BVA Responds to the Competition Commission
07 November 2002
In its response the BVA has emphasised that the statutory constraints on the supply of Prescription Only Medicines (POMs) are imposed for good reason. "The veterinary surgeon's role as `gatekeeper' is key" said Mr Jinman "and it is generally accepted that the attending veterinary surgeon is best qualified to ensure that the most appropriate medicine is selected, supplied and directed to the end user. Such a selection takes account not only of the animal's health but also the potential for the animal or products from the animal to enter the human food chain. The veterinary surgeon has a responsibility, not only to prescribe an appropriate medicine but also to advise on the application of that medicine, bearing in mind the specific management conditions on the individual farm and the potential to negatively impact on food safety. The safe use of these products is dependent upon the training and expertise of the prescriber and only the qualified vet has the appropriate training in pharmacology and the attendant disciplines to ensure the proper and safe use of these products.
"The veterinary profession", Mr Jinman continued, "is founded upon the need to preserve animal health and welfare and, in respect of food producing animals, to act as a protector of public health. Against this background the veterinary profession is unusual amongst professions, in that its members sell both services and products, and have developed a pricing structure that does not clearly identify each facet of that duality. However, what is not generally appreciated is that the veterinary surgeon does not view the sale of a medicine as the end point of any consultation. Indeed in many situations no medication is supplied but advice on a change of management is given instead. Medicines are one of the possible options open to the veterinary surgeon and only part of the holistic prophylactic or treatment package."
In noting that "the dispensing veterinary practice in both urban and rural areas is able to provide a 24-hour 365-day service" Mr Jinman suggested that "commercial imperatives make it unlikely that a retail pharmacist will be able to match this level of service. Furthermore, veterinary surgeons feel strongly that they prescribe and supply whatever medication is required to treat a clinical case effectively, regardless of commercial pressure. It is the diagnosis and not the financial consideration that drives the choice of medicine."
Mr Jinman confirmed that within the possible remedies in the Competition Commission's statement, the BVA agreed that the client should have a clear understanding of the cost of treatment for their animal and that it was incumbent on the veterinary surgeon to ensure that this aim was fulfilled. Nevertheless, "some of the suggested remedies seem excessive and an unnecessary intrusion into business practice that are not required of any other business. There are also instances where we believe economic theory and practicality part company. The first of these is the assumption that one solution fits all, bearing in mind that the veterinary profession is diverse both in structure and geographical location, with corporate, remote rural, single species and multi-centred practices."
Mr Jinman was adamant that "any attempt to move away from the three guiding principles of safety, quality and efficacy would be untenable" pointing out that the basis of the Medicines Act in the UK was to remove the danger of the public being sold products that were either dangerous or of no medical value. "It is fundamental when dealing with animals that treatment is objective not subjective" said Mr Jinman and the Commissioner's "assumption, that because some animals are kept by way of business it follows that the owner or keeper has a corresponding expertise with regard to medicines, is practically unsound. It is tantamount to suggesting that a human patient should be responsible for his own choice of medication."
While "concurring that currently transparency of price may be obscured by complex discount systems" Mr Jinman suggested that "the mere presence of such schemes would seem to indicate the presence of competition between the pharmaceutical companies supplying the profession." As a number of delegates at the recent BVA Congress pointed out to the Competition Commission "opening up the current complex monopoly may lead to an overall increase in the cost of owning and caring for animals. Price is not the only consideration. Time must also be considered since the nearest pharmacist will invariably be some distance from the premises where the veterinary surgeon examines an animal. We are also concerned that involving a pharmacist in the veterinarian/client relationship will increase the owner's costs since two businesses rather than one will need to operate profitably. Competition may be achieved, but at the price of increased overall cost and consequent animal welfare problems. Competition between veterinary practices has already established an efficiency of practice." There is no doubt however that the inquiry "will encourage a more business like and analytical approach by the veterinary profession that can only be of benefit to the animals under our care, their owners and to the profession itself. It is the intention of the BVA, through its divisions, to continue that process of business education."
In conclusion Mr Jinman noted that "throughout the inquiry, the BVA has attempted to be helpful and constructive. We would not wish to stand in the way of change where it can be clearly shown to be in the interests of the animals we serve and the consumer and public whose health we have a responsibility to protect. Nevertheless the recommendations outlined to date run contrary to the current strong pressure from EU institutions to intensify and strengthen food safety legislation and thereby reduce exposure of the consumer to potential hazards, such as harmful levels of residues of veterinary medicines in animal derived human foodstuffs. The Competition Commission's recommendations all too clearly highlight the clash between competitive policy and the need for protection of the public."
Notes for Editors:
- For further information please contact the BVA Press Office on 020 7636 6541.
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