Prague,13 December 1995

Mr.

Dr S.C. MacDiarmid

National Manager

Agriculture Security and Animal Health

Ministry of Agriculture and Fisheries

P.O. Box 2526

Wellington

N E W   Z E A L A N D

-------------------------------------

 

 

Dear Dr MacDiarmid,

 

 

    this is to acknowledge receipt with many thanks of the documents I asked for in my letter of 3 October this year.

 

    I would like to appreciate your publications and documents about animal disease risk assessment and in particular the original ideas and analytic methods. The system approach and structure of the two documents for the Ministry of Agriculture and Fisheries Regular Authority as a tool helping the decision making on import could serve as  examples for many other countries. As far as the compilation of world literature on the characteristics of different diseases, we must accept scientifically proved facts.

 

    Following our discussion in Yokohama I would like to express my view on risk disease introduction assessment:

 

    According to me  the main problem is how to assess the situation in exporting countries. First of all how the importing country can assess diseases situation (e.g. diseases prevalence and incidence, foci prevalence and incidence, territorial distribution, stage and tendency of epizootic process, etc.) and control measures effectiveness in foreign countries. Relatively often the available data are incomplete, particularly as far as the diseases with subclinical and carrier forms. How to assess the reliability of diagnostic methods used and certificates in cases when  s t a t e  veterinary service is lacking: necessary legislation, manpower, facilities, funds, infrastructure in the field practice, reliable reporting and information systems, a c t i v e  investigation programmes at animal  p o p u l a t i o n  level, effective field programmes able to reduce specific disease frequency and focality avoiding new outbreaks. Only proved concrete (measurable) results in the field are decisive criteria for veterinary services capability assessment.

 

    Therefore, assessing the risk, beside the biological scientific aspects the efficiency and credibility of exporting country veterinary service (incl.certificates’ reliability) as well as previous  e x  p e r i e n c e  must be considered. There are enough facts demonstrating recent catastrophic consequences of underestimating disease introduction risks (e.g. see the paper of Drs Blancou, OIE and Meslin, WHO presented during the World Veterinary Congress, 1995, Yokohama).

   

    I hope that you agree that the principal objectives should be to avoid international spread of animal diseases and to protect specific diseases free territories. This principle should be defended in spite of strong international and national business pressure and attacks. (In the Report of the Research Group of the European Commission for FMD, Vienna, September 1994 on page 123 is following sentence:"It also proved difficult to deal with international traders who seem to believe that they only have to respect their own laws.")

 

   The attack on protective veterinary measures, beside the dismembering of state  field and laboratory veterinary services in many countries, has different symptoms. Examples:

 

a) One of the "most welcome" component of this attack is abusing risk assessment currently used also in the past. Many new methods are based mainly on mathematical analysis of very "flexible" criteria often conducing up to absurd results demonstrating no risk in spite of opposite biological logic and practice experience. I know documents where the risk of introduction was calculated as once in millions of years or one case in billion, etc.!. Abusing this type of modeling is other form how to press importing countries to give up there protective measure or to reduce them up to ineffectiveness not respecting local situation, conditions and needs.

 

b) "New" definition that "disease-free" is applicable also for territory where the disease still exists (see Rev.sci.tech. Off.int.Epiz.,1993,12(4), p.1051) !? This concept is included also in OIE International Animal health Code, 1992, p.191 (brucellosis), p.199 (tuberculosis), p.206 (leucosis), etc. I saw it also in veterinary legislation of some exporting countries.

 

c)  Other part of this business policy is to press importing countries to accept the opinion of exporting country. In the Code Up-dates (1993,1994&1995) on page 28/2 is a paragraph on "Refusal to import" with following formulation: "In the event of a decision to refuse the importation of a commodity, or to impose significant constraints on the importation, the importing country should, if requested, be prepared to justify its decision by providing details of the procedures and results of the import risk analysis exercise to the exporting country." Why the importing country should justify that it does not want a particular commodity ? This is so called "free trade"? How importing country can prove that exporting country is not meeting necessary trust, conditions (e.g. favorable disease situation, control and knowledge of situation, reliability disease reporting or of certificates, credibility and capability of veterinary services, etc.). It is normal, that exporting countries try to reduce the importing country conditions not respecting the latter country situation and interests. In this cases, much more important should be the justification by exporting country providing all necessary details to demonstrate without doubt meeting importing country conditions.

 

d) Example of discrepancy between responsible chief veterinary officers and international business: In the Report of the Fifty-seventh Session of the Executive Committee of the European Commission for the Control of Foot-and-Mouth Disease, held in Thubingen, Germany, 1-3 March 1995 (at the level of European Chief Veterinary Officers) under Item 7-Risk Assessment... there is this paragraph: "It was stated that it was considered unacceptable that, under the new SPS (Sanitary and Phytosanitary Measures), one particular country could not avoid importing from another country which claims free status of particular diseases, even if no disease surveillance system exists in that country."

 

   This approach will contribute to slow or stop demanding but realistic programmes for diseases reduction, elimination and eradication in exporting countries due to easier, i.e. significantly reduced export conditions by reducing of protective measures of disease free herds, territories and countries. I know several recent cases of diseases introduction into specific diseases free countries by legal import due to so called "new policy" of risk assessment. And this number is increasing rapidly!

 

   Today's extreme pressure of exporting countries business together with increasing tendency to reduce significantly state veterinary services and disease testing (surveillance) under the false monetary arguments causes fear of animal diseases spreading creating much worse and difficult-to-solve situation for the next generations than today exists.

 

    Any import of animals and their products is a potential risk not only of diseases introduction but also of their spreading (with multiplying negative consequences) which is the main difference in comparison with inanimate commodities.

 

    The veterinary export/import conflicts should be solved in mutual agreement and cooperation spirit. The protection of country territory is the first duty and responsibility of any state veterinary service. Therefore, importing country must have the right to make the final decision of the problem and not other country or organization.

 

    Once again, I would like to thanks for the interesting and useful documents and reprints. I am very much interested in any your new methodology for animal diseases risk assessment.

 

 

                                Yours sincerely,

 

 

 

 

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

                                P.B. 516, 17000 Prague 7

                                Czech Republic