31
Examination of witnesses
Dr Elizabeth Mullineaux, Dr Rose Perkins and Dr Martin Whitehead.
Q12 The Chair: Good morning, and welcome to the Lords Committee on the Environment and Climate Change. Today is the second session of our inquiry into pet parasite medications, and we will look at the issue from the perspective of the veterinarians.
Before we start, may I remind everyone that the session will be webcast live on Parliament TV, and that a transcript will be taken and made public. Witnesses will have an opportunity to review the transcript and, if necessary, make very minor amendments. Members are reminded that they should declare any relevant interests the first time they speak, and that also applies to our witnesses. I will just take the opportunity here to say that I am a director of Peers for the Planet.
Let me start by thanking our witnesses. We are very appreciative of the time that you have taken to be with us this morning. Could I ask if each of you could say a line of introduction?
Dr Elizabeth Mullineaux: Good morning, and thanks for the opportunity to be here. I am senior vice president of the British Veterinary Association, and the BVA officer with responsibility for small animal products in particular. By trade, I am a GP vet, so I have spent over 30 years in general practice, mixed and then small animal. I am also a recognised specialist in British wildlife medicine.
Dr Rose Perkins: Good morning. I am a vet and a visiting fellow at Imperial College’s Grantham Institute. I have been a vet for 20 years. I still practise as a vet. I should declare the conflict of interest that I still work as a vet in practice and do sell parasiticides. I did my PhD on environmental exposure pathways for fipronil and imidacloprid used in pet flea treatments, and that was funded by the Veterinary Medicines Directorate.
Dr Martin Whitehead: I am also a general practice vet, but I do some referral and zoo work as well. I have been a vet for 27 years, 17 of those running a general practice, and 14 of them also owning that practice. I currently am employed by one of the large corporate groups, because I sold my practice to them. If I do see cats and dogs that would need parasiticides, I would be selling them to make a profit for my employer, as all vets do.
The Chair: Could you name your employer?
Dr Martin Whitehead: It has just changed its name, in fact. It is called Inspiring Vet Care, but most people would know it as Independent Vetcare.
The Chair: Let me start by asking each of you to give us an introduction as to why these chemicals are necessary. What are the main pet parasite products sold in the UK? Where can people buy them? Can you also address how their use has changed over recent years? Who would like to start?
Dr Elizabeth Mullineaux: I am happy to start with perhaps an overview of how things have changed. Certainly, when I and Martin graduated, our only way of treating fleas in dogs and cats was to pin the dog down or scruff the cat and spray it with an aerosol insecticide. As a consequence of that, we saw animals with really quite bad flea infestations. Several times during an evening surgery, we would see pets with flea allergy dermatitis.
We then moved into a different stage where new products were available. They were easier to use and allowed us to prevent problems rather than necessarily treat them. Those products increasingly also became multivalent and, at the time, we were quite excited about this. You could use a spot-on that did not just do fleas but also did ticks and worms. Wasn’t that wonderful?
Also, alongside that, what has happened is that owners’ relationships with their pets have changed. Dogs and cats largely lived outside or in the kitchen. These days, dogs are on the sofa; they are in people’s beds. I would say people have potentially also become a little bit more risk-averse. Initially, we are talking there about the parasites, but we might also talk about the environment going on with that.
As Martin has also alluded to, as part of this perfect storm, we have also had corporatisation of the vet profession, which has meant that this reason for regular prevention has become commercialised to some extent. That has meant that the selling of regular monthly treatments has become the norm.
Alongside that, we have also had some change in licensings by the VMD, so some of these products are now also very much out of veterinary hands. They are for sale on the internet. That has led us to where we are. At the same time, we have realised that some of these products are really environmentally damaging and that we need to backtrack at a rate of knots, which I hope we are beginning to do, but we probably need to do it more quickly than we are doing.
Dr Rose Perkins: Just to address your question about the different products and market shifts, we do not have very recent sales data for most pet parasiticides, but the data that we have indicates that fipronil, imidacloprid and fluralenar are the most widely used products.
Historically, fipronil and imidacloprid dominated the market, and those are the products that I did my PhD on and for which we have the best evidence of environmental pollution. There has, however, been a market shift over the last several years towards a new class of flea treatment called isoxazolines, which are available as tablets.
The Chair: Why has that shift taken place?
Dr Rose Perkins: There are a variety of reasons. They work in a different way. They are available as tablets, which are primarily given to dogs, so they are very convenient. They are extremely effective. I would argue that they are more effective than the older products. They are also available as spot-on products, which tend to be administered to cats, because cats are seen as difficult to give a tablet to. They work in a different way, in that a proportion of them are absorbed systemically into the body. I will not go into the detail of what happens to the rest of it, because we do not really know.
In terms of sales, we know that imidacloprid sales peaked in around about 2017 and have been slowly declining since then. The sales data that we have for 2017 is 4,200 kilograms, and about 2,900 kilograms in 2024. Fipronil sales seem to have been fairly steady over the last several years. We do not have very good recent data for isoxazolines, but my understanding is that those sales are really increasing.
In terms of distribution routes, isoxazolines are primarily prescription-only medications at the moment, so a lot of the shift has occurred in veterinary practices. Vets are shifting away from fipronil and imidacloprid for a variety of reasons, including pollution concerns. Vets are shifting towards these new isoxazoline products. Fipronil and imidacloprid are very easily available from supermarkets and online. My understanding is that they are primarily sold online at the moment.
Isoxazolines are sold primarily by vets. They are prescription-only but are becoming more accessible. In the last year or two, some isoxazoline tablets for dogs have been made available in the NFA-VPS category, which means that they can be sold with professional advice from a pet shop or online.
Dr Martin Whitehead: There are four reasons to sell parasiticides. One of them is animal health and welfare, and that is the one that probably immediately comes to people’s minds—preventing flea infestations or worms or suchlike.
One of them is human health concerns, because some of the things that animals get can infect us.
One of them is what you might call intangible benefits for owners—peace of mind, not having to think, “My cat has some horrible, yucky parasite inside it”, or something like that, and not having to think, “Maybe I will get a flea infestation one day”, and also appearing to be a “responsible” owner. The veterinary profession has put a lot of effort—not necessarily deliberately, but they have done so—over 20 years or so to convince clients, “You need to be treating your pet regularly – that is part of ‘responsible’ ownership”. My own view is that the huge majority of the parasiticides that are sold are sold to that intangible benefit market.
The fourth is that you make a profit from selling them, and they are a very large contributor to veterinary professions’ income, and to anybody else who sells them.
I would also point out that part of the reason that there has been a shift away from fipronil and imidacloprid towards newer compounds is because the newer compounds probably are better in the sense that they kill the fleas more quickly and may be more effective at that, but vets also want, as businesses, to distinguish ourselves from what you can buy in a supermarket or get hold of very easily without a vet. We can put across the advantages of isoxazolines and say, “It is better than that fipronil and imidacloprid stuff you can buy elsewhere”.
The Chair: Thank you. You have outlined four reasons why these are necessary, if you like. Does the veterinary profession recognise the growing concern around the impact of these very persistent chemicals, as we understand from our evidence last week, on the environment and their accumulative potential?
Dr Elizabeth Mullineaux: Yes. I would say that realising that concern has taken time. Vets are dealing with a whole range of things, and it has taken time. We have about 20,000 members, and we survey about 2,000 of them on a regular basis. Some 93.5% of the people who responded to our recent survey were concerned about the environmental impact of small animal parasiticides. Over 70% agreed that any blanket prophylaxis was inappropriate. Nearly 80% agreed that there should be a lot more restrictions on the sale of small animal parasiticides.
The Chair: We will come to the way that these chemicals’ use has changed.
Dr Elizabeth Mullineaux: Vets are aware of the risks, and I would say that that has been part of the shift away from fipronil and imidacloprid. The concern there is whether we have any certainty about the environmental risks associated with the alternative products, but there has been a shift.
I would agree with Martin that some of that shift is perhaps also commercial. If you can buy fipronil online very easily, why would you buy it from your vet? You can go to your vet, who has an alternative product which is an injection or a tablet, and which is maybe easier to give. The evidence would suggest that it is going to be a little bit better as well. Some of the shift is concern, I would say, with individual vets. Some of the shift, perhaps more at a vet practice or corporate level, is a commercial one as well.
The Chair: Has the fact that it has been corporatised—I think that that was your word—made a material difference to the way that these products are passed on to pet owners?
Dr Elizabeth Mullineaux: Yes, it has. I would probably refer you to the Competition and Markets Authority inquiry on this. The CMA has singled out pet health plans, where you get a range of services, but almost always including these parasiticides in some form, as being a potential issue where people were making a monthly payment for a package of things, and that was not necessarily of value. One of the CMA’s remedies that will go into its order at the end of September will be around transparency in those pet health plans and also offering price comparison prescription for these products.
What vets are doing is moving away from product in pet health plans anyway. I know we will go on to this, but there is a risk that we push people away from buying these products from vets. At the moment, they can just go online and buy some of the ones that we understand to be the most damaging.
The Chair: Who collects the data on how much of these products are sold through the different avenues?
Dr Rose Perkins: The Veterinary Medicines Directorate has made some of this data available, but it is not monitored in the way that antibiotic use is. There is a requirement for antibiotic use to be published every year, but parasiticide use is much harder to get hold of, so you have to submit freedom of information requests, and it is usually only data from several years ago that is available.
The Chair: The VMD has that data, does it?
Dr Rose Perkins: It has data from the past. It does not collect it very routinely. It is not contemporary, as far as I am aware.
The Chair: The producers of these drugs must know exactly how much is being sold, because there are profits.
Dr Rose Perkins: Yes. One of the companies has made available some of its sales data. A paper that came out recently looked at imidacloprid levels in waterways, and that was funded by one of the market authorisation holders that made available some of its sales data.
The Chair: Is it acceptable that the overall use of these chemicals cannot be quantified?
Dr Martin Whitehead: No, it is not acceptable. In fact, if you were likely to ask for recommendations later, one of my strong recommendations would be that the VMD should collect this data and publish it every year, as it does for antibiotics.
Q13 Lord Trees: Thank you for coming and giving us your time. I declare an interest as a veterinary surgeon. I did work for Elanco many years ago, between 1977 and 1980, but before any of these compounds were available anywhere. I was not involved with that and I have no current involvement with the pharmaceutical industry directly.
Could I just follow up on the segmentation of particularly imidacloprid and fipronil in terms of the marketing authorisation category? I am interested because recommendations in future, either from the VMD or from this committee, might involve changes to that. I know we do not have hard data, but could you give us estimates of the percentages of imidacloprid and fipronil products that are sold GSL or online, and the amounts, if you like, as well, compared to those that go through a prescription-only route?
Dr Rose Perkins: We did a survey a few years ago that looked at parasiticide use in pet owners, and they told us what routes they were purchasing their parasiticides through. This is from several years ago. The study was from 2000 and we published it in 2023, so it might have shifted a bit now, but 70% bought their parasiticides through veterinary practices, 20% through online channels and 10% through other routes such as pet shops and supermarkets.
Dr Martin Whitehead: In terms of the 20% buying from supermarkets and pet shops at the time, they would have been able to buy pretty much only fipronil and imidacloprid back then.
Q14 Lord Lennie: You are in this crosshair between being the good guys treating our pets and animals, and the bad guys making lots of money. That is the kind of crossover that you find us at. How aware are vets of the emerging evidence about how chemicals get into the wider environment? Are you seeing this reflected in how different products are prescribed? You indicated that you thought that they were aware, but I just wonder how widespread that might be.
Dr Martin Whitehead: They are certainly aware that imidacloprid and fipronil are getting into the environment, because that has been published and is very frequently discussed in places such as the Veterinary Record and the Vet Times. I do not know to what extent they are so sure about how it is getting into the environment. That information is out there and has also been discussed a little bit, but I do not know to what extent they have extrapolated from fipronil and imidacloprid, where the research has been done, to many of these other newer compounds. We do not really know what is happening to those compounds, and nor did your panellists last week, so it is going to be even harder for a general practice vet to do that.
Lord Lennie: If there was a greater awareness, would it affect the prescription or the advice on drug use?
Dr Martin Whitehead: It would affect some vets, for sure. For instance, one of the other large corporate groups came up with a policy whereby they were going to stop using fipronil and imidacloprid because they were aware of the environmental consequences. Certainly, their heart is in the right place, but it might do more harm than good because we do not know what harm the things they are switching to are doing.
Dr Elizabeth Mullineaux: There are two parts to this. One is that we need to change the way that we prescribe. We are using these products really routinely. If you ask most vets what they use with their own pets, we do not treat our own pets in the way that some practices are selling these products. Some of that is about risk adversity with our clients. Our clients, as Martin alluded to, do not want fleas in the house. The drug companies have used that as a marketing thread, which is something we have pushed back on, but we need to change the way we prescribe.
These products are different to antibiotics, but, if you go back 20 years, we would give all routine surgery antibiotics as a preventative in case there was some nasty infection there. We do not do that anymore. We do not use antibiotics routinely around surgery. It would be considered incredibly bad practice to do that, so we need to start treating these products in the same way. We need to prescribe them where there is a genuine need, and that genuine need might relate to the pet. In some instances, it could relate to the human beings involved in that household as well.
We need to do something about the way we prescribe, but we also need to look at the products we prescribe. One of the concerns at the moment is that, yes, vets’ knowledge is, “Two of these products are really bad for the environment. Let us stop prescribing them and prescribe something else, but we do not know that the something else is safer, and we have drug companies marketing those products really aggressively. One six-month injection is great. It gives six months’ protection with just one injection. Isn’t it brilliant?” Maybe it is not, because we do not have the environmental evidence there.
There are two bits. We need to know more about the products, but we also need to change our prescribing habits as vets, and I hope we are doing that.
Lord Lennie: Is that because the research on the new products has been done in laboratories rather than in a real-time environment?
Dr Elizabeth Mullineaux: It is a bit of both. That is more Rose’s area than mine, but it is a bit of both. Things such as the songbird trust’s work around these products being in birds’ nests make the headlines of the veterinary press. We care about animals. We do care about what goes on out in the environment, so those have been really strong messages. There is some real awareness and concern, and there is the same awareness and concern with some of our clients. A cross-section of our clients definitely do not want these products because they have heard that they are bad, but the danger then is that we move to other products that we do not know are any better, which is why we also need to change the way we prescribe.
Dr Rose Perkins: One of the challenges that the veterinary profession is facing is that the BVA has stepped up and advised for judicious use. It has recommended risk-based parasite control. This phrase “risk-based parasite control” has become very popular and widely used, but the problem is that we do not really have a very clear definition of what “risk-based parasite control” means, and there are various potential interpretations of this.
One interpretation would be that we do risk assessments on individual animals, and that we target preventative treatment towards higher-risk animals and just monitor lower-risk animals. That is the interpretation that has been put forward by organisations such as Vet Sustain.
One example of this, just to illustrate how you would apply this, would be for fleas. We know that fleas can occur in any animal. It is very difficult to completely eliminate the risk of fleas, but there are certain factors that research has shown increase the likelihood of fleas. They are more likely to occur in summer and autumn. They are much more likely to occur in cats than in dogs, so one potential approach, if we adopt this interpretation, would be to target preventative treatment towards cats in summer and autumn.
Another interpretation is arguably one that has been put forward by industry-funded advisory bodies such as ESCCAP, which is a parasitology advisory body. ESCCAP parasitologists have often recommended year-round treatment for cats and dogs, based on the premise that, if there is a risk, you should treat preventatively. I would argue that that is blanket treatment, and that is exactly what the BVA and RCVS, which is the veterinary regulator, state we should not be doing.
The problem is that that risk threshold is very subjective. In my experience, what tends to happen in practice is that it just gets put very low. Vets get very risk-averse, and this is certainly incentivised by healthcare plans, which do incentivise a very cautious approach.
We need a paradigm shift from having routine prevention as the default, and perhaps not treating if there are some exceptional circumstances, to having no treatment as the default, and then perhaps treating if there is a confirmed high risk of infestation. This is what I do in my own pets. I just got a puppy recently. We have not treated her for fleas and are not planning to. It is still an experiment that we have only just started.
I have had a cat for nine years. I have never treated her routinely for fleas. She has had fleas once. We picked that up through a flea dirt test, which is a test that all pet owners should be shown how to do. It is a very easy test that helps you pick up fleas early. It cleared pretty much immediately with an isoxazoline tablet.
The Chair: What is the name of the tablet?
Dr Rose Perkins: Do you want the brand name? The active ingredient is lotilaner. It is a tablet called Credelio, which is the product I recommend for cats, and I am not getting commission from anyone for that. I am very much a fan of tablets versus spot-ons. I do not like spot-ons.
This approach is really supported by the evidence. It is more in line with the way that we use antibiotics. It is much cheaper. You save a lot of money. Isoxazolines are incredibly effective. There are half a dozen studies showing that flea infestations clear rapidly with isoxazolines, with no need for household flea spray. It really weakens the argument for routine prevention.
Lord Lennie: You should front up the advert—“Your vet uses this. Do the same”.
Dr Rose Perkins: Yes, absolutely. Vets know what works. That is one reason that these products should be prescription-only. Vets know what works. If people buy the products elsewhere, they end up getting products that are less effective. This is the approach that I recommend to clients, and I find that it works very well.
Q15 Earl Russell: Thank you very much for your evidence today. You say that vets know what works. Is it not the case that all the direction from the pharmaceutical companies is really to cut vets out of the equation and sell directly to consumers online, where they sign up to a 12-month plan and overdose their pet? That is a way of making profit. I just wondered, first, if you agreed with that, and, secondly, what your thoughts were as veterinarians on that relationship, which, to my mind—and you might not agree—is developing between pharmaceutical companies and direct-to-consumer products, and where the environment sits in it.
Dr Martin Whitehead: There are two separate markets. One is through vets, and the bulk of flea treatment still comes that way. The other is not through vets, and I am sure that the drug companies would love it if both of those markets did year-round flea treatment, because that sells the most parasiticide and makes the most profit, so they will be happy to promote that both ways.
I am fully in agreement with Rose and Liz, and the BVA and the RCVS, that we should not be doing that. Almost all the parasiticides that are preventively applied to pets are unnecessary, because the pet was not going to get a parasite in the time that that parasiticide was working anyway.
There is a very strong feed-down from above, and it is not just the vet. The drug companies are making money. Veterinary practices make money from it. Although it is a smaller factor for supermarkets and pet shops, they will be making some money from it too, and that is a problem with private medicine in humans or animals.
Q16 Baroness McIntosh of Pickering: First of all, can I declare my interest? I am an honorary fellow associate of the British Veterinary Association, of which I am very proud. We heard from Johnson’s that the over-the-counter sales value of AVM-GSL products alone is £100 million. Presumably, you are losing income if over-the-counter sales go in place of prescription. Is that the case?
Dr Elizabeth Mullineaux: We do not have data on exactly which products are being sold in which categories and to which people, in the right way. There is a lot of over-the-counter. Some of it is online. Some of it will be in supermarkets. Things such as pet insurance companies will deliver your flea control to you every month, and that is a GSL product that they are selling the whole time.
Certainly, the evidence that I have read would suggest that, for dogs, vets are still the main place that people go. For cats, it is a bit different. A lot of people have multi-cat households. People with cats have a few of them, and having them all at the vets is going to be quite costly.
In terms of the prescription-only GSL, we have that suitably qualified person in the VPS category in the middle, and even moving to that would be better than just general sales because it would give out some advice with that category. Very few of our veterinary nursing colleagues are SQPs—suitably qualified persons—because they do not see a benefit from that training. There could be some advantages to more of these products that are GSL coming back to VPS, so that they could be sold in veterinary practices in a different way.
At the moment, if you have a dozen cats, you have to take them to the vet’s. They all have to be individually examined, and then you either get a prescription or you get products supplied. For some households, that is a problem. I was speaking to a colleague who, until recently, worked for the Dogs Trust, and she said that that is an issue. Even within their clinics, they were selling GSL products because they were cheaper—fipronil, effectively.
In an ideal world, these would be prescription-only products because they would then be sold with proper advice, and vets would move to using them in the same way that we use other antimicrobials, but we need to think about some of the most vulnerable households. I do not want to go back to where I was 30 years ago, where I got houses that were infested with fleas and people with masses of animals who really could not cope with that, and would probably be unable to cope with the costs of some of the POM-V products as they are at the moment. We need to shift that market to make things more affordable.
Baroness McIntosh of Pickering: I am going to come on to prescription-only in a moment, but are you worried about the advice to bypass that pharmaceutical companies are giving to pet owners on these products?
Dr Elizabeth Mullineaux: Yes. Pharmaceutical companies are definitely doing it. When Rose was talking about risk assessment, there are some tools for vets to risk assess individual pet and owner combinations. They always result in you needing to treat the animal. I have genuinely gone in and played with them and tried to create the least risky household, but they still tell me I need to treat, so that is not at all helpful.
We have provided some resources to try to help vets. Vets are professional people. They are also very busy people. Between us all, we need to provide some easier resources, but every household and pet combo is a little bit different, so they do need to be really easy.
In terms of some of the marketing from the pharmaceutical companies, one that I personally pushed back on in particular was about tapeworms, but it was, “Tapeworms are gross”. It was not that tapeworms are a health problem for your pet or any human health risk; they are just gross. You just cannot advertise like that. That is not a reason for us using these chemicals. It is really wrong, but they still very much push monthly, year-round, convenient prevention.
Baroness McIntosh of Pickering: It is quite bewildering if you look at the distribution routes for these medicines. What would a risk-based approach to prescribing parasite medicines look like in practice? Would it be more beneficial to the pets and their owners if we went down that approach?
Dr Elizabeth Mullineaux: If you go back 20 or 30 years, some of the drug companies produced things for you to look at in terms of what the risks were, and they worked very well, before we moved into more routine treatment. We need to look at the owners. It is a questionnaire, really, about the number of pets and the number of owners. That is the first thing. In very many situations, as Rose suggested, you would not need anything at the moment. We then need to be in a position, when people go in and say, “Now my cat has fleas”, that we are able to give them the right advice, which, again, would involve asking about other pets in the household, dogs going to doggy daycare, and getting a proper picture so that we can prescribe the right product in the right way.
I am saying “we”, which would be veterinary surgeons. It is possible for that advice to be given by other people. Veterinary nurses would probably be my preference there, but some, although not many, suitably qualified persons do give this advice for farm animal products and can be trained to do small animal work and make the products accessible to everybody. Not everywhere in the country will have a small animal SQP on their doorstep.
Baroness McIntosh of Pickering: Rose, we heard earlier that the CMA has got you under the cosh. If the monthly pet plans are going to be reviewed, is this a good opportunity to look at prescription status and the way these drugs are administered?
Dr Rose Perkins: Yes, absolutely. I am not particularly in favour of making these products NFA-VPS. I do appreciate that there is an argument for lower-income people. Taking the example of someone with a dozen cats, when the cats need vaccinations—because they should be getting them—they will need to take them to a vet for that. They will need to take them to a vet for any other prescription medication, such as antibiotics.
All of the factors that justify the requirement for a prescription are present for parasiticides. They are hazardous products. We know that they are dangerous for the environment. There are potential risks for human health. There are potential risks for resistance, which we have not touched on yet, but that is a real concern.
In terms of keeping them as NFA-VPS, I have done a little bit of research on this. I have gone to my local pet shop. I have spoken to SQPs about pet parasiticides. I had a look online. The SQPs who I spoke to were not aware of the environmental risks around fipronil and imidacloprid. I know that AMTRA has been making efforts to educate SQPs, but none of them was aware of it. They all recommended blanket treatment when I asked what advice they give on parasite control.
Fipronil and imidacloprid are easily available online, even when they are in the NFA-VPS category, so there are already fipronil products sold as NFA-VPS. You can buy them easily online. I do not see how you could get any suitable professional advice when they are primarily being sold online. You can also buy NFA-VPS products easily through subscription schemes with no problem and no barriers whatsoever.
I struggle to see how this proposed change is going to affect pollution levels at all, whereas, if we were to make these products prescription-only, I am quite certain that usage would plummet because vets do not use these products. I mentioned the survey that we did a while ago. One of the interesting findings from that—you have to dig into the data to see this—is that quite a few vets who responded to the survey told us what they use in their own pets. They do not use fipronil. We had one vet, out of 100 who responded to the survey, who reported fipronil as the primary product they were using in their own pets.
Lord Lennie: That is because they know about the environmental effects.
Dr Rose Perkins: They know that it is polluting and that it is ineffective. If we make these products prescription-only, vets will not sell them.
Baroness McIntosh of Pickering: Denmark has gone down that route.
Dr Rose Perkins: I am not sure that it has. I have tried to look into that. It is not clear to me that they are prescription-only. I would have to check that for you. I have been trying to find out for certain about that, but there absolutely is a very strong argument that these products should all be prescription-only.
Baroness McIntosh of Pickering: Martin, one of the issues seems to be, from the written evidence, how to define “prophylactic” use. Are you concerned about the findings perhaps being camouflaged by a lack of understanding of what the use is?
Dr Martin Whitehead: Yes, but, if I could first add to something Rose just said, in the current VMD consultation about changing the products from GSL to NFA-VPS, there is, from the VMD, a massive assumption that that would result in useful professional advice to purchasers of these drugs, which I just do not see being the case at all. I would say that what the VMD should do is a bit of secret mystery shopping and buy some stuff off the internet or from pet shops. That would be a very useful thing to do.
As for defining “prophylactic”, if animals come to the vet and they have an infestation, every vet will be very happy to treat. I am dead against prophylactic use and I certainly would be treating them if it is a harmful infestation. It is like Liz said – if I see a cat with tapeworm, you are treating it because the owner does not like it. But, for fleas, definitely.
If they do not have them, that is where the risk base comes in. You ask them about their cat. You think about the time of year. If somebody comes to me with a dog or a cat in the middle of winter, they are very unlikely to be getting fleas, although it is not impossible. You can ask, “How many cats do you have?” If they have six cats that are all going outside and interacting with wildlife, maybe one of them will bring fleas in, but, if they have one cat, it is very unlikely at that time of year. Even in the middle of summer, the probability is that it will not get fleas, so my advice, providing the cat is amenable, is, “Comb your cat every day, just very briefly. The cat will probably enjoy it. If you see flea dirt, come and get some product and we will give it to you”.
It is not just the probability of whether the animal will get a parasite. It is also the consequences of the animal having a parasite. Some dogs and cats have an allergy to flea bites, and they get really terribly itchy. If you have a dog or a cat that you know gets this terrible allergy to flea bites, I may be inclined in the summer to say, “Maybe let us treat it over the summer”, which is the high-risk period, whereas I may not do that for a cat that does not.
If you have a young cat and the owner has a severely immune-compromised elderly relative or child living at home, younger cats are, theoretically, prone to getting a flea-carried bacterial infection called Bartonella, which can, in very rare cases, cause serious illness in those who are immune-compromised, so there is maybe another reason. It might just be that it is a blind owner who is not going to notice fleas building up on their pet. That is risk-based prescribing. That is what we do in our practice.
Dr Rose Perkins: If I could just briefly make a point about this concept of professional advice, one of the underlying premises of providing professional advice alongside sale of the products is that, if clients are advised on how to use the products correctly—how to apply them and how to dispose of the pipettes—that will address pollution issues. Research that the VMD funded shows that pollution is occurring through correct use, so there is no evidence that incorrect application or disposal of the product is a source of pollution. Even if it is, it is not going to resolve the problem if we address that, because we know that the major routes to the environment are routine activities such as washing your hands for weeks after treating your pet.
The Chair: The current advice on correct use is not correct.
Dr Rose Perkins: No, not if we want to resolve pollution, and not if we are using them widely across the population.
Dr Martin Whitehead: I would describe it as distraction rather than just not correct.
Q17 The Chair: Before we move on, I just want to pursue this point a little bit further. I just want to completely understand what you said, which is that vets would not be prescribing these medicines in the volumes that we are seeing at the moment. Who sets a vet’s practice, and to what degree do vets have autonomy in their decision-making?
Dr Rose Perkins: That is a really good question. Guidance on responsible parasiticide use comes, I would say, primarily from ESCCAP, which stands for European Scientific Counsel Companion Animal Parasites, and, to a lesser degree, from RUMA CA&E, which provides guidance on responsible use of medicines. Both of these organisations are funded by the pharmaceutical industry.
As I mentioned before, ESCCAP representatives have largely continued to promote routine, year-round treatment for cats and dogs, even though, in my view, this is blanket treatment and goes against veterinary authority guidance. RUMA CA&E has not really said much about this. It has issued a very vague statement, saying that we should use medicines responsibly but there are too many knowledge gaps to know what to do about the pollution, so implying that we should carry on as we are.
I would just point out that both of these organisations have really obvious and substantial conflicts of interest. I would also say that the conflicts of interest around parasiticides are particularly acute. We know that they are highly polluting and also highly profitable products, so that is quite a dangerous combination, and there is a huge incentive to keep selling them.
In human medicine, the importance of managing conflicts of interest when it comes to developing guidelines on responsible medicine use is well recognised. The scientific bodies that develop guidelines on medicine use have really stringent measures in place to manage conflicts of interest, so there will be things such as a requirement that the chair of a panel has no funding from the pharmaceutical industry or has no conflicts of interest. Most of the panel members should not have conflicts of interest, and that kind of thing, with complete transparency.
Also, they will have really rigorous methods for developing guidelines on medicine use, so ways that we assess the body of evidence. We do systematic reviews of the evidence and we come up with balanced, evidence-based guidelines, but there is very little of that in the veterinary profession. There is a lack of appreciation in the veterinary profession of the gravity of the conflicts of interest surrounding the guidance that we get on parasiticides and that we are passing on to pet owners, and the potential bias that this introduces into the advice that we are giving to pet owners.
The Chair: Would it help if the VMD was to fulfil its responsibility and provide phase II environmental risk assessments—ERAs—so that we have the ecotoxicological data that we need?
Dr Rose Perkins: No, not necessarily. It is safe to say that these products are all hazardous, so they all pose a potential risk.
The Chair: Do we not need that definitive information, given that, at the moment, the Environment Agency cannot or does not collect the data?
Dr Rose Perkins: Yes. That data should absolutely be part of the environmental risk assessment, but, if we are talking specifically about the development of guidelines and who should be providing guidance, it is a separate issue from their environmental risk assessment. Of course, that should feed into the environmental risk assessment. The problem at the moment is that, as far as I am aware, the last time I checked, ESCCAP in particular has no mention in its official guidance of environmental risks, even though we know that there are environmental risks.
The Chair: Should it be the VMD’s clear responsibility to provide more detailed guidance on responsible use to vet clinics?
Dr Rose Perkins: I am not sure whose legal duty it is to provide that guidance. My feeling is that it is the veterinary profession—
The Chair: You said that suitably qualified persons are not well enough informed, if at all, on the environmental hazards of these compounds, so whose responsibility is it to disseminate this information to the point of sale?
Dr Rose Perkins: The organisation that has largely provided guidance to the people who are selling the products has primarily been ESCCAP, but I would argue that the veterinary profession does need to—
The Chair: What about pharmaceutical companies? What responsibilities do they have?
Dr Rose Perkins: They provide guidance as well. There are lots of promotional activities. They provide continual professional development activities. They sponsor talks at congresses. My view is that there should be an independent scientific body that sets the standards. At the moment, it is being set by organisations that have huge conflicts of interest. There needs to be an independent body that sets the standards.
The Chair: Who should that body be?
Dr Rose Perkins: We do not have one at the moment. There needs to be one.
Baroness McIntosh of Pickering: Should it not be the VMD?
Dr Rose Perkins: It does not provide detailed guidance on medicines use. What tends to happen in the veterinary profession is that it collaborates with other organisations. It is involved with RUMA and with SCOPS. All of the organisations that provide guidance on parasiticide use tend to have the VMD collaborating with NOAH, which is the pharmaceutical trade organisation that does a lot of lobbying for the pharmaceutical industry. It is heavily involved in the guidance that is developed for vets. It tends to all be very influenced, in my view, by the pharmaceutical industry. There will be some independent vets as well.
Baroness McIntosh of Pickering: What slightly concerns me is that the pharmaceutical companies are not setting guidance. It is a promotional thing that they are doing. It is not setting guidance as to what the pollutant could be or what the adverse effect on the pet could be.
Dr Rose Perkins: Pharmaceutical companies are involved, to some extent, in the guidance. RUMA CA&E’s treasurer is the chief executive of NOAH, which is the trade organisation. Basically, with RUMA, effectively, the person holding the purse strings for the organisation providing guidance on medicine use is the chief executive of an organisation that lobbies for the pharmaceutical industry, and this is considered normal in the veterinary profession.
Q18 The Chair: We will do a whole session on the question of policy implications, so we will park this discussion here. Just on a few factual points on this issue, can you say definitively which category fipronil and imidacloprid come under? Where do the newer products sit in those distribution categories? Where would you like them to sit?
Dr Martin Whitehead: Fipronil and imidacloprid are on the general sales list. That is what they call off-the-shelf. Most of the parasiticides, and especially most of the newer ones, including this group of compounds called isoxazolines and bispyrazoles, are ‘Prescription-Only Medicine—Veterinary’, so they need a prescription sold by a vet, or the owner to have been given a prescription.
The Chair: That is POM-VPS, is it?
Dr Martin Whitehead: Yes, well-.[1]
The Chair: You will have to use the technical terms.
Dr Martin Whitehead: There is POM-V, which is by a vet,[2] and then there is POM-VPS,[3] which is vet pharmacists, – who I suspect sell relatively little of it – and the “S” is for Suitably Qualified Person. Most of those products are in there.[4] A few of the isoxazoline products are in the NFA-VPS category, so you can go and buy those. I forget the precise names.[5]
The Chair: I have another quick question that I would like an answer to. What is the price difference in terms of prescription by going to see your vet? What is the consultation fee? How much are you going to pay for the medication as opposed to buying it off the shelf? That will be a key consideration for people with pets.
Dr Rose Perkins: In my experience, what tends to happen in veterinary practice is that, when animals come in for their annual vaccination, a script will be quite often put up for whatever parasiticides are considered necessary. They will often not necessarily be handed out at that point, but, if the animal needs a parasiticide at some point over the next 12 months, it is usually a 12-month script that they can just ring up for and get, so there is no need to come back for a consultation.
In terms of cost, fipronil and imidacloprid are generally cheaper if they are bought online. One of the issues that was raised by the CMA was the fact that veterinary practices were quite heavily marking up parasiticides if they were not sold through the healthcare plans, which helps to argue that the healthcare plans are very good value for money because they are so much cheaper than the alternatives that are not provided through the healthcare plans, but, if you buy them through independent pharmacies with a written prescription, they are a lot cheaper. That written prescription would cost money. It is usually about £28. That is what it costs at my practice. There is an additional fee for prescription products, but, in my view, it is absolutely worth it.
The Chair: You do not think it will be particularly onerous financially on pet owners.
Dr Rose Perkins: I do not think so.
The Chair: That is an important point, so if you have any further thoughts on that, could you write to the committee?
Q19 Lord Krebs: Thank you to our witnesses for being here. I want to ask a bit about the prevalence of pet infections from parasites. We have been given various figures. The group at Imperial College, which you, Rose, are associated with, said the largest published survey of veterinary consultats identified fleas in one in 400 dogs and one in 85 cats, and ticks in one in 150 dogs and one in every 625 cats. On the other hand, NOAH has told us that one in four cats and one in six dogs have fleas, so we have very divergent views. Can you give us an insight into which of those estimates is more accurate?
Importantly, if we changed from prophylactic to reactive prescription, would the flea and tick population in companion animals go up? Rose said that she does not treat her pets routinely and that they rarely, if ever, get fleas or ticks, but maybe, if everybody else stopped treating their pets routinely, the flea population would blossom. What is the best estimate of the prevalence and how would that prevalence change if we went from prophylactic to reactive prescription?
Dr Elizabeth Mullineaux: I have those same figures that you just quoted. That was the best data that I could find.
Lord Krebs: Which one?
Dr Elizabeth Mullineaux: The one in 400 dogs. Of course, that is against the background of us currently treating prophylactically. It is not that straightforward, in that the flea population waxes and wanes according to temperature, so we get some years that are really warm and the fleas go crazy. One of the arguments for using year-round flea treatment is whether you would get the same issue when you put your central heating on.
We probably will see more fleas, but, when I opened the session by talking about how we used to treat fleas, we did not have terribly effective methods of treating them. We now have some really good products such that, if somebody comes in with a dog that is really hooching fleas, we can get rid of those really quickly compared with the products that we used to be able to use, such as sprays and things.
There would have to be some increased awareness as to how you look for fleas. I have a black dog and it is not that easy to spot fleas on them, but that can be part of what vets teach owners right from the beginning with puppy and kitten consultations. Instead of us saying, “Of course, you will need to use this product every month”, we could teach them some skills to be able to recognise parasites in their pets, and know when to come and see us and when we need to intervene. It is a little bit of re-education, but that is really useful, and anything that encourages conversations with our clients is a good thing.
The figures probably are somewhere between those, but they will also wax and wane over the year. If you have half a dozen cats, a flea problem is quite quickly going to get significant in your house, whereas, if you have just one dog, you might never see a flea from year to year. I treat my dog once a year in the tick season, and that is all I do, but she is a single dog and is not in contact with other dogs. That might be really different for people in other situations.
Dr Rose Perkins: Looking at the studies that you mentioned, the first one with the much lower prevalence was a SAVSNet study from Sean Farrell at the University of Liverpool. That looked at veterinary electronic health data. They collected vets’ notes across millions of practices, and that study had about 6 million cats and dogs in it.
Lord Krebs: This is the one that we got from Imperial College.
Dr Rose Perkins: Yes. That is the figure of one in 400 cats and one in 85 dogs. There are a couple of things to say about that study. Every study will have pros and cons and drawbacks. It is possible that that prevalence was slightly underestimated because not all pet owners are aware that their animals have fleas, and not all animals would have been checked for fleas. These were just routine consults and, if vets happened to identify fleas, they made a note of it.
On the other hand, you could say that animals are perhaps a little bit more likely to present at the vet if they have fleas than animals from the general population, because some people do take their pet to the vet if they have fleas.
There is a bit more to say about the other study. That is the Abdullah study from 2019. This is the one that is very often cited by industry, and it had a far higher prevalence than the SAVSNet study. Some 28% of cats were reported to have fleas, and 14% of dogs. That was a much smaller study that involved 800 cats and 600 dogs. In that study, they got vets to check animals and do a flea prevalence check, but there are some problems with that prevalence figure.
The first issue is that there were no randomisation protocols in that study. They do say that animals were randomised, but the protocols are not described. Another study done a few years previously used exactly the same methodology and looked at ticks. In that study, they found a prevalence of 30% of dogs having ticks. The authors of that study explicitly said that their method of participant recruitment was likely to have inflated the prevalence values. I have checked with the authors and it was exactly the same recruitment method.
I worked in a practice that participated in that study, and the instructions that filtered down to me as a practising vet were, “If you see a tick, collect it and fill in the form”, so there was no randomisation, and I am sure there was quite a lot of selection bias in that study. I find that figure very difficult to square with what I see in practice. In terms of one in four cats having fleas, I would challenge anyone to go out and do a random flea comb on any cats they come across and find that one in four had fleas. I have been in practice for 20 years around the country. A worst-case scenario would be in the middle of summer in a place that is prone to fleas, and you would probably see a few fleas a week, but it is very normal in practice to go for weeks without seeing fleas.
I would just note that they say roughly 50% of owners are unaware that their pet has fleas, so we are probably missing some.
Dr Martin Whitehead: The way that I would put it is that we have no idea what the prevalence of fleas is. The Abdullah study was funded by industry, and there are some severe defects in that. One of my favourites was that they specifically asked people not to count dogs and cats that came in with fleas,[6] but to include free flea checks, which is where people bring their dogs to us.[7] There were biases in that study very much to increase the prevalence of fleas, but the truth is we absolutely do not know the prevalence of fleas. It varies a lot from year to year. It varies from north to south, up and down the country, and probably from city to countryside as well.
Lord Krebs: Thank you. Those were very helpful answers to my main question. If I may ask a supplementary question, do we have a similar degree of uncertainty about how many cases there are of humans contracting zoonotic diseases through companion animals? The VMD lists a whole lot of alarming things that you can catch from fleas and ticks. Do we have any idea of how much of that comes from companion animals, in terms of the prevalence?
Dr Martin Whitehead: It is very little. The main zoonosis from fleas is the Bartonella bacterium that I mentioned earlier. There has not been a huge study done in England. The US has more fleas, especially in the southern states. Using data from American workplace health insurance, which is the nearest equivalent to our NHS, researchers looked at 280 million person years of data trying to find evidence of bartonellosis. The figures were about 45 cases per million, of which two per million were serious enough for hospitalisation. The average hospitalisation time was three days. There were no fatalities. This is a very mild disease in the vast majority of cases.
The nearest data we have in the UK is from the UK Health and Safety Authority, which used to be Public Health England. It publishes a zoonosis report. It does not even include Bartonella because, basically, it is not either common or serious enough to be included. NHS England publishes lists of all the diagnoses of hospitalised patients. Over the period from 2022 to 2024, there were 10 cases of Bartonella diagnosed in hospital a year in England, which has maybe 60 million people, so you are looking at one in 6 million people. This is incredibly rare. Although there are case reports of people with severe other illnesses being badly affected by Bartonella, it is not clear that you need to treat tens of millions of pets dozens of times a year in order to reduce that risk.
Dr Rose Perkins: What I find quite interesting about the NHS data is that they include diagnoses of bartonellosis, but they do not specify what kind of Bartonella it is. There are other forms of Bartonella and one of those, interestingly, is Bartonella quintana, which also occurs in the UK, but that is not spread by fleas; it is spread by lice. If we were to apply this logic to kids, we should be applying insecticides to our kids all year round to prevent a rare disease.
Lord Krebs: Liz, was there anything in particular you wanted to add to what Rose was saying?
Dr Elizabeth Mullineaux: No. We do not have the data, and the data that is there would suggest that infection levels are incredibly low.
Lord Krebs: You have talked about flea-borne diseases, and you have mentioned Bartonella. Also, VMD mentioned Rickettsia, Mycoplasma and Dipylidium, so there are others, but I assume those are also equally rare. I just wanted to check on tick-borne diseases, particularly Lyme disease and tick-borne viral encephalitis. Is there any evidence that humans contract Lyme disease or tick-borne encephalitis from companion animals?
Dr Martin Whitehead: As far as I am aware, if you own a dog, you do not catch it off the tick,[8] and particularly the most common ticks in the UK. Lord Trees taught me parasitology. Once a year, they jump on an animal, have dinner, disappear off, and jump on another animal a year later, so that is not a procedure where you are likely to get illness.[9] Having a dog does make you go places where you are more likely to pick up ticks from deer and sheep, so there is a risk association, but you are not getting it from your dog. You do not generally get Lyme disease from your dog.
Lord Krebs: You have confirmed what Lord Trees told me before the session started, so thank you very much for having it on the record.
Dr Rose Perkins: On the question of whether we would see an increase in diseases if we decreased our level of parasiticide use, my view is that we have an extremely low occurrence of human zoonoses, as far as we know. All the data shows that the prevalence is extremely low. We know that coverage of the pet population with parasiticides, even though we are widely treating routinely, is not complete, so we do not have good data.
For argument’s sake, if we say that a rough percentage of pets are being treated routinely, if we stopped that and just treated reactively and had a proportional increase of infestations and zoonoses, then, arguably, we would have a doubling, proportional increase of the occurrence of those diseases. Doubling an incredibly rare disease still gives you an extremely low prevalence, and you would have an enormous decrease in pollution and human exposure to these chemicals and in resistance risks.
Q20 Lord Trees: In terms of the clinical prevalence or incidence of these parasites in the pets themselves, as you well know, generally, quite a lot of the animal population will get parasites, but only a few of them will suffer clinically. Do we have any secular data, for example, on flea allergy dermatitis in relation to the introduction of these products, particularly imidacloprid and fipronil? During the time that those have been used, has there been a diminution of those clinical presentations, or do we have any data on that?
Dr Martin Whitehead: I am pretty sure that we do not. Certainly, as an old enough general practice vet, there used to be clients coming in with more cases. We still see them, but there used to be more cases than there are now. I do not think that there is any data on that.
Dr Elizabeth Mullineaux: There might be some stuff from organisations such as SAVSNet. I do not have it to hand. We could have a look and see if we can find that for you. Martin is right. If you are as old as us, you would see a couple of consults every night with flea allergy dermatitis. We would sell a lot of steroids and related products. We do not sell those at all anymore.
Part of that is about the efficacy of the products we were using. We did not have great treatments, so even when we were treating, we were not doing it very well. Now, if we see those cases—it is rare to see them in the way we used to—it is very easy to treat them. We have very effective and easy-to-give products. We can give them in a variety of ways. If you think you have a compliance issue with a patient, it is very easy for them to administer things themselves.
I do not imagine we will drift back to the bad old days simply because we are not using these products all the time. We would if we went back to using the same chemicals we were using. We are in a much better position to be able to treat when we have to treat, but that does not mean we need to prevent in the way we have been doing.
Lord Trees: Thank you. That is very helpful. To what extent is there evidence of acquired resistance in ticks or fleas to these products we are discussing?
Dr Martin Whitehead: Nobody in the UK monitors that, and I am not sure that anybody is really monitoring it worldwide. There used to be a scheme for monitoring imidaclopid resistance. They did not find any, but I do not know if that is still ongoing. There is a very strong anecdotal view among the veterinary profession, which is backed up by a survey that has been published, that fipronil lacks efficacy. That is not the same as there definitely being resistance.
I would also point out that resistance is not the only thing you have to worry about. In, say, cyathostomin worms in horses, it has been shown that, if you very frequently worm, the wormer works, but the time after the worming until worm eggs re-appear, showing there is a new infestation, greatly shortens. You are selecting the parasites just to be more efficient, even though they are not resistant. We might well be doing that with all the fleas and worms in this country with the irresponsible way we are using parasiticides, but, again, there is no evidence of that because nobody looks.
Dr Elizabeth Mullineaux: There is some evidence that there may be some resistance to fipronil, but it is very localised. It is not a widespread problem, and it is unlikely to be a big issue. We do not have the data, though. We need to record this, and this does come down to vets reporting it as an adverse reaction and that the product seems to not be working. It is quite hard to judge because compliance is definitely an issue. If a person comes in and says that their fipronil is not working anymore, how are they applying it? Are they using it on all their pets? Do the pets go to doggy daycare? What is going on there?
There is a lot to unpick, but, as a profession, certainly at the BVA, we have been promoting the fact that you need it. If you think there is an issue with resistance, you should not just be selling an alternative product, because that is probably not what we want. We do not want to be changing between products unless we have good reason to be doing that, and we should be reporting that suspicion of any resistance.
Dr Rose Perkins: I am not aware of any research showing that fipronil resistance is uncommon or localised.
Lord Trees: Extending that, what about invertebrates in natural ecosystems that have been exposed, as your work has shown, to concentrations of these drugs in natural waterways? Is there any evidence of wild invertebrates, for want of a better word?
Dr Martin Whitehead: I do not think anybody has looked to see if there is acquired resistance. There is huge variability in the natural resistance level.[10]
I probably should clarify that there is no question that there are fipronil-resistant strains of flea. They have been taken out of the field and out of the wild, put in labs and studied, but the thing is, if you have a cat with a resistant strain of flea, and you treat it with fipronil and it does not get better, you nip down to the vets and just get one of any of the other products, and you clear it. It is not so much about whether there is resistance, but whether there is resistance that is causing a problem across the country. That is difficult to tell when you are using many different products.
Dr Elizabeth Mullineaux: We are bound to get resistance. We have very high reproductive rates in these things and we know we generate resistance in other parasites, so it would be unlikely, over a summer of a big flea build-up problem, that some of those individual fleas would not be selected to have resistance.
Dr Rose Perkins: I do see treatment failure for fipronil in practice on quite a regular basis. My practice does not sell fipronil, but a lot of people who bring their pets in, if they suspect a flea infestation or if their pet has a skin condition, would have tried it, so that is not uncommon at all.
That is not just my experience. As Martin said, this is very common knowledge in the veterinary profession. There is a study that showed very widespread treatment failure for fipronil. Cooper et al showed that 62% of cats and 45% of dogs that had been treated with fipronil and presented at a veterinary practice still had fleas. There is every reason to think that resistance might be out there. We know that resistance has developed in fleas to other parasiticides such as organophosphates, carbamates and pyrethroids. As Martin said, resistant strains have been demonstrated in the lab. There is just no active surveillance. Without looking, we cannot know what level of resistance is out there.
At the moment, regulators depend on passive pharmacovigilance, so they rely on the end user to report treatment failure. As far as I know, they have not flagged up any issues, which, to me, shows that that system is not working because we know that treatment failure is out there. Either it is not being reported or it is not being flagged up by the system, but this absolutely is a priority for research. We should absolutely be looking at this.
It is important because resistance drives increased parasiticide use, so if you have a resistant infestation, you will be treating for longer. You will be using more products. They are more likely to spread it to other animals. It also drives the perception that flea infestations are difficult to resolve, which fuels this narrative that they should be prevented at any cost and that routine prophylaxis is appropriate.
Lord Trees: The next question is about awareness, guidance and the advice that is available to pet owners. The VMD has launched an awareness campaign about appropriate usage. We had a bit of discussion about this earlier. Is the advice available to pet owners adequate? Given that a significant proportion of pet owners will buy over the counter, is the advice given on the products adequate? A particular example that we have already been made aware of is not to let your dog go swimming for two days after treatment, which seems to be very inadequate. Could you comment on the advice available to pet owners?
Dr Elizabeth Mullineaux: We would support the aim behind the VMD’s campaign, but we have the same concerns that you do about some of the advice. It seems to not go far enough. Dogs having spot-on products should not swim at all. If your dog swims or it is bathed regularly or something like that, you should not be using a spot-on product. The VMD has stopped short of saying that. There is also inconsistency in some of the messaging we are seeing. Some of it is two days; some is four days. It is really variable. The scientific evidence suggests that we would have wash-off way beyond two and four days.
There is more that could be done. It comes back a little bit to what Rose was referring to about how independent VMD is of the drug companies. If it is trying to support everybody’s products, that is not independent enough. It needs to be able to give independent advice that is correct across all the products, and then the manufacturers need to be labelling things accordingly. There could be much more visual labelling, such as, “Do not use this if your dog swims”, with a swimming dog and a big red cross through it. More could be done.
It has been based on the data sheet advice, and it probably needs to be more independent than that. How many of us read a whole data sheet when we take a medication or use one for our pets? The highlights of that data sheet need to be in a really usable, accessible form that is easy for everybody to read. Certainly at the moment, we have GSL products, and people are making those choices themselves. It needs to be really clear in terms of what products are and are not appropriate for their pet.
Dr Rose Perkins: The VMD’s own research did show that these products are washing off through correct use. As I said before, there is no evidence that significant amounts are getting into waterways through incorrect applications. This new campaign that it has launched, and also the proposal to change the distribution category, do seem to be based on the premise that, if we provide advice and if the products are applied correctly, we will resolve the issue, but that is not an evidence-based assumption.
In fact, in its recent campaign, it states that the products are safe and effective when used correctly, which is just not true. The products are not safe when used correctly. Its own research shows that. They are not safe for the environment. There are very serious questions about their potential risk to human health and about resistance, so I would argue that that is quite misleading communication. It is misleading the public about the safety of the products.
Lord Trees: I am sure we will pick this up with the VMD, so thank you.
Q21 Baroness Whitaker: If we could focus again on human health, not as induced by the parasites but by the treatments, there does not seem to be terribly conclusive evidence. Can you say what assessments have been made of the human health risk of pet parasite medications, and particularly exposure in the home—I would there include waterways and drinking water—and also, of course, in the workplace for the vet themselves?
Dr Rose Perkins: This whole field is quite poorly understood. The research on human exposure and health risks from pet parasiticides is quite limited and quite inferential. We know that these chemicals are selective for invertebrates—they are insecticides—but they can have effects on people. Both fipronil and imidacloprid are classified as moderately hazardous to human health by the World Health Organization. There are examples of fatalities from poisoning from these insecticides.
The real concern is not so much obvious poisoning, but more subtle, long-term health effects through prolonged exposure. We know that they disseminate widely in the home after spot-ons are applied to pets. Our research group at Imperial recently did a study looking at dust and mop water in the home, and we showed high levels of imidacloprid in the homes of treated pets.
We know from our previous research that residues are constantly present on the hands of pet owners for weeks after applying the product, so we know that long-term skin exposure is occurring. There are very few studies looking at internal absorption and how much gets absorbed into the system, and what the potential impacts of that might be, but there are emerging concerns around these chemicals.
It takes a very long time, quite often, for the full implications of any hazardous chemical to be fully understood—not just the environmental risks, but also the human health risks. It is very difficult to fully assess the risks in any risk assessment. There is new evidence that is coming through regarding these chemicals. One particular concern is the potential to act as endocrine-disrupting chemicals. These are chemicals that can affect hormone levels in the body, and they can have effects even at extremely low doses and potentially affect things such as fertility and neurodevelopment.
Fipronil and its toxic breakdown product, fipronil sulfone, have been identified as potential thyroid-disrupting chemicals, so one particular concern is around pregnancy and early life exposure. We know that foetal neurodevelopment is extremely sensitive to thyroid hormone disruption at critical periods of development.
There is a study that found that fipronil exposure in mothers was correlated to lower levels of certain hormones in newborns, and also with lower Apgar scores, which is a standard measure of newborn condition. Exposure sources were not investigated in that study. They do not know where the fipronil was coming from, but there was a report on fipronil health risks from California’s Department of Pesticide Regulation.
Baroness Whitaker: Are you saying that that is a correlation but not a cause?
Dr Rose Perkins: Yes, it is a correlation. Also, the exposure sources were not identified. There was a report from the California Department of Pesticide Regulation a few years ago, which looked at health risks from fipronil. It found negligible health risks from dietary exposure, but it did find a potential risk, through exposure to flea products, and particularly sprays and spot-ons, to pet owners, to children and to occupational users.
In that study, they looked at groomers. They did not look at vets. I am not aware of any user safety assessments for the products that have done occupational exposures for vets. The exposure is likely to be quite similar to groomers. We can easily touch 10, 20 or 30 animals a day.
The only exposure assessment that I could find in the veterinary literature was an assessment for a fipronil-based product, and that was for groomers. The assumption in that exposure assessment was that, basically, PPE was worn, so it included gloves and protective clothing. A lot of the time, the user safety risk assessments are quite opaque. A lot of detail is not available to the public, so it is quite difficult to see what risk assessments have been done.
Baroness Whitaker: It would be helpful if you could give us, in writing afterwards, the WHO references and why it considers it moderately hazardous, and, indeed, all the references, so we can have a look.
We did have some evidence about the possibility of autism. Johnson’s, having heard this evidence, wrote to us and said, “There is no such thing”. I know that autism has many fathers, and I imagine this was a correlation, again, if anything, but have you heard anything about that?
Dr Rose Perkins: There are a couple of studies, although not many, that have looked at this and have found some potentially concerning results. There was a study from 2014, which looked at maternally reported use of imidacloprid spot-on. They found that there were slightly increased odds of mothers of children with autism spectrum disorder having used imidacloprid when they were pregnant. That association strengthened: the likelihood of the children developing that issue was greater if the product had been used very regularly.
There was another study from last year by Goodrich, which looked at flea treatment exposure in the home. I cannot remember the details of that study, but they did find a correlation between flea treatment exposure during pregnancy and early life. The significant findings were for the older products such as powders and shampoos, and some of the older parasiticides that were associated with an increased risk of neurodevelopment. These were cognitive issues in children who had autism spectrum disorder. It was not with autism itself, but issues in children who had autism.
Baroness Whitaker: It sounds as if there ought to be a bit more done and perhaps larger surveys, looking at cause a little bit more exactly.
Dr Elizabeth Mullineaux: On that point, when we have gone through this, we have ended up with a long list of research requests and things we would like to be looked into. There is masses of it, but the reality is that research such as that does not always get funding, and it is very broad. It feels like the drug companies have been told that, until there is really good data, these products are fine to use.
I would like us to flip that around. We need to have confidence that these products are safe, within reasonable limits, if we are going to use them. We all knew that neonicotinoids were an issue for these, but we thought that putting these products on dogs was okay. The reason we thought that is that we had confidence that these products were safe, but we have learned that they are not.
That is what we need to flip around, because I do not think we are ever going to have all the evidence to prove that they are problematic across humans and the environment, but we need to take a precautionary approach, which needs to start with the pharmaceutical companies showing us that these products, within reasonable limits, are safe, and then we can use them with confidence. We are using them in people’s homes, and we are using them with pets that we are increasingly very close to physically, and that is an issue.
Dr Martin Whitehead: I would like to add to that. These products are not really medicines. They are being sold to treat dogs and cats, but what they actually are is pesticides. They are being given to dogs and cats to kill organisms on or in the dog or cat. You are not really treating the dog or cat, if you see what I mean.
There are differences in the way that pesticides are regulated. There are pesticides in arable agriculture on crops, and pesticides that are biocides for termite treatment in some countries, and for ant and cockroach treatment. These pesticides that are put on dogs and cats need to be regulated as medicines because they are being put on dogs and cats, but they need to be regulated as pesticides too.
Q22 Earl Russell: My question follows on quite nicely from your last comment that these are really insecticides that we are putting on our pets. The question I want to ask you is about the main gaps that you think need to be addressed to determine the comparative benefits of these products to animal and human health versus the potential costs to the environment. What more do we need to do to be in a better position to determine possible environmental impacts? How do we weigh those against the benefits from using these products for animal and human health?
Dr Martin Whitehead: This is one of these apples-and-oranges questions. As I started with at the beginning, ignore the profit side of it - you have a small human health benefit, an unquantified but fairly large animal health benefit, given that we are trying to stop animals getting bad flea infestations and suchlike, and the psychological benefits of the owners feeling better about such things, as well as convenience.
You are balancing that against harms not just to the natural environment but also to the household environment, as Rose has just explained, where, if you treat your dogs with these things, you are living in a sea of pesticides, as well as the development of resistance and maybe just making the parasites more efficient. There are other harms too. All medicines have adverse effects on dogs. If you do not need to be treating the animals—and we do not need to be using preventive ones on many animals—and they have adverse effects, that is unnecessary. There are the possible long-term health effects on humans. All of those are unquantified. There is 100 years of research to do there, I am afraid.
Where do you start? The single most useful thing we could possibly know would be to determine which of the parasiticides gets least into the environment and does the least harm when it gets there. If somebody could develop a parasiticide that we knew was completely broken down by the animal’s body into harmless things, we could all go, “Great. Let us use that”.
Earl Russell: I do not know if somebody else would like to come in, particularly on what more we can do to understand the impact of these products on the environment and, as you say, the pathways to how they get there.
Dr Rose Perkins: I can expand a little bit on that. The area that we really need to focus on is isoxazolines, because that is where the shift is occurring. We know that they are very toxic and very persistent. We are applying them in quite large quantities, but we do not really know where they are going, so that is definitely a priority research area.
I would also say that pet wormers have been a bit neglected. Something such as moxidectin is quite a concerning chemical. We use it as a wormer all the time, but, from my understanding, it is persistent, toxic and bio-accumulative, which is a very worrying combination, so I would very much like to know what is happening with that.
I do have a bigger wish list of things that I would like to research. Resistance, as I have mentioned, should be an absolute research priority, so that we can maintain the efficacy of these products. They are important products and we need to make sure that they can still be used effectively. Then, of course, as I said, it is very important to look into human exposure and health risks.
I would also like to see more robust, independent research on pet parasites. One area that does need to be looked at is lungworm. That is often used as a rationale for routine worming in the UK, but we have very little data on the true prevalence of clinical disease from lungworm, so that is a research gap.
Dr Elizabeth Mullineaux: On a positive note, if we started prescribing in a different way and gathering information about pets and households and whether a product seemed not to work, and there were veterinary systems to do that, that would give us some of the information we are missing. We do not know which pets are most susceptible or which environments they live in, or what time of year it is. There are veterinary systems that could really gather that information, and that would be reasonably independent.
One of the issues that you are seeing is an argument between the drug companies and the environmental groups. Unfortunately, ordinary vets are caught up in the middle of that, so we need some genuinely independent research that gives us the facts. By virtue of us taking good histories about every family situation and prescribing only when we needed to, we would then start gathering some really useful information that would answer some of the questions.
The Chair: Where would that very useful information be gathered collectively?
Dr Elizabeth Mullineaux: There are a couple of veterinary systems. There is VetCompass, which is run by the Royal Veterinary College, and SAVSNet, which came out of the University of Liverpool. The six large veterinary corporates, of course, have their own datasets now. There is an opportunity there. With a system such as SAVSNet, you just put in some key things about the case you have just seen, and it is really useful.
Of course, everyone has a computer system now, so there are ways of gathering this, and, at a practice level, that is probably the best way of doing that. It is just about simple things such as, “Where are the products being sold? Which products are being sold?” We have not been able to give you definitive answers on that, which seems wrong. That information should be out there because it needs to be our starting point with this.
Lord Rooker: We have had a long list from the witnesses of things that they would like to see happen. Basically, I would be asking you to repeat yourselves in respect of the Government, the industry and the veterinary profession. In many ways, with a variety of your answers, we have a list from you of what you would like to see happen. Therefore, it would be quite superfluous if I asked you the same question again.
Q23 The Chair: There is only one thing that I would like to pick up on, which we have not discussed yet, and that is safe disposal schemes for these chemicals. Do any exist? Do we know?
Dr Martin Whitehead: There was what started off as a one-week antibiotic amnesty, where practices and some other organisations advertised to the public to say, “Bring your medicines, and especially your antibiotics, back to us”, but there is no big, formal scheme. One of the other recommendations, I am sure we would all say, is that there should be some sort of scheme for getting rid of these things. The National Health Service runs a scheme where people can take used medicines of any form back to pharmacies, and the National Health Service will pick them up and dispose of it in whatever responsible way they do, but there is no veterinary equivalent.
Dr Elizabeth Mullineaux: Vets will usually take back things that they have sold. If an animal dies, they would have that product back and dispose of it, but given that quite a lot of this is being sold outside of veterinary practices, there is nowhere for it to be returned. I would also say the handling and disposal information around particularly some of the spot-ons has been really variable. You hear dreadful anecdotal things about people washing out spot-on containers and things, so that needs to be better too. It needs to be easier for people.
The Chair: We have placed quite a lot of emphasis on making pet owners aware of how they can see whether they have a problem that would need them to go to the vet. Is that something that we can work on to raise awareness amongst pet owners, or is there awareness already?
Dr Elizabeth Mullineaux: There is, but we could change the emphasis. Most people who get a puppy or kitten will come into a vet practice, and you will have a consultation with a veterinary nurse and maybe see a vet. At the moment, that will have been talking through which products they might use preventatively, so we need to change that conversation.
If you are doing it with a new puppy, sometimes you have a new owner, or one who has not had a puppy for 15 years, so they are keen to learn, and that learning needs to be different. It does not need to be, “Are you going to use a spot-on or a tablet?” but, “Let us have a conversation about how you recognise these parasites, what you would do if you saw them, and which products you should be thinking about”. We can change those conversations at a practice level.
Q24 Lord Trees: I was disturbed by what you said, Rose, about SQPs not understanding the environmental damage. Could you send us a note or any evidence that you have for that? You had a bit of anecdotal evidence, but it is a bit worrying, since SQPs are meant to have some sort of expertise in terms of prescribing and dispensing drugs such as this.
Dr Rose Perkins: It was one or two who I spoke to from that small sample. I can write down and describe to you the conversation I had.
Lord Trees: Was that last week?
Dr Rose Perkins: No, it was a few months ago. Maybe it has changed in that time.
Lord Trees: That would be helpful.
Q25 Baroness McIntosh of Pickering: Could you write to us with the average price of a health plan? We have on record the cost of the drugs, but what the comparative health plans are, top and bottom, in various practices would be really interesting.
Dr Elizabeth Mullineaux: Yes, I am sure we can find that. I do not know if you have seen it, but there is a nice section in the CMA stuff as well about how these things are structured.
Baroness McIntosh of Pickering: It would be nice to get it on the record for this inquiry.
Dr Elizabeth Mullineaux: Yes, we can do that for you as well.
The Chair: Thank you. I am very sorry that we are over time, but it has been a really useful session. The enormous harm, which is what we are hearing with these chemicals in the wider environment, with implications for the food chain as well, is something that we need to increase awareness of. That could be a very useful outcome of this and then, hopefully, lead to better prevention of the issues around fleas and ticks. Thank you all very much. It has been very reassuring hearing from the veterinary professions. With that, I call an end to the public session and the committee will now move into private session.
