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Consultation and bureaucracy

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IT IS one of life's ironies that the more the Government tries to reduce red tape and bureaucracy, the more bureaucracy it seems to create. An example can be found within the Department for Business, Enterprise and Regulatory Reform, where a special executive has been established to ‘work across government to reduce and remove unnecessary regulation for the public, private and voluntary sectors’. One result of this initiative is that Government departments are now required to publish ‘annual rolling simplification plans’, identifying ways in which they can cut red tape and make savings against measurable targets and demonstrating how these reductions can be achieved. The paper-generating capacity of this exercise is illustrated by the fact that, in the case of just one Government department, defra, the two simplification plans that have been published so far have between them clocked up nearly 150 printed pages. There are many other instances where well intentioned efforts seem to have added to the paperwork. A consultation document issued by defra on the future of the Veterinary Medicines Directorate last week (see p 312 of this issue) is a case in point.

The consultation on the vmd is itself the result of an initiative aimed at reducing red tape. Its origins lie in a review undertaken by Sir Philip Hampton in 2004 with a view to reducing the administrative burden on businesses, as part of the Government's ‘better regulation’ initiative. The Hampton report was published in 2005 and made 35 recommendations. These were accepted by the Government and are now being applied across all departments. One of the recommendations was that the many organisations carrying out regulatory and inspection functions on behalf of the Government should be reorganised and consolidated into seven ‘thematic’ regulatory bodies. The current consultation seeks views on whether that particular recommendation should be applied in the case of the vmd.

The consultation document considers two main options: either merging the vmd with Animal Health, the Health and Safety Executive, or the Medicines and Healthcare Products Regulatory Authority; or retaining the vmd as an executive agency of defra. It discusses areas of possible overlap between the vmd and each of the three merger candidates, as well as presenting ‘the business case’ for each option along with the obligatory impact assessment. In the process, it makes a pretty strong case for retaining the vmd as an executive agency of defra, noting, for example, that the vmd has few direct synergies with the three other agencies, and that it is unlikely that much could be achieved through economies of scale. It also suggests that a merger could result in a loss of focus on veterinary medicines, reducing the level of service provided.

One could think of other reasons why a merger might not be appropriate, not least of which is that veterinary medicines regulation is a specialised area making it important to retain core expertise, and for this reason alone it would seem desirable to retain the vmd as a separate agency. However, this does raise the question of why, if the case against a merger is so strong, defra is taking the trouble to consult on the issue in the first place, unless it is to meet some bureaucratic requirement within government. That said, it will be important that those with an interest in veterinary medicines respond to defra's request for comments, because the consultation document suggests that, despite the information available so far, ministers have still to make a final decision on the issue.

Consultations are now an established part of the Government's policy-making process and are generally acknowledged as improving transparency. At the same time, as the House of Commons Science and Technology Committee pointed out in an excellent report on ‘Scientific advice, risk and evidence-based policy making’ (see VR, November 25, 2006, vol 159, p 725), there is a need to guard against consultation fatigue and to maintain a consistent approach. It is of course a matter for the Government to decide on whether or not to consult on any particular issue, although there are times when it seems happy to consult on some issues but not on others. In this context, there seems to have been little consultation on its recently announced plans to review the England Implementation Group (see p 313 of this issue), although it does intend to consult on the wider issue of cost and responsibility sharing on animal health later this year.

The fact that the Government is consulting on the future of the vmd makes one of the debates planned for the bva Congress later this month all the more topical. The title of the debate is ‘Better regulation on medicines?’, and speakers will include the chief executive of the vmd, a past-president of the bsava and the president of Veterinary Ireland. The subject up for discussion is whether the Government is being overly pragmatic in its approach to regulating veterinary medicines, or whether it can be accused of gold plating.

  • The bva Congress is to be held at the Royal College of Physicians in London from September 25 to 27. Full details are available from bva headquarters (e-mail: bvahq{at} or at

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