Dr Bernard
V a l l a t
Deputy Director General for Food
Chief Veterinary Officer
Ministere de l'Agriculture et de la Peche
President, OIE Code Commission
251, rue de Vaugirard
75732 P a r i s Cedex 15
F R A N C E
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Dear Dr Vallat,
I am writing you again regarding the OIE Code.
First, I am appreciating the improvements in the OIE Code 1999 in comparison
with the 1997 issue. I would like to add some comments to my letter of
First, I would like to stress urgent need to change the OIE Code
concept from actual admitting diseases spreading to original purpose of the OIE
policy avoiding diseases spreading. This concept should be clearly
expressed also in the preamble of the Code and applied in the whole document.
The OIE Code never before has been servicing in subordinate position to traders
or trade organizations but to member country governments to protect
consistently animal health in the world. The OIE should consequentially
defend animal health, as for example, other international organizations are
emphatically defending animal welfare, environment, etc.
We
both know very well that government services are under permanent pressure and
that must "struggle" against different contra interests which do not
want to respect measures for animal health protection. Responsible government
officers have always been between two "mill wheels" - consumers and
farmers asking for the best possible health protection against diseases and
highest possible health quality of introducing animals and their products on
one side and on the other the traders (having much more influence,
money and profit) and politicians. This is the fate of our services at all
levels from the very beginning. In spite of the outside pressure the OIE
documents should not support the interests of the others to the detriment of
animal population health protection !
I have
tried to understand why the OIE changed its policy so significantly in
contrast to the past. Why the OIE information system was substantially reduced,
e.g. the disease occurrence to be reported only by "+" (they say for
risk standardization !?), why reporting of disease introduction cases was
stopped, excellent information source such as HANDISTATus (containing valuable
information, e.g. on individual diseases development in individual countries
from 1990 in form of time series) disappeared. Why so called risk assessment
(trying to minimize artificially the risk abusing mathematics), officially
admitting diseases spreading, became almost the priority of the OIE. Why this
organization started to impose upon importing countries to accept animals and
animal commodities in spite of their refusal. Why many of my professionally
reasonable recommendations sent to OIE have not been accepted (i.e. for
improvement of information system, for correcting risk assessment procedure,
for avoiding extremely benevolent import conditions, etc.). Why the import
conditions were made more benevolent "to facilitate the export"
which in practice means to be benevolent "to facilitate diseases
propagation" through international trade.
These
days I have found in my correspondence one letter explaining me the reason
for this so negative change. It is a letter dated
This
clarifies the "philosophy" which brought the change, i.e. importing
countries do not need to know real disease situation in exporting country
!?. It should be sufficient to know if the disease exists or not, does not
matter if in import quarantine only or in the whole country territory !? Risk management system is able to avoid
diseases spreading !??. And the consequences: ergo, why to have
demanding and costly national programmes for diseases control, reduction or
eradication when for the export diseases situation does not matter and when
importing country is obliged to minimize the risk. Now, I understand why the
OIE Code conditions became benevolent (e.g. permitting export from zones with
high incidence of BSE - 3.2.13 !?). Further consequences of this dangerous
philosophy is the introduction of so called "diseases zoning"
without clear cut international conditions avoiding the abuse. Zoning is
useful, however applicable for stable situation in chronic diseases, i.e.
without incidence which proves the instability of situation (out of complete
control). Internationally approved zones should be published in the OIE
information documents, including OIE Animal health yearbook. "Relevant OIE
list" was promised in previous issues of the Code (1996,1997,1999 -
1.4.4.5), but never published.
The
above mentioned false concept so unfavorable to importing countries obviously
created the basis for the WTO "Agreement on the application of sanitary
and phytosanitary measures" which came into force on
I would
like to repeat my previous statement: 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 about the import and not
any other country or organization !.
I have
seen the new proposals for chapter 1.4.3 regarding to "Evaluation of
Veterinary Services". I am pleased that finally this extraordinary
important part will be properly elaborated. I would suggest to stress more its
purpose, i.e. to provide information to importing countries to be able to
asses the reliability of veterinary attests ! (The other aspects not
related with trade can be published separately in the OIE Bulletin). Priority
importance has the legislation including diseases obligatory notifiability and
duties for disease reporting. Further important aspects are: government
services responsibilities, organization, manpower, material and financial provisions,
professional standard, diagnostic
laboratories capacities and level; disease situation evaluation system, surveillance ability to detect all cases of
trade important diseases, system of analysis for confirmation disease free
animals, herds and territories as the basis for issuing veterinary attests; who
is issuing these attests (for international trade the attests should be issued
only by responsible government services; in exceptional case of non-government
veterinarians must be known their qualification - accreditation training and
testing); pre-export measures, reclamation system, etc. In the list under
1.4.3.8 I recommend to include "investigation
of animals, herds and territory for confirming diseases free status"
which according to me is the most important activity needed for issuing
veterinary certificate for export. General comment: to avoid excess of
bureaucratic paper work. In this context a particular component of the OIE
Animal Health yearbook should be elaborated to provide periodically basic
uniform information on veterinary services evaluation criteria (special table
with mainly quantified indicators).
Again,
I would like the extremely wordy part of "Risk assessment"
(reflecting unacceptable diseases spreading admitting) to be significantly
reduced or better to be rewritten in form of reasonable, feasible,
practical, logical, transparent and proved procedures. It must be stressed that
the priority has zero risk import !
Few
words regarding so called Section 4.5 "Epidemiological surveillance
systems". First of all I would not call it "standards". We
have to distinguish the surveillance for control programmes and surveillance as
the basis for confirmation diseases free status for international trade
purposes. The text is obviously written for the first purpose. For the second
one however the sampling methods are unacceptable due to the fact
that they represent an open door for diseases spreading ! For
confirmation of disease free status there is a need to investigate all
animals or to use much demanding sampling method. "95 % probability to
detect one positive sample given that infection is present in the population at
a level of 5 % or greater" cannot be acceptable even when not considering
that current diagnostic methods have never 100 % sensitivity ! The OIE cannot
recommend the world something which is so holey ! Permitting to use for export the method able to detect
the disease only if its occurrence is higher than 5 % calls for reducing or not
applying necessary control measures and for exporting diseased animals and
herds. Therefore, it should be eliminated from the Code or substantially
corrected respecting fully scientific sampling for confirming disease free
status (and not 5 % occurrence). My suggestions is applicable also on the
paragraph 4.2.4.1.4 (including Table II) which is "officially" (acc.
to OIE Code) permitting to export poultry salmonellosis !?.
In
order to avoid these kinds of problems in the future, I would like to suggest
to use official opponents for all the new or conflicting parts of the Code
using the best specialists in the world and also ask for written comments
(or agreement) of the FAO and WHO. From the discussion with the Chief,
AGAH, FAO last year I understood that this service had not been involved in the
Code preparation and clearance and
therefore the responsibility is with the OIE only. I think that the
responsibility should be of all these international organizations having
similar or identical aim in protecting and improving animal health in the
world.
At the
end only one small desire if you could arrange for the restoration of the
scientific term for one of the most important zoonoses caused by "Brucella melitensis" which
somebody (??) has eliminated from information system and from the Code few
years ago. In spite of my repeatedly written comments it has been left
confusing the countries making OIE information not transparent. Scientific name
must be fully respected and used. Similar fate has my recommendation to include
data about specific testing which are extremely important for importing
countries decision making .
With
best regards !
Prof. Dr Vaclav K o u b a, DrSc.
P.B. 516, 17000