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INTRODUCTION
Vulture is a large sized bird, weight of adult bird ranges from
10-15kg, source of food is carcasses of dead animal, very rarely
takes live prey. Vultures are described as endangered species
due to decline in its population. This decline has been noticed
in all parts of the world including western countries.
SUPPORTIVE REFERENCES RELATED TO WORLD OVER
DECLINE FILE A
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Bearded vultures is an endangered
species in Europe, because its population no. Fewer than 250
pairs listed on annex 1 of EU wild birds’ directive and appendix
2nd of burn convention and born convention reference
page 4of 23, final draft September 1999 bird life international.
Ø
Griffin vulture in Cyprus is
decreasing from year to year, on some traditional nesting sites
no more birds are seen. This decrease was also ob served in
other European countries. (Glutz el Al). In the late 80’s and
early 90’s vulture became a rare phenomenon in the skies of
Cyprus. General breeding colonies ahs possibly been exterminated
page 1 of 3 the world of Cyprus kyprosnet .web.
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The most under pressure species
the sword fish, African bull log, and the South African cap
culture (Scottish wed 25 October, 2006).
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In the Alps bearded vultures were
exterminated in the course of Nineteenth century. WWF bearded
culture population and distribution.
Ø
Between e the beginning of 1970
and early 1990 the breeding population of the Egyptian vulture
in Italian peninsula decrease from 29 to9 breeding pairs. We
analyzed the main aspect the decline of the population during
last 30 years. Biological conservation source 2001 volume.
Ø
Vulture population found in Spain,
Turkey, Iran, Afghanistan, china, India, Sudan, Pakistan,
threatened world over. Accipitride hawks and trees eagles;
http://my.org.il/holon/birds/q11.html
CAUSES IDENTIFIED FOR VULTURE
DECLINE WORLD OVER
Most of the researchers world over have identified the following
factors responsible for vulture decline.
1.
Shortage of carcasses available to vultures due to better
arrangements of its disposal.
2.
Bacterial and viral diseases affecting the vulture.
3.
Breeding failures.
4.
Urbanization and climatic changes.
5.
Pesticides and chemical contamination.
6.
Loss of habitants and deforestrization.
7.
Decrease in wildlife.
8.
gun shooting
9.
Poisoning.
DICLOFENAC AS SOLE CAUSE OF
VULTURE DECLINE.
Dr. Aleem professor of zoology Bhauddin Zakariya
University with financial support of peregrine fund USA
conducted a study on vulture decline in Pakistan form 2002-2003
(Annexure1. File B)
His paper concerning to this research was published in 2004.
According to his findings Diclofenac treated animal when dies
they contain of residue of Diclofenac sodium
When vulture consumes flesh of these dead animals their kidneys
are being affected and they die due to kidney failure. The
findings of Dr. Aleem’s research are altogether different than
the findings of other researches conducted world over.
POINTS FOR RECONSIDERATION
Diclofenac sodium containing preparation REUFLOGIN from FATRO,
Italia was registered in Pakistan 1996 and launched in 1998. The
price for 50 ml pack was Rs: 450, due to its high price the
acceptance was very poor in the market. Locally manufactured
Diclofenac sodium was registered in year 1998. It is obvious
that any drug introduced in the market takes years to be
popularized, the customers of veterinary drugs are mostly
illiterate and scattered in remote areas, their behavior towards
new invention is very rigid, they still believe on conventional
type therapies to treat the animals.
Dr. Aleem started his research on vulture decline in year 2000,
how one can believe that in span of 1-2 years Diclofenac is
being spread throughout the country and being consumed by 100
million animals of the country. In his own research paper Dr.
Aleem has declared that the vulture population decline in sub
continent was first noted in 1990. According to his assumptions
Diclofenac sodium is responsible for vulture decline before its
launch. Research published by Dr. Aleem is controversional to
all researches conducted world over on this subject at different
times. He has ignored all other factors identified in previous
scientific studies and made only Diclofenac sodium responsible
for the decline of vulture population.
This study was discussed at different scientific
forums in Pakistan and nobody was satisfied with the findings to
this research. WWF with the collaboration of ICUN conducted a
workshop on 2nd September 2004 as WWF Head office,
Lahore,. This session was attended by the staff of WWF and MOH,
professors of pharmacology departments BZU and UVAS, Ministry of
Environment, Department of Livestock and Dairy Development. It
was a day long session attended by 50 participants, Dr. Aleem
presented his research paper afterwards the participants had a
detailed discussion on this subject. Majority of the attending
delegates disagreed with the finding to the Dr. Aleem on
scientific bases. Concluding remarks of the chairperson Dr.
Manzoor ahmed, Vice Chancellor, UVAS were as following.
(Annexure 2. B)
There is need for action to stop the rapid decline of vulture
population and offered all the support of university, he further
said that the causes of population decline were still in
question. Minutes of the session were prepared by Uzma Khan,
conservation biologist WWF Pakistan and circulated to all
participants. Surprisingly Uzma Khan, advocated to standing
committee to National assembly on Environment to ban Diclofenac
sodium in veterinary use to show her efficiency.
CONTROVERSIAL POINTS
1. No research world over except that of Dr. Aleem have made
responsible Diclofenac sodium for decline of vulture population.
2. Dr. Aleem in his research has stated that
the residue of Diclofenac sodium in the carcasses of treated
animal are responsible for the decline of vulture. According to
him when vulture consumes flesh of Diclofenac treated animals
they develop hyperuricaemia, which results into deposition of
URATES in the kidney of vultures leading to kidney failure. This
statement is entirely different than the data published in the
Martindale Pharmacology 33rd Addition 2002(Annexure
3. B)
The book states that the terminal plasma half life of Diclofenac
Sodium is 1 – 2 hours it means that Diclofenac is eliminated
from the body very quickly. 50% of the drug is excreted in 1 – 2
hours.
A research conducted in Department of
Pharmacology College of veterinary medicine and Animal resource
king Faisal University of HOUFOF Saudia Arabia
(Annexure 4. B),
by Dr. Abdullah PhD,
Dr. Khalid PhD,
Dr. Badar Uddin PhdD
Dr. Muzaffar PhD
on pharmacokinetics of Diclofenac sodium in sheep has the
following findings “Diclofenac is quickly eliminated from sheep
with terminal T12 of 2-3 hours for both route of administration.
The drug should be administered 2-3 times to maintain
therapeutic concentration.
In
Pakistan Diclofenac sodium is administered once in 24 hours to
the ailing animals the usual dose is 2.5mg/kg body weight.
Diclofenac sodium do not has any prolong use, in most of the
cases 2 or 3 injection are enough to treat animals. Drug having
rapid excretion properties and short treatment regimen how can
be made responsible for residual effect. This may happen with
the Drug having long half life and prolong use.
3.
All experiments done by the respectable researcher are
hypothetical. Some debate able points of the study are as
following.
A.
In his first experiment on captured vulture, he injected 2.5 mg
\ kg body weight.
The dose of 2.5 mg \ kg body weight is for animals, according to
him both of the vultures who received animals dose died.
In
his study he has ignored the fact that Diclofenac reaches in the
body of vultures, through the dead bodies of the animals.
Practically it is impossible that the same strength of
Diclofenac injected to any animal will be transferred to
vulture. Diclofenac when administered to any animal majority
portion of it is exerted without 2 To 3 hours, and moreover we
are not sure that when the animals is going to die, So how we
can presume that Diclofenac when injected will be transferred to
vulture without any loss in its potency .Dead bodies of animals
are exposed to extreme weather conditions. External field
factors affects the potency of the drug. Most the medicine
including Diclofenac is stable below 30°c.
In
open areas the temperature in summer reaches above 50°c, at such
a high temperature drugs are destabilized.
B.
In his second experiment he stated
to verify that carcasses of treated livestock contain sufficient
Diclofenac concentration to cause kidney failure and death. Ten
juvenile OWBW were fed meat from a Buffalo or Goats that were
injected intramuscular with 2.5mg \kg of veterinary Diclofenac
once daily for 3 days, and that were slaughtered 4 hours after
the Injection. The captured vultures were then fed on the meat
of Diclofenac treated animals. The logic followed is not
appealing what certainly the researcher have that all animals
treated with Diclofenac injection are surely have to die within
4 hours after getting injections and have to be available as
food for the vultures.
C.
The whole research of Dr. Aleem is based on in-door
observations. He has totally ignored the field facts. Instead of
injecting Diclofenac directly to Vultures. He should have
collected flesh from carcases, and then the vultures should have
fed on them to observe the effect.
4.
Diclofenac sodium is not a life saving drug. It is used in
livestock for controlling inflammation of joints. Diclofenac
sodium is not the first line of treatment is emergency ccases
such as septicaemia, shocks, pneumonia etc, where sudden death
can happen.
If
we assume that the animals dies within 24 hours after getting
injection, the --effect may not be 10% at the time of
availability of carcasses to vultures. A lot of processes are
involved from the time of injections till the availability of
dead body to vultures, during these processes the drug is not
supposed to retain its injected potency. If a vulture being of
15 \ kg body weight consumer 1 kg meat then it will ingest 0.016
mg of Diclofenac. It is not possible that whole of ingested
medicine will be absorbed, I t may be 50% of 0.016, then
strength of absorb Diclofenac is 0.008 mg, which according
researcher own findings is not toxic.
PRACTICAL ASPECT
The Departments of Livestock and Dairy
Development have been providing extensive field services to
farmers both a prevention and
CURATIVE SIDE
These costs of animals have gone up, the farmers are conscious
about the health of their animals, proper medication have
reduced the mortality rate.
The animals when do not respond to medication are sold out the
butchers at a reasonable price.
Disposal of dead animals is a commercial activity. On union
council levels yearly contracts are awarded for lifting of dead
animals. The contractors pay having some amount to the farmers
for lifting the dead animals. Dead animals have commercial
importance, hides are sold out, bones and flesh is consumed for
preparation of protein and bone meal. Which is used as
ingredients in. Poultry and Livestock feed.
Vulture entirely feed on caresses, they are not prey birds.
Shortages of food have made them survival difficult.
BANNING PROCESS
(Annexure 5. C)
1.
NGO’s having their vested interest
contacted ministry of health to ban Diclofenac sodium veterinary
use.
2.
Ministry of health referred the
matter to ministry of agriculture and livestock for obtaining
views of the expert committee on veterinary drugs. The chairman
veterinary expert committee to who in the matter was referred
was of the view.
“Diclofenac has a well established therapeutic use in human and
animals.
The banning of its use in animals on a single study is not
advisable. It needs more research by veterinary scientists;
however this issue will be discussed in detail in next meeting
of veterinary expert committee.
This said committee in its 63rd
meeting held on 5th August 2004 considered this
matter, and decided to propose a study to be carried out by Prof
Dr. Muhammad Ashraf University of veterinary and animal sciences
Lahore out of central research fund Ministry of Health. This
matter was considered by the registration board in its 186th
meeting held on 13th and 14th October
2004 in depth and deferred till study report of Prof Dr.
Muhammad Ashraf Various hypothesis concerning to research were
presented by Dr. Muhammad Ashraf , which were not agreed by
Ministry of Health. Dr. Ashraf was requested on 24-12-2004 to
submit the research projects along with detailed methodology and
budget estimate. Professor Dr. Muhammad Ashraf was called for
detailed presentation on the matter before registration board,
however he could not attend the meeting the board recommended
that Dr. Muhammad should be redefine his studies specifically
pertaining to the matter.
(Annexure 6. C)
3.
Ministry of
environment sent reminders to expedite the progress made in
imposition of Bann on manufacturing and use of Diclofenac in
animals. Matter was taken to the Ministry of environment by the
NGO’s for their vested interest.
4.
Ministry of Environment on pressure from NGO’s referred the
matter to standing committee on environment of National Assembly
of Pakistan
(Annexure7. C)
A meeting was held on 19th November 2005 in Islamabad
very few concerned were called to attend this. The meeting was
deferred to next meeting.
In next meeting of standing committee on
environment held in Islamabad on 14th March 2006
(Annexure 8. C).
None of the concerned from pharmaceutical’s Live stock
Department , Health Department were called to attend this
meeting.
5.
Ministry of food agriculture and livestock sent letters to all
Director Generals of livestock ----Pakistan, professors of
medicines of veterinary colleges; to send their recommendations
to ban Diclofenac. Letter Ref No. F3-1/84-D Islamabad dated 13th
April 2006(Annexure
9. C).
6.
On 26th April 2006 Ministry of Health Ref No
F8-1/2004 Reg / issued show cause notice to Ban \Diclofenac,
suggesting MELOXICAM as alternative drug .MELOXICAM have longer
half life and is expensive. A Comparative study of both the
salts have been attached as reference
(Annexure 10. B)
7.
An opportunity was provided to manufacturers of Diclofenac on
10-06-2006 to appear before registration board. Manufacturer
presented their point of view
(Annexure 11. C)
8.
The registration Board in one 1999 meeting held on 23rd
and 24th August 2006 decided to de-register
Diclofenac for veterinary use
(Annexure 12. C)
9.
Ministry of Health issued circular Ref No. F 3-4/06- Reg – 1
(M-199) dated 15th September 2006, cancelled
registration) of veterinary use Diclofenac with immediate effect
(Annexure 13. C)
10. On appeal of manufacturer, Appellate
board called the Diclofenac veterinary manufacturers to appear
on 21-2-07 at Islamabad. The manufacturer gave a collective
presentation to the appellate Board.
(Annexure 14. C)
11. Appellate Board circular Ref. No
F1-6/2006-AB (PT) (M-131) dated 29th March 2007
decided to uphold the decision of the registration Board
(Annexure 15. C)
Conclusion
The decision to ban Diclofenac sodium injection was based on
single controversional study. The field facts entirely different
than picture presented in the research. Registration Board and
Veterinary Expert committee agreed to conduct further research
on this subject, but it was not completed due to certain unknown
factors. The Decision seems to be unjustified. It looks that it
is just obeying the pressure of the foreign NGO’s who are
working here for their vested interest. The decision taken is
without considering the hardships of poor farmers and
veterinarians. This drug is not banned in Europe Middle-East
Africa etc.
It
is claimed that decline and lost of vulture population has
serious negative impact like the loss of natural scavenging
system that could lead to the spread of animal and human
diseases. It is amazing that we still believe on primitive
practice of disposing dead animals. The conditions and old
practices have now changed. Health requirements are that dead
animals should be disposed off immediately. Why we still believe
on old dated practice for disposal to put at risk the human
population. Natural scavenging system is an old system in which
body of dead animal is consumed in long time, during that period
bad smell makes the atmosphere unpleasant, and also dead body
may be source for deadly infections diseases. It is in the
interest of general public: by adopting scientific latest
disposal method both the human beings and vultures will be
benefited.
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