NSAID regulation in vulture range states: A review and analysis of European and South Asian policies regulating the licensing and banning of vulture-toxic drugs.

Abstract

Within a decade (1994-2004), the nephrotoxic effects of the non-steroidal anti-inflammatory drug (NSAID) diclofenac reduced South Asia’s once abundant endemic vulture species to one of the most threatened groups of birds in the world. After a suite of bans on the veterinary use of diclofenac across the Indian Subcontinent in the late-2000s, vulture populations in some areas are thought to be stabilising although numbers remain critically low. Further regulatory progress on banning other NSAIDs also known to be vulture-toxic has been slow and a mosaic of inconsistent licensing decisions exists across the range states of these obligate scavengers. This thesis documents the workings of existing drug licensing procedures for the authorisation and banning of veterinary NSAIDs across key vulture range states in Europe and South Asia, before analysing these procedures through the lens of various policy legitimacy indicators. While contextual factors limit direct comparisons between certain case studies, all are facing similar challenges that restrict legitimate and evidence-based veterinary NSAID regulation: (i) decisions on NSAID licensing have been made without regards to safety testing in non-target species including vultures, (ii), the limited bindingness of national and international vulture conservation commitments is impeding evidence-based decision-making, (iii), policy variation across the Indian subcontinent has engendered incoherence and ambiguity, while the transparency and enforcement of measures remains a challenge and (iv), the precautionary approach applied to the regulation of other diffuse ecotoxic chemicals in the European Union has not been afforded to the use of veterinary NSAIDs.