NDB0042
Written evidence from British Specialist Nutrition Association BSNA
The British Specialist Nutrition Association (BSNA) is the trade association representing manufacturers of high quality foods designed to meet the needs of people with very special nutritional requirements. Our members produce infant formula, follow-on formula, young child formula, complementary weaning foods, gluten-free foods on prescription, parenteral nutrition and medical foods for diagnosed disorders and medical conditions. These products include oral nutritional supplements and enteral tube feeds. The industries partner with the NHS to provide essential products and services to patients in need of nutritional solutions to help manage their health and reduce demands placed on the NHS. As a skills-based industry we support every NHS trust and the patients that depend on a better nutrition to both sustain and improve their lives.
What the impact of a no-deal Brexit* is likely to be on their sector of the health and social care system (whether that be patients, suppliers to the health and social care system, providers of NHS or social care services, NHS or social care staff, or others)?
Concerning medical foods, BSNA members support 47,000 patients living at home with tube feeding and another 250,000 patients receiving medical foods. The products may be critical to life. Part of this support relies on the availability of nurses to care for these patients. Currently, 6% of these nurses are from the EU 27 and 2% are from outside the EU. It is important that the industry has access to this labour pool in the post Brexit scenario in order to protect the health of the patient. If these 45,000 patients were in hospital, it would cost the NHS £18.9 million at a cost of £420 per day in hospital. This is equivalent to £138m per week, £592m per month and £7.1 billion per year!
Factories producing products including medical foods usually work close to capacity with limited possibilities to generate stockpiles other than by delaying supplies to other markets. 10 articulated trucks full of medical foods are used in the UK every day. Building a 6-week stockpile amounts to 420 trucks and Good Distribution Practice standard warehousing is not available.
BSNA members import most of their products in finished form primarily from the Euro zone. The devaluation of Sterling has added 16% to the cost of products. Although speculative, customs may add 5% to cost. Tariffs, if introduced, may add further costs and may be 16%. Based on these figures, costs could increase by 37%. The turnover of the sectors is £400 million with the added costs increasing this figure to £548 million. Most of this additional £148 million will be at the cost of the NHS.
Parenteral (Intravenous) Nutrition is life-saving in patients where the digestive tract is no longer functioning due to surgery, etc. 2,500 patients live at home on parenteral nutrition with another 1,500 patients in hospital. The components for parenteral nutrition are imported and it is important to ensure that transport is not disrupted or that mechanisms are in place to overcome barriers such as air freight.
Specifically, what the risks are to patients and to the health and social care system of leaving the European Union without a withdrawal agreement. The Committee would be particularly pleased to hear from patient representative groups about the extent of the potential risk to patient care of any disruption to the supply from the EU-27 to the UK of medicines, medical devices or substances of human origin.
It is important to note the critical life sustaining nature of certain medical nutrition products such as in the case of rare metabolic disorders. These products may be prepared in a single factory, including in the UK, supplying the world but made-up of a small number of patients in each country. In the case of any emergencies, it is important to be able to move such products across Europe with speed. It is also important that such products can clear customs very rapidly. A lack of regulatory equivalence could lead to regulatory barriers and delay of these supplies to those who rely on them for life and health maintenance.
Companies usually carry 3 to 4 weeks of stock. Patients normally receive a 4 week supply when their stock has run down to 5 days. If a no-deal Brexit leads to delays of up to 6 weeks at ports, and given the volumes involved, the most effective means to ensure supply to the patient is to deliver an additional 4 weeks of supply in advance of 29 March 2019. A small percentage of patients, such as those living in small apartments, would not be able to accept additional stocks and companies will supply from their warehouses. In order to enable additional deliveries, clinicians would need to be enabled to write additional prescriptions or prescriptions covering longer periods.
How effectively stakeholders are planning for the possibility of a no-deal Brexit.
Stakeholders are planning as effectively as they can, given the information available to them and the uncertainty involved. Supply chains usually need lead times of 6 months with some lead times being more than 1 year. As such, companies have or are now planning for March 2019. In the case of medical foods, the most appropriate response is to provide additional deliveries. For PN, companies will stockpile additional quantities but may need access to air freight if transport is delayed for extended periods.
How effectively they consider the Government is planning for such an outcome.
The publication of the Technical Notices has provided visibility to the extent of the problems that would be created by a no-deal Brexit. However, the cost of dealing with the problems foreseen are being pushed onto industry. Tax relief and/or tax credits should be offered to companies to offset no-deal Brexit costs.
What further planning, or reassurances, are required in order to ensure that the impact of a no-deal Brexit on health and social care would be minimised.
In the case of medical foods, tariffs should be set at zero as is the case with pharmaceuticals. Zero tariffs will avoid unnecessary costs that will have to be paid by the NHS.