Mr.
National
Manager
Agriculture
Security and Animal Health
Ministry of
Agriculture and Fisheries
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
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,
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