Ban Veterinary Diclofenac Now! - EC Letter Template

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  • Please copy paste the text below and send to Mr Tonio Borg, Health Commissioner of the European Commission
     
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    Subject:  Veterinary use of diclofenac
     
    Dear Commissioner Borg,
     
    I write you to express our deep concerns about the authorization of the drug Diclofenac for veterinary use in Spain and Italy and ask you to take urgent action to protect Europe’s vultures from poisoning by this drug. 
     
    Diclofenac is extremely toxic to vultures. The veterinary use of the drug has been responsible for a 99 % decline of vultures in India and Pakistan within a few decades. A single event with a high exposure of the drug can kill a large number of vultures. In addition, diclofenac breaks down very slowly in cattle and pigs, which means that even after several days an animal dosed with Diclofenac is still very dangerous. India, Pakistan and Nepal have banned diclofenac for veterinary use. 
     
    As recognized under the Animal Byproducts Regulation (749/2011), supplementary food supply can be necessary for the conservation of endangered necrophagous birds, including vultures. Vulture populations in Spain depend significantly on feeding stations which provide this supplementary food supply. The feeding stations are strictly regulated by Article 14 of the Animal Byproducts Regulation. However, the strict controls in the Animal Byproducts Regulation do not prevent carcasses from domestic animals treated with Diclofenac from ending up in feeding stations. 
     
    Adjusting the labelling of veterinary Diclofenac will not be an adequate safeguard to prevent vultures being poisoned by Diclofenac. First of all, the veterinarian administering the drug will not oversee the disposal of the animals at the feeding stations, so even if everything is done correctly it is up to the farmer to remember that an animal must not be sent off. Second the farm where the domestic animals originate and the vulture feeding station might be far apart, but it is unlikely that farmers or veterinarians would follow the labelling on farms where vultures do not occur in the vicinity. Testing the carcasses at the feeding station is also not an option, as this is prohibitively expensive. 
     
    Under Article 35 of Veterinary Medicines Directive (2001/82/EC) the Commission can start a procedure for the withdrawal of an authorized veterinary medicinal drug which affects Community interests. Wild animal species are of Community interest, as stated in the preamble of Habitats Directive (92/43/EEC), and thus fall within the scope of this provision. The effect of Diclofenac on vultures has not been examined at all in the risk assessment. Together with the risks described above this is a sufficient basis to start a Referral procedure.  
     
    I would like to emphasize here that a safe alternative to Diclofenac is available. The drug Meloxicam has been tested on vultures and has comparable veterinary properties, but is completely safe for vultures. Another alternative however, Aceclofenac, is unfortunately also very dangerous for vultures, as it is converted to Diclofenac in the body of vultures and cattle and can thus not be used as a replacement. 
     
    I believe that only the full withdrawal of Diclofenac from the market will keep the vultures safe. I would therefore urge you to start a Referral procedure for Diclofenac for veterinary use, asking for a withdrawal of the authorization of Diclofenac for veterinary use in the European Union. 
     
    Sincerely yours,
     
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