Food Animal Matters
August 8, 2023
Food Animal Matters
Robert Tremblay
Editors’ Introduction
This column is a communications tool for food animal production and related issues. It is expected to fill an important gap, as much of the narrative regarding food animal agriculture and food animal veterinary practice is not written by food animal veterinarians. This column will be a regular feature of The CVJ, coordinated by Dr. Robert Tremblay and intended to inform food animal veterinarians and others who want to understand more about the day-to-day professional activities of food animal veterinarians.
Recently retired, Dr. Tremblay spent 40 y in professional life working in large animal veterinary medicine. For most of that time, his primary interest was food animal medicine. Dr. Tremblay takes great satisfaction in having been involved in food animal veterinary medicine. He is grateful to have worked with dedicated food animal veterinarians, farmers, and ranchers in Canada and beyond.
Tim Ogilvie
John Kastelic
1. Opportunities in food animal practice
First, some background on farming in Canada
The percentage of the Canadian population that is involved in agriculture is steadily declining (1). The most recent Statistics Canada agricultural census data (collected in 2021 and released in 2022) estimates that only 2.1% of the Canadian population is now directly involved in food production. Concurrently, the number of farms has also steadily declined. A farm’s primary function is to produce food. Farms are also businesses. In Canada, farms are predominantly family owned. Like all businesses, farms must change and adapt to market needs to continue as viable businesses. That means they must become more efficient, usually by adopting new technology, implementing better production techniques and, in some cases, becoming larger (2). Running a family livestock farm is a 7 days-a-week, 52 weeks-a-year occupation. Vacations or even a few days off typically require sharing of duties by the remaining family members. Larger family farms that can afford to hire outside help have more flexibility for time away.
Because farming is a business, food animal veterinarians need to be mindful of 2 things. The 1st is that the farm they are serving is a business that needs to generate adequate income to support the farm family; the 2nd is that the farm’s products are food. The 1st point means that there has to be enough income to look after animals properly, to pay farm personnel — including the farm family, and to maintain the viability of the farm itself. Therefore, it may not be possible to have enough profit to implement all the changes that the farm’s veterinarian suggests (3). The 2nd point requires that any treatment recommendations, including preventive recommendations, must consider the safety of the food produced on the farm. That means being mindful that all treatment recommendations must be accompanied by appropriate withdrawals, a requirement that can severely limit optimal treatment options.
Most farm sectors, like other primary industries, control neither the prices they are paid for the food they produce nor the prices they pay for purchased inputs. Farm gate prices for animals and animal products that become food and input costs are heavily influenced by external (often international) factors that are outside the control of the farmers themselves.
The complicated role of food animal veterinarians in agriculture
Animal agriculture is frequently criticized. Criticism can be very useful, but much of the criticism of animal agriculture seems to be directed at its elimination. Because food animal veterinarians work so closely with food producers, often trying to improve practices that are the objects of criticism, it is easy for those veterinarians to perceive that they are also under attack, even by members of their own profession.
Livestock and poultry farmers are directly responsible for the care of their animals. The public has a great interest in how farmers treat those animals and in the animals’ quality of life. As a consequence, the welfare of agricultural animals is under scrutiny and often in the news. Much of that news is negative or has a negative bias. Food animal veterinarians may take this negative news personally. Like other veterinarians, they take an oath to protect animal welfare and such reporting seems to question the integrity of that oath. Because food animal veterinarians work closely with farmers, they are well-placed to evaluate the accuracy of stories about farm animal welfare. They know that the portrayals that make the news are not the norm. Consider that, if an organization used the disciplinary cases from provincial veterinary associations’ websites to create the belief that veterinary medicine is rife with misconduct, veterinarians would be outraged. The organization could argue that misconduct by veterinarians is documented in the disciplinary process and that, since the disciplinary process usually begins when someone in the public complains, misconduct could be grossly underreported. This is quite similar to the way in which animal rights extremists portray undercover videos.
Society’s attitudes towards animals are complex. The book, “Some We Love, Some We Hate, Some We Eat: Why It’s So Hard to Think Straight About Animals,” written by Hal Herzog, addresses those complexities (4). This book discusses the complicated relationships between humans and animals. Unlike many books on this topic, Herzog’s book openly confronts some of the paradoxes in the value that members of society place on certain animals and how we manage them. Farmers and food animal veterinarians are often bewildered by the paradoxical value system that society imposes on animal agriculture.
Criticism as a catalyst for change
Outside observers often provide observations and insights that can be difficult to see from inside either an industry or an individual business. There is value in having outside observers express their opinions. Ideally, the observations and suggestions should be constructive. These can be useful for identifying issues and problems and suggesting solutions. It is wise to listen to what others say. However, caution is needed when evaluating criticism, because some outside observers have no intention of being constructive with their actions or comments.
When addressing criticisms of food animal agriculture, it can be beneficial to find out how other businesses have dealt with their own controversies. Consider the book, “The Battle to Do Good: Inside McDonald’s Sustainability Journey,” by Bob Langert (5). Langert worked for McDonald’s for many years. In the book, he describes how the company dealt with some of the issues that confronted them, usually as a result of public protest.
Langert describes how, when confronted with criticism, you first need to consider whether the criticism addresses a genuine issue. If so, it is wise to find out if there might be groups or organizations that will work with you towards identifying and implementing solutions to the problems at the heart of the criticism. Sometimes, the complainants are not really interested in finding solutions and may even have stated goals to see the end of your business. There is no way to work with people whose intention is to drive you out of business. Regardless, there are often other people with similar concerns, but less radical views, who are more interested in finding solutions. Identifying and working with them is likely a good plan of action.
Another point raised by Langert is that there are not easy solutions to every problem. There may be no way to completely resolve every problem. Extreme examples are those that have been categorized as “wicked problems” (6). It can be easy to use the complexity of the problem as an excuse to not act at all. Langert describes situations where it was not possible to implement or even generate complete solutions to complex problems. In the situations he describes, the inability to resolve a problem completely or to satisfy all the critics completely should not be used as an excuse to not even start addressing the issue. However, the first steps shouldn’t be seen as the only steps that you will eventually take.
One additional observation from Langert’s book is that there were often other positive outcomes for McDonald’s when they identified and made changes in response to the original controversy. Sometimes, by investigating and addressing 1 controversy, they found that there were other, unanticipated benefits for their business, even though the changes were intended originally for
another purpose entirely.
The pressure to change and improve is continuous, whether in farming or veterinary practice. Consumers should be aware of how their food is produced and should be expected to be
concerned about how their food is produced. Farmers, ranchers, and their veterinarians should consider those concerns when making both short- and long-term plans for their future in food production.
2. The complex problem of food animal drug availability in Canada
The number of drugs that are available to treat animals in Canada is steadily declining. The Canadian Animal Health Institute (CAHI) is an organization that represents most companies that sell veterinary drugs and vaccines in Canada. In January 2023, CAHI released an analysis of the availability of veterinary drugs in Canada (7).
The CAHI used data from the Health Canada Drug Product Database to determine how many veterinary medicines were available each year between 1970 and 2022. They divided the products into categories based on actual availability. The most relevant category is products with Drug Identification Numbers (DIN) that are marketed and available for purchase. At the end of 2022, the number of those products was at its lowest level since the early 1980s. The number of marketed products peaked in the mid-1990s and has only declined since then. The number of marketed products has declined even more sharply since 2018, when regulatory fees began to increase dramatically and regulations making it more difficult to source drug components were implemented.
Products that are approved but are not presently available for purchase fall into 3 categories. One category consists of products that were approved for sale in Canada but were actually never sold here. The other 2 categories, cancelled drugs and dormant drugs, include drugs that have been licenced and available in Canada in the past but are not sold now.
Cancelled drugs are those for which approval and DIN have been cancelled. The number of drugs that fall into this category now substantially exceeds the number of products that are actually available.
Dormant drugs are still approved and licenced but have not been sold in the previous 12 mo. Unlike cancelled drugs, the approval and DIN of a dormant drug have not been cancelled. The number of dormant products has increased sharply since 2017. The number of dormant drugs is close to 1/3 of the total number of approved veterinary drugs. Theoretically, since the approvals have been maintained, it would be possible for dormant drugs to become available for purchase again.
The data from CAHI’s analysis do not tell us why there has been such a steady loss of veterinary drugs. It is likely that there is no single reason. Pharmaceutical companies seldom disclose the reason(s) why the sale of a product was discontinued. One notable exception was a formal disclosure that a commonly used intramammary mastitis therapy had become dormant due to regulatory changes related to the manufacturing process. In 2018, Health Canada implemented a number of changes to the regulation of veterinary pharmaceuticals that affected production of some products.
The CAHI believes that another change that occurred at approximately the same time has affected drug availability. Health Canada substantially increased the fees related to the approval and sale of veterinary drugs. There are 3 types of fees. One is for submitting a drug for approval or changing an approval. There are also fees to obtain and maintain licences for facilities that manufacture drugs. Finally, once a drug is approved, there are “right to sell” fees that must be paid annually.
These fees are designed around a cost-recovery principle. The fee increases are set to continue until 2027, with additional adjustments each year based on changes to the Consumer Price Index. The current cost for evaluation of a new food animal drug is approximately $100 000, and the licencing fee for an establishment that manufactures sterile products is approximately $45 000 per facility. Detailed information on the most recent fees is available here.
One concern with the cost-recovery model that has been expressed by CAHI is that the fees do not consider the size of the potential market for the sale of specific veterinary medicines in Canada. Food animals, especially those in smaller commodities like sheep, goats, meat rabbits, and aquaculture, are especially vulnerable to this limitation. A product must have sufficient sales to justify the investment in not only regulatory costs, but all costs related to producing and marketing the drug. Although these fees might have a greater impact on access to food animal veterinary drugs intended for use in minor species, they could affect availability of veterinary drugs in the larger commodity groups (i.e., pork, beef, and dairy) because Canada’s industries are smaller relative to the sizes of these commodities in our international competitors.
Shortages of drugs are unique neither to veterinary medicine nor to Canada. There are similar ongoing challenges in the availability of drugs in human medicine. Dr. Jacalyn Duffin, a Professor Emerita at Queens University, Ontario, wrote a commentary regarding human drug availability (8). This article references the website www.canadadrugshortage.com that contains information specific to the Canadian situation. In Canada, supply issues are mostly related to the availability of generic drugs.
The website contains links to numerous subtopics. One link is to a secondary page entitled Possible Causes of the Drug Shortage. Numerous causes for the lack of drug availability for humans are listed. The first 2 sentences on this page are, “The causes are unknown to most people — patients, pharmacists, and physicians — who are dealing with this problem. Those who do know the causes are reluctant to publicize them.” It is reasonable to assume that some of the causes that are described are remarkably similar to those that have been raised to explain the veterinary drug situation.
In Canada, the associations that represent agricultural commodities, food animal veterinarians, and the pharmaceutical industry are working together to identify solutions to the problems related not only to lack of access to drugs but also to lack of access to vaccines and pesticides for use in food animals.