|
|
espa�ol - fran�ais - portugu�s |
Search
|
EC Measures Concerning Meat and Meat Products (Hormones) Complaint by the United States Report of the Panel (Continued)
Dr. Ritter
430. I think only to say that
unless we were to spend a great deal of time strictly defining
what we mean by the phrase "risk assessment" we could
continue to go around this circle, I think, all night. The point
that I was trying to make that, in the opinion of the scientists
that were gathered at the Conference, it was their collective
wisdom, for whatever reasons they considered. I think, as Professor
Bridges has already quite correctly indicated that it did not
include extensive examination of some of the evidence which was
presented today. But for all the totality of reasons that they
considered, at that time, they came to conclusions which have
already been made clear. One may raise the question if they were
redoing it tomorrow, would they come to the same conclusion?
I think this is speculation. One could raise the question, if
they were doing it again a year from now, would they come to a
different conclusion? I don't know.
Dr. Lucier
431. Were the acceptable levels,
or the acceptable daily intakes, were they derived, primarily,
from the tests of hormonal activity in non-human primates? Is
that correct?
Dr. Ritter
432. No, I don't think that's
correct. I think there were extensive carcinogenicity data that
were available to the JECFA Committee. These data have been described,
the assessments provided, at least in the case of two of the xenobiotic
hormones. To the best of my recollection, monographs on the three
natural hormones are not available, but they are available for
the two synthetics, and certainly they were based on chronic toxicity
carcinogenicity studies that had been conducted in a very classical,
NTP kind of methodology.
433. No, the naturals were evaluated,
what I indicated, to the best of my knowledge, monographs are
not available on the naturals. But data was evaluated by the
Committee, on which they drew their conclusions, I have not been
privy to that data. But then again, I have to be candid, I have
not re-evaluated the carcinogenicity data for any of these compounds,
in order to prepare this session. This would have been neither
practical or arguably even necessary. I would never pretend to
suggest that I have greater wisdom in this area than the collective
wisdom of the JECFA Panel.
Chairman
434. Dr. Randell, please.
Dr. Randell (Codex)
435. Mr. Chairman, just perhaps
to clarify that point.
436. In the case of zeranol,
for example, the JECFA Committee did evaluate carcinogenicity
studies, in rats and in mice, and so forth, but the conclusion
that JECFA came to in this substance and in the other substances,
that the carcinogenicity was linked with the hormonal effect,
and therefore the establishment of the "no hormonal effect"
level was the point at which the evaluation hinged, it hinged
around that point.
437. This is why the new data,
which we're hearing about today, is of interest because it would
supplement that evaluation and help us considerably. However,
the information which was available to JECFA definitely did include
carcinogenicity studies for all of the substances concerned.
Chairman
438. I'm looking at my watch.
It's about 7.30. Could you come to a close for today?
Mr. Christoforou (EC)
439. Mr. Chairman, I will come
to a close on this particular point, if you allow me.
440. I will read from what the
response of Dr. Ritter was to Question No. 5, because that is
what we are discussing now.
441. I quote page 12 of his reply
to Question 5, at the end of the first big paragraph:
442. For progesterone:
For testosterone:
"Results from mutagenicity
studies, although available to the Committee, were not described
in the report."
For the synergy:
"The issue of potential
synergy has been addressed, at least in part, through the context
of biochemical studies, directed at the effect of excretion of
hormone combinations when compared to single hormones alone."
This is on page 14.
"It is, however, clear,
that definitive studies relating to genotoxicity or carcinogenicity
of hormone combinations have not been carried out even though
this is frequently the preferred method of use."
443. I'm slightly puzzled by
the positive terms in which Dr. Ritter is now phrasing his replies
for the review of the, in the JECFA report. All issues we have
been discussing here now about the genotoxicity, not only due
to the hormonal effects, as has been rightly pointed by Dr. Lucier
but all the other possible sources of risks we have identified.
444. At least the way I understand
his replies is that these studies have not been carried out.
They might have been available but they have not been reported
in the report. We don't know if they were real studies.
445. He was not part of the JECFA
committee, in that particular case. So I don't know where he
has got this information. Whereas Dr. McLean was part of this
report and also he might have an interest to explain to us whether
this has been done. From the reports we have in front of us,
Dr. Arnold has provided a table, where there are some black
holes where things which have not been examined. I see there
is, at least some, contradiction between what our scientists are
saying on this particular issue. If one reads the entire report
of JECFA, it is clear that only the hormonal effects of those
substances have been studied for the potential carcinogenic effect.
So what is the exact scientific basis on which Dr. Ritter is
making these comments?
446. One more comment.
447. I think Dr. André,
because he was part of the Organizing Committee of the 1995 Conference,
he has, in my view, direct inside information on how this conference
was organized. The Community only funded the Conference and left
the scientists entirely to address some issues.
448. In the report of Dr. Ritter,
it is frequently referred to as the EC Conference. It is not
the EC Conference. It is a conference funded, but no more than
that. It was entirely left to the Steering Committee who to invite
and what to discuss in this conference.
Chairman
449. I would propose that we
have a final round on this question and then we will close the
meeting for today, and I would give the opportunity to respond
to the scientific experts.
450. Maybe Dr. Ritter would speak
at the end.
451. I'll start with Dr. McLean.
Dr. McLean
452. I thoroughly concur with
the comments of Dr. Randell. We were trying to put a positive
view on the availability of JECFA, if people wanted to take that
opportunity, rather than forcing people to do it.
453. In relation to the mutagenicity
data for the naturally-occurring substances, the mutagenicity
data that was reviewed is referenced in the report, in each case,
and so therefore, not so much that is was silent but it referred
to mutagenicity data that was in the open literature. So, in
the case of progesterone, testosterone and oestradiol 17 beta,
there were a number of published documents that the Committee
did look at, and they are referenced in the report.
Chairman
454. Dr. Arnold.
Dr. Arnold
455. Mr. Chairman, I have two
points.
456. The first point is I have
difficulty understanding how it could happen, but the legally
competent authorities of the EEC, on the advice of the competent
advisory scientific body, have established no MRL for oestradiol
and this happened two years ago.
457. The public summary report
states, inter alia, "The conclusion of the FAO/WHO
Expert Committee on Food Additives, JECFA, that no ADI and MRL
for oestradiol need to be established, as adopted." And
then all the other things I mentioned this morning, this is what
I have difficulty in understanding, this happened in 1994. And
this Regulation has been implemented, it has passed all the EC
institutions and the result has been published in the Official
Journal. I refer to this in my answers to the question of the
Panel.
458. My second point is I was
rapporteur of the Codex for five consecutive years. That means
I had jointly, with the secretaries of the two agencies of the
United Nations and with the US Secretariat of the Committee, to
prepare the report. I was in a really difficult situation because
it's true that the EC objected to move these MRLs to the next
step in the procedure, but without raising any health issues.
So, I was really in trouble and you can find the result in the
report. I finally got a written statement and the arguments you
will find there are, inter alia, the EC is opposing because
they have specific legislation prohibiting the use and the EC
consumer doesn't wish to receive meat from animals treated.
459. These were the arguments,
so I'm a little disappointed that these questions have not been
raised earlier, first of all, in earlier years during the Codex
discussions. It could have happened, for example, to refer the
whole matter back to JECFA with new health arguments for re-evaluation,
at that time, but this proposal was not made.
460. And that secondly, two years
ago it happened that we came to the same conclusions by the competent
authorities of the EC regarding oestradiol. Progesterone has
also been finished but not yet published in the Official Journal,
and testosterone is still under evaluation.
Chairman
461. I think we will reserve
this for tomorrow.
462. I'd like to conclude and
if anybody of you would like to speak?
Dr. André
463. Just to say a little more
about this Conference because I have been asked to do so.
464. It's clear that the EC has
just asked four experts to organize this Conference: Sir John
Maddocks is the Head Director of the Nature Review, a scientific
paper, an Irish colleague, Bergen colleagues and myself.
465. I can witness that we were
very, very free of our to our choices, in terms of selecting scientific
people. And we organized this with a first group of two people
for the three Work Shops, and they proposed that we invite scientific
people and we agreed, on the basis of the publication and the
famous of these people.
466. But, I think, and I personally
regret now that we didn't take enough care with the scientific
publication. I discovered this morning a lot of publications
on this topic and some of them were available and the scientific
were also available, and maybe we have not done our best. We
have done our best but maybe it was not good enough, and that
will explain also the missing of some information in this Conference.
467. On the last point, I would
like to say that the conclusions are a reflection of a common
discussion, and it is not a complete reflection of the majority
of people. It is not a total opinion of the members of the Committee
and it cannot be taken into account as something coming from an
official body. Our objective was just to put some light, some
knowledge, on these hormones in order to inform politicians preparing
new regulations and no more. It is not the same thing as to establish
an official MRL. The responsibility was not exactly the same
order.
Chairman
468. Dr. Lucier.
Dr. Lucier
469. I'm just surprised in reading
through this report that, given the fact that oestradiol is a
known human carcinogen, that an ADI was considered unnecessary
for it. There is a tolerance but not an ADI, if I'm reading the
report correctly.
Chairman
470. What page?
Dr. Lucier
471. 19.
Chairman
472. The JECFA Report. This
was the 1988 JECFA Report. Is that correct?
Dr. Lucier
473. In the middle of page 19
it said the Committee considered an ADI unnecessary for a hormone
that is produced endogenously in human beings and shows great
variation and level according to age and sex.
Dr. McLean
474. The difficulty that JECFA
had of setting any ADI was the problem of the increase that one
saw upon treatment, against a background of very large levels
that occurred naturally. And so therefore it meant that the setting
of the ADI really wasn't possible, because the treatment altered
the levels by such a small amount when compared with the endogenous
levels in cattle to make any ADI meaningless, and that was the
difficulty we had.
475. I would suggest, today,
that is not possible to regulate the use of the three naturally-occurring
hormones by the setting of an ADI because you can't tell the difference
between treated animals and untreated animals, by a method that
is suitable for regulatory purposes.
476. It's a practical consideration,
a real and practical consideration. I don't quarrel with what
you say, but in practise there's no way of regulating it.
Dr. Lucier
477. But if one knew, which we
do know, what are given body burden in the cattle would be produced
by the use of growth promoters, we can certainly estimate various
eating habits of people, what they would take in their body from
those agents that were exogenously administered.
478. One could come up with reasonable
estimates on that and establish an ADI. In my mind, that could
be done. From my comments this morning, I don't argue with your
point that it's a very small number of molecules, one in 28,000
I came up with in my calculations, not taking into account the
fact that it is poorly absorbed and that would make it one in
280,000.
479. But nevertheless, some sort
of an assessment should have been made, in my mind, of what that
risk was, as low as it is. I'm not saying that the risk is high
but I believe the risk is extraordinarily low or zero. That's
not my point. I am just surprised that that exercise was not
done.
Chairman
480. If more points on this are
to be discussed, I would like to discuss them tomorrow because
I think we are a little tired.
481. Would you like to make statements
tonight?
482. I apologise for the length
of the meeting but it has been, in my view, very informative and
I would like to thank the experts and also the delegations for
their support.
483. As agreed, we will meet
tomorrow at 2 o'clock, hopefully sharp, and we will open discussions
with the statements and questions by the Canadian Delegation.
484. Thank you very much and
good night.
485. The meeting is closed.
Second day - 18 February 1997
Chairman
486. As announced yesterday,
we shall proceed in the following manner. We will go first to
Canada for their comments and questions to the experts. We will
then turn again to the European Communities and I would urge the
Community to limit their interventions to the utmost necessary
in order to save time. We will see how much time can be allocated
when the Canadians have made their statements and questions and
then there will be final questions from the Panel to the experts
and then the final statements by the experts in the end. I have
to be able to conclude this meeting by around 6 o'clock. I am
not able to say whether we will be able to do so. It depends
on you and I am in your hands to a large extent.
Mr. Christoforou (EC)
487. We would really do our best
to respect what you have indicated, but our delegation has a serious
problem in the sense that the planes of two of our scientists
are leaving at 6 o'clock and we consider their testimony and their
presentation very important. It is just a request and we hope
we have the understanding of the Panel in this room. If it is
possible by 4 o'clock, Canada does not finish, I do not know how
many questions they have, if we can stop for a while they can
make their presentations and if there are any questions or answers
and then they could probably be able to take their taxis and get
to the airport in time. That is the request.
Chairman
488. Thank you very much. I
think we will see where we are with Canada at 4 o'clock.
Mr. Brinza (US)
489. Mr. Chairman, a procedural
question. Last night we had left that the Panel was going to
deliberate on our question about the follow-up submission. That
was requested by the Europeans and I wondered if the Panel had
come to a conclusion with respect to the matter we had raised
last night. It is important, in part, because as we understand,
the procedure that was just described, there would be no more
opportunity for comments by either Canada or the United States
after the Canadians have finished their questions today (and obviously
we finished our questions yesterday), and there are a number of
points that have been made that I think it would be appropriate
to give us an opportunity to respond to.
Chairman
490. Thank you very much. I
intended to take this up at the end of the meeting but since you
raise it I can give the answer of the Panel. We have looked into
the question and based upon the text which was communicated on
3 February by the Secretariat to the Parties, which I will read
in a second, we reviewed the decision I made yesterday and we
will not accept any ex-post submissions from the Parties. The
United States has submitted some materials, you have submitted
some materials yesterday which we took on the file, but we will
not take on any more written materials after this day. The text
reads "Please find attached the responses of four of the
five scientific experts responses to Panel questions. Professor
Arnold requested a few more days to submit these responses. [They
came later on.] The Parties are informed that their comments
to these questions at the 17-18 February meeting with scientific
experts should be made available, as is customary with the Parties'
oral statements at panel meetings, in the written form and if
possible on diskette to the Secretariat". So this means
that we expected these comments by today and I think we will conclude
the proceedings based on this letter. So if you have additional
materials, please hand them in by the end of this meeting.
Mr. Christoforou (EC)
491. Mr. Chairman, the practice
though is that we are allowed to submit a document at least the
next day after the oral presentation. This has always been the
case. We are adjusting the text while we are speaking and I have
been doing that for so many years and it is always the next day
we are allowed to submit in writing the oral presentation. It
is very restricted this time-limit of today. I would appreciate
it if tomorrow there is also a chance for us to submit a document.
Thank you.
Chairman
492. I think the problem is that
then we need to have another go on rebuttals. And I think we
stick to this here for the moment because this has been a hearing
of experts by a panel and we do record on tape and will transcribe
everything which is being said at this meeting so I do not think
that we would need another written statement on the side of your
part.
Mr. Christoforou (EC)
493. Mr. Chairman, if you apply
this rule then the entire text which is in the text that the United States
has circulated has not been read out orally. Then I would have
unfortunately to request you to exclude all those parts of the
documents which have not been read out. I really regret that
in this part of the document there are so many things which have
not been said yesterday.
Chairman
494. I think it was not required
that this be read out because it says that the comments on these
questions should be made available to the Secretariat. It is
not exactly the same proceeding in my view as in the ordinary
first and second substantive meetings here. I do hope that you
are able to provide some of the materials as it was done yesterday,
today - the statements by the experts and so on.
Mr. Thompson (Canada)
495. Thank you Mr. Chairman.
If I am going to get started before my 4 o'clock deadline then
I had best get quicker with the finger on the button. 496. It had been Canada's original intention to comment quite briefly on the experts' answers to the Panel's questions. Primarily by noting in point form some seven areas where the experts were in general consensus and then to put what we hoped were a few focused questions. We still intend to do that, however some of the events of yesterday require some broader comments on Canada's understanding of the purpose of this meeting and the rulings that you made on how we were to proceed.
497. We came here prepared to
comment on and explore the Panel of Experts' answers to your questions
and abide by your ruling that no new evidence would be introduced
after 8 February. I believe, Mr. Chairman, that you will
recall the purpose of that ruling was intended to provide all
participants with an equal opportunity to review relevant material
in advance so that informed commentary could be made.
498. Yesterday we all had the
privilege to hear some of the world's leading experts comment
and debate the properties and characteristics of the substances
in issue. Some highly technical and complex issues were discussed
with clarity and precision. Unfortunately and unfairly, in Canada's
submission, we were sometimes deflected from that very high level
of debate by the introduction of new material, some of which was
apparently presented out of context and in a selective way. The
Panel's experts were asked to make extemporaneous replies on matters
they had not had an opportunity to consider in advance. This
sometimes led to prolonged discussion clarifying facts on matters
of marginal importance to the issues this Panel must decide.
499. An example, no better or
worse than many I could choose, is Dr. Epstein's table on
oestradiol residues in eight-year olds, which ultimately led to
the somewhat surprising assertion that two quarterpounders
or 110 gram whoppers were the equivalent of 500 grams of
meat. If I could be permitted a pun, that was a real whopper!
With respect, it is important to refocus the issues these experts
are here to help elucidate.
500. The complaint before this
Panel concerns a measure of the EC which bans the importation
of beef or any of the six hormones, alone or in combination, that
have been used for growth promotion purposes in the face of properly
established international standards of safe use.
501. One goal of the SPS Agreement
is to further the use of harmonized sanitary measures between
Members so as to protect health but not unnecessarily interfere
with trade. The Agreement permits a Member to depart from these
standards for certain prescribed circumstances. The relevant
one for the issue concerning the Panel's experts, and the only
one in my submission, is a scientific justification. Dr. Randell
has spoken eloquently of the high standards of JECFA and Codex
and the subject matter that was taken into account in establishing
the standards of both the natural and synthetic hormones and the
very conservative assumptions adopted to ensure safety through
the use of ADIs and MRLs where required. It is clear that these
organizations are to be commended for their work and nurtured
rather than criticized.
502. We have learned that studies
have been conducted for more than 12 years to try and prove a
hypothesis that oestrogen is genotoxic. Many of these studies
were known to and considered by JECFA. Dr. Liehr, in one of his
studies, has injected comparatively massive doses of oestrogen
in a male Syrian hamster in an experiment designed to produce
tumours. The quantities are about twice the dose given to cattle.
Dr. Lucier, as I understood him, agreed that in light of this
evidence there was a risk, but he puts that risk at a level somewhere
between zero, a concept which cannot be achieved in absolute terms,
and a factor so small that it cannot be measured.
503. The question for this Panel
is this in my submission: is that a risk that justifies departing
from an international standard in light of its impact on trade
and the objects of the Agreement. One way of testing that, Mr.
Chairman, is by comparing other EC sanitary measures where there
are similar or greater risks. Canada will pose some questions
on the issues of consistency or lack of it in the EC's handling
of these and other veterinary drugs.
504. Before turning to those
questions I would like to review what Canada submits are the points
of consensus between the Panel's experts: (1) good animal husbandry
practice is a broad term encompassing good herd health, management
practices and includes good practice in the use of veterinary
drugs; (2) in the event that good practice in the use of veterinary
drugs is not followed, higher residue levels may result.
505. However, given the fact
that the MRL was derived from an ADI where a large safety margin
has been applied, such an event is unlikely to cause an adverse
health effect; (3) consumers are not able to distinguish the
meat of an animal treated with growth-promoting hormones and the
meat of an untreated animal; (4) observing withdrawal times for
the hormones does not guarantee zero residues in meat. No
residues detected does not imply that there are no residues present
in meat as they may be present at levels that are below detection;
(5) following treatment with the natural hormones, for either
therapeutic, zootechnical or growth-promoting reasons, hormone
levels will fall to those normally associated with untreated animals.
There are no differences between the residues of natural hormones
that are endogenous to the animal and the residues of the same
hormones administered exogenously to the animal. Extensive data
relating to genotoxicity and carcinogenicity were available to
the JECFA and were considered by the Committee. The Committee
concluded that the five compounds evaluated are not genotoxic
carcinogens; and (6) growth hormones have been used in animal
husbandry for many years; in some cases up to 40 years and there
are no human epidemiological data that suggests a hazard. Adverse
health effects have not been observed in those countries using
growth hormones.
506. I have just one other point
I wanted to raise briefly, not for purpose of resolution but rather
to alert the Panel to an additional concern that Canada has.
It has become apparent that the European Communities intend
to present a slide demonstration at some time this afternoon.
I have not seen that demonstration and I do not know the contents
of it, but I am concerned that it may well be fresh evidence which
would be introduced after the February deadline the Panel has
set and I am also advised by some people who claim to have seen
these slides that it is of little scientific assistance and may
well be inflammatory. If and when the EC chooses to present that
slideshow I would hopefully have an opportunity to discuss whether
it is appropriate or not.
507. If I may I would like to
turn to my questions.
508. Dr. Arnold, on pages 10
to 12 of your written answers you described the evaluations conducted
by the EC for oestradiol and progesterone pursuant to Regulation 2377/90.
As a result of the evaluation oestradiol has been put into Annex
2 of that Regulation and progesterone is pending I understand.
Could you describe the significance of putting these substances
in Annex 2 and could you contrast it with the significance of
putting a substance in the accompanying Annex 4 and perhaps describe
some of the substances that are in Annex 4?
Dr. Arnold
509. I should perhaps spend the
first minute describing the working relationships between JECFA
Codex and the competent bodies of the Community because I think
then you would better understand how this happened.
510. We have set up in the Community
a working party obliged to propose maximum residue limits for
residues of veterinary drugs in 1984. We started at the beginning
without having a true legal basis so it was a big advantage when
Regulation 2377/90 became effective on 1 January 1992. If you
look, for example, at the Official Journal, or maybe at Volume
6 of the Rules Governing Medicinal Products in the European Community,
you will see a whole volume devoted to this issue. You will see
the regulation, you will see guidelines, what the requirements
are for the evaluation and you will see an annex to that regulation
with a list of studies required in order to scientifically evaluate
the substances. This list is absolutely identical with the list
of JECFA requirements because it has practically been copied from
JECFA.
511. I was the Chairman of this
Safety Group at this critical time for more than three years and
was helping drafting these rules and regulations at that time.
This was also an interesting time because JECFA had just started
doing reviews and we quickly realized that this could be of great
help to us in the European Community.
512. If I look back at the time
between 1984 and 1988-90 we had not achieved to set any MRL because
it is really a tedious procedure, and as soon as we were able
to cooperate with JECFA and Codex and harmonized our procedures
with a system, we also harmonized with the Food and Drug Administration
we had regular meetings the EC Commission and various experts
with the Food and Drug Administration, there was an exponential
growth. If you check the list of MRLs we have so far adopted
it is quite a considerable list. But you will find the exposure
limits, the ADI, are almost every time identical, those proposed
by JECFA with those used in the EC. There are slight differences
in the MRLs and this can be readily explained because veterinary
practices are not the same in all countries.
513. Coming to the hormones,
when JECFA has proposed MRLs and ADIs for hormones it was impossible
to discuss this issue in this Safety Group and in the Committee
of Veterinary Medicinal Products because it is well known that
we have had already at that time the specific agricultural policies
and the specific rules. Therefore it was surprising to me, and
I told you yesterday, that six years after JECFA had discussed
these substances, a Committee of the EC came to the same conclusions
that the JECFA position is adopted and they also felt it was unnecessary
to set an amount in ADI for oestradiol and was unnecessary to
set an MRL and this has been signed by the competent authorities
of DGIII, of DGVI, it has been published in the Official Journal.
And this demonstrates that, scientifically spoken, what JECFA
produces, what the JECFA Codex system produces, even if the results
have not been officially accepted in the Codex procedure they
are used everyday and to the benefit of the consumer protection
in Europe.
514. I wanted to say this at
length because otherwise you could have the impression that we
feel very uncomfortable with JECFA. In fact the opposite is true.
515. Coming back more specifically
to your question Annex 2 is meant for substances which no MRL
is needed. I give you maybe two examples. If you use sometimes
a local anaesthetic on a horse it might be necessary to set a
withdrawal time but this is a ridiculous problem in view of setting
MRLs for consumer safety in a community like the EC. This could
be a candidate for such a substance, or if the substance absolutely
harmless after the evaluation had been done. The usual procedure
is that the company has to apply for inclusion in Annex 2 and
they have to submit scientific evidence. Harmless substances,
mainly harmless substances, for which there is no need to set
an MRL, for example, elements which endogenously occur in the
body. It is a rather long list and they are put into Annex 2.
516. In Annex 4 it is a little
bit more difficult. Originally this Annex had been developed
to include substances for which it is impossible to develop any
conditions of safe use. This means for real hazardous substances,
this was the original meaning. But what then occurred that later
we had substances for which there were indications that they could
be hazardous and gaps in our knowledge missing information. Since
these were all out of patent substances and since no sponsor applied
to prolong the presence of these substances on the market in order
to be able to develop the missing data, some of these substances
have also been included in Annex 4. That means we find there
substances for which it is quite sure that they are hazardous
under all circumstances and other substances for which there is
a strong indication that they might be hazardous and no sponsor
could be identified who is willing to produce the missing data.
Maybe this is enough for the moment from my point of view.
Mr. Thompson (Canada)
517. My second question is also
drawn from some of the material in Dr. Arnold's answers. By way
of prelude I can let you know it is a compound question and there
will be some follow-ups that come with it.
518. In your answer to question
2.2 on page 5 of your written answers there is a table that describes
the uses of nature identical hormones and their esters in the
European Communities. My first series of compound questions are:
How are these substances used? Why are they used for oestrussynchronization
and when used for synchronizing oestrus, are the animals treated
because they are sick or for a zootechnical purpose? This question
may also venture into the expertise of Professor McLean.
Dr. Arnold
519. I cannot satisfactorily
answer all your questions and subquestions. I wanted to
show only a few examples of substances for which I absolutely
know that they are used. The list might be longer because a list
of substances which are in compliance with our rules in the EC
has been set up early on the advice by the Committee for Veterinary
Medicinal Products, there are more substances on the market.
I am not a veterinarian so I cannot really tell you whether this
is justified to use these substances for this purpose. What I
wanted to show you was how similar some of these substances are
which are used on the one side for growth promotion and on the
other side for therapeutic and zootechnical purposes, but there
are also differences in the esters, and based on this table I
developed my answer so these were just examples and I can as a
non-veterinarian not justify their use but I am sure they are
used in accordance with the directives in the EC.
Mr. Thompson (Canada)
520. I wonder if Professor McLean
or one of the other experts can assist me with that information?
Dr. McLean
521. Thank you Mr. Chairman.
Oestrus-synchronization is a commonly-used animal husbandry practice.
You synchronize the reproductive activity of your herd for a
variety of purposes; it may relate to the availability of feed,
it might relate to the availability of markets, etc. It is a
relatively common animal husbandry practice.
Mr. Thompson (Canada)
522. After use would residues
of these administered substances be present in meat and milk of
the treated animal?
Chairman
523. I would suggest that all
of the experts may take the floor if they wish to do so. Who
would like to go first?
Dr. McLean
524. Yes, the residues would
be in meat or milk if the animal was slaughtered. It is interesting
that oestrus-synchronization that is often used in dairy cattle
in a variety of production circumstances and the residues would
be in milk.
Mr. Thompson (Canada)
525. If I could continue with
that table and some of the information on it. I wonder if any
of the experts who feel confident could help me with the use of
these various esters in the EC formulations. What are the chemical
differences between the esters and why are different esters used
and is there any comparison of persistence in the body of these
various esters?
Dr. McLean
526. The esters are generally
used to alter the rate of uptake of the drug from either the injection
site or if it is in some sort of intravaginal device for example,
although generally not there, it alters the rate of uptake. But
what generally happens is that the oestradiol ester is actually
metabolized either at the site of injection in the blood or in
the tissue and the bond between the active substance, the oestradiol,
and the side chain to which it is bound is readily broken and
the active constituent oestradiol 17 beta, or testosterone
in its various forms, is the active constituent.
527. There can be under some
circumstances small quantities of the ester appearing in the blood
and that is picked up by analysis. But those levels are small
and no consideration when it comes to looking at the toxicity
because, for example, if there were esters in the meat and someone
ingested that meat then the enzymes of the gastrointestinal tract
of humans that digests normal food readily cleave the ester bond.
Chairman
528. Mr. Thompson, just for the
benefit of the Panel, would you anticipate to draw some conclusions
from these statements? I am not in a position to do so myself.
Mr. Thompson (Canada)
529. I thought that was the purpose
of tomorrow's meeting when I would be presenting oral argument.
But the general purpose of these lines of questions and a few
others that I have is to try and demonstrate that the European
Communities use some of these hormones either alone or in combination
for zootechnical purposes such as in increasing the rate of production
in sheep and cattle. Notwithstanding that other alternative means
may be available they continue to use these substances for these
purposes. What I would be arguing tomorrow in a like manner is
that North America and other places use growth hormones.
Dr. André
530. Mr. Chairman, I think there
is a very big difference between the use of such drugs for therapeutical
or zootechnical purposes. In very precisely defined animals,
as Professor McLean said, and the use of the same hormones or
similar hormones in large scale for growth promotion. No scientist
has said that it is a bad thing to use these hormones for therapeutical
use. The problem is for growth promotion on large scales on all
the animals, it is not the same thing as is being discussed now.
Chairman
531. Is it true that for therapeutical
reasons this is done under prescription by assistance of the veterinarian,
while the growth promotion is not done so? Can I ask this just
for my clarification to one of the experts?
Dr. André
532. In Europe it is done under
veterinarian control. Directly by veterinarians in some countries
or under veterinarian control by prescription in other countries.
For growth promotion we have no experience.
Mr. Thompson (Canada)
533. Perhaps I could continue
with some of the other parts of my question and it may become
clearer as to the reasons I am asking this. My understanding
is that it is not so much therapeutic uses as zootechnical uses
in order to increase the production of sheep and cattle so that
their gestation periods are reduced and happen more frequently.
534. Can the experts help me
with whether there are any synthetic hormones used in the European Communities
for synchronization of oestrus such as medroxy progesterone acetate
or allyltrenbolone, or whether oestradiol is combined with progesterone
in some of these proceedings?
Dr. Arnold
535. I would like to ask my colleagues
to assist me. What concerns allyltrenbolone there is an exemption
in the directives. This substance can be used because, as I said
yesterday, it is not suited for growth promotion. Although the
name is suggestive, it does not have the properties of trenbolone.
Allyltrenbolone is totally different from trenbolone with respect
to the biological facts. So this is the first part of my question.
536. The next part I am not so
sure. I know that the European Medicines Evaluation Agency and
the CVMP has just finished an evaluation of medroxy progesterone
acetate under my recommendation and this does not fit into my
picture of what is legal in the EC. Maybe you, François,
you know?
Dr. André
537. No, I have no information
of this regulatory point but in any case this compound is used
for zootechnical purposes and not for growth promotion. It will
never be evaluated by EC Organization as growth promoters. It
is a very different thing. We are speaking about things that
are not of concern with growth promotion here.
Dr. Arnold
538. My problem is that it is
synthetic and it doesn't yield the natural hormone upon hydrolysis.
That is my point. It is certainly not suitable for growth promotion.
Dr. McLean
539. Medroxy progesterone acetate
is sometimes included into an intravaginal device along the lines
of the second line on table 2.2 of Dr. Arnold's submission. It
is used in a number of countries.
540. If I might just add for
the sake of clarification, whilst these substances for zootechnical
purposes are used in individual animals, it is not unusual in
some practices for a significant portion of the herd to be treated
over the life of a reproductive season, if I could put it that
way.
541. In other words, whilst individual
animals are treated you might get 10 or 15 or 20, I am not fully
familiar with the production procedures of EU, of the herd treated
over one part of the year that is associated with the breeding
season.
Dr. André
542. Mr. Chairman, may be you
are not very familiar with the reproduction control in farm animals.
In this case, may I explain to you that the medroxy progesterone
acetate is included in a sponge and the sponge is put into the
vagina of the sheep with a small cord. During a period between
10 days, 15 days, two weeks or maybe a little more but it is not
a problem. Then the sponge is pulled out with a small cord and
then after this treatment the animal comes into oestrus and is
then inseminated and becoming pregnant in most cases. Only one
per cent fail to be pregnant and this maybe could be a problem
for these animals, but usually people try again and it is not
really a problem. It is not a problem of residue of synthetic
hormones because these animals are bred to have sheep and they
will stay a long time in the farm. They will not be slaughtered
after such treatment. It is not the objective. It is very different
to treating animals for growth promotion and to slaughter them
at the end. It should be very clear in your mind.
Chairman
543. Is this a step of preventive
medicine or is this a treatment for animals who have difficulties
to conceive?
Dr. André 544. It is just a so-called zootechnical practice. That means it is more easy for the farmer to have all the females at the same date on oestrus and to inseminate them at the same time and then to have products at the same time. It is more convenient for management of animals. No more. TO CONTINUE WITH EC MEASURES ON MEAT - COMPLAINT BY THE U.S. |
|