Prague, 10 December 1999

Dr Bernard V a l l a t

Controleur general des services veterinaire

Chef du service de la qualite alimentaire

et des actions veterinaires et phytosanitaires

Direction General de l'Alimentation

President, OIE Code Commission

175, rue du Chevaleret

75013 P a r i s

F R A N C E

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Dear Dr Vallat,

first I would like to express my appreciation that the Code Commission under your chairmanship has improved several parts of the Code. However, there are still a lot components to be changed respecting the main responsibility of the OIE, i.e. to improve animal population health status and avoid animal diseases spreading in the world. OIE as the global organization is responsible to its member country governments and not to WTO (as its servicing agency).

I have been reading about the dispute between United Kingdom and France regarding the import from BSE affected territory. Thousand new cases testify that the situation is not under control and creation of disease free zones is more than problematic. This is valid for any disease incidence. Past experience of BSE introduction in spite of official certification of disease free status is other fact supporting French position. Therefore, I fully agree with France authorities which are responsible for the protection of health of its human and animal populations. Government authorities (such as Chief Veterinary Officer) must have not only the responsibility but also the right to decide about the import, including the refuse, and nobody else who is not responsible for country population protection. It cannot be acceptable that international agencies, such as WTO or International Court, can impose (dictate) to accept animals or raw animal commodities which represent the diseases introduction risk against the will of importing countries. This case clearly confirms my concerns regarding "new" international trade policy facilitating animal diseases spreading, imperfect international information system and very problematic risk assessment methodology which I have expressed several times in my letters to OIE HQs. This case also shows that OIE dispute referee system should reconsidered. What about the majority of countries having not so competent veterinary service able to defend their territory and having not such international authority as France has ?

The above mentioned case and many others have proved that the "WTO Agreement on the Application of Sanitary and Phytosanitary Measures" has nothing to do with fair trade due to gross discrimination of importing countries !!!. This document has created legal basis for animal disease spreading through the trade as never before ! It should be abolished. I think that OIE Code alone should be sufficient as before. However, if the relevant agencies decide to have it, then only after a complex revision and p r a c t i c a l testing giving the highest priority to strengthened protection against diseases spreading. OIE as World Organization for Animal Health is the right organization to initiate this steps. As follow-up of the above mentioned WTO document, the OIE Code, which had always been the recommendations only based upon member countries consensus (not the outcome of scientific research and not always transparent !), was converted into obligatory international regulations. On the other hand the importing countries are pushed to justified "scientifically" (with sufficient scientific evidence) the refusal of the commodity which they do not want ! As I remember, the policy of international veterinary organizations was always to avoid diseases spreading and not to admit their spreading !

OIE information about diseases occurrence necessary for importing country decision-making was significantly reduced instead to provide more data. Symbols about the grades of disease occurrence were reduced to "+". The numeric data about the incidence are usually very incomplete. I would like to mention one example from recently published "Dictionary of Veterinary Epidemiology" on page 147: "It is assumed, that for every case of salmonellosis recorded in humans in the United States at least nine are not reported." This is the reality in human diseases reporting and what about animal diseases reporting. How to assess the risk ? Some exporting countries try to use mathematical models to demonstrate theoretically that the risk is minimal or zero. But the reality is very often different.

General tendency in international trade is to increase the quality requirements. Trade in animals and their products must not be the exception. Trade should be facilitated by improving animal population health quality in exporting countries through disease reduction and eradication and not by imposing upon importing countries the "duty" to reduce the protection barriers against diseases introduction. Not speaking about the tendency to reduce (due to "economic reasons") government veterinary services and their control/inspection role in field, laboratory and trade instead to strengthen it. Accredited private veterinarians replacing government staff are not always reliable.

I am concerned about the future animal health situation in the world. The situation has become critical. We have to avoid this kind of ecological disaster. No to globalization of diseases, yes to globalization of health ! I am attaching a text about "Risk of zoonoses spread through export and import" which could be of your interest.

Best regards !

Prof. Dr Vaclav K o u b a, DrSc.

Former Chief, Animal Health Service, FAO UN

Annex:

RISK OF ZOONOSES SPREAD THROUGH EXPORT AND IMPORT

Rapidly increasing international trade in animals and raw animal products increases risk of zoonoses spreading among countries and continents. Many recent cases of zoonoses introduction by trade have proved that current veterinary import conditions, certifications and measures do not correspond with the new situation. Import of these commodities represents a potential risk not only of zoonoses introduction but also of their after-import spreading with multiplying negative, often long-term or permanent consequences. The detection, control and eradication of introduced and spread zoonoses are usually very difficult and costly. Not all introduced zoonoses can be blocked within the quarantine to avoid secondary outbreaks. Not all introduced zoonoses can be eradicated (e.g. diseases with natural nidality), some of them only after long period requiring a lot of economic and other inputs. Due to biological complexity, it is not easy and often impossible to identify how and when the disease was introduced if discovered after quarantine period. The risk grade is directly correlated with import size and frequency as well as with the number of origin and destination places and distances between them. The post-import losses and demanding additional measures are paid by tax-payers and not by profiting traders. All these facts represent the main difference in comparison with the risk when importing any other commodities.

There have been a lot of cases of zoonoses "import", some of them discovered and reported to international organizations (international information system covers about 1/10 of known zoonotic species), some discovered and not reported (e.g., majority of zoonoses are not obligatory notifiable and not controlled) and much more cases not discovered at all (lack of active investigations to detect subclinical carriers, etc.). Emerging diseases represent a new insidious threat.

There have been many cases when a specific disease was introduced into a "free country" in spite of favorable risk assessment, risk reducing measures and veterinary certification according to international standards.

There are many factors facilitating directly or indirectly zoonoses spread through international trade such as:

a) Mono-etiological instead of poly-etiological risk assessment based only on theoretical mathematical calculations without considering: real diseases occurrence and dynamics (reported absolute data on zoonoses occurrence are usually incomplete), biological complexity (e.g. carriers, ways of transmission, etc.); ability of diagnostic methods to discover all affected herds and animals (false negative results due to low test sensitivity); veterinary services abilities; possible post-introduction consequences; human factors; etc..

b) Lack of legal codes requiring effective protection of animal populations and declaring conscious man-made zoonoses spread as criminal act; benevolent international regulations not respecting that the trade in animals and their raw products is much more risky than in all other commodities; missing legal duties of traders to cover losses caused by zoonoses introduction; etc..

c) Not applying normal fair trade practice, e.g., when importing country veterinary service is not free to decide if or not and where to purchase the given animal commodity and to define health quality conditions; reduced national animal production (low self-sufficiency) requiring larger import; instable trade partnerships, too many and too distant origin and destination places; international agreements unfavourable to importing countries' disease protection, i.e. without sufficient guarantee of disease free quality and without fair reclamation procedure; illegal import, black market, re-export, dumping prices; etc.. For exporting countries is easier and cheaper to manage importing countries to reduce protection barriers than to implement demanding zoonoses reduction or eradication programmes at home.

d) Lack of or deficiencies in protective veterinary measures; lack of ability to apply effective preventive, control and eradication measures; insufficient import quarantine and post-import surveillance; weak government veterinary services being unable to monitor animal population health situation at field level, to inspect export/import on the spot and to issue certificates without being dependent upon not fully reliable non-government services; reporting specific "disease free" status without adequate investigations; benevolent import conditions (unjustified concessions) reducing barriers against zoonoses introduction instead of strengthening them.

e) Human factors: exporting country not reporting true situation, mistrust, risk underestimation, not taking lesson from previous disease introduction, inexperience, errors, irresponsibility, cheating, corruption, lobbying, blackmailing, outside "pressure", identity / health certificates falsification, abusing "disease regionalization" and "disease zoning", low discipline when applying laws, regulations, norms and veterinary measures, low authority of veterinary service, low standard of accreditation of private veterinarians, etc.

Controlling only few selected zoonoses and confirming "free status" of exporting animals and products means omitting not notifiable and not controlled diseases transmissible to man. What about newly emerging zoonoses ? Therefore, it can be supposed that among imported animals and their raw animal products can be also carriers of etiological agents which in importing country are considered as exotic species, types, subtypes or strains. Not all can be controlled. Absolute "filter" doesn't exist. In spite of the best possible protective measures, zoonoses introduction cannot be always avoided when importing above mentioned commodities. Every import of these commodities is a risk.

The situation is getting worse as never before in spite of having much better scientific knowledge as in the past. General tendency in international trade is to increase the quality requirements. Trade in animals and their products must not be the exception. Improvement of animal health quality in exporting countries through diseases reduction and eradication is the best way to facilitate fair trade in animals and raw animal products.

November 1999