Reduce use of other production pharmaceuticals that operate within intensive systems
Restrict own-use importation and extra-label use
Reduce corporate concentration in the veterinary drug industry
Reposition veterinary education
Assess impacts of pharmaceuticals on ecosystem structures and processes
Reduce use of other production pharmaceuticals that operate within intensive systems
As reduced animal product consumption and extensification take hold, there will be reduced need for many pharmaceuticals and feed additives that serve as production aids, including many hormones and feed conversion efficiency products. Extensive systems mean animals consume more plants for which their digestive systems are better designed, particularly grass for ruminants, and a much more diverse diet for ominvorous poultry and pigs. Many production aids have been designed to facilitate efficiency of current conventional diets and therefore they will not be as useful in the shift to sustainable systems.
Re-evaluations should be undertaken at this stage to determine if there is legitimate need for such products, given that many are controversial. Currently the main focus of re-evaluations is for medically - important anti-microbials, obviously essential, but the re-evaluation program should be expanded, as sustainable production systems are implemented, to a wider range of products that may be unnecessary or problematic, whether currently produced domestically or imported. The approval process for new drugs should also require that need be established, in addition to current safety and effectiveness assessments, within the context of sustainable production systems. In many cases, new products that increase yield or feed efficiency will be unnecessary, but those that add value within extensive systems may be approved. This will require changes to the Food and Drug Regulations, and the associated assessment protocols employed by Health Canada evaluators. Similarly, some veterinary biologicals and feed additives, regulated under the Health of Animals Regulations and the Feeds Regulations, may also be assessed in re-evaluations or for new approvals, for their compatibility with sustainable production systems and this will require comparable amendments to the regulations.
Related to this, reductions in production aid use should be fully integrated with sustainable code development (see Goal 5, Sustainable food and Goal 9, Human relations with animals).
Products that are manufactured, but not permitted, in Canada for reasons related to lack of need or lack of compatibility with sustainability requirements should also not be permitted for export. This complies with Goal 10.
Restrict own-use importation and extra-label use
Historically, farmers could import medication for use on their own animals including some drugs not approved for use in Canada. There was limited monitoring, training and enforcement, and as a result, there were rumours of abuse of the program parameters (Glen, 2017). Farmers could also administer drugs in ways that did not respect the label conditions (extra-label use). Both have essentially represented means of getting around the existing approval system. Because they were somewhat beyond the regulatory process, they have been implicated in problems associated with veterinary drugs including AMR because there was evidence that the use could be inappropriate.
Finally, recognizing the significant of it's contribution to potential problems, the federal government began to restrict own-use importation by creating a list of products that could be imported but not sold, given to others, or in quantities exceeding a 90 day supply (List B incorporated by reference in the Food and Drug Regulations). Most of them are for the control of internal parasites and for growth promotion. Importantly, the imported drug cannot be a medically important pharmaceutical, cannot be prescription status, must have a comparable product approved in Canada, and must have a MRL.
Part of the rationale for these earlier programs was to take pressure off veterinarians, especially for emergencies. But the changes proposed on this site mean that there will be reduced numbers of animals, and more health promoting practices, so the own-use program should be eliminated and extra-use restricted to veterinarians, who should be more available for emergency requirements, except potentially in more isolated regions where veterinary services are limited. This will require changes to the Food and Drug regulations. The other reason to eliminate the programs is avoiding inappropriate disposal of pharmaceuticals.
Reduce corporate concentration in the veterinary drug industry
The Canadian Animal Health Institute (CAHI) claims that the human pharmaceutical industry is 40x larger than the veterinary one. However, the veterinary sector is dominated by some very large firms, the top 10 on a global basis largely being integrated firms dealing in human and animal drugs and other agrichemicals: Zoetis Inc. (a subsidary of Pfizer), Boehringer Ingelheim Animal Health, Merck Animal Health, Elanco (a subsidiary of Eli Lilly), Bayer AG, Ceva Sante Animale S.A.,Virbac SA, Vetoquinol SA, IDEXX Laboratories, Inc. and Covetrus, Inc. In 2018, the global market was estimated at $45 billion in sales, and expected to rise to $67 billion by 2025 (Market Research Reports). Most of these top 10 firms operate in Canada, but are not Canadian firms. Canadian firms are more niche players in a global market.
The general strategy of large input firms is producing products that are considered applicable across a wide range of geographies and types of conventional farming systems. However, such products are typically less useful in regional and sustainable systems. Given this reality, these large firms will fight to retain their markets and will not readily comply with the transition to sustainable systems.
A related looming issue is corporate purchase of rural veterinary clinics. Firms, having been put under scrutiny the Competition Bureau for consolidating urban vet practices, are now moving into areas with mixed pet and agricultural practices. The rules around clinic ownership (51% owned by a veterinarian is typical) are easy to work around. The corporate model is criticized for focusing on investor returns rather than excellent animal care. The situation is particularly problematic in agriculture since large animals are generally not profitable for veterinarians, with break even often the best outcome. The fear is even greater reductions in vets working on large animals as corporate consolidation increases. Provincial veterinary medicine bodies do not typically have the authority to restrict ownership so they are relying on the Competition Bureau to intervene (Klager, 2022).
Not to be ignored is consolidation in the veterinary practice sector as well, fuelled by international private equity funds at a recently accelerated pace (Hannay, 2022).
See Goal 3, Reducing Corporate Concentration for strategies that can also be applied to the veterinary sector.
Reposition veterinary education
Canada has 14,000 veterinarians and some are employed in the public sector, often as government inspectors or policy analysts, but a majority work in private practice as individuals or in groups. Only about 1/3 work with food-producing animals, although very few do so exclusively as clinics typically serve the pet and food animal populations to be financially viable (Jelinksi and Campbell, 2009). Shortages of large animal vets are an age-old problem in Western Canada (Lewis, 2021). Looking at courses, there is limited training in sustainable food systems and animal welfare.
Veterinary medicine, like human medicine, is a strategic profession, but we treat it primarily as an open market profession to which individuals can try to gain entry. About 400 vet students graduate from Canadian schools per year, and growing. Instead, veterinary training should be viewed as a public good training, especially since a part of this very expensive training is already covered by public contributions. It's pretty clear that veterinary labour force development is very poor because of mismatches between admissions, student choices of specialties and regions, and actual need (see also Goal 8 Labour Force Development). There are not enough graduates in many agricultural specialties to cover all the vacancies and not enough agricultural veterinarians are working in rural areas, which as with many other areas of the food system, results in calls for more imported professionals. COVID has been identified as a tipping point for veterinarian burnout and departures (White, 2023). Vacancies advertized in rural large animal practice in Ontario typically receive no applications (Martin, 2021). A pandemic survey of vet practices in Western Canada found that it took 8-12 months to find vets to work in food and mixed animal practices, and shortages were substantial (Jelinkski et al., 2022). Salaries are often higher in dedicated urban practices because many pet owners are willing to pay more and the structure of urban clinics is more amenable to higher total daily billings. Fewer graduates are willing to live in rural areas since urban lifestyles are often more appealing. With the gradual shift to prevention, protocols, animal welfare and one-health, demands on vet time are increasing (Lewis, 2019). In the near term, overworked veterinarians probably prescribe more frequently because they don't have time to take a more holistic approach. There are also shortages in veterinary technicians.
However, at the substitution stage, there will be reduced need for veterinary time with animal population decline. Spots in vet schools will thus have to be very targeted to certain animals in certain regions, with 5-year commitments required when students accept an admissions offer or they don't gain entry to the program. Funded seats can also be used to stream students to certain activities and regions. The BC government is moving in this direction by funding additional seats at the Western College of Veterinary Medicine (U. Sask) in the hopes of making it more viable to have graduates do large animal work in rural BC (Dekay, 2022). Recognizing the rural large animal vet shortage, the Alberta government announced expansions to veterinary training that will take 7 years before the benefits become apparent. Saskatchewan and Manitoba have also made funding commitments for additional seats. Although interest in rural practice will be part of the admissions process, how they will guarantee that graduates will work in rural areas is unclear. Saskatchewan has a forthcoming expanded loan forgiveness program for recent graduates that is tied to agricultural and rural practice (Lippai, 2022). Ontario has taken a different approach to shortages, announcing a program to increase remote access to veterinary services with higher levels of support for underserved areas (Ferguson, 2022).
Training in sustainable animal husbandry will be a central part of veterinary courses, which also requires changes to provincial accreditation via Canadian and American veterinary medical associations. Urban companion animal practice must be a lower priority since we have too many companion animals. By this stage, however, municipal restrictions on the permitted number of domestic pets / household will increase which will lower urban demand for vets. It will also reduce demand for pet food which will allow the pet food industry to better create pet foods from waste products that humans can't consume, important for demand-supply coordination (see Goal 2 Demand-supply Co-ordination and Goal 5 Reducing Food Waste).
Training in sustainable agriculture and animal welfare will also position veterinarians for certification in support of sustainable and welfare protocols, including for trade purposes. For example, currently Canada has very few vets certified to claim that beef production is free of specific hormones not permitted in beef in the EU, or that pork is free of trichinella, both of which have been reducing exports to Europe under the CETA (see Arnason, 2019). Providing these and related certifications could be a substantial role for vets with sustainability and welfare training.
Assess impacts of pharmaceuticals on ecosystem structures and processes
Assessing impacts on organisms is very important (see Efficiency), but equally significant are the impacts on ecosystem structures and processes, in other words the impacts on assemblages of organisms. Such assessments are not required in Canadian environmental assessments, although they may be requested at the discretion of Health Canada assessors. The Edmonds Institute set out ways to do these types of ecosystem assessments for GE organisms (see Goal 4 Genetic Engineering, Efficiency) and these protocols can be adapted to assess environmental impacts of pharmaceuticals. Such changes will require amendments to CEPA regulations.
