transferring from existing employment, especially farm practice. Thus relatively few 'new' jobs will be created in this area.
Teaching and research
There are currently about 60 veterinary surgeons engaged in teaching and research. This number is unlikely to increase, although teaching of non-professionals and in para-veterinary subjects will provide some opportunities.
Local Authority
Local authorities employ less than fifty veterinary surgeons. This number is likely to increase due to the need to provide supervision of animal health and protection of human health. The extent to which these services will be provided by local authorities or by the State remains unclear. A valid case can be made for ensuring the independence of this local authority work.
FUTURE TRENDS
Looking ahead, the veterinary profession is keen to learn from the past and to build on it for the future. For example, we see a vitally important role for the profession in mediating food safety between the producer and the consumer. The reality of the “stable to table” approach is being appreciated on a more widespread basis. There is now a clear fusion between a Veterinary role in animal health and welfare and the promotion of quality food strategies which can enable a Veterinary Practitioner to add real value to his clients product. We hope to provide the leadership and the vehicle through which Irish Vets can continue to make a real contribution to ensuring the production of safe, quality food for consumers at home and abroad during the next decade and beyond.
Food quality and consumer protection
Developments in food quality and assurance will involve an increasing number of veterinary surgeons. This is not to suggest that these areas will, or should be, veterinary preserves. The ideal situation is for the development of multi-disciplinary teams. Unfortunately there has not been a history of such teams, and there has been a tendency to regard certain areas as the exclusive preserve of single disciplines.
Significant veterinary involvement in these areas is logical because of the many relevant fields of expertise. In fact most of the subjects on the veterinary training curriculum are relevant to the improvement of animal health, prevention of disease and its spread and the identification of risks to humans involved in the industry and to consumers of foods of animal origins. These facts have been more than adequately demonstrated during recent food scares caused by BSE, E.coli O157 and others.
Consumer concerns
It would be totally unacceptable however, to rest on these laurels and expect current production and processing systems to be adequate. A number of very significant trends are already apparent. Consumers are more affluent, educated and concerned about animal health and the production systems. The future success of Irish agriculture is heavily dependent upon producing the highest quality products and having these targeted to the specific requirements of their intended markets. It is these markets and consumers however; who are most fastidious regarding the product quality and means of production. Animal welfare is a major concern in these prime markets. As in all quality matters it is difficult to demonstrate a reputation for superiority of product, but easy to lose it. Ireland has a much envied, extensive, grass-based production system for many of our livestock products. This can easily be marketed as a positive attribute, but just as easily lost due to defects in the production, or processing system.
The structure of the Irish beef industry is not conducive to ensuring traceability, because of the many animal movements involved. This is one of the many changes, which are necessary in the structure, and ethos of this industry. In particular, the emphasis has been on securing commodity prices for live beef exports, rather than realizing the opportunity costs of the product at home and targeting top quality markets. In a similar way there is a need for producers to understand consumer needs and concerns. The reaction to quality assurance is "how much will it cost?” rather than "will this result in a better, more secure market for my produce?”
Vets have a role through the entire animal production system, including meat processing. It is not possible to produce quality products from diseased animals. Modern production systems render animals more prone to diseases due to the formation of large groups of similarly aged animals, often kept in close proximity. Emphasis must be placed on simple, practical and low cost prevention systems, rather than the treatment of disease when it is identified. Once disease is detected in one or more animals, many have been infected sub-clinically and considerable production and economic losses have occurred. Veterinary involvement should place more emphasis therefore, on an advisory role, rather than on a 'fire brigade' role.
Herd Health Schemes
Herd health schemes work well in other countries. Here is Ireland they are operated in intensive farm enterprises involving pigs, poultry and fish. They need to be extended into the dairy, beef and sheep enterprises. Realistically the chances of this occurring are at best slim. When enthusiastic veterinary practitioners propose such schemes the response is most disappointing. When applied they quickly fall into disuse, as soon as improvements have been demonstrated. This is not to suggest that farmers do not aspire to improvements in animal health and production, but rather to an ethos within these industries which lowers all costs, irrespective of their 'cost / benefit'. Respiratory disease in cattle have been shown to affect about one farm in ten, and when this occurs the losses far exceed the expected profit from the farms. Similarly parasite control, where excessive use of treatment is as financially damaging as poor control of parasitic disease. 'New' diseases such as neospora also require new preventive approaches. Neonatal calf mortality, which accounts for about 15% of calf births, and major opportunity cost losses, also responds well to investigation and preventive measures. These and many other potential areas require to be addressed, as the agricultural industry cannot afford continued costs, losses and missed opportunities.
VETERINARY CERTIFIED FOOD ASSURANCE BOARD (VCFAB)
The VCFAB is representative of the following Irish Veterinary Bodies:
Its purpose is to initiate, formulate and co-ordinate Veterinary Public Health Policy and to add value to Veterinary Certification in terms of the consumer, producer and state. Customers at home and abroad expect to be able to buy safe, wholesome, Irish food at a reasonable cost. This is paramount to maintaining and expanding our markets at home and abroad. Irish Veterinarians have recognised the importance of, and are committed to, the production of food in which domestic and international customers can have the highest confidence. We are of the view that any safety inspection programme must be a seamless one “from the stable to the table” if it is to provide the required customer assurance.
PRE-HARVEST ON FARM FOOD SAFETY CONTROL
The Pre-Harvest consideration of food borne agents and other hazards associated with the Farm or indeed the Sea could, in our view, be increased for the following reasons:
Food Safety “from the stable to the table” should not simply be compliance with the minimum legal standard.
Effectively addressing food safety issues requires co-ordination of efforts throughout the food chain, comprehensive food safety research, and practical cost effective solutions and responses “from the stable to the table”.
GOOD FARMING PRACTICES
We believe that while traceability is an important part of the process it is not the “be all and end all” it is held out to be. At farm level we would encourage the development and education of all involved in what we term good farming practices, which are so essential to ensuring food safety pre-harvest including:
For example, we would encourage simple residue prevention programmes, rather than attempting solely to enforce the animal remedies regulations in the absence of a proper producer educational environment. Such a residue prevention programme should be planned between the bona fide farm Veterinarian and his / her client and the processor based on key critical control points of concern to customers.
The basis for such a residue prevention programme should be simple, practical ways of reducing the hazards associated with animal remedy use and providing compliance with legislation – put at its simplest, the message is that what goes in at farm level cannot be taken out at processor level e.g. Drug Residues.
VETS AS AUDITORS OF FOOD SAFETY AT FARM LEVEL
Vets are ideally placed for the role of Auditors of Food Safety at farm level.
Vets are trained professionals in:
Vets are:
In this farm veterinary public health certification role vets are:
Licensed veterinary practitioners with a bona fide client relationship at farm level can:
At farm level we recognise commercial concerns and the fear of bureaucracy and we are prepared to work diligently to find safe solutions to problems that are perceived or otherwise.
OTHER PROFESSIONAL COMPETENCIES
The change to food safety assurance “from stable to table” requires an integrated and multi-disciplinary approach in which the veterinary profession has a major role to play. Our approach to Food Safety Assurance fully recognises and acknowledges the competence of other professionals and their complementary roles in this process including:
FOOD SAFETY AUDITS
As veterinarians we believe all professionals involved should have a basic and common food safety management audit training and experience preferably to a recognised international standard which could add value at another level to our national marketing / sales drive. We believe the concept of food safety audits and the drive for continuous improvement is best suited to our national food safety objectives. We believe the pass and fail philosophy of inspection is not suited to this process and places the onus on the inspector rather than on the system.
To achieve this almost 500 vets in practice have been trained as Veterinary Internal Farm Auditors and to date a further twenty, mainly regulatory vets, as Lead Auditors - all to a standard agreed with the International Register of Certified Auditors.
It is our strong view that food safety should not be based solely on routine farm inspections. The dairy industry provides a good example in this regard.
Our present understanding of factors affecting milk food safety leads one to conclude that the main critical control points of milk food safety criteria are only marginally impacted by routine traditional type government mandated inspections. If we are serious about public health then we have to look in greater depth at the “Process” not only in farming but also in the food industry in general and apply HACCP principles in a meaningful way. The approach being taken on dairy hygiene certification provides a cost effective model for the sort of Food Safety Assurance programmes that might be extended to meat with little or no expense to the tax payer.
All that is missing are measurable parameters, which are related directly or indirectly to food safety and as in the dairy programmes the technical assistance (veterinary etc) on farms re: critical control points e.g. Animal remedies, specific pathogens etc.
SUMMARY OF THE CURRENT ROLE OF THE VETERINARY PROFESSION IN FOOD SAFETY.
Full Time Permanent Employment
State Veterinary Service.
Local Government
Part Time Temporary Employment - Practitioners
Full Time:
Herd Health Management Programmes etc. and day to day “farm associated work”.
CURRENT MEAT INSPECTION PROGRAMME
Inspection of commercial food processors is an integral part of the States food safety programme. Currently the veterinary role in meat inspection programmes ranges from continuous carcass - by - carcass inspections in slaughter plants while operating random inspections of other food processing plants e.g. dairies and imported foodstuff. The purpose of the meat inspection service is to ensure that the minimum legal requirements of animal health, animal welfare and public health are implemented by Irish meat and meat product processors.
AT FACTORY LEVEL
Under the current inspection system operating in cattle slaughter plants Temporary Veterinary Inspectors are assigned to fixed stations on each line. Their function is to identify diseases / defects in carcasses. Consumers demand and have a right to safe food, but consumers the world over also demand wholesomeness and the history of the Irish Governments Veterinary Meat Inspection Service is that this has been delivered in the past and can and should continue.
The veterinary profession seeks to implement science based inspection programmes as a means of preventing food safety hazards and providing increased consumer protection. We believe that Hazard Analysis Critical Control Point based inspection systems are the means to achieve this. As a profession we believe that the State should focus inspection resources on high priority activities such as sampling for micro pathogens, verifying zero tolerance standards for carcass contamination, and verifying HACCP Systems.
We wish to see the food safety approach move from one of compliance with the minimum legal requirement to one of embracing the concept of food safety assurance. In this regard we believe a key requirement is that the service becomes adequately resourced. The facts are that a service has developed with a huge expertise and knowledge - one in which the State depends to retain open many of its export markets yet it cannot expect it to survive, develop and be dynamic without the necessary resources.
TRAINING
One example of the paucity of available resources is in the area of training. General practitioners joining the service for the first time could find themselves responsible for an EU Meat Plant in any part of Ireland without a single day's training. In the case of the Temporary Veterinary Inspectorate, other than a requirement to spend two weeks unpaid on the line under the supervision of an V.I., there is not a single other requirement other than the base veterinary degree. The profession out of frustration with this situation in late ’98 began a Voluntary Modular Self-Training Programme funded by each individual veterinary participant. Vets have begun this process by completing Pre-HACCP Good Manufacturing and HACCP Courses.
EXISTING INSPECTION APPROACH
REVIEW OF THE INSPECTION PROCESS
RECOMMENDATIONS
Processor run Animal Health Schemes
As already mentioned, the Department of Agriculture and Food employs a considerable proportion of the veterinary surgeons in Ireland. It has therefore an immense influence on the disposition of the National veterinary resources. It also has a legislative and facilitatory role in the development of Irish agriculture. It would be possible therefore to devise animal health schemes in conjunction with the processors of animal products, funded by financial deductions from the product receipts. This would make better use of veterinary skills, enable the maintenance of a veterinary presence in less populated areas and most importantly, result in the production of healthier animals, which would realize better returns for producers and processors.
Independent Quality Assurance
In the past many of the quality assurance schemes have been devised and operated by one of the 'interested parties'. Clearly this will not be accepted by consumers. Worse than this, these schemes have the ability to damage the credibility of Irish produce and of genuine quality schemes. Quality assurance schemes require to be independent, comprehensive, transparent, practical and cost effective. They also need to be operated for all animal products, based on consumer requirements and with the intention of being inclusive rather than exclusive.
Veterinarians wish to be involved in the overall process of providing safe and wholesome Irish food and to date this profession has clearly demonstrated its willingness by attempting to kick-start this through training. We welcome the co-ordination that we believe the Food Safety Authority can bring to this area and we would hope that, for the majority of the stakeholders in the whole area of food production, we can deliver safe product in a manner that gives some uniqueness in the market place.
Post Graduate Training
It is not possible for any veterinary surgeon to be superbly well qualified in more than a small number of areas, or disciplines. Similarly it is not possible to keep up-to-date with new developments without constant training and education. Continuing professional development (CPD) has already been introduced within the profession on a voluntary basis, and has met with considerable support, as indicated by attendance at quality assurance training courses and at Clinical Societies which are participating in voluntary recording of attendance and post-meeting examinations. Unless this progresses to a requirement by the registering body (Veterinary Council) for annual registration, it will result in falling standards of professional knowledge, skills and performance. The Veterinary Surgeon's Act, now in preparation, should facilitate this development.
Finally, we wish the Agri Food 2010 Committee success in its deliberations. The Committee’s recommendations can be vitally important in forming the basis for the successful development of Irish agriculture and food as we move into the next century.
The Irish veterinary profession would hope to build a “Food Island” partnership with producers and processors that will lead to the highest possible levels of quality and customer assurance.