Written evidence submitted by NOAH (the National Office of Animal Health) (PEG0193)

NOAH (the National Office of Animal Health) represents the UK animal health industry. We promote the benefits of safe, effective, quality products and services for the health and welfare of all animals.

Animal health is an innovative, high skills-based sector: NOAH members, representing over 97% of the UK industry, employ over 4,000 people in the UK and indirectly support thousands in related industries. The authorised veterinary medicines sector is valued at approximately £725m of B2B UK sales every year. NOAH membership ranges from large global multinationals, SME’s to family-run businesses who manufacture, import and market products both within the UK and for global export.

The animal health sector is closely allied to the overall Life Sciences sector, with several companies involved in human and animal health. There is a One Health approach as policy in several vital areas:

• reducing the spread of antimicrobial resistance (AMR) through the research and development of new antibiotics, alternatives to antibiotics and preventative health approaches. The medical and veterinary professions (mirrored by the companies that serve them) are in full dialogue in this area
• the fight against new exotic diseases through surveillance and the development of new technology vaccines and awareness on issues such as Lyme Disease
• public health and the production of safe food from healthy animals
• the benefits of pets to society – in terms of health and benefit to the UK economy. There is much research showing the benefits of living with a pet. It is not just individuals that benefit, the UK as a whole does too: a recently published study by CABI ‘Companion Animal Economics’ estimated that pet ownership may reduce use of the NHS by £2.45 billion a year, through people needing to make fewer visits to the doctor.

NOAH’s vision is to be at the forefront of UK animal health and welfare. Our medicines protect the health and welfare of all animals: pets in our homes; livestock or fish on UK farms. All have a right to be treated with appropriate medicines to protect their health and welfare, to prevent disease and reduce suffering, and to ensure they can continue to provide companionship or to produce the safe, nutritious food that the UK public expects.

Our priority is a vibrant and innovative UK animal health sector, encouraging the development of new and improved animal health products and services. The UK is in a strong position to be a global centre of excellence for animal medicines, supporting both cutting edge product developments and a regulatory model to benefit our national and international trade.

Measures that promote an effective and sustainable R&D pipeline for animal health solutions will improve our knowledge and understanding of disease challenges and their solutions, and will place the UK in a strong position as a world-class hub of expertise and investment in animal health. 

Examples include:

(1)    support for industry-academic-policymaker-regulator partnerships, which direct and enable the expertise of academic research environments, whilst focusing on the solutions with commercial potential,

(2)    creation of a highly attractive UK animal health investment environment and 

(3)    investment in the resources needed to deliver e.g. infrastructure, talent and access to vital resources.

The UK will need improved solutions, processes, innovative regulatory systems and protection to capitalise on our expertise.

Impact of COVID-19 on the animal health sector

The COVID-19 crisis has severely challenged health care systems across the globe. The pandemic has also presented challenges to delivering veterinary health care effectively and safely. When lockdown was put into place on 23 March, the provision of veterinary care was considered an essential service in the context of protecting public health with food safety and security (e.g. farm veterinary work allowed to continue) and for companion animal emergency care and urgent treatment. Current veterinary professional body guidance asks vets to take a risk-based approach to clinical decision making and has responded quickly to the pandemic to allow remote consultation and prescribing. Despite these measures and adjustments, and because of the nature and protracted duration of restrictions, companion animal and equine services are experiencing the greatest impact.

In May, the Royal College of Veterinary Surgeons (RCVS) said 46% veterinary practices reported a fall in practice turnover of between 25% to 50%. The RCVS CEO reflected that “…veterinary businesses are still struggling financially, with some of them reporting a very acute impact of the coronavirus and the associated restrictions on their businesses”.

COVID-19 Recovery Phase: steps for Government, academia, and pet owners

The four Governments of the UK have published their plans for easing lockdown restrictions. The British Veterinary Association has followed with updated guidance to help vets work safely. These tentative steps are the beginning of what is anticipated to be a long and difficult journey. Meanwhile, the COVID-19 crisis continues to inflict an unprecedented impact on companion animal veterinary care. To understand, and importantly, to attempt to mitigate against the ongoing impacts of this crisis, both economic and to health and welfare, steps are needed to:

• Raise awareness
• Monitor and research the impact on pet health and welfare
• Take Government level responsibility for pet health and welfare

NOAH has produced a paper ‘COVID-19 and Companion Animal Health & Welfare: Impact and Considerations for the UK’ which gives further detail on these steps, and information on the impact on the veterinary profession and the animal health sector - available at:

https://www.noah.co.uk/wp-content/uploads/2020/06/2020-06-NOAH-report-COVID-19-Companion-Animal-Health-and-Welfare-vf.pdf

We will now address some of the specific questions which the enquiry is considering.

•                               What measures and support will businesses need to rebuild consumer confidence and stimulate growth that is sustainable, both economically and environmentally?

Businesses need certainty, clear messages, a predictable, but nimble regulatory environment and business incentives to increase the attractiveness of the UK market. A suite of measures is needed to address the dual challenges recovering from COVID-19 and EU Exit with the end of transition phase.

Animal health, in particular veterinary medicines, is a highly regulated industry, and this framework needs to be robust and predictable, taking an evidence-based approach, to encourage investment and innovation, and  continue to maintain public confidence in veterinary medicines and any food from animals that have been treated with those medicines.

The regulation of veterinary medicines in the UK is controlled by the Veterinary Medicines Regulations. The UK regulatory body is the Veterinary Medicines Directorate (VMD), a Defra agency. This veterinary medicines legislation is under review, enabled by the Medicines and Medical Devices Bill. The update of the legislation will provide an opportunity to avoid hurdles that stifle innovation, making the UK an attractive place to do business in our sector.

Existing UK Veterinary Medicines Regulations are based on the EU Veterinary Medicines Directive, which contained elements considered to be a disincentive to innovation, as shown by the fifth in a series of Global Benchmarking Surveys undertaken in 2015 by NOAH’s global association HealthforAnimals. This survey examined the interactions between industry and regulatory systems, particularly the impact of regulations on the animal health industry’s ability to be competitive and innovative.

It stated that, in 2015, the majority (69%) of the federation’s members from the EU regarded the current EU regulatory environment as having a negative impact on innovation (compared with 36% in 2011). The three most important factors affecting this were the restriction on obtaining registrations for certain types of product, the regulatory framework itself and insufficient data protection.

This EU Veterinary Medicines Directive is being replaced by a new Regulation which will address a number of these negative impacts. The UK regulatory body, the VMD, played an important role in shaping the new Regulations, which will be implemented in the EU later this year. The UK must now capture the benefits of these new Regulations for the UK market.

Before any veterinary medicine can be placed on the market, it needs to be granted a Marketing Authorisation, to ensure it is safe (to animals, users of veterinary medicines, consumers of any produce from treated animals and the environment), of high quality and efficacious in line with the licensed indications. Future UK legislation needs to ensure the processes for obtaining new Marketing Authorisations (including aspects such as improved protection of technical documentation) and maintaining them (including aspects such as pharmacovigilance systems that monitor product safety post-authorisation) include measures to encourage innovation in veterinary medicines and the development of new veterinary medicines.

Making the UK attractive for veterinary medicines investment: government could provide incentives to encourage innovation, such as increased protection of technical documentation for new and innovative products, making the UK a more attractive country to invest in new product research and development. More resources could made available by reducing the administrative burden, enabling redirection towards research and development.

Product innovations: The industry estimates are that the veterinary medicine sector faces are proportionately twice the administrative burden of the human medicines sector.  Given that the veterinary medicines market is very small compared to human medicines (circa 4%) any steps to improve this would be welcome. This is not ‘watering down’ safety but is focussed on improvements in use of IT systems and better formats for transmission of regulatory information between regulators and the marketing authorisation holders.

•                               Whether the government should give a higher priority to environmental goals in future support? 

By including support for improvement to animal health, Government can also deliver on environmental goals. Improving livestock health and producing food efficiently reduces the environmental impact of producing food from animals, so supporting and incentivising improvement of livestock health will support delivery of net zero.

Healthy livestock require less resource input (feed, water, energy) to produce meat, milk, and eggs. Healthy animals generate less waste, including manure and carbon emissions. Healthy livestock are essential for land management in many marginal or upland areas.

Improving the health and welfare of animals will improve productivity through efficiency, as healthy animals are naturally more productive. Key to achieving these improvements in productivity is proactive and preventative herd/flock health planning. Business performance is linked to levels of skills and education. Incentives that drive productivity, skills and therefore overall business performance will increase our competitiveness and at the same time address our environmental responsibilities.

For Government, this will mean a recognition and acknowledgement of the importance and opportunity facing the UK’s food and farming industry, prioritising the development and delivery of a vision and integrated plan for animal health and welfare, rewarding farmers for going beyond regulatory standards and co-operation with devolved administrations.

Part of the toolkit to enable these improvements to be made are innovative animal health products, including vaccines.

•                               Whether the Government should prioritise certain sectors within its recovery package, and if so, what criteria should it use when making such decisions? What conditions, if any, should it attach to future support?

We believe there is much potential in cultivating world leading sectors and trade associations can perform an important role to promote adoption and to communicate along the supply chain.

The Life Sciences have been identified as an area of focus through BEIS, with the Life Sciences Industrial Strategy being published in 2017 and updated earlier this year. The animal health sector is closely allied to the Life Sciences sector sphere as part of One Health, because animal health, human health and our shared environment are deeply interconnected, meaning positive or negative impact on one of these strands will ultimately affect the others. 

The COVID-19 pandemic has shown how quickly a disease originating in animals can become a threat to the human population. Taking a One Health approach can enable tools and expertise including research, development, communication and behavioural science, to be shared for the benefit of all. Animal medicines are essential here, and collaboration between the human and animal health sectors is necessary to solve our shared problems and to provide innovative solutions. By sharing data, best practice and innovation to mutual benefit, we can build a better understanding of these problems and our potential to solve them.

This kind of collaboration has in the past led to the successful control of deadly disease outbreaks. In future, as put into sharp focus by the current pandemic, experts in both sectors need to work together to prevent disease outbreaks across species and address the root cause of their spread: innovation in our sector is integral to this work, and so better opportunities for collaboration with, for example, our sector and the Office of Life Sciences could be beneficial.

Allied to the animal health sector (and supported by it) is UK livestock farming and food production. Within livestock farming and the production of safe food from healthy animals there is a tradition of good collaboration in the UK in other spheres, such as through the Responsible Use of Animal Medicines (RUMA) Alliance, which has a membership across the food supply chain, from suppliers to the veterinary profession, to farmers in all livestock sectors, to retailers. It includes organisations working in food quality assurance and animal welfare. There are observers from Government and the human medical profession. Included within its work is excellent collaboration on antimicrobial resistance (AMR), demonstrating the way the sectors can pull together to meet this challenge, and work together to promote innovative best practice.

This approach can be extended: this is a sector that is proven to be able to organise behind strong leadership to address shared challenges and opportunities. Animal health and welfare is a devolved issue and we are constantly witnessing examples where each of the 4 nations are all on their own path. Sometimes great ideas in one country are not even visible in another – we need a joined up, high level agreement to share and disseminate innovative ideas to improve animal health and welfare. The Agriculture Bill and Animal Health and Welfare Pathway (AHWP) can provide a framework for this to take place that we strongly support.  However, the AHWP is England only: there is great potential to work innovatively (e.g. industry-Government co-design of programmes) but this stops at the Welsh and Scottish borders. Collaboration between the devolved governments would enable better diffusion of innovative ideas.

European public-private platforms such as the Animal Task Force provide an example of industry (through representative organisations / trade associations) and academia (knowledge providers) working together. This group promotes a sustainable and competitive livestock sector with the Agri-Tech centre CIEL (Centre for Innovation Excellence in Livestock, funded through Innovate UK) in membership, as well as AnimalhealthEurope, the European federation, of which NOAH is a member. We would encourage continued participation, and participation in similar initiatives on a global scale.

Similarly, with the health and welfare of companion animals being the principal area of innovation within our sector, there is a great opportunity for collaboration in the UK in this area to capitalise on the UK’s expertise. Here, less collaboration has taken place (except through the Sector Councils, for example) and there is the scope for support to bring together Government, industry and academia. We believe innovation in this sector would benefit from a Government minister having responsibility for both pet health and welfare.

•                               How can the Government best retain key skills and reskill and upskill the UK workforce to support the recovery and sustainable growth?

Improving the skills of the workforce and the ability to harness them via effective leadership are critical to productivity growth. A correlation exists between business performance and levels of skills and education. Investment in skills is key. However, this is coupled with the need to invest in IT infrastructure to support online education.

In our area, a demonstration of the inter-relationship between provision of training to upskill and the need for improved data access is NOAH’s Animal Medicines Best Practice (AMBP) programme. For this, we worked with stakeholders across the food supply chain to develop training for farmers in the responsible use of antibiotics. A training platform, with eLearning for farmers to work independently and resources for vets to deliver training to farmers, was launched in partnership with Lantra (a leading land-based awarding body) in 2018. There is an opportunity for Government to work with industry to maximise the potential of these resources and capture the benefits for food production, export market opportunity, animal health and welfare and public health, for the benefit of the UK faming economy.

Embracing new technologies and investing in improving skills demonstrates ambition and a drive to progress and improve competitiveness. Skills development offers a clear demonstration of professionalism. Investment in skills will help to attract and retain the brightest and best into the agricultural profession and drive much needed improvements in productivity.

•                               What opportunities does this provide to reset the economy to drive forward progress on broader Government priorities, including (but not limited to) Net Zero, the UK outside of the EU and the ‘levelling up’ agenda? What should the Government do to ensure that delivering on these priorities does not exacerbate the vulnerability of businesses, consumers and communities/workers that have been impacted by COVID-19? 

Animal health businesses in the UK range from large global companies to family-run SMEs. The structure and work of these companies mean they are based throughout the country providing a range of job opportunities in diverse locations and fields including R&D, manufacturing, sales, marketing and technical field-based representatives.

All of these opportunities are underpinned by a vibrant product market, supporting the supply of food from UK farms from healthy farm livestock, as well as the health and welfare of our companion animals. 

Initiatives that support UK animal health businesses to flourish into the future will help to ensure that their R&D and manufacturing work translates to opportunity throughout the UK. This starts with a strategy to attract institutions, businesses and investment to key areas of the country with, for example, centres of R&D excellence. To realise this ambition, the UK market and regulatory landscape must also work for business, offering opportunities and avoiding unnecessary regulatory burden. 

To ensure that a healthy market exists for animal health products, measures that deliver a strong and vibrant agricultural sector are needed; this in turn will achieve levelling up aims by providing skilled, high quality employment across the UK, and will help cement the UK as a centre of excellence, able to do business across the world. 

Improving the health and welfare of animals will improve productivity in UK farming as healthy animals are naturally more productive. Innovative animal health products to help prevent disease support this. Improving UK livestock health and producing our food efficiently reduces the environmental impact of producing food from animals, thus supporting Net Zero. Healthy livestock require less resource input (feed, water, energy) to produce meat, milk and eggs from UK farms, for the home and international markets. They generate less waste, including manure and carbon emissions. Healthy livestock are also essential for land management in many marginal or upland areas.

The COVID-19 crisis has highlighted that the UK is missing some fundamental basics when it comes to diagnostics, surveillance and skills which extends to animal health. We need a world class IT/database system to benchmark performance, drive evidenced-based changes and support trade opportunities by demonstrating the UK’s world class animal health and welfare standards.

•                               What lessons should the Government learn from the pandemic about actions required to improve the UK’s resilience to future external shocks (including – but not limited to – health, financial, domestic and global supply chains and climate crises)?

The COVID-19 crisis has highlighted that the UK is missing some fundamental basics when it comes to diagnostics, surveillance and skills which extends to animal health. We need to build a world class IT/database system to benchmark performance, drive evidenced-based changes and support trade opportunities by demonstrating world class animal health and welfare standards.

We need a proper nationwide 4/5G network to enable a leveraging of IT driven improvements. We are missing some of the basic building blocks that need to be in place for further investment and innovation to thrive.

•                               What opportunities exist for the UK economy post Brexit and the pandemic for export growth? 

The UK has a world class reputation and strength in life sciences and innovation, including expertise in animal health. Policies to support and encourage this to be nurtured in the UK will be a real opportunity for the UK economy, and will have spin-off benefits in supporting our own agriculture and food supply, with an excellent product for home consumption and export.

The business environment for NOAH’s member companies needs to be sound for their global/parent company to continue to invest in the UK. This extends to R&D, product launches and operations.

August 2020