Prague, 26 March 2001

Dr Bernard V a l l a t

Director General

Office International des Epizooties

12, rue de Prony

75017 P a r i s

F R A N C E

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Dear Dr Vallat,

many thanks for your letter of 19 January 2001 responding my letter of 6 November 2000 regarding the comments about OIE policy, OIE Code, WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS) and other matters.

1) I fully understand that for diplomatic reasons is for you (the same for Chief Veterinary Officers of individual countries) very difficult to criticize the SPS which was approved, although thanks to WTO cheating, by the governments. This was the reason why I wrote myself to Dr Moore, DG WTO (copy sent to you). I wrote as i n d e p e n d e n t former UN officer, having nothing to do with SPS.

My intention is to stimulate the defense of global animal health and the protection of results achieved by all previous generations. The only tool I have is to warn relevant international organizations about catastrophic development of animal diseases situation in the world hoping in adequate follow-up correcting actions.

2. I would like to stress that my letter to WTO was prepared after very careful study of official documents and information as reported by the countries. The letter presented f a c t s and t r u t h and not my personal impressions. The letter is holding up a "mirror to the reality". I cannot do more. Rectification depends upon relevant international organizations. I am sure that world public (consumers, breeders, etc.) will welcome measures improving global protection of animal and human health replacing the disaster policy (FMD in Europe is the latest alarming example).

3. SPS started benevolent risky trade policy "facilitating" diseases spreading which is against original OIE policy to assist member countries in promoting and protecting animal health. Therefore, I welcome your information about a new formulation in the Code "to avoid the transfer of disease agents that are pathogenic for animals and humans." This represents the signal in right direction. I hope that in this sense to OIE Code will be modified in all its components.

However, the problem is how to liberate the OIE from the yoke of the SPS which converted the OIE Code from useful recommendations into obligatory import conditions and how to recover the freedom for member countries to decide themselves on animal trade. Plainly said, how to protect animal population health globally and locally, i.e. first to stop diseases spreading through legal international trade.

4. It is obvious that international organizations should cooperate to be able to serve member countries as best as possible. Cooperation between OIE and WTO as two inter-government organizations of the same legal level will be welcome only if based upon the principle "quality first", in our case "health first", i.e. "trade yes but only with healthy animals and wholesome products" avoiding diseases spreading through international trade. In this case WTO could play very important role when supporting health protection and disease control/reduction/eradication programmes to achieve the best possible health quality and thus to facilitate the trade.

5) I have finished additional analysis of animal disease introduction in developing countries using available official data sources. During 1995-2000 number of reported cases of disease introduction through international trade in animal commodities in developing countries was higher than in developed countries. Developing countries reported also more cases of disease reintroduction. Similar proportion was reported as far historically first cases of animal diseases. At the same time animal import in developing countries was only a half of size of developed countries import.

6) We both, as former responsible national officers of government veterinary services, know very well what mean the introduction, reintroduction or first appearance of diseases in country. How it is easy to import them and how it is difficult to discover them and how it is difficult (latest example: FMD in UK) up to impossible to eradicate them. What about poor developing countries having not yet government veterinary services able to cope with new situation ? Not speaking about losses and other consequences including negative impact on their future trade. In some countries, mainly developing ones, government veterinary services instead to be strengthened, were reduced due to the pressure from some international organizations. In some countries these services became almost defenseless and are able to carry out only administrative tasks. To find out if the service can or cannot cope effectively with the diseases and trade at national level, you can evaluate average number of animals per one government veterinarian. Generally, these services are weak when comparing them with rapidly increasing problems to be solved. Only strong, well staffed, trained and equipped government service can manage new animal health/disease problems and the trade. Only this kind of service is able to transfer OIE recommendations into country practice. OIE should pay attention to it as to one of the highest priority.

7) I didn't overlook the development of the information technology. For example, in my previous letter you can read: "On the other hand I would like to appreciate the quality and usefulness of the OIE Manual of Standards for Diagnostic Tests and Vaccines, OIE Scientific and Technical Review and operational information about new outbreaks of List A diseases on OIE Internet pages". New HANDISTAT was not yet available during preparation of my previous letter to you. I am very pleased that the HANDISTAT is again on Internet pages.

8) The problem of OIE information system in not only the form which will be developing continuously anyway. The main problem is professional contents. I have suggested in my letters to OIE a series of improvements, however without any positive reaction. Now I understand that my recommendations to provide more and more useful data to member countries was against the aim to "facilitate trade" through "blinding" importing countries concealing deliberately the true disease occurrence and its development (time series) in exporting countries. This devaluated information prevented many importing country governments from correct decisions about import conditions which caused irreparable catastrophic consequences. Now I know that it was not a mistake, it was integral component of SPS follow-up actions according to very dangerous philosophy "what does it matter what starting risk was ?".

9) In this context see the annex of my letter to DG WTO (paragraphs 24 and 25) and my letters to DG OIE during previous years (example in Annex). I must reiterate that OIE annual data about diseases status needed for decision about import are incomplete, confusing and camouflaging the true situation. These misleading data used for misleading "risk assessment" "to facilitate trade" have contributed to risky trade. Consequences are generally known. The rectification can be done without any delay when preparing questionnaire and accompanying letter for the year 2001 statistics ! No need to wait for SPS abolishment !!! In May is the first chance !!!

10) CVOs have a lot of professional competencies however the problems of veterinary service position, manpower, material, legislation, budget, investment etc. depend on higher government body decision. Therefore, I would like to suggest that the OIE as inter-governmental organization to address the major recommendations to the highest possible government officers (at least at the level of minister). OIE should provide recommendations and arguments for supporting and strengthening government services to able to cope with new problems and conditions. The events of the last period have demonstrated that these services are weak, depending upon not--enough reliable non-governmental services.

11) I recommend regular analyses of practical impact of OIE documents and of diseases spreading through international trade; to start comparing experience with different disease control and eradication methods at country level, comparing practical results of different veterinary services systems, etc. as background for OIE follow-up actions. These topics should have the priority in OIE publications.

12) As I know DG of any international organization has the right to invite advisors according his personal decision. He is responsible to contributing member country governments for fulfilling and defending the objectives and not permitting to deviate them out of their "boundaries". DG keeps as advisers those who proved to be sufficiently competent strictly supporting objectives of the organization. Good advisors mean a half of success and vice versa.

a) I do not want to interfere into internal problems of the OIE. However I would like to mention that among influential OIE advisors are still some whose writings supporting disease spreading are not in compliance with the main duty of the OIE. One wrote about trade "what does it matter what starting risk was ?". Other one wrote about trade that it is the "need for free circulation of animals and their products", "it is no longer possible to apply the old system under which animals and animal products had to come from specific and disease-free zones, and were subjected to isolation, quarantine, inspection and diagnostic testing before and after export." It is difficult to understand this antimedical approach.

b) Other example: After my protest against significant reduction of disease occurrence information, DG OIE answered me on 30 October 1998 that it was "the result of discussions by eminent specialists on risk analysis.." to can standardize risk probability. (From one "+" ?!). The "eminent specialists" obviously didn't understand practical problems what has been proved dramatically during recent events. Where are the OIE standards for risk probability from "+", e.g. for FMD risk ?

c) These "specialists" have been damaging not only OIE professional prestige but first of all the member countries. They are probably behind the false policy to "facilitate trade" at the extent of animal and human health. OIE is obviously under strong influence of "paper veterinary epidemiologists" confusing these biological science and practice with statistics, economics and bureaucracy, i.e. paperwork. (see Dictionary of Veterinary Epidemiology, 1999). Control of animal diseases is first of all the work in the field and not only in armchairs.

d) It should be respected the t r u e situation, its real development and not opinion (impressions, illusions) of those "specialists" who prefer other approach. Very dangerous are the lobbies trying to achieve decision advantageous unilaterally for one or a small group of countries at the expense of the others.

13). It should be taken the lesson from the past experience and recommend only methods already proved as feasible, helpful and effective in field practice at country level.

14) Other matters

a) I would like to mention once again that the term "Brucella melitensis", belonging among the most important zoonoses, is still used in the world literature with exception of the OIE (several years of asking to recover this term without reaction proved that somebody in OIE doesn't respect scientific nomenclature). This change happened simultaneously with eliminating from List A - Teschen disease, a killing diseases without possibility to recover affected pigs and which could be the first disease globally eradicated. On the other hand vesicular stomatitis is still in the List A in spite of the fact that it is not killing disease and requires only mild measures. This is residuum from times when the diagnosis was based mainly on clinical symptoms.

b) In the Index of Diseases, World Animal Health: instead of "Klobouk's disease - see Rinderpest" to be "Klobouk's disease - see Enterovirus encephalomyelitis".

c) Handistatus II Selection Criteria, Disease B016: instead of "Chrysomya" to be "Chrysomyia"; the same in the WAH. I do not understand why in the same table are included only E001 Brucellosis and E002 Salmonella infections and not other zoonoses. It is obviously an administrative mistake.

d) In the Questionnaire for annual reporting on "Cases of Animal Diseases in Human Population" the title should be added by "(As officially reported to Ministry of Health)" as before and to avoid reporting often only estimates by veterinary service. I suggest to include very dangerous zoonoses: Ebola disease and plague and the list of species by primates.

e) On OIE Internet page are not published all reported data on veterinary manpower; only total veterinarians and total AHA. The most important manpower data for services evaluation from disease control and trade point of view - number of government veterinarians - are missing. Other manpower indicators are secondary, more for statistics. I recommend to include in next questionnaire "number of accredited veterinarians ",i.e. non-government veterinarians who on behalf of government carry out the tests and issue official veterinary certificates for exporting animal commodities. They have key position in countries where government service is unable to do it itself.

f) Actual disaster due to FMD in Europe and global reaction represent the fiasco not only of the OIE risk assessment system. It calls also for significant revision of the Code being e.g. in case of BSE and FMD not respected at all.

With best personal regards,

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

ANNEX

From the letter to Dr Blancou, DG OIE of 19 October 1998:

"In World Animal Health in 1997 to my surprise I found that the "new" list of disease occurrence symbols was significantly reduced which means the availability of much less information needed for decision-making, in particular for risk assessment when importing animals and their products, than before. The graduation symbols of disease occurrence estimates suddenly disappeared after decades of practical application without problems. I cannot see any scientific or practical justification.

Following occurrence symbols were deleted (in comparison with previous years):

(+) Exceptional occurrence

+ Low sporadic occurrence

++ Enzootic

+++ High occurrence

+.. Disease exists; distribution and occurrence unknown

)( Ubiquitous

! Recognized in country for the first time

<= Only in imported animals (quarantine).

All these symbols are replaced by "+". This "new" symbol does not differentiate the disease frequencies in the given country (e.g. it can mean the disease in one animal only, or among imported animals only, or enzootically spread or ubiquitous distribution, etc.).

The disease occurrence (prevalence) value in the exporting country is the starting point for risk assessment when importing animals and their products (see also OIE Code). The member countries should obtain more and more detailed information than before starting computer era and not less.

My opinion about the list of the occurrence symbols was expressed in my previous letter..

I suggest to keep the previous occurrence symbols. I learned from your letter that the new annual questionnaire on animal health for 1998 will be sent to the veterinary authorities of the member countries at the beginning of 1999. This is the chance to issue this new questionnaire with the missing disease occurrence symbols ! According to my experience as former Chief-Editor of the FAO-OIE-WHO Animal Health Yearbook I am convinced that there is still time to do it.

I would like to stress that we cannot avoid using symbols estimating the grades of animal population health situation. In no country A and B lists diseases are all obligatory notifiable. In no country exists country-wide active surveillance system to detect a l l specific foci of all OIE lists diseases. This creates problem with the reliability and complexity of reported numeric data. Therefore, the absolute numbers of officially reported outbreaks/cases are usually lower or incomplete than in the reality. This is normal also in human medicine."