Environment and Climate Change Committee

Wednesday 17th June 2026

(began 2 months, 1 week ago)

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None Portrait Speaker 1
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Excellent.
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None Portrait Speaker 1
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Your organisation.
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None Portrait Speaker 1
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You. Lord Krebs.
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None Portrait Speaker 5
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So pretty big gap.
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None Portrait Speaker 2
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It is a pretty big gap. Yeah. So the big flea project was carried out in 2018 and that asked um vets to randomly select pets in their practice and actively look for fleas. Um, if they found fleas, they submitted them and a prevalence was worked out on the basis of the percentage of dogs and cats where fleas were found. Now, we know from studies that are carried out in this way that those studies tend to be somewhat overestimates because not because vets are looking to mislead anyone, because they're enthusiastic.

If they find a flea on another pet, they think, oh, you know, the researchers might like this and they send it in. And that can be very difficult to to pair that out. Um, but I mean, as that research was carried out, 1 in 4 cats and around 1 in 7 dogs were found to be positive by fleas. Um, the other study was by Sassnitz. So that isn't actively telling vets or nurses to do anything. It's just looking for flea records in, in the records.

And I mean Sassnitz in their paper, just as, um, the authors of the Big Flea project acknowledge that theirs was likely to be an overestimate. Um, the authors of the paper acknowledged that theirs is likely to be a significant underestimate. And that's because every time a pet comes into a consulting room, vets and nurses aren't actively looking for fleas. You know, many of those pets won't be you won't look for fleas at all. So those figures are, by definition, going to be a significant underestimate.

So, I mean, what would be really useful would be to have a controlled study for, for prevalence. Um, I've asked for that. SCAF have asked for that. Um, but these to, to recruit practices to have oversight to analyze that data, um, costs a significant amount of money. Um, so, you know, but I mean, if I could have, you know, if I could have the research of my choice, another prevalence study of fleas would be very useful. Um, but I do believe, and I said it's not my belief.

I mean, the authors of the paper, um, emphasized that that was a significant underestimate of the numbers. Um, what the paper did show is that flea exposure happens all year round. And the nature of the flea life cycle is that any pet could be exposed to fleas. Once fleas establish in the house or in the home, often takes at least 2 to 3 months to eliminate them. So, you know, we can look I mean, there aren't European wide escape, have a list of risk factors that pet owners and vets should consider before considering whether flea treatment should be initiated as a preventative.

Um, but we really don't have any large scale data on what those risk factors might be for the UK. With a humid climate and centrally heated homes. Uh, so more research into risk factors, prevalence. So a lot of debate about to what extent, for instance, indoor cats are exposed to fleas. Um, so, you know, more information in these areas would be really useful. I don't know if you want me to go on and talk about other parasites.
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None Portrait Speaker 3
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The only.
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None Portrait Speaker 4
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Yes, because not.
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None Portrait Speaker 5
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Everybody.
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None Portrait Speaker 4
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We've got a.
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None Portrait Speaker 6
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How.
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None Portrait Speaker 2
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There is still a lot of publicity because it's also inherently linked to dog fouling, pardon me, an anti-dog fouling campaigns. Um, but you know, with the, with the wide range of clinical ways it can present, it's often people often don't go with the symptoms or they're not diagnosed. And if they are diagnosed, it's not reported. What we do have though is soil study data from around the UK. So Ayres et al. In 2022 looked at toxocara eggs, which are potentially infective to people in public parks around the UK, and found 86% of public parks in the UK to have toxocara eggs that could infect people.

Um. Similar study carried out by Kaul et al. In 2022 in the East Midlands, found 74% of public parks to be positive, so there's certainly the potential for exposure. It has been argued that foxes may be contributing to that environmental load, but excellent modelling by the University of Bristol suggested that that wasn't the case, because the very low numbers of foxes, compared to the very large number of domestic and stray dogs and cats in the UK. So there's certainly the potential for exposure there for for fleas.

Um, 11% of fleas in the big flea project. And however those fleas are collected, I mean, it's still a percentage of the fleas collected were found to be positive for Bartonella, which is a significant zoonosis to people. Also not reportable or tested for in the UK. So we don't know what the human prevalence background of that is. Um, 5% of fleas were found to be positive for Rickettsia felis, which is a significant zoonosis. And these diseases are transmitted Bartonella through flea dirt in the home.

So if we lose control of fleas in the home, potentially people will be exposed. And you know, so for Bartonella, the greatest risk group, um, would be the immune suppressed for toxocara, the, the sort of the most at risk group would be young children or the immune suppressed. Um, and then there are a wide variety of tick borne pathogens that are zoonotic in the UK. So Lyme disease anaplasmosis tick borne encephalitis virus, which is an example of an exotic pathogen that recently established in the UK.

Um, dogs and cats there don't represent a direct zoonotic risk. Um, but you know, if there are ticks, you know, that don't fully attach to pets drop off in the home, or if people are living a similar lifestyle to their pets, then, you know, there's the possibility of communal exposure there.
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None Portrait Speaker 3
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Well, they will look at things like the characteristics of the compound and how it could impact on human health and the exposure and the likelihood of exposure. So I can follow up with more detail to the committee about about that, but I would just like to go into a little bit more detail about the post authorisation and assessment of these products, both here and elsewhere, through what is known as pharmacovigilance system. So reports of adverse impact on human health must be reported to the regulatory authority. If a company receives reports of that nature, the regulators look at that data on an ongoing basis across the many doses sold across the world, and consider what impact that is having and whether changes are needed.

Alongside those reports. They also are required to assess and consider things like new and emerging scientific literature of the nature that you referred to, and consider. Does that in any way alter the benefit risk balance of the product and any risks to human health?And in summary, I'm not aware of any global regulator who has looked at this subject of which they are required to do to fulfil their obligations, and has reached the conclusion that there are human health risks. So from arising from the use of these compounds.

So it is part of the regulatory system. But before entry into the market, after entry into the market, the compounds involved have been widely used for for decades around the world. And I'm not aware of any global regulatory view that they pose a risk to human health. Thank you.
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None Portrait Speaker 6
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Anything to add?
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None Portrait Speaker 4
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Yeah, I mean, I think I'm sure Ian will have lots to say on this topic, but happy you are stuck with me. That's absolutely fine. I think the challenge is that this parasite is not widely looked at. We simply do not know what the real rate of it is in the population is, because it is not routinely screened for some of the conditions that it causes are, you know, are kind of general malaise, fatigue, running a fever, things that we experience. They may cause significant economic loss because people take a few days off of work, etc.

but we simply would not have a route by which to achieve a definitive diagnosis. In most cases, we know from incidence rates that the parasite is out there. Ian mentioned, you know, the levels of it that we do see in fleas in the UK. We know that people suffer from illnesses all of the time. We know it has the potential to become serious. But I think that the step, the step through which a person would have to go to actually achieve a diagnosis.

And I've actually known veterinary clinicians who have been suspicious from their clinical signs and history that Bartonella could be a consideration for them, but they have really struggled via the medical routes to get GPS to consider that and to run the necessary tests, which I presume have a cost associated with them. So I think we need to be very careful. I think, again, it's back to a space where it would be lovely to have better work on this. It's something that I think is challenging to do because it relies on doing testing in humans.

It relies a lot of investment, but I think we need to be careful that, you know.
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None Portrait Speaker 2
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Yes, yes.
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None Portrait Speaker 3
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If I could take that.
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None Portrait Speaker 4
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In my head. No.
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None Portrait Speaker 8
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But not the UK.
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None Portrait Speaker 3
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The UK is a. If I could just expand the. Those are the founding members. The UK since exit from the EU is now what's known as a standing Committee member, which is basically observer status, but the UK has been implementing VICH guidelines through part of its membership of the EU, which is where, of course, the history of these products lies. So within that there is a um and I know that you've heard about this in the earlier evidence sessions, there's a two tier assessment process of the products.

And I know Doctor Boxall on one of your earlier sessions referred to this and a decision tree whereby a companion animals generally do not. Companion animal products generally do not progress to the second tier of the assessment process. But I do want to make very clear that within the VICH guideline, there is something that is referred to as the however clause. And what that means is that if the regulator is of the view that a particular substance has particular characteristics, that means it should be subject to a more in-depth assessment.

They have the ability and the power to ask the applicant, the company, to progress that. In the years when these products were authorised, they were not required to do that. The views of regulators was that that was not an necessary. So and I would also just add that as an overarching principle, the benefits of these products versus the risks are kept under constant review. And regulators here in the UK and elsewhere have the power to ask for new data. And in order for the company to prove that the benefit risk balance of the product remains positive and that it's suitable for the product to remain on the marketplace.
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None Portrait Speaker 3
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Okay.
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None Portrait Speaker 8
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We follow that.
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None Portrait Speaker 3
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Pardon me.
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None Portrait Speaker 8
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Thank you very much.
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None Portrait Speaker 3
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No.
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None Portrait Speaker 1
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No guidelines.
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None Portrait Speaker 9
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Yes.
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None Portrait Speaker 3
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Yeah.
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None Portrait Speaker 3
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Okay. Well, um, the first point I would say is, is as you say, there is currently the second tier environmental risk assessment. That's um applied to, to livestock products, I think to were there to be a system developed that would be applied to companion animals. Obviously companion animals are not livestock. The way they're kept, the husbandry systems are very different. So the development of such an assessment system would need careful consideration to ensure that it was going to be science based and appropriate for the species and products being developed and used.

So, um, it's, um, I mentioned the EMA guideline. They're going through the process of considering that as part of their work at the Committee for Veterinary Medicinal Products. So, um, that is, um, were the UK to go down that road also as an industry, the companies that I represent and NOAA would engage in discussions about that and look at how such a system could be developed. And the companies would. And this is a principle that I think applies to many of the Commons, including the earlier reference to V I, c h when products are being developed, the companies will be required to develop that data and as a result, it is appropriate for them to be able to give their views on how such data could be developed and, um, into a format.

What way trials should be done in order to prove the various points that they would like to make. So I think that that is where industry dialogue and views and should form part of the discussion. And I don't believe it represents regulatory capture. And we will follow up as you requested. Um. That's all on that point.
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None Portrait Speaker 3
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Well.
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None Portrait Speaker 9
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In VMD environmental.
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None Portrait Speaker 10
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Okay.
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None Portrait Speaker 2
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But can I, can.
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None Portrait Speaker 4
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So I'm happy to start here. With regards to imidacloprid, we have a paper which has been submitted as part of our evidence by Brown et al from a few months ago, which is helpful. So the overall picture, what this is showing is in the Environment Agency's own data is the overall picture is a positive one with time. So levels of imidacloprid are falling despite the fact that veterinary sales, as we've already discussed, are static to slightly declining the overall picture. There appears to be that the further away we get from that agricultural cessation of use of that product, the less of an impact on our waterways.

That agricultural picture is having. So the sort of half life of the product, if you like, under different environmental conditions, can be very protracted. But as we move further away from that, the overall picture is one of decline. We don't dispute that veterinary medicines are a plausible route through which some of these chemicals can enter the environment. We're not arguing about that, and the industry wants to do everything within its power to minimise any contribution that is coming from veterinary medicines.

But I think the literature does agree that veterinary medicines, whichever model, there's different figures in different papers, but the literature does agree that veterinary medicines are likely to be a minor part of the national picture, that that plant protection, historical usage is probably still a very big part of it. We have no information on sources such as so horticultural use, although it's not sold for horticulture anymore. We know that people retain products, amateur gardeners, etc. for a long period of time, and it's likely that use still goes on and we know that there are authorised and registered biocides which contain these products for which no sales data is available.

So there are multiple sources. That doesn't mean we want to downplay the role. Veterinary medicines. That doesn't mean that we absolve ourselves of any responsibility to make the picture as positive as we can. But certainly it is a multifaceted picture for many reasons. But overall, as I say, a positive one with a trend of decline over time.
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None Portrait Speaker 4
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Yes.
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None Portrait Speaker 11
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Doctor. Right.
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None Portrait Speaker 3
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Have anything to add.
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None Portrait Speaker 11
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Thank you. Thank you.
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None Portrait Speaker 4
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I'm happy to take this. Most of our products are sold through prescription routes. Is the first thing that I would. I would say so we. Your prescription on prescription. So the vast majority are in the vet channel. We do sell some through general sales is a much more minor route for our company. But we engage, we engage at every level. So we provide education and resources for vets. Vets have to undertake compulsory CPD.

We have specific programmes which are designed around, you know, correct and appropriate use of parasite control. One health factors that come into this. So that's been a very big source of investment for us for a long time and will continue to be. We also take part in Sqp training and education. We have reactive, um, phone lines, email contact points. Our goal is to have a close relationship with all stakeholders of that prescribing space. But we do also produce consumer facing both physical and online resources to help pet owners educate.

So we have a website called My Pet and I, which is a consumer facing website, which has a very high level of traffic. We have all manner of pet education pieces on there, including, for example, articles around how to treat your pet appropriately with a topical product, how to dispose of the, you know, the importance of disposing of feces, etc.. So I think we as an industry really want to amplify this. We recognise that there are still significant education gaps and we need to keep doing that, but we are proactively doing a lot already and hope to do more in the future.
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None Portrait Speaker 3
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Um, there's a couple of points I'd just like to make on this. Firstly, with regards to instructions and packaging of products, that is part of the regulatory system. Companies don't get to decide what goes on the product packaging. There's absolute regulatory oversight for owners about, um, correct use of the products, about the instructions on correct use of the products. And then as part of your question, you referred to potentially moving the products to prescription only status. And a couple of points I'd like to make in response to that.

Firstly, there are a percentage of the pet of pets that don't register with vets and owners that struggle to access veterinary care. So I do think that there needs need to be considered and other routes other than prescription only product, um, are necessary for those owners. And so that's the first point. At the second point I would add is, is just for context about what happens elsewhere. The products that have been the main topic of discussion here today are classed as over-the-counter products in all of the EU, with the exception of two EU member states.

So I don't think the UK's approach is an outlier in terms of regulatory thinking about these products. And then also you will have heard reference at various points, I think, to the Competition and Markets Authority inquiry into the veterinary practice sector. They did make points about the need to consider reclassifying products away from prescription only status. Now, it's not our position that that's always going to be appropriate, but I do just want to give the context that there is a view that having products available through channels other than prescription only does have a place.

A final comment I know we're tight on time is that the bulk of licensed veterinary medicines are prescription only. The vast majority.
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None Portrait Speaker 2
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Absolutely.
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None Portrait Speaker 10
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Thank you.
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None Portrait Speaker 3
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Okay. So, um, firstly, the packaging requirements do apply to all licensed veterinary medicines, regardless of the different classification they fall under, whether they are prescription only or general sale. So yes, the packaging is overseen by the regulator. And once again, the same system applies in, in other um countries. And as to your your specific question regarding the warnings that are included on the product literature, so, um, the companies will have, as I outlined earlier, will have submitted their application many years ago to the regulator, um, to, and that will inform the contents of the packaging.

I think what you're referring to is. New evidence from the scientific literature over the last year or two years. And so in terms of whether it is misleading, the companies are putting the information on the literature that has been agreed with the regulator. The question then is, is do the does the regulator view the evidence and make a decision that they would require the company to change their product literature?And that has not happened. So it's not that there is misleading information.

It's that the current position is that the literature, the product literature is, um, is as it should be now, product literature changes over time. So and this applies to, to all licensed veterinary medicines. I referred earlier to the pharmacovigilance system and the way new evidence is assessed and reviewed by regulators, when regulators do that, if they believe that, that means that changes are needed to products and to the indications for use to the contraindications or warnings, they will require the companies to do that.
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None Portrait Speaker 13
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Thank you chair.
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None Portrait Speaker 10
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Thank you.
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None Portrait Speaker 3
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Yes. Correct.
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