CRITICAL ANALYSIS OF O.I.E. ANIMAL HEALTH CODE FOR INTERNATIONAL TRADE FACILITATING INFECTIONS/PATHOGENS’ LONG-DISTANCE (INCL. INTER-CONTINENTAL) SPREADING – the most dangerous document for global animal population health in the history
Formerly: Animal Health Officer (Veterinary Intelligence), Senior Officer (Veterinary Services) and Chief, Animal Health Service, Food and Agriculture Organization of the United Nations; Editor-in-Chief, FAO/WHO/OIE Animal Health Yearbook; Informatics Expert, OIE; Veterinary Public Health Expert, WHO; Technical Vice-Director and Chief Epizootiologist, Czechoslovak and Czech State Veterinary Service; Professor of Epizootiology, Brno University of Veterinary Sciences
Contents (according to the structure of the Code)
2. Original concept of the OIE Code
3. World Trade Organization concept of the OIE policy
4. Code Foreword and Users’ guide
6. List of diseases
7. Notification and epidemiological information
8. General obligations and ethics in international trade
9. Certification procedure
10. Risk analysis
11. Evaluation of veterinary Services
12. Surveillance and monitoring of animal health
13. Guidelines for reaching a judgement of equivalence of sanitary measures
14. Recommendations applicable to specific diseases
15. Epidemiological surveillance system
16. Model international veterinary certificates
17. Other comments
1.1 The author has been studying animal population health/diseases
development in the world during more than fifty years. Several years ago, he
found out alarming worsening of global animal health situation, mainly due to transmissible diseases’ spreading through
international trade. He recognized that the World Trade Organization “Agreement on the Application
of Sanitary and Phytosanitary Measures” (WTO/SPS)
initiated the policy of "facilitating trade" to the detriment of
animal and human health. The WTO/SPS has
the main responsibility for negative consequences of risky international
trade in animals and their raw and semi-raw products (i.e. no-sterilized). The WTO/SPS
converted the OIE and its Animal Health Code into a subordinate position to the
WTO. This was the reason why the author, feeling the moral duty as the former Chief,
Animal Health Service, Food and Agriculture Organization of the United Nations
(FAO), was asking several times Dr Jean Blancou and
Note: At the beginning of the nineties of the 20th century a
delegation of the GATT (General Agreement on Tariff and Trade) visited the FAO
1.2 The most expressed OIE policy is concentrated in the OIE Animal Health Code for international trade. The Animal Health Codes for international trade in animals and animal products published by the International Office of Epizootics (OIE) started in 1968 providing member country governments certain recommendations for this kind of trade. The Code was issued as a book in 1968, 1971, 1976, 1982, 1986, 1992, 1997 (special issue) and afterwards every year. New editions had similar structure and contained some amendments and new components in comparison with the previous ones. For the critical analysis the tenth edition entitled “International Animal Health Code – mammals, birds and bees 2001” (further only Code) was used. This document of 473 pages was internationally registered under ISBN 92-9033-526-2. Some comments on following issues were included later.
The OIE Code Commission is dominated by the major countries exporting animal commodities defending through the OIE Code the export without sanitary guarantee (= profiting export of pathogens) regardless of importing countries’ needs for animal population health protection. The OIE Code Commission members are fully responsible for animal infection spreading and globalization through deliberately benevolent veterinary conditions for the trade. Logically, if diseases/pathogens’ spread through international trade is to be avoided, the Code Commission should be in the hand of importing countries defending animal population health. Today situation reminds a saying “set the fox to keep the geese”. This perverse arrangement is behind the anti-sanitary criminal policy of the OIE.
OIE International Animal Health Code Commission was established in 1960 under the name of “Commission for the study of sanitary
regulations on the importation and exportation of animals and animal products”.
The Commission was presided successively by Dr K.F. Wells (Canada), Dr H. Gasse (
The first after WTO/SPS OIE Code Commission in 1995
was composed from: President Dr W.H.G. Rees (
Members of the OIE Terrestrial Code Commission in 2000: President Dr Alejandro B. Thierman (USA), Vice-President Dr Wolf-Arno Valder (Germany), Secretary General Dr David Wilson (Australia), Members: Dr R. Benaissa (Algeria), Dr Alexander N. Panin (Russia) and Dr Stuart Hargreaves (Zimbabwe).
Example: Members of the OIE Terrestrial Code
Commission, 2003-2007: President Dr A. Thierman (USA), Vice-President Dr W.A.
Valder (Germany), Secretary General Dr S.C. MacDiarmid (New Zealand), Members: Prof.
A. Hassan (Egypt), Dr A. N. Panin (Russia) and Dr S. Hargreaves (Zimbabwe). In
2007 Dr Panin was replaced by Dr Jorge Caetano (
The members of the OIE Terrestrial Code Commission have key influence on the formulation of the Code. Who are these members ? Dr A. Thiermann was initially laboratory specialist in leptospirosis, later becoming Senior Trade Coordinator, United States Department of Agriculture, Aphis International Services, US Mission to the European Union. More information on the author of abused risk assessment method - Dr S.C. MacDiarmid see in chapter 10. Dr A.N. Panin has been for years a specialist of national laboratory research institute. No one of the decisive members of the Code commission has personal experience with responsibility for national animal population health prevention and diseases’ control/eradication as well as having national practical responsibility for country health protection. They are irresponsible “armchair” theoreticians and bureaucrats producing pseudoscientific papers for easier export of non-healthy animals and non-pathogen-free animal products regardless the animal and human health in importing countries. They are imposing on importing country governments anti-sanitary measures without any objective (non mentioning scientific) analyses of the risk and of the practical impact of their policy. They do not accept any critical comments and arguments against the Code and the WTO/SPS. They have published repeatedly demagogical statements (having not any convincing concrete arguments) defending and supporting the criminal policy of man-made conscious animal disease spreading through international trade. They are absolutely not interested in the very real negative consequences of their theoretical “products”. For their pseudoscientific, non transparent, non defendable and non convincing Code the risk assessment is obviously not applicable due to the risk (fear) to discover the horror impact and their incredible irresponsibility and unscrupulousness. They cannot have any idea on the reality in importing countries, usually unable to defend themselves against the continuous streams of diseases/pathogens from exporting countries organized by the WTO/SPS and the OIE. They cannot have any idea what it means to import communicable disease pathogens and how difficult (or even unreal – usual case) is to eradicate them ! This is valid also for other leading OIE officers such as Dr Jean Blancou, DG OIE, originally laboratory specialist, responsible for the initial uncritical and incredibly servile support of the WTO/SPS and for the betrayal of the original anti-epizootic policy of the OIE or Prof. Dr Vincenzo Caporale, excellent laboratory specialist, President, OIE Scientific Commission for Animal Diseases, etc. No one of the above mentioned officers has practical experience of successful diseases’ eradication and country anti-epizootic protection as fully responsible officer at national level, i.e. as Chief Veterinary Officer of government public services. The OIE is dominated instead by globally responsible experienced specialists of successful anti-epizootic nation-wide practice by globally not responsible veterinarians – theoreticians lacking the required territorial field practice experience.
Example: Dr A.B. Thiermann published a paper entitled “Protecting Health, Facilitating Trade, or Both ?” in Annals of the New York Academy of Science 916:24-30, 2000 commenting on the usefulness of the WTO/SPS as the outcome of seven-year exercise: “we must recognize the significant gains in trade thanks to the SPS agreement. Consumers are in general better off, since they have… increased safety in what they can buy.” The truth is the gain in trade, however, at the detriment of animal and human health in importing countries where incalculable millions of animals and persons have been suffering and dying due to imported pathogens thanks to the WTO/SPS discriminatory anti-sanitary policy. The second sentence represents a demagogy and lie – the consumers are much worse off as far as the safety in what they can buy !
The same author in several publications has been defending repeatedly, without any analyses and proves, the WTO/SPS. E.g. In one international journal (among the major “speaking tubes” for the SPS) - Preventive Veterinary Medicine, 2005, 67 (2-3):101-8 under the title “Globalization, international trade and animal health: the new role of OIE” it can be found following abstract: “In order for countries and their stakeholders to maximize the benefit of globalization they must become familiar with, and must adhere to, the rights and obligations set out by the WTO/SPS. For the purpose of trade in animals and animal products, they must also adhere to the standards, guidelines and recommendations established by the World Organization for Animal Health (OIE). Only after implementing these requirements and after strengthening the veterinary infrastructures and their surveillance and monitoring system, will countries be able to fully benefit from these new international trade rules.”
The same or almost the same text can be found in hundreds of papers produced by the OIE or “supportive” journals (written - copying by the OIE staff headed by the DG, members of the OIE commissions, contributors to the OIE publications, etc.) and always without any objective analyses and proves (= parroting the lie; “hundred time repeated lie becomes the truth” – author Goebles – Nazi Propaganda Minister). In the reality the “benefit” of globalization have only exporting countries while the importing countries, against their farmers and consumers’ will, are seriously irreparably damaged ! The rights have only exporting countries while the importing ones have only discriminative obligations.
Using the words “must adhere to..” documents the significant change in comparison with pre-SPS OIE Code based on reasonable recommendations and not on any dictate !
The theory could be correct and useful for scientific discussions but not for practical policy of any intergovernmental organization, such as the OIE. However, the member country governments need only useful, concrete, convincing, feasible practical health protection methods already proved under real conditions and not “methods” unreal in decision-making practice, lacking logical justification, transparency, corresponding testing and respective assessment of diseases/pathogens spreading risk.
The demagogy, incredible lies (converting “black into white”), scientific nonsense, falsification, trickery have become the main “arguments” of the OIE irresponsible bureaucrats and documents defending, without any international testing, impact analyses and proofs, the anti-sanitary criminal policy of animal disease spreading and globalization through international trade. Well paid hypocritical propaganda through international mass media and unilateral anti-sanitary training courses support trade export profits regardless of the negative lasting and even irreparable consequences. The OIE has become historically the “gravedigger” of global animal population health and preventive medicine !
1.3 The Code as an international “standard” is unique in the world history by its absolute instability - issuing every year (from 1998) a new version without any indications of the changes in these thick books and thus seriously confusing the users. Every new issue conduces to facilitate more and more the conditions for exporting countries at the even major detriment of the importing country animal and human health. In the other words, every new issue increasing diseases/pathogens export risk facilitates more and more the globalization of animal communicable diseases through international trade. The instability due permanently replacing previous issues documents very serious lack responsibility, scientific standard, objectivity, transparency, respect to international trade practice experience and logic as well as very low professional quality of the Code.
Example: In the Code 2007 there are 15 revised chapters and 8 revised appendices on the following subjects: general definition, zoning and compartmentalization, rabies, foot and mouth disease, rinderpest, bluetongue, bovine tuberculosis, BSE, equine influenza, equine infectious anaemia, equine piroplasmosis, equine rhinopneumonitis, glanders, equine viral arteritis, avian influenza, surveillance for rinderpest, surveillance for bluetongue, surveillance for avian influenza, etc. It means that the Code 2006 can be thrown into basket as not more valid. In the Code 2009 there were 53 new or revised texts (Dr Thiermann, President of the Code Commision considered that it had been a “very productive year” !?). The same exercise has been repeated every year from 1997. One doesn’t know what is still valid and what not.
Permanent changing the Code gives evidence of that the OIE is not scientifically and even not logically justifying (not able to implement it or simply it is not justifiable at all) not only any Code “new” provisions (also “new” information systems) in spite of repeatedly requiring importing countries to scientifically justify their demand for healthy animals and pathogen-free animal products ! This can be understood as a top of the OIE demagogy and hypocrisy !
The size of the extremely wordy Code has been increasing: in 1986 - 510 A5 pages, in 1992 – 550 A5 pages, in 1997 – 642 A5 pages, in 1999 – 468 A4 pages, in 2000 – 473 A4 pages, in 2001 - 473 A4 pages, in 2004 - 554 A4 pages and in 2005 even 634 A4 pages (about 300 pages of annexes !) and in 2006 - 652 A4 pages of 1.5 kg (again more than 300 pages of annexes !). Actually a new version – Code 2007 of about 510 A4 pages is being advertised by the OIE HQs (price: 55.- euro). The latest Codes are full of ballasts having nothing to do with avoiding animal disease spread through international trade. This must be the key concern and component not merged and lost among other numerous unnecessary provisions significantly fogging the main issues and diverting the attention of the readers !
No any other global intergovernmental organization is characterized by exorbitant formalism, mass producing papers full of without-proof-theory, demagogy, hypocrisy, and even professional nonsense, without regard to: the need of the countries, the lack of scientific justification, simple logic and convincing concrete arguments; their usefulness for member country governments; practical feasibility, cost, opinion of the practitioners and of final users; and real negative impacts as it is current in the case of the OIE. Mass production of different all-time-changing documents and provisions overburden by the paper work (usually not necessary and not helpful) not only all Chief Veterinary Officers and their staff but also all veterinarians in relatively weak government service and even in private service. The consequence is the loss of a lot of time and money needed for the solution of practical problems as well as methodological/management instability in all the world.
Example: To stabilize a new global animal health information system up to grass-root levels requires many years The OIE is changing this system almost every year not considering at all the difficulties to train all relevant staff of veterinary services, to produce and distribute all necessary new forms, to adjust or replace previous software, get necessary funds, etc. in all the countries in the world. The member country governments cannot afford any gap in national information systems as it is normal in the OIE (the change from original HANDISTAT into OIE HANDISTAT II simple created the gap of 3 years ! Similarly the new OIE WAHID has created the gap about 1.5 year.). It seems that for the OIE irresponsible bureaucrats it doesn’t matter.
The OIE is experimenting unscrupulously with the
health and lives of global human
populations (reminding Nazi murderous
experiments *) and of global animal populations as with laboratory animals, not interested at all in the
consequences - mass suffering and mass killing. The authors of the criminal
impacts should be judged at
*) OIE experiments’ consequences are world-wide (not only in importing countries but also in exporting ones after loosing motivation for diseases’ active surveys, monitoring, control and eradication thanks to WTO/SPS and “new” OIE Code), irreparable, long-term (or lasting) and without any evaluation of their impact on the health (the OIE staff and “experts” are not interested at all in their “fruits”) while Nazi criminal experiments’ consequences were local including selected persons only, short-term (during II. World war) and with detailed evaluation of their impact on human health.
1.4 In the Codes there has been
missing the most important commodity of the international animal trade – food
of animal origin. If we compare the 2004 year reported values of imported
life animals of 10,633 million US$ and of imported animal products of 110,937 million
Examples: In 2004 the import monetary value
of live animals reached 10,633 million US$,
meat and meat preparations 63,921 million
An incredible deterrent example is represented by the European Union policy and by the OIE Regional Commission for Europe (chaired during last two decades by irresponsible Dr N. Belev, Bulgarian Chief Veterinary Officer) applying the trade in food of animal origin without any investigations and any sanitary documents ! This conscious and organized mass daily spreading of communicable foodborne diseases applying the OIE Code policy “doing nothing” = non pardonable crime against European human population !
State veterinary service in Prague, Czech Republic reported on 19 April 2007 the discovery in Dyšín cooling chambers in Pilsen Region 78 consignments of 1,528,333 kg beef from Bulgaria coming from different abattoirs in Uruguay and Brazil (FMD countries) = inadmissible re-export! Where is the supervision of Bulgarian public veterinary service (unfortunately destroyed under Dr Nikola Belev, Bulgarian Chief Veterinary Service and long-term “Adviser “to DG OIE) ? Where are the OIE Code provisions for avoiding this guile. One would expect that the home-country of so high level OIE officer would represent an example of consistent anti-epizootic measures avoiding diseases’ spreading.
This is other illustrative case of the OIE (“World Organization for Animal Health”?) demagogy having nothing to do with anti-epizootic practical life and animal health protection needs. The gap between the OIE theoretical provisions/declaration and practical reality is enormous ! The above mentioned examples document that the OIE is doing nothing (not considering hypocritical declarations and paper works on “food hygiene”) against the spreading of pathogens through meat and other animal products. On the contrary the OIE Code is facilitating this kind of animal diseases/pathogens transmission (according to the OIE Code importing country cannot require pathogen-free animal products). The inadmissible anti-sanitary practice is mainly possible for lack of sufficient government veterinarians. Private “accredited” veterinarians without necessary supervision can confirm anything, in particular when deciding on profiting export.
1.5 The treacherousness of disease spreading through animal products is represented by the invisibility, minimal or zero etiological investigations carried out to detect imported disease pathogens, absence of post-import quarantine, rapid mass territorial distribution through destination localities multiplied by further horizontal and eventually vertical spreading to following generations (grades of spreading: international multiplied by national following by local spread) and by the product derivatives ! The cheapest policy of exporting products of animal origin is, according to OIE Code, simply “doing almost nothing” for avoiding disease pathogens export. The veterinary service control of these commodities’ export is even much more limited, if any, than the control of live animals’ export.
1.6 In the Code there are missing also veterinary conditions for the import of non-animal commodities which could be carriers/vehicles of animal disease pathogens.
Example: In 2000 the foot-and-mouth disease
virus was imported in
1.7 The semi-anonymous authors of the after-SPS OIE Code share historical responsibility for the massive horizontal and vertical (to next generations) spreading of animal communicable diseases through international animal trade due to imposed provisions for zero or minimal protection of animal and human health in importing countries. Obviously, these irresponsible “armchair veterinary specialists-bureaucrats”, behaving almost similarly as the supermen of colonial times, do not care at all about the disastrous multiplying international impacts of their anti-sanitary activities. They do not care about immense suffering and incalculable deaths of animals and humans (= mass murders) not only of actual but also of future generations due to imported pathogens (real bioterror) thanks to the Code. The health and life obviously have not any value for the OIE Code authors. They showed total disregards of animal and human health.
Imported pathogens, if not eradicated without any delay, can continue in reproducing and further spreading and in some cases they can establish a permanent “breeding pool” (e.g. after penetrating among uncontrollable wildlife) from which they can re-infest other animals, domestic and/or wild ones, in the future.
Example: Virus of African swine fever imported in Sardinia Island, Italy in spring 1978 not being eradicated in time, penetrated among wild boars creating “breeding pools” from which the virus has re-infested domestic pigs during next three decades (up today); late anti-epizootic programmes (supported even by the European Union = not ASF free territory !) have not be able to eradicate this disease due many local difficulties such as particular social conditions not favourable to classical radical depopulation measures (successfully applied in Malta, Cuba, Dominican Republic, etc.).
This example represents a convincing prove that to “import” communicable disease pathogens is relatively simple, however, to eradicate imported disease is usually extremely difficult up to impossible. This example represents further argument against the new after- WTO-SPS OIE Code concept supporting not consistent protection of importing countries but the export of diseases and their pathogens to save international trade and not to save animal and human health!
The Code authors as well as the DG OIE and his staff do not care at all about importing country farmers and consumers’ opinion and health protection. They are, consciously or not, in “service” of the major exporting countries and their exporters and not in international animal and human populations’ health “service”. They create even serious doubt about the sense of the “new” after-SPS existence of the OIE.
Notes: In “Terrestrial Animal Health Standard Commission Home Page” (2006) there are the requirements of the Members including “.. shall be veterinarians with.. an understanding and practical experience of the relevant international trading rules.” Then is the question why the Members absolutely do not apply any normal international trade rules ?
It is very probable that the anonymous (?) irresponsible anti-sanitary “specialists” who in 1994 formulated the anti-sanitary WTO/SPS, all post-SPS OIE Codes and in 1996 significantly reduced international regular information on animal diseases occurrence “to facilitate trade” including disease import data (making impossible objective decision on animal import) were from the same group of major exporting countries.
Obviously, the OIE Code authors must be irresponsible “paper-veterinary bureaucrats” having not any idea or not considering how easy is to export diseases/pathogens and how difficult is to detect them in time in importing country, to discover and eradicate all their outbreaks (if feasible at all under particular local conditions). The “veterinarians”- organizers of animal disease criminal international spreading can be also understood as the “killers” of veterinary medicine and its reputation !
1.8 Human history and international fair trade do not know any similar international document dictating the paying purchaser to “justify scientifically” in written its demand for full quality commodity or its refuse of non-full quality commodity to convince the seller, as requested by the perverse WTO/SPS and the OIE Code ! These documents refuse to apply absolutely normal free market principle when the sellers try to convince (often in well documented written form) the paying purchaser on their commodity quality giving him the chance to select freely, without any outside dictate or interference, from different offers and different qualities of a particular commodity. These WTO/SPS and OIE Code have already caused consciously enormous damages to animal and human health of importing countries. Organized man-made spreading of communicable diseases is considered in all civilized countries as non forgivable crime. Conscious and deliberate international spreading of diseases transmissible to man (there are known more than one hundred animal diseases transmissible to man) is considered as the crime against the humanity. Similarly is classified the shameful “doing nothing” against this spreading in spite of knowing about this. Normal and professional logic has been “stood on its head” by irresponsible WTO and OIE bureaucrats, authors of this condemnable policy.
1.9 The main trick consists in abusing “risk assessment” to be elaborated by paying purchasing importing country instead of diseases/pathogens-free guarantee of the commodity by selling exporting country. The authors of the trick knew very well that to elaborate “scientifically justified” risk assessment according to non-sense OIE Code methodology to convince exporting country would be quite unrealistic = reducing up to nullifying importing country sanitary defence = facilitating profiting diseases/pathogens export. The Code is “infested” by repeatedly requiring “scientific risk assessment” to be elaborated by importing countries what is something unknown in any other commodity and in any pre-WTO/SPS OIE Codes. Neither the WTO nor the OIE presented to member country governments any risk assessment of these documents in spite of knowing about their catastrophic consequences. If the member country governments would have known about diseases’ spreading consequences, i.e. about the truth, they would have never approved the WTO/SPS and the follow-up anti-sanitary OIE Code ! This fact documents that it was a very serious dirty trick against importing countries’ health and life of animals and humans. The authors knew very well about the enormous risk of diseases/pathogens spreading, but in order not to complicate the export by the “zero risk approach” and to insure relatively easy profit of the major exporting countries, they deliberately concealed the truth from the member countries.
Note: The risk assessment trick, obviously originated in New Zealand (MacDiarmid deliberately influencing the World Trade Organization through his friend Mr. Moore from the same country who was becoming the Director General, WTO and the OIE policy through the “experts” from the major exporting countries */), was pushed through fraudulently by some major exporting countries during the preparation of the anti-sanitary WTO-SPS in 1994 and afterwards it was abused in the OIE Code. The same “lobby” is still in charge not admitting any change in favour of animal and human health in importing countries applying through the OIE Code all anti-sanitary provisions of the WTO/SPS. On the contrary, any new OIE Code issue contains some “novelties” facilitating even more the export to the detriment of importing country health. The unscrupulousness of some exporting countries, their “veterinary pseudo-specialists” and OIE HQs irresponsible “professional staff” is unbelievable.
*/ Dr Stuart MacDiarmid, National Manager Risk Analysis, Ministry of Agriculture and Forestry, New Zealand was even awarded by the OIE Medal of Merit in May 2002 for the “work in developing risk analysis as a basis for insuring safe trade in animals and animal products and for developing standards to reduce the threat of bovine spongiform encephalopathy (BSE)” !? His merit is exactly the opposite: “insuring unsafe trade”! He was “awarded” by his friends in the OIE for findings a “method” how to facilitate the export of diseases/pathogens through international trade in the whole world! This again confirms the anti-sanitary policy of the OIE !
1.10 According to normal international legal principles, any member-countries binding document being adopted thanks to trickery, lies, corruption, force, dictate and deliberate concealment of negative consequence risks, the WTO/SPS and the OIE Code cannot be valid as international legal documents !
In spite of illegal character of the both documents, there has been a general false tendency for “legalization” of them abusing also other international organizations such as the FAO, WHO (World Health Organization), EU (European Union), WVA (World Veterinary Association), ISVEE (International Society for Veterinary Epidemiology and Economics), etc. and being supported by well paid incredible offensive of international mass information media not admitting any critics or undesirable comments not to irritate the powerful profiting major exporting countries. To inform the public in the world about the truth on internationally organized spreading of communicable diseases and its consequences is practically prohibited or auto-censored.
1.11 The main criterion of any methodology is its practical result. In the case of the OIE Code, the result has been catastrophic. During the recent years (beginning in 1995) the OIE shared the highest professional and moral responsibility for sanitary and ecological global disaster due to “legalization” of animal diseases/pathogens export. The OIE during this long period has never presented to member country governments any analysis of this the negative impact, obviously being afraid of the reaction what could cause the end of this organization which has become an anti-sanitary one.
1.12 The author of
this paper tried to find out how the WTO/SPS had been prepared, justified and
presented to member country governments and parliaments for its final approval
at ministerial meeting in Marrakech on
Similar demagogy and
hypocrisy can be read repeatedly in many DG papers and editorials
when announcing “Improving animal health worldwide is a priority”
(e.g. Editorial of
1.13 The falseness, “black” conscience and double meter is documented also by the fact, that in spite of the basic trick requiring repeatedly importing countries to document their import conditions by written risk assessment, neither the WTO or the OIE have carried out and presented to member country governments even the simplest assessment of the sanitary risk (consequences) related to their documents – WTO/SPS and after-SPS OIE Code - during the whole period of their false “validity”. The OIE “risk assessment specialists”, demonstrating at the beginning extraordinary initiative to reduce significantly information on the occurrence of communicable diseases, have been “silent as the grave” having fear of the truth.
There have been many cases when the countries, originators of the above mentioned dirty trick, themselves did not present to exporting countries any “scientifically justified” risk assessment when refusing to import of some animal commodities. Example see in paragraph 10.11.
1.14 The only reason for the WTO/SPS and the “new” after-SPS OIE Codes has been the fact that the major exporting countries have been unable to guarantee the export of really healthy (not only clinically) animals and of pathogen-free animal products (mainly meat), i.e. to guarantee full sanitary quality = full innocuousness for animal and human health. Therefore, both international “documents” do not know at all the terms such as “healthy animals” or “pathogen-free food of animal origin”, etc. documenting their anti-sanitary concept supporting diseases/pathogens export and not the innocuous one!
1.15 General principles of international trade is steady tendency to increase the quality of exporting commodities and to apply fair competence among the exporters. The principles of the WTO/SPS and the “new” OIE Code are based on absurd opposite tendency – to decrease the sanitary quality of exporting commodities and to eliminate any fair competence among the exporters thanks to bureaucratically deformed risk assessment method.
1.16 Among the general principles of international trade is to strengthen decisive position of paying importing country (importers). The principle of the WTO/SPS and the OIE Code is based on absurd opposite position of paying importing country becoming subordinated to exporting country unilaterally supported by the dictate of the mentioned documents. Which farmer would accept consciously and voluntarily to import diseased animals (incl. pathogen carriers) and pay as for the healthy ones ? Which consumer would purchase consciously and voluntarily pathogen-not free food and pay as for pathogen-free one ? The same question is valid also for the level of importing country. The obvious answers prove the criminal character of the mentioned shameful documents. What about their authors ?
1.17 In the Code, as well as in many other OIE publications, there are repeatedly the references to the WTO/SPS indicating that the OIE is only implementing this WTO document as having not other possibility. The truth is, however, that the anti-sanitary WTO/SPS was elaborated in close cooperation with the OIE providing full support and incredible initiative in spite of being contradictory to the original mission of this professional inter-governmental anti-epizootic organization. The OIE is professionally and morally fully responsible for negative (catastrophic) sanitary consequences not only of the OIE Code but also of the WTO/SPS what without the OIE initiative and active participation would never come into the world ! The OIE permanent referring to WTO/SPS is only in advance “cleverly” prepared by the major exporting countries and by the OIE itself a false alibi (non transparent and non convincing) for “facilitating trade” through disease spreading and globalization policy abusing the OIE Code. The “new diplomacy” of the OIE (not more fighting in animal health interest) consists in currying favour with the WTO (fighting naturally in trade interest, i.e. quite opposite interest) and with other international organizations such as World Bank (applying the reduction up to the dismantlement of government services), the richest exporting countries and their lobby, instead of defending global animal health fighting contra disease spreading through trade and defending/strengthening public veterinary services. For the OIE “new policy” is obviously much more important being priced by the anti-sanitary powerful organizations having quite opposite policy than to protect animal and human health in the world.
1.18 The Code as an internationally “standard” doesn’t provide import conditions for individual species and types of animal commodities, i.e. for individual species and categories of animals and for individual species and categories of animal products. All the trade is normally differentiated according to the commodities and not according particular deficiencies as it is in the Code, i.e. according to selected diseases. The exceptional unnatural OIE concept represents one of many factors confusing importing countries by not admitting trade in animal commodities of full sanitary quality, i.e. in healthy animals and pathogen-free animal products. This concept consciously and deliberately supports only the export of animals and their products of non full sanitary quality = diseases/pathogens export. The Code consciously prevents from applying normal trade requirements for full quality of exporting commodities giving very bad example for member countries and their veterinary services. This represents other prove of the OIE corruption in service of international trade business lobby sacrificing unscrupulously the main OIE anti-epizootic duties.
In case of applying commodity structure (and not disease structure) of the OIE Code it should be defined as the standards what is “healthy animal” of particular species and categories and what is “pathogen-free animal product” of particular type and categories. This would require health guarantee documents and not simple not binding information called “OIE international veterinary certificate”. This absolutely normal requirement is not acceptable for highly profitable diseases/pathogens exporting countries and for their corrupt “servants” in the OIE.
If we apply the disease and not commodity structure of the OIE Code on non-animal commodities, then their standards should be according to individual deficiencies of the particular commodities (e.g. according to non-functioning car breaks and not according to the cars as the commodities) = absolute nonsense ! (See paragraph 17.32).
1.19 In the case to include missing import conditions according to animal commodities, it will be necessary to define what to be understood as the “healthy animals” e.g.”, “healthy cattle”, “healthy bulls“, “healthy pigs” etc., “pathogen-free animal product”, e.g. “pathogen-free pork”, “pathogen-free eggs”, etc. Only this simple and absolutely logical change according to individual commodities can change the anti-sanitary character of the OIE Code into an instrument requiring significantly improved sanitary quality. This change will give the impulse to exporting countries to apply measures for effective disease control and eradication facilitating export guaranteeing full sanitary quality (zero risk approach) not to the detriment of the health in importing countries, as it is today. This change will stop the OIE camouflage as self-nominated “World Organization for Animal Health” being today, thanks to its Code, de facto a world organization for animal disease spreading and globalization !
1.20 The concept of the OIE Code is based not on the health quality standard defining healthy animals according to species and categories, pathogen-free animal products according their species and categories, but on individual specific diseases’ “standards”, i.e. on deficiencies. This is absolutely contrary to all fair trade principles and to other trade standards where the problem is to define commodity quality and not non-quality ! The WTO/SPS and the OIE “clever” approach is deliberately favourable only to highly profiting traders thanks to not requiring full sanitary quality of animal commodities, i.e. at the expense of importing countries animal and human health. The documents of the both organizations do not know and even prevent from (even not consider) the trade in healthy animals and pathogen-free animal products !!
1.21 The OIE Code is contrary to other general principle of the trade – deregulation = liberalization providing freedom to both participating sites to decide and make bilateral agreements without any outside dictate or interference. The Code applies very strict absurd regulation prohibiting the freedom of international trade in animals and animal products dictating conditions not respecting animal and human health in importing countries, i.e. requiring to accept non-healthy animals and non pathogen-free animal products.
1.22 The Code is contrary to other general principle of the trade – free competition (concurrence) based on differences in commodity quality, in our case sanitary quality) and prices. According to the Code the importing countries cannot freely select exporting countries and require all necessary protective conditions to avoid diseases/pathogens introduction.
1.23 The countries need to import commodities without any post-import problems - undesirable complications - what is absolutely normal requirement in all international trade ! A shameful exception is represented by the OIE Code imposing on importing countries to accept sanitary problems (diseases/pathogens) of exporting countries and pay for it = export of non-desirable and difficult-to-solve sanitary problems.
1.24 The OIE Code instead to make significantly stricter the import conditions to avoid diseases/pathogens spreading through international trade, introduces zero or much more benevolent sanitary quality requirements than before, in spite of the new conditions of rapidly increasing size, distances and speed of the trade as well as the number of distribution places. The Code represents the main supportive document for and justification of the conscious man-made export-spread and globalization of almost all animal communicable diseases, including those transmissible to man.
1.25 The OIE Code doesn’t respect at all the particular features of animal commodities (animals and animal products) as potential and real vehicles of disease pathogens and their biological characteristics. The Code doesn’t respect the difference that non-animal commodities in case of not being of required quality can be return to exporting country what cannot be in the case of introduced and spread pathogens ! Therefore, there is urgent need for importing countries to apply the most strictly possible protective veterinary conditions and not the absurd benevolence required by the OIE Code !
1.26 The OIE Code hypocrisy is reflected also in the facts that requiring the member countries to elaborate their auto-evaluation and importing countries to produce scientific convincing risk assessment is not valid for the OIE itself. The OIE has never carried out any auto-evaluation and the assessment of the OIE Code risk for diseases/pathogens export. The OIE obviously doesn’t feel any obligation to report member country governments on its activities and their consequences for global animal health, i.e. behaving as an absolutely independent organization without any international responsibility!
1.27 The OIE selected for the new 21st century the worse possible scenario !
The author of this paper cannot be silent about conscious and organized destruction of the anti-epizootic results achieved in the world by the previous generations ! The OIE changed its original policy to protect consistently global animal population health into communicable diseases’ global spreading combined with eventual less or no-effective follow-up “fire brigade” actions against imported diseases/pathogens. Basic historical principle of the medicine “Primum non nocere” (First, do not harm.) has become for the OIE an unknown principle not applied at all in the “new modern” OIE Code policy !
Even the old Greeks and Romans applied the principle “Praevenire melius est quam praeveniri.” (“It is better to precede than to be preceded.”)
1.28 The OIE documents state repeatedly and demagogically *) that “within its mandate under the WTO SPS Agreement, to safeguard world trade by publishing health standards for International trade in animals and animal products”. The only reference to the OIE Code in the WTO SPS (annex) doesn’t mean any new mandate contra the established one many years ago in the OIE basic text (constitution) by the founding member country governments and parliaments! No any government or parliament have approved explicitely the change of initial OIE anti-epizootic mandate of consistent protecting animal health in the world into an organization supporting animal diseases/pathogens spreading through international trade! This self-made disease-spreading “mandate” legally doesn’t exist; it was “created” illegally by irresponsible OIE HQs staff in service of major exporting countries.
The OIE has no any “mandate” for animal diseases/spreading even when referring to the WTO/SPS where in the preamble it can be read following text: “"Desiring to improve the human health, animal health .. in all Members;", i.e. no desiring to make worse animal health ! The above mentioned OIE statement that it is “safeguarding world trade” deliberately omitting “safeguarding world animal and human health”! The OIE has lost the main reason for its existence as an independent organization ! The question arises: is there any international organization safeguarding global animal population health ?
*) “100 times repeated lie becomes the truth”(Goebels)
1.29 In the Code there is no one word on the basic principles of animal population health protection against diseases/pathogens introduction from abroad such as country self-sufficiency in animal production to minimize as much as possible the animal commodities’ imports and avoiding risky imports without pathogens-free status guarantee, mainly from distant territories.
1.30 What an incredible difference of the health-damaging OIE Code in comparison with the excellent OIE Manual of Standards for Diagnostic Tests and Vaccine !
The appreciation merit: Professor Dr Marian Truszczynski (Poland) as the former President, OIE Standards Commission and Dr Yosh Ozawa (Japan) as the former Head, Scientific and Technical Department, OIE (before the Chief, Animal Health Service, FAO) who founded this OIE document.
1.31 The OIE as non-UN organization in 1995 usurped illegally through trickery the leading global position in animal health policy without any responsibility for its negative impacts and dictates sanitary conditions for international trade in animals and their products without any official clearance neither by all member-country governments nor by FAO and WHO, UN organizations officially responsible for animal and human health in the whole world. However practically, these two UN organizations have only the responsibility for global animal population health and not the right (with final word) to decide on international measures for its protection against the introduction and spreading of animal infections through international trade. Unfortunately, no one of the mentioned international organizations worries about the negative impact of the OIE Code conducing to globalization of animal infections and its catastrophic consequences.
2. Original concept of the OIE Code
2.1 The original aim of the Code was to ensure sanitary safety of international trade in animals and animal products, through the detailed definitions of health guarantees to be required of trading partners so as to avoid the transfer of disease agents that are pathogenic for animals and humans:
2.2 International Zoosanitary Code, Fifth edition, 1986, Preface: "to provide the necessary measures to prevent the spread of epizootic diseases and hence facilitate international trade in live animals, animal semen and products of animal origin."; "the Code offers several possibilities to importing countries for adopting the most satisfactory position with regard to the animal health status in exporting countries." This clearly documents the former OIE policy to prevent spread and reasonable flexibility in adopting necessary protection measures by importing countries without any dictate from outside. The consideration of animal disease situation in exporting countries was absolutely normal starting with studying very useful data (including on disease import) of common FAO/WHO/OIE information system which was dismantled by the OIE in 1996 (“to facilitate trade”?).
2.3 International Animal Health Code, Sixth Edition, 1992, Foreword: "The principal aim of the IAH Code of the OIE is to facilitate international trade in animals and animal products through the detailed definition of the minimum health guarantees to be required of trading partners, so as to avoid the risk of spreading animal diseases inherent in such exchanges." This corresponds with all other international standards (norms) representing always the requirement for the minimum acceptable quality supporting the best one to be guaranteed by the exporting countries.
2.4 From the above mentioned quotations is clear that the original OIE Code policy was recommending z e r o r i s k trade avoiding diseases spreading. Up to 1995 the Code had served as very useful recommendations for the formulation of animal health import conditions.
3. World Trade Organization concept of the OIE policy
3.1 Initial Code editions’ aim was to assure sanitary safety of international trade in animals and their products. Following WTO/SPS prepared in 1994 thanks to pressure of major exporting countries, exaggerated initiative of the OIE and negative consequences concealment, the very useful OIE Code of minimal recommendations for the protection of importing country health were converted into maximal limits. The only purpose was to facilitate trade at the expense of animal and human health in importing countries.
3.2 As follow-up of the World Trade Organization “Agreement on the Application of the Sanitary and Phytosanitary Measures” (WTO/SPS), 1994 the Code was converted under very strange and unfair circumstances (see copies of author’s letters to Mike Moore, DG WTO in http://vaclavkouba.byl.cz/warnings.htm) into obligatory standard”. The role of the Code was changed completely from the freedom for importing country decisions into international dictate limiting health protection conditions. The change has been favouring exporting countries to the detriment of animal and human health in importing countries.
In the WTO/SPS Article 2 “Basic Rights and Obligations” similarly as in all other provisions there is no one word on “recommendations” but only “Members shall”, i.e. are obliged to fulfil the WTO provisions. Following these wording the OIE Code provisions became obligatory as well. Texts of the paragraph 2 and 3: “Members shall ensure that any sanitary measure is applied only to the extent necessary to protect human or animal life or health, is based on scientific principles and is not maintained without sufficient scientific evidence,” “Sanitary measures shall not be applied in a manner which would constitute a disguised restriction on international trade.”
3.3 The WTO/SPS for the first time in the international trade history the current quality guarantee provided by the exporting countries was replaced by so called “measures” in importing countries ! These non-concrete and non-quantifiable “measures” have introduced an anarchy into international trade in animals and animal products confusing importing countries when deciding about particular animal trade. The definition of so called “sanitary measures” represents an incredible mishmash including all spectrum of veterinary activities having nothing to do with the sanitary quality guarantee for international export. The “sanitary measures” are addressed to importing countries what to do when diseases/pathogens have been introduced through trade. The WTO/SPS quite openly organizes the export of diseases/pathogens as something absolutely normal ! This nonsense is multiplied by the abuse of “risk assessment” to replace original zero risk principles.
Example: WTO/SPS definition of sanitary measures: “Any measure applied: a) to protect animal life or health within the territory of the Member from risks arising from the entry, establishment or spread of diseases, disease-carrying organisms or disease-causing organism. Sanitary measures including all relevant laws, decrees, regulations, requirements and procedures including, inter alia, end product criteria; processes and production methods; testing, inspection, certification and approval procedures; quarantine treatments including relevant requirements associated with the transport of animals, or with the material necessary for their survival during transport; provisions on relevant statistical methods, sampling procedures and methods of risk assessment; and packaging and labelling requirements directly related to food safety.”(!?).
The sanitary measures are addressed to importing countries to restore themselves health/pathogen-free status from non-healthy animals and non-pathogen-free animal products introduced (thanks to anti-sanitary OIE Code) by exporting countries and to control/eradicate imported diseases !? This is another prove that the WTO/SPS and the OIE Code count openly with diseases/pathogens export !
The importing countries are concerned only about full sanitary quality confirmed by objectively justified guarantee documents and not about WTO/SPS theoretical and speculative “measures” (being anyhow the internal problems of the importing countries) replacing the logical duties of the exporting countries to assure the export of only healthy animal commodities!
WTO text “Understanding the WTO Agreement on Sanitary and Phytosanitary measures”: Questions and answers: Problem: How do you ensure that your country’s consumers are being supplied with food that is safe to eat – “safe” by the standard you consider appropriate ? And at the same time, how can you ensure that strict and safety regulations are not being used as an excuse for protecting domestic producers?” These two sentences demonstrate clearly the intention of the WTO/SPS the consumers not to ask for sanitary fully safe food not to complicate trade in non-pathogen-free products. However, the consumers are not interested in any WTO/SPS speculation regarding sanitary innocuousness of imported food. It is obvious that the food originated from local known conditions is for them preferable to the food from countries of unknown animal health/disease situation and even without any sanitary guaranty of the innocuousness. The same problem is with the international trade in animals. The WTO and the OIE have been organizing thousands of courses to convince the trainees to accept non-pathogen-free commodities.
3.4 The WTO/SPS and the OIE Code consider absolutely falsely the importing country protective measures against the introduction of animal diseases/pathogens as international trade barriers and not the occurrence of animal diseases/pathogens in exporting countries! The problem is not in importing countries but only in exporting countries ! If they are able to export only healthy animals and only pathogen-free products, then it cannot be any problem with sanitary trade barriers.
3.5 The “new” concept of the Code as follow-up of the WTO/SPS was described in the OIE Code (Special Edition) 1997 Foreword and explicitly in the article 22.214.171.124 :” Import risk analysis is preferable to a zero risk approach”(!!!). This “principle” unknown in international trade history is unimaginable in any other commodity. In other words, the Code started supporting risky trade = man-organized disease spreading, instead of previous policy avoiding spreading diseases/pathogens through international trade. The consequences of this de facto criminal policy have been catastrophic. Animal communicable diseases have been spread as never before. The OIE became an organization consciously supporting trade at the expense of animal health. This fact confirms the Foreword using following formulations: “.. contributes greatly to the fluidity of international trade”; “..measures in order to minimise negative effects on international trade”, etc.
3.6 The OIE Code is consciously organizing not only the export of communicable animal diseases/pathogens but also of the exporting country sanitary problems. Importing countries must pay for new sanitary problems which solution is usually not easy or unreal at all. The imported sanitary problems may last a longer-period (particularly when the same import is repeated or continuous) or for ever.
3.7 Veterinary import conditions for meat, meat products, eggs, milk, milk products and other products of animal origin, representing the overwhelming majority of international animal trade monetary value, have been systematically, obviously deliberately, missing. These products represent the most important factors of invisible pathogen spreading. The import conditions protecting against foodborne disease pathogens are missing as well and thus consciously opening the door for their mass and daily international and post-import countrywide spread due to speedy distribution (without any quarantine), as irreparable disastrous consequences of the extremely holey Code. This “policy” is reflecting minimal or zero etiological investigations of animal products in exporting countries being interested in “smooth trade” (no investigations = no pathogen discovery = easy export, regardless of the pathogens). The widely propagated Hazard Analysis Critical Control Point (HACCP) avoiding only the contaminations doesn’t bloc streams of pathogens initiated at animal farms, i.e. cannot replace field disease control activities !
3.8 Unjustified exaggerated importance of the HACCP, based mainly on only relatively easy and cheap visual and documents inspections at food processing and storing plants, combined with absolute underestimation of decisive and demanding disease control and eradication at field level when applying principle “doing nothing”, represents other form how to “facilitate” export of invisible disease pathogens. Only at the farm level is the key stratum for producing diseases/pathogens-free animals and their products for export!
3.9 This incredible change of the OIE policy was unimaginable when the Directors General (all of French nationality) were Dr Emmanuel Leclainche (1927-1949), Dr Gaston Ramon (1949-1959), Dr René Vittoz (1959-1980) and Dr Luis Blajan (1980-1990) who strictly guarded the original anti-epizootic mission of the organization to be as much as possible helpful to all member countries in protecting animal health *). This extremely useful policy was later betrayed to serve to the World Trade Organization and not to anti-epizootic protection of animal health in spite of self-nomination (non legal) as the “World Organization for Animal Health” (!?).The organization organizing international disease spreading cannot be called an organization for health ! This is taunting to any logic. The “new” OIE policy represents spitting on and insult to previous veterinary generations experience and results ! The OIE today doesn’t respect at all the original constitution and duties (the principle “Pacta sunt servanda” is obviously not valid for the “new” OIE).
*) International Agreement (signed
by 28 founding governments) for the Creation
of an Office International des Epizooties in
“a. To promote and co-ordinate all experimental and other research work concerning the pathology or prophylaxis of contagious diseases of livestock for which international collaboration is deemed desirable.
b. To collect and bring to the attention of the Governments of their sanitary services, all facts and documents of general interest concerning the spread of epizootic diseases and the means used to control them.
c. To examine international draft agreements regarding animal sanitary measures and to provide signatory Governments with the means of supervising their enforcement.”
The establishment of the OIE was preceded
by an International Conference,
3.10 The “new” OIE, instead to focus all efforts and available very
limited resources on 100% fulfilment of basic duty - on anti-epizootic problems
of international importance, i.e. “concerning the spread of epizootic diseases”,
deals with other problems not requiring international solutions wasting time
and resources. The international
anti-epizootic standards for full sanitary quality trade are not replaceable (the
OIE is only one inter-governmental organization responsible for these
standards). Others than international anti-epizootic problems (such as local food
hygiene, animal welfare, etc.) are from international trade point of view of incomparably
lower importance being supported by many available publications (textbooks, documents
of other intergovernmental organizations such as WHO, FAO/WHO
3.11 The secondary consequences of the anti-sanitary OIE Code consist in dismantling of government veterinary services, minimizing up to stopping active surveys and diseases’ control and eradication measures in exporting countries “saving” money and other resources due to easier animal export not considering disease/pathogen-free status. On the other hand the Code causes serious problems – newly affected animal and human populations’ health (sufferings and deaths) by imported pathogens and enormously costly and demanding introduced diseases’ control and eradication measures (if feasible at all) in the importing countries.
3.12 In this context, the OIE Code should be concise and transparent containing only sanitary definitions of the animal commodities and veterinary import conditions to avoid diseases/pathogens export. The annexes should be only for the comments (explanation) on the code provisions, justification of the changes, analysis of disease import cases, etc., i.e. what the countries when dealing with animal trade are interested in.
4. Code Foreword and Users’ guide
4.1 The International Animal Health Code 2001 started as usually by Foreword and Users’ guide continuing by following structure: general provisions composed by general definitions and notification of animal diseases, obligation and ethics in international trade, import risk analysis, import/export procedures, risk analysis for biologicals for veterinary use; recommendations applicable to specific diseases containing List A diseases, List B diseases (multiple species diseases, bovine diseases, sheep and goat diseases, equine diseases, swine diseases, avian diseases, lagomorph diseases, bee diseases) and diseases not covered by List A and List B; appendices included diagnostic tests for international trade purposes, collection and processing semen, collection and processing of embryos/ova, health control and hygiene establishment, quarantine recommendations, inactivation of pathogens and vectors, transport of animals, epidemiological surveillance systems and a set of model international veterinary certificates. Following new Code issues maintain the same structure with some exceptions such as the changed list of diseases beginning in 2005.
4.2 The Code structure mixed quality standards with different other aspects having nothing to do with health standard (e.g. risk analysis) what should define the parameters to be applied. On the other hand, there was completely missing the most important part of any quality standard – in our case sanitary quality standard, i.e. of healthy animals and their products. The key problem is to guarantee full health quality, i.e. to ensure that the exporting commodity is epidemiologically and epizootiologically innocuous. This is what the importing countries need. The risk assessment is first of all current internal problem of importing countries.
4.3 In the Users’ guide there were texts such as follows: “International veterinary certificates are intended to facilitate trade and should not be used to impede it by imposing unjustified health conditions” (What is “unjustified”, who decides it ? Exporting country or the OIE ?). “It would be irresponsible and contrary to the principles of encouraging international trade to insist on guarantees as to the absence of commonly found infections that are present in the importing country”. (In other words the importing country must accept also non healthy animal and non pathogen-free products !!??) “first steps to be followed when drafting international veterinary certificate is: list the diseases against which the importing country is justified in seeking protection (what is “justified” ?!) and then to list the health requirements for each of these selected diseases” (What about the other diseases ?) The others, i.e. the overwhelming majority (tens, hundreds) of known communicable diseases are out of the protection and they must be permitted to be imported !?!)).
According to this Code the import requirements for healthy animals and pathogen-free food of animal origin are “scientifically not justified”, i.e. not permissible ! This absolute nonsense will be saved in the world veterinary history memoirs!
The real irresponsibility is not to insist on the sanitary guarantee for the protection of importing country! The historical extraordinary irresponsibility is represented by all Code provisions supporting disease spreading through international trade and by their authors not respecting at all basic veterinary medicine principles and ethics !
4.4 The formulation proves the absence of legislation culture avoiding in official international documents (standards) any formulations such as “it would be irresponsible and contrary to the principles…” (acceptable perhaps in some newspapers). International legal documents are always written in a simple manner, i.e. what to be done and what not.
4.5 Instead of applying basic sanitary and preventive principles, i.e. to insist on the export of healthy animals and their products to be free of the pathogens, the Code admitted and supported also disease spreading through international trade in accord with the anti-sanitary WTO/SPS. The OIE became, from neutral independent inter-governmental organization established in 1924 to defend consistently animal health, a WTO-dependent organization unilaterally favouring exporting countries discriminating importing ones to the detriment of animal and human health. The OIE is slavishly parroting the WTO/SPS provisions not respecting at all its original international obligations and instead supporting diseases/pathogens spreading through trade.
Note: Even in 4th century B.C. Greek physician Hippocrates taught that “better preventing than treating”.
4.6 In the OIE 2005 Code Foreword it can be found other “pearls” such as: “The SPS Agreement is aimed at establishing a multilateral framework of rules and disciplines to guide the development, adoption and enforcement of sanitary measures in order to minimize their negative effects on international trade.” This formulation reflects the OIE concern about the trade and no about animal health. “In cases where a government chooses to apply stricter measures, the importing country must be able to show that its measure is based on a scientific assessment of the potential health risks.” (!?). Why this nonsense requirement ? Importing country only concern is to avoid introducing a n y communicable disease pathogens. For this absolutely normal natural demand, there is not any need for any paperwork. Importing countries are not subordinated to exporting ones or to OIE as it is required by the Code. On the contrary, the demand for written scientific justification must be required from exporting countries to document the guarantee of the sanitary quality, i.e. innocuousness of exported commodities. Unfortunately, this absolutely logical principle is unacceptable to WTO and OIE irresponsible bureaucrats in service of unfair anti-sanitary trade business not respecting at all animal and human health and lives in importing countries.
4.7 According to the Code the importing countries can exceptionally require healthy animals or pathogen-free food only if this is “scientifically justified” in writing to convince exporting country !? If this perverted logic would be applied on any other commodity, e.g. on motor cars, then importing country cannot require fully functioning cars without written “scientific justification” !? This comparison shows absolute nonsense of the Code anti-sanitary provisions.
5.1 In the chapter 1.1.1 there are general definitions of the terms used in the Code. Among 63 terms the key ones are still missing in spite of decisive terms for the fair trade: The Code as any other international standard for trade should define the 100 % quality parameters of the commodities, in our case “healthy animal”, “sanitary innocuous animal product”, “pathogen-free animal product”, “foodborne disease pathogen-free foodstuff”, etc., i.e. free of communicable disease pathogens. The most important term for the internal trade -“pathogen” is missing at all. The key problem of the international trade in animals and animal products is to avoid the export of the pathogens !!! *) The missing terms reflect the OIE Code concept as contrary one in comparison with any other commodities of international trade. The impact of this false approach favouring exporting and discriminating importing countries has had globally catastrophic consequences due to mass spreading of diseases through the mentioned trade. The Code doesn’t know the above mentioned terms in the whole text ! The same is valid for other missing important terms such as “guarantee “, “health quality guarantee”, “guarantee period”, “fit for human consumption” etc. The OIE is publishing documents of many thousands of pages, however, in no one of the most important terms for sanitary innocuous international trade in animals and animal products is mentioned.
*) Note: When studying the “root” of the
dangerous philosophy facilitating international trade conducing to avoiding the
term “pathogen”, the author found interesting statement in the “OIE
Handbook on Import Risk Analysis for Animals and Animal products”, 2004 on page
32 where Dr N. Murray, Dr MacDiarmid and
others authors distinguished between the pathogens:“ pathogenic agent is a hazard” and “pathogenic agent is not a hazard”.
They do not accept international medical definition of the term “pathogen”
(Oxford Dictionary: = “agent causes disease”; Last’s
Dictionary of Epidemiology: = “organism capable of causing disease”,
etc.) and tried to justify the export of
the pathogens what they do not understand as a “hazard”. On the next page 33
they presented an example of a list of
5.2 In the Code 2005 there were added further 25 new terms to the list of 105 terms of the previous Code 2004. All the most important terms for the trade in healthy animals and pathogen-free animal products are again missing. Among the new terms are those being generally known to everybody having nothing to do with the particular international trade to avoid disease spreading such as “death”, “killing”, “loading/unloading”, “slaughter”, “travel”, “transport”, “transporter” etc. This is other example how to overload the Code by unnecessary ballast to conceal the truth that this document is serving to trade business and not to the protection of the health in importing countries.
5.3 The Code is consciously not supporting the trade with pathogen-free “healthy animals” and “innocuous pathogen-free animal products” ! The Code is written de facto for trade with non-healthy animals and non-innocuous animal products, i.e. facilitating disease spreading !
5.4 The Code is concentrated, instead on full epidemiological and epizootiological health avoiding export/import of all diseases/pathogens, on only several selected specific disease-free status admitting free spread of all other diseases/pathogens representing their overwhelming majority.
5.5 This concept unacceptable from animal health professional point of view was obviously applied deliberately (“to facilitate trade” ?!) when several time sent protests to the DG, OIE were left without any attention (see http://vaclavkouba.byl.cz/warnings.htm).
5.5 The OIE policy deviation from its basic anti-epizootic duty is reflected also in the term “Central Bureau” where is only mentioned “World Organization for Animal Health” and not the official name “International Office of Epizootics”.
5.6 Other prove of “facilitating trade” through cheating importing countries is reflected also in separating the definitions of “Diseases” (“means the clinical and/or pathological manifestation of infection”) and “Infection” (“means the presence of the pathogenic agent in the host”) what is correct. However, for the trade and for the importing countries is decisive the commodity to be free of the pathogens ! The most dangerous commodities are those carrying the pathogens without any visible manifestation! Therefore, the differentiation between “disease” and “infection” cannot have any international trade importance for importing countries! Unfortunately, the Code is abusing these definitions to identify import conditions differently according to disease manifestation narrowing them as much as possible only on manifested forms and minimizing or avoiding the requirements as far as the epizootiological situation in the neighbourhood (farm, ranch, zone, territory, etc.). Due to the fact that the majority of communicable diseases’ cases have subclinical course, there is absolutely necessary to include in all import conditions the epizootiological situation in the surrounding environment and not only individual animals (their negative tests themselves cannot guarantee pathogen-free status, i.e. to avoid the pathogen carriers) ! From infected environment cannot be avoided the export of pathogen-carrier animals. The OIE anti-sanitary approach increasing significantly the risk of diseases/pathogens export is reflected also in reduced regular international reporting of some diseases when the subclinical course is not notifiable (= improving artificially the picture of exporting country animal disease situation).
5.7 The definition of “prevalence” is too general conducing to different interpretations of one of the most important animal population health/disease indicators such as prevalence rate. It is pity that scientifically exact definitions of the incidence and prevalence rates using mathematical formulae and examples in FAO/WHO/OIE Animal Health Yearbook were not used in this Code. They disappeared in 1996 under very difficult-to-understand circumstances “thanks” to the so called “experts” of the OIE informatics commission. This step could reflect the fact that, according to OIE World Animal Health yearbook, the majority of exporting countries do not know real occurrence of internationally notifiable diseases and therefore the prevalence rate at national level cannot be calculated under these circumstances. The Code is using the term “low prevalence” or “low risk zone” without any transparent and logical explanation confusing importing countries about the occurrence of diseases when almost all available data are not of informative value (obviously the reason is to export from the affected territory considered by the exporting countries as of low risk).
definition of the term “Official Veterinarians” is
deliberately and illogically confusing
(mixing) government veterinary officials who are in entirely different position
than accredited private veterinarians only authorised by the Veterinary
Private veterinarians have completely different priorities requiring full-time employment (income through the treatment of sick animals) while their role in international trade is only ad hoc or part-time.
5.9 The definition “Quantitative risk assessment” (“means an assessment where the outputs of the risk assessment are expressed numerically”) belongs, as far as practical international animal trade is concerned, to theoretical fantasy being repeated systematically in all parts of the Code and OIE publications. The authors themselves have never presented during the whole 10 years period any convincing and defendable scientifically based quantitative risk assessment of communicable diseases, even in the special OIE publication on this subjects (see http://vaclavkouba.byl.cz/riskassessment.htm). The Code is “infested” by the terms and definitions related to the disease risk replacing the basic requirements for diseases/pathogens-free trade.
5.10 Detail definition of “Sanitary measures” is referred to the WTO/SPS. It is very strange that the definition of one of the basic term of animal health is not in the OIE Code of 643 pages but in the document of the WTO which the only interest is to minimize the protection of health in the importing countries to facilitate the export! The WTO/SPS definition represents from professional point of view an incredible mishmash !
6. OIE listed diseases
6.1 The Code 2001 chapter 1.1.2 contains OIE List A and List B diseases. The lists covered traditional structure of animal diseases. It is pity that the FAO List C (including many zoonoses) used for decades in the FAO/WHO/OIE Animal Health Yearbook was missing. Again this fact supports author’s above mentioned assumption that the Code was written for exporting countries not to have many problems and to can export also animal commodities – carriers of diseases including those transmissible to man. The list doesn’t know the disease caused by Brucella melitensis as etiological entity. Instead, there is used (in spite of author’s several protests) a scientific classification nonsense - “caprine and ovine brucellosis excluding B. ovis” - what has been used uncritically (repeated mindlessly) in all OIE documents after 1996.
6.2 The OIE Lists didn’t include some very important diseases such as salmonelloses (as foodborne diseases) in mammals, plague, Ebola virosis, etc. in spite of being suggested several times by the author to DG OIE.
resistance to include mammal salmonelloses could be also linked with the opinion
of Dr Stuart C. MacDiarmid, that time National Adviser (Animal Health), MAF
Policy, actual Secretary General, OIE Commission for the Terrestrial Animal Health Code
who wrote in the document “The Importation into New Zealand of Meat an Meat Products: A Review
of the Risk to Animal Health”. Ministry of Agriculture and Fisheries New
Zealand, 1992, pages 98-99: in paragraph 2.28.2 “Effect of introduction”: “Salmonellae are already widespread and
, it is impossible to obtain salmonella-free foods of animal origin.(!?)
Imported meat products may cause cases of human salmonellosis.”
Dr S.C. MacDiarmid in the above mentioned document (as
6.28.4 “Meat as a vehicle”) quoted WHO, 1988: Salmonellosis control: the role
of animal and product hygiene, WHO Technical Report Series 777, Geneva: “The most common vehicles for human infection
are poultry, pork, beef, eggs, milk and their products. In the
These statements help to understand the fact that the OIE Code and FAO/WHO Code Alimentarius do not require the food of animal origin to be free of zoonotic salmonellae and that these pathogens are not included in the OIE international information system and in any international control programme ! Ergo, the policy against this zoonosis in exporting countries is “doing nothing”. Where is the OIE, WHO, FAO, EU etc. widely declared programme to protect consumer health against foodborne diseases and on the other hand letting them to be freely exported? Where is “famous” risk assessment ?
This is one of the reasons why the WTO/SPS and the OIE Code are not admitting importing countries to require pathogen-free animal products !
If we consider the above mentioned information and the consciously holey OIE Code than it can be supposed that
every day is introduced, without any ante-export and post-import specific controls and investigations, into importing countries enormous quantity of zoonotic salmonellae (including exotic strains) spreading freely in extensive territories infecting incalculable numbers of human beings ! This disease is the first one reaching its globalization thanks to “doing nothing” at international level.
What are the thousands of papers and hundreds of international meetings on animal salmonellosis as foodborne disease for, when the situation in the world is rapidly worsening as never before thanks to internationally organized “doing nothing” at the field level?
6.3 It is pity that the FAO (responsible for global animal health policy within United Nations framework), that has developed very useful programme against local transboundary transmission of communicable animal diseases, has not been interested in avoiding long-distant spreading of them through international trade in animals and animal products. FAO Animal Health Service has conceded this agenda, including veterinary import conditions and global information system on disease occurrence, to the OIE, a non-UN intergovernmental organization applying unfortunately WTO/SPS anti-sanitary policy globalizing animal diseases through trade.
6.4 The Code 2004
as a “novelty” abolished traditional
logical disease classification according to their importance mixing killing diseases (previous List A)
with diseases of lower importance
(previous List B). This change is favourable only to exporting countries
unable to eradicate some List A diseases (e.g. African Swine Fever in
6.5 In the Code 2005 there is other novelty: Criteria for listing diseases. The criteria for the inclusion of a disease in the OIE List are as follows: International spread, significant spread within naïve populations, zoonotic potential and emerging diseases. The formulations of the decision tree represent a risk that some diseases of importance for importing countries will be eliminated from international reporting system (the criteria based on illogically fixed limited number of reporting countries – why exactly 3 and not 2 or 4 or other number ?). The importance cannot by identified only according the number of countries reporting or not a particular disease. The decision must be based on scientific analysis of all relevant factors with the only aim to avoid spreading through international trade. Otherwise, also this “new” method will be abused to “facilitate trade” for the exporting countries at the expense of the health in importing countries, similarly as it is in all other OIE Code provisions. The OIE “new” principle is not respected anyhow even by the OIE itself – e.g. mammal zoonotic salmonelloses and some other foodborne diseases able to kill humans are not included in the Code! *) This part of the Code confirms the domination of the bureaucratic super-writers overburdening the Code by unnecessary components to “camouflage” the absolute absence of the main problems such as sanitary guarantee of animal commodities !
*) Note: The resistance to include mammal salmonelloses could be also linked with the philosophy of Dr MacDiarmid, actual Secretary General, OIE Commission for the Terrestrial Animal Health Code, who wrote in the document “The Importation into New Zealand of Meat an Meat Products: A Review of the Risk to Animal Health”. Ministry of Agriculture and Fisheries New Zealand, 1992, pages 98-99: in paragraph 2.28.2 Effect of introduction: “Salmonellae are already widespread and common in New Zealand.” and in paragraph 6.28.6 The risk of introduction: “it is impossible to obtain salmonellae-free foods of animal origin !?!
There are other diseases corresponding with the OIE Code “artificial criteria” but not included in the list of diseases for international information system and in the OIE Code. As an example can be mentioned very dangerous zoonotic disease (Yersinia pestis) suggested by the author to DG OIE.
Note: The reason can be the
fact that some influential OIE countries with the plague occurrence (
This chapter again confirms the hypocritical discrepancy between the OIE Code provisions and the respect being given them by the exporting countries and the authors themselves.
6.6 In is
understandable that the Code cannot cover individually all communicable animal
diseases. However, at least the zoonotic infections should be included such as:
listeriosis, toxoplasmosis, dermatophytosis, colibacillosis (highly pathogen
strains), viral hemorrhagic fevers,
6.7 The export/import conditions for some zoonoses transmissible from non-human primates are included in a concise form in the Chapter 2.10.1.
6.8 The OIE Code doesn’t respect biological features of the etiological agents in full spectrum, depth, dynamic and infinite variability! The OIE Code doesn’t consider at all the difference between particular types and strains of the same biological species of etiological agents as far as their virulence, pathogenicity, resistance, mutation, etc. are concerned. The OIE Code doesn’t consider at all that conditional pathogens are able under particular stress conditions to reach real pathogenicity and to cause clinical or subclinical diseases. The OIE Code doesn’t consider at all the fact that mixing animals with different environmental and internal “normal” microflora, i.e. from different localities/conditions, can provoke latent diseases in local as well as in imported animal herds.
6.9 The Code is static, bureaucratically formal and inflexible not respecting at all the logic of epizootiology/epidemiology science and practice that every case of export/import is different in place and time !!
7. Notification and epidemiological information
7.1 The chapter
1.1.3 is called “Notification and Epidemiological
Before the WTO/SPS this OIE Code section was called “Notification and epizootiological information” (e.g. OIE
Code 1992, section 1.2, page 17). The change in the terminology, replacing scientifically
exact term “epizootiology” used in all documents of intergovernmental
organizations by “epidemiology”, was the “work” of so called “veterinary
epidemiologists” educated in Veterinary
Epidemiology and Economics Research Unit, Department of Agriculture, University
of Reading, England (founder Dr Peter Ellis), in Veterinary Faculty, Davies,
California, USA (founder Professor Calvin Schwabe) and in Veterinary Faculty,
Maisons-Alfort, France (founder professor Bernard Toma). So called “veterinary
epidemiology” taught by the mentioned schools narrowed original “epizootiology”
dealing with animal population health/disease situation and control/eradication
measures into a subject dealing only with animal population health/disease analysis
(not with follow-up field actions) confusing it with biostatistics and
economics (= “armchair/paper epidemiology”) and isolating it from practical
problem solutions. The followers of the mentioned “schools” gradually dominated
the OIE (after Dr Luis Blajan, DG left in 1991) and converted its practical and logical approach into
theoretical one “facilitating trade” at the expense of importing countries.
They have been imposing, according to them, a supposedly “new modern” concept (not
considered the experience of the other no so influential countries) on all
other international organizations, their member countries, World Veterinary
Association, veterinary research and schools, etc.. The fiasco of this
dangerous philosophy can be documented by catastrophic animal disease globalization,
FMD record disaster in
7.2 In the same article is other text, contrary to basic epizootiological and epidemiological principles, confusing the reporting system: ”presence of an infectious agent does not necessarily imply the presence of a disease..” (!?) In other words, the presence of the pathogens without clinical symptoms is not required to be reported and to be considered for export certification !? When we consider that the overwhelming majority of communicable diseases have subclinical forms, then this text conduced to report only a very small part of cases, i.e. strongly confusing importing country decisions on import conditions. Clinically diseased animals are not the major problem, the main danger is represented by the animals-carriers of pathogens without clinical symptoms considered usually according to the Code to be “healthy” animals (!?). The above mentioned sentence represents the most dangerous nonsense which can be expressed in relation with international animal trade, i.e. clearly conscious support of disease pathogens export !! This formulation in the OIE Code for international trade conditions can be only a “work” of irresponsible pseudo-scientists in service of international business.
7.2 The formulations in article 126.96.36.199 regarding so called “disease free zones” in exporting countries not requiring clear cut conditions to can be accepted by importing country without any doubts are very problematic. Self-declaration of these zones is not confirmed by independent international body and therefore the exporting countries can abuse this provision and declare this status as they wish without any international control. There is not any clear guarantee of the zone isolation from other territories to avoid specific pathogen introduction, particularly when national epizootiological situation is not stable. This OIE arrangement is welcome by the exporting countries only giving them the chance to reduce or cancel demanding and expensive nation-wide disease control and eradication programmes.
The border control among the member of European Union has been abolished and the animals and animal products can cross freely. What about the control of the borders of “disease free zones” to avoid free crossing of animals and their products ? It can be supposed that these “measures” are similar to those at the inter-country borders = minimal or zero !.
At the occasion of the 32nd Congress of the
World Association for the History of Veterinary Medicine,
*) example see in http://www.vfu.cz/acta-vet/vol72/453-03.htm.
7.3 In the article 188.8.131.52 there is following sentence: “Central Bureau, on the basis of information received and of any official communication, shall prepare an annual report concerning the application of the Code and its effects on international trade.” This analysis has never been submitted to member country governments. The negative effects of the Code on global animal health obviously are not of the OIE interest at all. The OIE in 1996, in spite of repeated author’s protests, deliberately stopped regular collecting data on the introduction of diseases/pathogens through international trade and thus it made impossible to analyse properly global impact of the OIE Code on animal and human health in importing countries, i.e. concealing the truth about anti-sanitary character of this document.
The author himself tried to analyze available official reports on communicable disease introductions through international trade. Number of available reports on these cases during 1980-2000 (regular reports till 1996 and later only ad hoc reports) reached 607 : 114 OIE List A disease cases (including 33 of foot-and-mouth disease), 365 OIE List B disease cases (74 of multiple animal species diseases, 142 of cattle diseases, 42 of sheep and goat diseases, 29 of horse diseases, 12 of pig diseases, 49 of avian disease, etc.), 108 OIE List C disease cases and 17 cases of other diseases. Introductions of diseases transmissible to man were reported in 212 cases (34.93 %). Cases of disease reappearance, i.e. newly imported or reemerged, after 3 and more years were reported 329 times. Number of reports on animal disease "recognized in country for the first time" reached 420 cases. All above-mentioned data represented only small "tip of the iceberg".
Disease import cases are often followed by territorial spreading very difficult to control, sometimes no manageable and with catastrophic consequences. Very limited number of successful control and eradication programmes against communicable diseases, together with individual sick animal treatments, cannot compensate at all rapidly increasing animal population morbidity in the world. The import of the diseases devaluates the results of control and eradication programmes. No one animal disease has been globally eradicated yet. Diseases are spreading as never in the past when the trade used to be of much minor size and intensity at much shorter distances to much lesser number of destination and distribution places. The situation is getting worse every day towards man-made irreparable global ecological disaster. Continuing worldwide mass spreading of communicable diseases, not being blocked by effective measures, represents serious global crisis of veterinary medicine which historical mission is to protect and recover animal population health.
7.4 Actual regular information system on disease occurrence, in comparison with the anterior system is formally improved (thanks to current computerization general development) but the most important professional data on real epizootiological situation, required for import decision, have been significantly reduced = minimal or zero. This deliberate data (indicators) reduction = organized disinformation making importing countries impossible to identify correctly the risk and necessary protective measures.
7.5 The reduction of the trade-necessary data was done deliberately what can be proved by the fact that no one author’s protesting letters, with justified recommendations to restore previous or to introduce new more informative system, were left without positive reaction. Instead of providing at least previous or better information on animal population communicable diseases, the OIE has concentrated its attention to pure formal aspects related with current modernization of software programmes.
Several protesting letters were sent to Dr Jean
Blancou, Director General, OIE,
7.6 Deliberately minimized data published in the OIE World Animal Health yearbook are for import condition decisions not only absolutely not sufficient but also very confusing providing minimum or zero information on animal diseases situation in exporting countries. The OIE “new” information system on disease situation in the member countries reminds a form of “garbage in, garbage out”! The incredible deliberate reduction of disease occurrence data reporting was done without any scientific, practical and logical justification, without any necessary analyses of available experience and future needs, without any consideration of that time existing satisfactory FAO/WHO/OIE information system (it was dropped without any replacement)! The reduction was done without presentation to member country governments any risk assessment of the negative consequences for importing country animal and human health and for international anti-epizootic programme. For the “clearance” was used the usual OIE system of lie and cheating.
7.7 The overwhelming majority of numeric data published by the OIE are based on “ad hoc” reporting mainly by not always reliable private veterinarians, i.e. can be understood as only a “tip of the iceberg”, i.e. the data have not informative value needed for anti-epizootic decision-making and confuse importing countries. And the reports such a “+” following by “…” “no information available” confirm the after-WTO/SPS-OIE information system as being almost without any practical anti-epizootic importance for international trade. The “new” system was established by irresponsible “theoretical pseudo-specialists” and bureaucrats deliberately “simplifying” the list of occurrence indicators to the most primitive “+” for anybody knowing read and write (to “facilitate trade”?!) instead of former epizootiological characterization of disease occurrence estimates requiring the university veterinary education. During the pre-WTO/SPS decades there were no any problems in any country in the world to report data on disease situation characterization from exceptional imported case up to ubiquitous occurrence. Instead of providing more and better data on disease occurrence than before, the OIE has done exactly the opposite going back at the beginning of the 20th century.
In any international information system its contents (usefulness) is decisive and not the form of the data collection !
7.8 Among the members of the OIE Working Group on Informatics and Epidemiology sharing responsibility for the after-WTO/SPS significant reduction and deformation of the global animal health information system belonged : Dr Randall S. Morley (Canada), Dr Stuart C. MacDiarmid (New Zealand), Dr G. K. Bruckner (South Africa) and Dr Sharon R. Thompson (USA). All of them are historically responsible for the shameful dismantlement of animal health system including also very important disease occurrence epizootiological characterization as well as on disease imports.
If we look at the disease occurrence reports from the home countries of the above mentioned destructors of the international animal health information system and main propagators of the abused risk assessment “to facilitate export” then we can understand their anti-sanitary positions.
One of the initiators and fervour defenders of
the “new” significantly reduced information system was Dr R.S. Morley
7.9 Up to 1996 the international information system on animal health was common – joint venture of the FAO, WHO and OIE. Every year there were organized meeting of informatics experts of all three international organizations to revise and further develop this common system as far as the contents and forms. Unfortunately, DG OIE abolished this tripartite “Informatics committee” and in the OIE World Animal Health yearbook eliminated the FAO and the WHO, the organizations belonging to the United Nations Organization (what is not the case of the OIE), even not mentioning their names. Only after personal intervention of the author of this paper, the DG OIE arranged for including at least the emblems of these organizations on the internal cover page. Nothing more ! Even in the regular foreword the names of these international organization have not been mentioned. The OIE “usurped” the international information system and therefore took over full responsibility for its “mutilation” and consequences. The OIE deliberately abused this system to adjust it for “facilitating international trade” through minimization of animal health situation data on exporting countries to confuse importing country decisions on veterinary trade conditions.
7.10 The OIE in 1998 even abolished without any scientific, practical and logical justification and without any replacement international statistical (numeric) classification of specific communicable diseases ! This is something unimaginable in human medicine and in the computer age also in all other relevant fields ! Without international statistical classification the terms of individual diseases defined by particular numbers code is very easy to confuse the diseases having in different, even official languages (more than one hundred), different expressions. What about the OIE changing sometimes the terms of specific diseases? This “clouding” disease situation in exporting countries represents further step of the OIE “to facilitate international trade” at the expense of animal and human health in importing countries.
8. General obligations and ethics in international trade
8.1 In the chapter 1.2.1 General obligations it can be found following text: “International trade in animals and animal products depends on a combination of factors which should be taken into account to ensure unimpeded trade, without incurring unacceptable risks to human and health.” (!?). Unimpeded trade de facto means logically unacceptable risks. The Code of the OIE should be for avoiding communicable disease export and not for easy trade of exporting countries at the expense of the health in importing countries. There is not any doubt that this extremely wordy document has been written by the “experts” of and for the major exporting countries.
8.2 In the article 184.108.40.206 is following text: “The import requirements included in the international veterinary certificates should assure that commodities introduced into the importing country comply with the level of protection that it has chosen for animal and human health. Importing country should restrict their requirements to those justified for such level of protection.” Who decides what is “justified” an what not ? This formulation does not respect that every country has different situation and conditions. Again, the vague formulation opens the door for the import of non-healthy animals and non-pathogen-free animal products. The position of the Code authors is always on exporting country side discriminating importing ones, mainly defenceless developing ones. It is logical that importing countries need to import healthy commodities and not the diseases or pathogens ! This is obviously, according to the Code, not of the OIE interest in spite of hypocritical un-official self-declaration as “World Organization for Animal Health” without any official, i.e. legislation clearance by member country governments.
8.3 This OIE hypocrisy follows WTO/SPS introductory false attractive and promising statement "Desiring to improve the human health, animal health .. in all Members;". Similarly as in the WTO/SPS also in the whole OIE Code is no one word about the improvement of the health ! In contrast with this statement the both documents are concerned only how to "facilitate trade" to the detriment of human and animal health ! Both documents are responsible for diseases/pathogens “legal” spreading into importing countries and for reducing, stopping or not starting new communicable diseases control and eradication programmes (i.e. letting these diseases to spread freely) in exporting countries when the export of animal commodities has become a relatively easy profiting job. The reality = organized significant continuous worsening of animal population health in the world !
The “new” OIE Code has nothing to do with the improvement of animal and human health ! On the contrary ! Where is the ethics ?
8.4 In the same article there is other “jewel” reflecting anti-sanitary concept of the Code.” The international veterinary certificate should not include exclusion of pathogens or animal diseases which are present within the territory of the importing country and are not subject to any official control programme. The requirements applying to pathogens or diseases subject to official control programmes in a country or zone should not provide a higher level of protection on imports than that provide for the same pathogens or diseases by the measures applied within that country or zone.” This is other open invitation to can export diseases/pathogens! Every country has different epizootiological and epidemiological situation continuously changing in space and time, reflecting different specific diseases’ structure including different types and strains of etiological agents and applying different measures. How can importing country apply the same protecting measures for the import as for the local trade when the information on export country situation and exporting commodities are incomplete or missing at all, i.e. risky ? How can import requirements can be the same when the knowledge of epizootiological situation in foreign exporting countries is very often unknown (“terra incognita”) in comparison with the knowledge of the situation in own country territory ? It is doubtful if the countries “behind the Code” would accept these illogical principles themselves “at home”. This is other prove of missing seriousness and responsibility of the anti-sanitary OIE policy organizing de facto the globalization of communicable diseases!
According to the Code the importing country cannot require fully innocuous products, e.g. that the pork or beef or poultry meat to be free of pathogens such as Salmonella enteritis or Salmonella typhi murium because the country itself is not free of these pathogens and according to OIE World Animal Health yearbook no country has any national control programme against these very dangerous diseases transmissible to man. It is doubtful that any of the OIE most influencing countries “ behind the Code” would accept to import these infected commodities and inform openly through news media all consumers about this fact !
8.5 Considering this example, there is clear that the Code as subordinated to WTO/SPS is written against professional logic and against animal and human health and is more a political unilateral document damaging importing countries, mainly developing ones, and thus facilitating the globalization of animal diseases. The Code doesn’t respect at all today’s knowledge about epizootiological and epidemiological complex characteristics of the majority of individual diseases as biological phenomena, i.e. it bears the stamp of bureaucratic unilateral approach and not of professional one as it was always in the OIE Code before the WTO/SPS. The Code demonstrates that the OIE policy has been changed and original consequent protection of the health in the world is not more its programme. What is actual OIE programme for ?
8.6 According to the article 220.127.116.11 “The Head of Veterinary Service of the exporting country is ultimately accountable for veterinary certification used in international trade.” This theoretical principle is correct, however in the majority of leading exporting countries is absolutely unreal - the Chief Veterinary Officers are as the generals with their headquarters but without “army”. They are dependent on almost un-controllable private sector often not reliable and objective when testing and issuing “official” certificates. Relatively very weak public services are unable to control effectively the trade and very often they are unable even to see exporting commodities. Therefore, the supervision is usually too superficial, formal (mostly paper control only) and benevolent without drawing corresponding conclusions in cases of not respecting regulations and ethics.
Example: “A large rendering company in
8.7 In the article 18.104.22.168 there is mentioned ethical responsibility for mutual informing between exporting and importing country about eventual cases in traded commodities, what is correct. However, there is no one word of ethical and financial responsibility for eventual exporting pathogens as it is absolutely normal in any other commodity when non-quality products have been exported. The Code doesn’t know the practice of drawing conclusions and punishing irresponsible veterinarians certifying falsely non healthy animal commodities as disease-free or pathogen-free. No one word on the duty of exporting country to cover the damages caused to importing country. The Code provides de facto welcome alibi arguments for exporting side. Under this Code the export of diseased animals and their products is un-punishable ! On the other hand, the countries introducing diseases trough trade are punished. They must pay not only for the commodity imported as healthy (pathogen-free) even in the cases when not being healthy (the same price = organized robbery “legalized” by the WTO/SPS and the OIE Code supporting trade in non-healthy animals and non-pathogen-free products), but also for the import of difficult to detect and solve disease problems causing enormous losses and requiring a lot of expensive inputs. This fact reconfirms ones more that the “new” Code is obviously written for the thievish profit of major exporting countries only and represents a travesty of preventive veterinary medicine and sustainable development programmes.
Even in the Code of Hammurabi of 18th
century B.C. “if the healer has carried out an important operation on an ox or
donkey and caused its death, he must pay the owner one fifth of the animal
price.”(ordinance No. 225 ). In the history of mankind the robbery has been
always understood as serious criminal act and the thieves have been punished.
8.8 The OIE Code provisions on the ethics of international trade in animals and animal products are the mere hypocrisies. All components of the Code supporting diseases/pathogens export have nothing to do with the ethics !
9. Certification procedures
9.1 Very problematic is the chapter 1.2.2 Certification procedures. The problems of the current international fair trade are quality guarantee documents and not certificates as information not binding documents only. The Code does not know at all the basic principle of international fair trade, i.e. quality guarantee declaration and the period of this guarantee responsibility. The importing countries need the guarantee that the commodity is free of communicable diseases/pathogens. The Code does not require full sanitary quality and therefore, also in this part, is supporting disease spreading. The OIE international veterinary certificates guarantee nothing !
9.2 According to the Code the exporting country issues only information documents on selected diseases omitting the majority of them. In the Code cannot be found one word about key trade document - quality health guarantee, i.e. guaranteeing the health status of animals and epidemiological and epizootiological innocuousness of animal products. Avoiding the responsibilities for full health quality replacing them by incomplete veterinary certificates, not sufficient for eventual claims for disease import and post-import damages, is obviously one of the reasons for the WTO/SPS to “facilitate trade”, i.e. export at the expense of health in importing countries. The demagogical words about ethical standards and professional integrity are very vague when considering the fact that in the international trade the priority has unfortunately the traders’ profits. The sentences “It is essential not to include in the requirements … matters which cannot be accurately and honestly signed by a veterinarian.” and “They should not require a veterinarian to certify matters that are outside his/her knowledge or which he/she cannot ascertain and verify.” In other words the OIE Code certificate is only an information paper not reflecting real health status but only the “knowledge” of the signing veterinarian, i.e. no investigation = no disease = “health”. Without strict supervision he can undersign what he wishes (no any effective supervising inspection), in spite of exporting eventually non-healthy animals and non-innocuous products. Thanks also to OIE Code alibi, he is not responsible for negative consequences in importing countries having troubles with imported diseases/pathogens. This is the way for the conscious organized propagation of communicable diseases what belongs among international criminal acts ! This is other example how the Code is avoiding the guarantee of health quality, i.e. facilitating the export without any sanitary guarantee. This provision for certifying only what the signing officer knows is unimaginable in all other trade commodities requiring full quality guarantee with full responsibility of the issuing persons or organizations.
9.3 According to article 22.214.171.124 “Certifying veterinarians should have no financial interest, other than fee for provision of a service, in the animals or animal products being certified.” This formulation does not avoid the dependence on the exporters when their animals or products originate from the service area of certifying private veterinarians; the owner of exporting animals or products provides these local veterinarians normal work and income (they are concerned about not to lose their clients and jobs). This fact is completely omitted in the Code and thus is supported also the certification by non fully independent veterinarians. This is other way for the propagation of communicable disease through “legal” international trade.
9.4 Every exporter naturally commends his commodity quality trying to convince attest issuing veterinarians about it. Certifying veterinarian can take advantage of knowing that in case of diseases/pathogens export, in spite of his “favourable” certificate, there is no risk of being punished (due to: absence of importing country claim, late discovery, arguing by “not knowing about it” or by false negative results of used tests, having more effective advocates than importing side, etc.). He is signing according to OIE Code only information “certificate” and not health guarantee document as it is normal in any fair international trade. In many cases he can rely on the fact that the majority of imported diseases/pathogens are discovered too late without possibility of proving external origin or not being discovered at all. Back tracing of imported pathogens is often extremely difficult or unreal not only in developing countries having not sufficiently developed public veterinary services.
Examples of the “unreliability” of certificates (informing only and not guaranteeing) issued by private “accredited” veterinarians:
- Czech Agriculture University, Prague imported 60 pregnant heifers from Denmark to Lany-Pozary university ranch in 1993 and 395 pregnant heifers from France to Ruda university ranch in 1995 – import supported by government financial grant; in spite of international veterinary certificates according to OIE Code both shipments were found as affected by trichophytosis (Trichophyton mentagrophytes) even with clinical visible changes (the local herds were free of this mycosis) infecting not only animals but also 76 persons and by paratuberculosis (disease never reported among indigenous cattle in the whole country): the breeding programme instead to be improved was paralysed in both ranches, originally with healthy herds; these ranches were eliminated from normal trade and until today (2006) the paratuberculosis cannot be eradicated. All grant money for supporting the development of the cattle herds went to waste.
- In 1994
reported USDA/USA 182 cases of cattle con macroscopic postmortem tuberculosis
findings imported from
9.5 The certifying officer has a key role in the animal trade, particularly in the international one. Therefore, it merits to define exactly his characteristic and detailed conditions for assuring real independence and professional quality to be able to guarantee the health as fully responsible officer. Their supervision by the public service specialists is usually very problematic or unreal or even zero. Not properly supervised private veterinarians can sign also certificates not corresponding with real health status knowing that there is very difficult to discover the falsification. Even in the case of this swindle discovery by the importing country, the consequence for false-attest-issuing veterinarian are close to zero or zero (i.e. without risk). In some exporting countries almost all private veterinarians have been given the public authority after not always considering properly their competence and objectivity, i.e. not applying demanding selection criteria. In some exporting countries almost all private practitioners as “accredited veterinarians” (often without special training and proper examinations) have government rubber stamp for “official” international veterinary certificates.
9.6 In the chapter “Certification procedures” is missing the most important provision for guaranteeing full independence of veterinary attests issuing persons on producers and exporters as well as for consistent government supervision on them; they can confirm what they wish without any penal responsibility. The lack of effective control = breeding ground for the corruption = diseases/pathogens export. This can be documented by incalculable numbers of disease export cases in spite of having “OIE international veterinary certificates” being only of information value and not guaranteeing the animal health or pathogen-free status.
Only public service veterinarians can be fully independent on producers, exporters and businessmen. So called private “accredited veterinarians” are usually not fully independent and are easier to become corrupt. Therefore, instead of the signature of “official veterinarian” according to the Code, it must be distinguish if the signature is of “public service veterinarian” or of “private accredited veterinarian”. In spite of substantial difference of the “weight” (reliability), the OIE Code deliberately doesn’t distinguish at all government and private veterinarians’ international trade role and signature on the animal health documents. This trick “facilitating trade” at the expense of importing countries’ health can be found in the whole OIE Code text.
This OIE policy is linked with its full support of the privatization of previous public veterinary service imposed on the governments by the World Bank and International Monetary Fund and thus debilitating ad absurdum these services decisive for animal population health protection, disease control/eradication measures and fair trade. It was a further form of the OIE support of diseases’ globalization through international trade “in line” with the WTO business policy. That time due to minimalization of public veterinary services ended postwar period of intensive control/recovery measures eradicating many important animal diseases at national levels.
9.7 In order to avoid animal disease spreading there is a need to change the OIE Code certifying policy guaranteeing absolutely nothing as far as sanitary criteria. The change should be based on guarantee document, e.g. Sanitary Guarantee Certificate guaranteeing for example that:
- the exported animals are healthy (clinically and free of all communicable disease pathogens) or
- the exported animal products are communicable disease pathogen-free
( = full price);
- the exported animals are specifically healthy (clinically and free of all pathogens of all internationally notifiable diseases) or
- the exported animals are specifically healthy (clinically and free of listed specific communicable disease pathogens)
- the exported animal products are free of specific pathogens of all internationally notifiable diseases or
- the exported animal products are free of listed specific communicable disease’s pathogens (defining the list of the absent pathogens)
( = accordingly reduced price).
In the case of bilateral agreement the Sanitary Guarantee Certificate could have different form such as to identify diseases/pathogens which cannot be avoided to alert importing country for special post-import measures blocking eventual diseases/pathogens presence in post-import quarantine (the price must be naturally reduced).
9.8 The most important principles of certification procedures are to inform importing country on true sanitary status of introducing animals and their products and exporting country to be fully responsible for it. The importing country must be informed what is guaranteed and what is not !
9.9 The OIE international certificates are formulated in non-guarantee form, i.e. not binding the exporters, similarly as in all Code provisions, to avoid (make impossible) normal reclamations in case of diseases/pathogens export. In other words, the importing countries, also according to this Code “arrangement”, become defenceless when the possibility to claim diseases/pathogens introduction and follow-up losses has become minimal or zero. The OIE Code is offering exporting countries the chance to abuse the fact that imported diseases/pathogens will be not discovered at all or too late for successful reclamation (e.g. in many diseases the clinical manifestations appear after longer time and/or after several passages).
9.11 The article 126.96.36.199 “Certifying veterinarians”, paragraph 4 has very strange formulation: “Certifying veterinarians should have no conflict of interest in the commercial aspects of the animals or animal products being certified ..” . This is open instruction how to accommodate the demands of the exporters at the expense of sanitary quality, i.e. regardless of the health aspects ! In practical life the interests of the health protection is usually in conflict with the opposite economic interests of the producers, exporters and traders!
The OIE has lost any health protecting concept, professional duty, moral and ethics !!!
9.12 The article 188.8.131.52 “Electronic certification” reflects the OIE Code tendency to simplify the certifying procedure through increasing the “distance” (in place and time) between the exporting commodities and information attest (not sanitary guarantee) issuing person without seeing them. This provision represents other factor “facilitating the trade” and the falsification and abuse of the veterinary documents.
9.13 Almost all exporting countries report on the majority of internationally notifiable diseases occurrence that “no information available”. How the importing country can trust the reliability of the export veterinary information certificates ?
10. Risk analysis
10.1 Section 1.3 is dedicated to Import risk analysis introduced in the OIE Code after the WTO/SPS. In the previous OIE Codes the “risk analysis” was not existent – it was not necessary as internal problem of importing countries ! This section represents exceptional component unknown in any other commodity international trade standard. The basic principle has always been international trade with zero risk, i.e. with full quality commodities, not avoiding the possibility to agree bilaterally on certain degree of tolerance by the importers compensated by lower price. However, the after WTO/SPS Codes are on the contrary based upon risky trade, i.e. accepting also the export of non-healthy animals and no-innocuous animal products with the motto “to facilitate trade”. This is the only reason for the WTO/SPS and the OIE Code: to create historical exception having nothing to do with normal fair trade principles!
Risky trade = diseases/pathogens export !
10.2 First some texts of this section: “The risk may be represented by one or several diseases or infections.” (what about tens and hundreds of other diseases !?).”The principal aim of import risk analysis is to provide importing countries with an objective and defensible method of assessing disease risk associated with the importation of animals…”.”The analysis should be transparent. This is necessary so that the exporting country is provided with clear reasons for the imposition of import conditions or refusal of import.” “Transparency is also essential because data are often uncertain or incomplete and, without full documentation, the distinction between facts and the analyst’s value judgement may blur.””…conducing transparent, objective and defensible risk analysis..” “..scientific justification..” “sensitivity analysis”, “uncertainty” etc. The whole section (initial sentences have been repeated every year, incl. 2009) belongs to some theoretical discussions and journals (where everybody can present what he wants and without any prove of practical feasibility and without any responsibility for the consequences) and had nothing to do with practical sanitary quality standard for international trade. This wordy section represents the main tricky instrument of the major exporting countries how to “facilitate trade” exporting animal commodities without full sanitary quality. From practical viewpoint of importing country governments the OIE Code risk analysis method for international trade is a big even professional nonsense (up today there has not been published any case proving usefulness and practical feasibility of this OIE absurd “method”). The method is not considering at all the main source of real risk for importing countries, i.e. the diseases occurrence in the exporting countries !
Dr S. C. MacDiarmid (New Zealand)
who was obviously the initiator of the trickily abused risk assessment
“mania” *) was promoted from the member of the OIE Working Group on
In other words according to this perverse statement, there is not important what is the disease situation in exporting countries (because they do not know it !) !? The authors of this extremely dangerous philosophy, dominating the OIE Code, obviously have not (or have ?) any idea on the importance of false negative tests and ineffective treatments. International trade must be based on avoiding risk and not on problematic reducing risk only, i.e. in our case admitting disease spread..
This was the ideological basis for the WTO/SPS “sanitary measures” addressed to importing countries what to do with imported diseases/pathogens (instead to insist on full sanitary quality of imported animal commodities) and for the OIE deliberate absurd reduction of data on diseases’ occurrence !!!
*) Author’s opinion is based on personal discussion with Dr S.C. MacDiarmid in Yokohama, Japan in September 1995, letters received from him (dated 3 November 1995 and 15 January 1996) and on the study of his numerous publications on the risk assessment.
10.3 Similar reports on disease occurrence (“+”) with “…” = “no information available” can be found (after the significant reductions of occurrence data by the OIE in 1996) also in the official reports from the majority of exporting countries. The real epizootiological and epidemiological situation in the countries are not known. How the importing countries can assess the risk of diseases/pathogens introduction when the information on disease situation in exporting countries is minimal or zero ?
Examples: In OIE World Animal Health 2002:
“It is assumed, that for every case of salmonellosis recorded in humans in the
10.4 The OIE risk assessment methodology is for importing country governments a mere theory and fantasy, i.e. de facto a camouflage for covering the export of animal commodities not having full sanitary quality. The trade based on subjective (estimates, assumption, unfounded impressions) and not on objective quality criteria is open for wide corruption favouring to exporting countries!
Note: The authors of the OIE risk analysis methodology themselves were not be able to provide any example corresponding fully with its detailed procedures: In the “OIE Handbook on Import Risk Analysis for Animals and Animal products”, 2004 on pages 34-48 (15 pages!) Dr N. Murray, Dr MacDiarmid (both from New Zealand) and others authors in the first Volume selected African horse sickness as the detailed example how to carry out correct risk assessment for the importation of horses into New Zealand. Unfortunately, in this example there is not used at all any of recommended quantitative methods as described in absurd details using artificial super-mathematics formulae (“science-fiction” is more realistic) in the second Volume of 123 pages !!! The carefully selected example is not sufficiently transparent, convincing and documented as required by the OIE Code. The authors even admitted on the page 27 :
“qualitative and quantitative analyses are inevitably s u b j e c t i v e”
How can be required risk assessment transparency when the analyses are subjective and non-quantifiable ?!?
Among the authors
not respecting at all biological reality and practical needs for the protection of animal
health in importing countries, i.e. supporting
diseases/pathogen export during the particular international trade, were
also: Marion Wooldriche (UK), Bruce
Gummov (South Africa), Randal S. Morley (
10.5 The simplest and logical requirements of importing country for full quality goods, in our case for healthy animals and innocuous products, i.e. free of communicable disease pathogens, do not need any “convincing scientific” justification of risk assessment to be presented to exporting country !
The importing countries for their decision on the import need maximum possible information on epizootiological situation in exporting countries and not minimum or zero information on disease occurrence (as the OIE introduced its “new policy” after the WTO/SPS referring to tricky “risk assessment method”) !
10.6 Chapter 1.3.2 Guidelines for risk analysis describe in exaggerated details the procedure requiring a lot of data. The authors either had not good knowledge about practical life or the whole concept was elaborate deliberately to make impossible necessary protection of importing countries. The Code asked maximum duties and “works” for importing countries (who pay) and minimum for exporting countries (who profit) = discrimination of importing countries, mainly developing ones. The authors have not any idea what would signify the implementation of their risk analysis methods for all relevant diseases in required details. They are confusing the very limited capacity of Chief Veterinary Officer office staff and facilities in almost all importing countries with a big research institute very well staffed, equipped and financed with full access to respective world literature. Also in the ideal case the most complex risk analysis results must not be for exporting country convincing and acceptable.
10.7 The whole absurd section on the risk assessment for importing country decision can be replaced simply by only referring to any university textbook on communicable diseases of animals where there are necessary data, based on accumulated world scientific results and practical experience, on pathogen sources and transmission ways.
10.8 The top of the nonsense from practical point of view is the article 184.108.40.206: “The risk assessment should be based on the best available information that is in accord with current scientific thinking. The assessment should be well documented and supported with references to the scientific literature and other sources, including expert opinion.” “.. transparency is essential in order to ensure fairness and rationality, consistency in decision making and ease of understanding by all the interested parties.” This statement requires a big well staffed, equipped and financed institute to work a longer period to produce the documents (for each selected disease risk) which finally will not be acceptable by the exporting country in case of complicating its export. How can, for example, a developing country having minimum number of public service veterinarians, lacking of almost everything, be able to elaborate something what is absolutely out of the current reality. This OIE method is not feasible even in the most developed countries which are obviously behind this “professional” science-fiction. This method serves only to cheat importing countries pushed into defensive position and to “facilitate export” without the need for the guarantee of full sanitary innocuousness.
10.11 The irony is that also the countries pushing this method forward do not apply it themselves when they consider it as not advantageous for them. Some of the major exporting countries, authors and fervent defenders of the Code and the WTO/SPS, do not respect their provisions themselves. They respect the Code as well as the WTO/SPS provisions only when these are favourable for them using “double standard” regardless of the others demonstrating once more that this OIE method is only a trick to confuse importing countries.
Example of not respecting the OIE Code and the
WTO/SPS provisions: In the
first line of the authors, fervent defenders and propagators of the WTO/SPS and
OIE risk assessment method are the “specialists” from
Among many examples not respecting the OIE Code and the WTO/SPS it can be mentioned the case when at the beginning of 2006, after the identification of the first avian influenza H5N1 case in France, 30 countries (among them Japan, Morocco, Thailand, etc.) prohibited import of poultry products from this country without any OIE “risk assessment scientific justification” method which again proved to be a mere theory.
10.12 Article 220.127.116.11 Risk assessment steps contains a list of the data to be available for the procedure not respecting that the majority of them are not available even in the home countries of the authors.
“Risk estimation consists of intergrading the results from the release assessment, exposure assessment and consequences assessment to produce overall measures of risks.”. “For a quantitative assessment, the final output may include: probability distribution, confidence interval, and other means for expressing the uncertainties in the estimates; portrayal of the variance of all model inputs, a sensitivity analysis to rank the inputs as to their contribution to the variance of the risk estimation output, analysis of the dependence and correlation between model inputs.”
The text is demonstrating that this part of the Code was elaborated by so called “eminent specialists on risk analysis” (according to below referred letter of DG OIE sent to the author) having no any idea about the need of importing countries. They didn’t respect at all the infinite diversity and dynamics of animal diseases/pathogens phenomena and their ability to reproduce and mostly invisible rapid spread (unknown in any other trade commodity !) as well as they didn’t’ consider any personal responsibility for practical consequences of their absurd methodology: This is from the practical point of view a cardinal nonsense having nothing to do in any international trade standard. The problem is not the non-quantifiable theoretical subjective risk analysis but how to guarantee practically the export of really innocuous animal commodities !
From the letter of Dr
Jean Blancou, Director General, OIE dated
10.13 It is clear that importing country not having necessary information cannot follow the absolutely nonsense theoretical OIE methodology not applicable even in those countries whose “experts” belong among its authors. The tragedy is that this „fantastic“ unrealistic method is uncritically, i.e. unscientifically, supported by irresponsible theoretical „top level veterinary epidemiologists“ of these countries influencing the others (e.g. through World Veterinary Association, International Society for Veterinary Epidemiology and Economics - ISVEE, international postgraduate courses, journals such as Preventive Veterinary Medicine, etc.). They obviously had not any good idea about practical international trade reality and protection of importing country animal and human health. The Hippocratic oath of medical ethics based on restoring and protecting the health is not more valid for them ? They obviously are not interested in the negative consequences for importing country animal and human health. They prefer flattering to and being priced by powerful business lobby of their country forgetting that their basic duty is to defend the animal health. They “forgot” that effective livestock development and food production as well as protection of man against zoonoses require healthy animals and not diseased ones. They “forgot” (to please business lobby?) that the science means the search and fight for objective truth and not to repeat mindlessly the provisions of bureaucratic theoretical absurd political documents, in this case serving to the globalization of communicable diseases in the interest of major exporting countries at the expense of importing ones (mainly developing ones). It is difficult to believe that among fervent supporters of disease spreading into importing countries through trade are unfortunately also some irresponsible veterinary epidemiology “teachers” having international influence.
As an example of pseudoscientific servile support, without any concrete objective justification, data and prove, of anti-sanitary policy of the WTO/SPS and the OIE Code organizing disease spreading through international trade can be mentioned a “new concept” of the International Society of Veterinary Epidemiology and Economics (ISVEE) applied during its congresses in Breckenridge , USA in 2000 and mainly in Vina del Mar, Chile in 2003 (even not permitting plenary discussion on this extremely critical animal health situation in the world). This false anti-sanitary concept was expressed clearly e.g. in the paper of Drs C. Zepeda (USA), M. Salman (USA) and R. Ruppaner (Canada) called “International trade, animal health and veterinary epidemiology: challenges and opportunities” (Preventive Veterinary Medicine, 48, (2001), pages 261-271) lacking any scientific analysis and prove not respecting at all epidemiological principles of consistent protection of importing country animal population health. The ISVEE de facto has became one of the main lobbyist organization fighting for the WTO/SPS and the OIE disease globalization policy and not for globalization of animal health supporting business instead of health protection.
10.14 The only reason for using OIE „risk assessment“ method is to replace diplomatically the need for exporting full sanitary quality commodities requiring completely different approach (zero risk) and measures in exporting countries such as disease eradication and surveys, strong public veterinary services, intensive etiological investigations and other measures not easy to organize and finance.
10.15 In the article 18.104.22.168 is following text: “The objective is to manage risk appropriately to ensure that a balance is achieved between a country’s desire to minimise the likelihood or frequency of disease incursions and their consequences and its desire to import commodities..”. In this article it can also be read:” The efficacy is the degree to which an option reduces the likelihood and/or magnitude of adverse health and economic consequences.” These formulations represent other confirmation of the OIE Code policy admitting, i.e. supporting instead of avoiding the export of diseases/pathogens into importing countries !
10.16 The whole anti-sanitary Section 1.3 has nothing to do with normal international standard identifying quality parameters of traded commodities. Traditional risk assessment principles are blatantly abused to “facilitate export” from those countries not being in the position to export full quality goods. The diseases/pathogens risk as a biological phenomenon, depending on many influential factors, is not quantifiable (!!!) and therefore everybody can get completely different results. There is not any prove of practical feasibility of the above mentioned OIE method, i.e. it is entirely unrealistic. However, it is able to confuse importing countries to import deficient commodities in favour of exporting countries. It is difficult to understand how this nonsense could be included in so important document for practical application in the whole world, without any critical scientific analysis and practical testing or proof. The authors obviously had decisive position (more important than professional medical ethics) at the OIE HQs when their absurdity was accepted and even published as an official global “standard”. It can be supposed that the authors originated from the major exporting countries having difficulty to guarantee full sanitary quality of exported animal commodities. This case has created serious doubts about fairness of the OIE decision policy.
10.17 The problem how to “facilitate export” without requiring to respect international fair trade principles and without implementing costly programmes for creating conditions to export and guarantee healthy animals and sanitary innocuous products without pathogens was concerning the major exporting countries. The solution was found: to replace necessary sanitary guarantee by theoretical “risk assessment” to be elaborated in convincing manner by importing countries. The major exporting countries managed to include this historical trickery into WTO and OIE documents. From the beginning of the nineties of the 20th century the OIE and the WTO started a campaign endeavouring to convince veterinary professionals that this was the only method for “facilitating trade”. There have been published many thousands of papers, many hundreds documents and organized incalculable number of training courses and seminars at global, regional, national and local levels to propagate this absurd theoretical subjective anti-sanitary method. The authors and trainers have been veterinarians from the major exporting countries trying to demonstrate using false and nonsense examples that the disease import risk is minimal. No one word and no any courses on how to “facilitate trade” through assuring export of healthy commodities and thus to avoid disease propagation. One would expect from intergovernmental organization, such as the OIE, to publish only the documents propagating the methods avoiding diseases spreading and the documents previously proved as practically feasible, useful to a l l member country governments, not contrary to f a i r international trade and not purely theoretical unrealistic procedures favouring to some privileged countries !
WHO/Merieux Foundation/OIE Seminar on Management and International Cooperation,
10.18 In spite of absolute failure of these methods based on the subjective theory and not on the objective reality, the OIE Code continues with this nonsense. Obviously the “weight” of the major exporting countries in the OIE is so great that the professional logic and medical ethics have no chance to be applied. This is other fact demonstrating unilateral policy of the OIE discriminating importing countries, mainly developing ones. The member country governments need methods proved in practice as feasible and effective and not wasting time and money for the theoretical fantasy.
Examples: The OIE published in its Revue scientific and technique, vol. 12,
No 4, 1993 an issue dedicated only to the disease risk analysis methods as the models
for the others. This compendium of 430 pages contained 16 papers, all written by the authors from
the major exporting countries (6 from USA, 3 from Canada, 3 from Australia, 2
from New Zealand, 1 from United Kingdom and 1 from Argentina) trying
theoretically to minimize the disease risk for importing countries (i.e.
facilitating the export without guarantee of full sanitary quality). All those purely theoretical methods have proved as
absolutely not feasible for practical use. In spite of this the OIE has
continued to publish new and new papers on the risk assessment with practical prove (evidence) always missing. The
publication was coordinated by Dr R.S. Morley from Canada who belonged among
the irresponsible “experts” imposing on the trade the absurd risk assessment
methods not suitable for fair international practice and on the OIE disease
occurrence information system its significant reduction having global catastrophic
consequences. In this issue was also a paper from S.C. MacDiarmid (
The above compendium issued in 1993 about the risk assessment demonstrates that the OIE was preparing the abuse of this method for the WTO/SPS and the “new” OIE Code well in advance ! The OIE must knew very well about the catastrophic consequences for the importing countries’ health of both documents in preparation!
The latest publication of theoretical
fantasy and in general practice no feasible methods for member country
governments are two volumes entitled “Handbook of Import Risk Analysis for Animals
and Animal Products”, OIE, 2004 of
57 and 126 pages. Again the
authors are from the major exporting countries, this time under the leadership
Practical risk analysis is extremely complex process considering mainly non-quantifiable multi-etiological biological phenomena influenced by many factors what the OIE Handbook did not take into account at all. More information see in http://vaclavkouba.byl.cz/riskassessment.htm.
10.19 The above mentioned OIE Handbook documents convincingly that the WTO/SPS and “updated” OIE Code were introduced with the only aim – to facilitate legal export to the detriment of animal and human health in importing countries. The “new” risk assessment policy is de facto a camouflage for facilitating export of non-healthy animals and products without full sanitary quality. This historical “exception”, unthinkable in any other commodity, has nothing to do with the fair trade. The problematic risk assessment is abused to disarm importing countries by imposing restricted protection against disease introduction. This has indirectly contributed to incalculable millions of animals and humans newly affected by imported pathogens, following the OIE Code provisions, mainly in almost defenceless developing countries (international help !?). The Handbook seems to be one of the most dangerous insidious trickery facilitating global man-made spreading of animal diseases. I wonder why the OIE produced this highly theoretical document having nothing to do with its main duty to assist member country governments in animal health protection (or this is not more valid ?). Conscious support of disease spreading represents flagrant betrayal of Hippocratic oath of medical ethics based on restoring and protecting health and very seriously damages veterinary medicine prestige in the world.
The publication could be perhaps useful only for theoretical discussions among “veterinary paper-epidemiologists” and for those journals or conferences where everybody can present what he wants without any scientific, feasibility and usefulness proofs and without any responsibility for the consequences.
10.20 Instead of the application of fair trade principles based on full quality, in our case of full sanitary quality, the OIE continues supporting WTO/SPS anti-sanitary policy. The OIE started, instead to strengthen disease control and eradication in the world to “facilitate trade”, a “risk assessment mania” at all levels and branches of veterinary medicine. Many countries even established special units for disease risk assessment in central veterinary administration. Their theoretical paper work has not given desirable results, i.e. to avoid disease import. The irony is that the leading countries pushing forward the WTO/SPS and OIE risk assessment methods are not able themselves to assess correctly the risk and import some infectious diseases.
Example: According to official reports published by the OIE: in 2003 the USA, in spite of having “risk assessment unit”, introduced the BSE from Canada through legal import using OIE international veterinary certificates (up to 2007 there were reported nine BSE cases in the Canada and two in the USA); New Zealand imported infectious equine anaemia, haemorrhagic virosis of rabbits and varroosis in spite of having the “most advanced risk assessment” methods and globally leading “risk assessment specialists”.
10.21 The consequences of the “new” import risk analysis concept has contributed to serious
deviation of veterinary services structure, organizations, education, training and research in the world from disease control and eradication programmes to theoretical consideration of secondary problems. It is easier to model “scientifically” unrealistic situation than to implement demanding animal health programmes to can export healthy animals and products and not the diseases/pathogens. For exporting countries it is much easier to apply “doing nothing” policy relying on risk assessment swindle including in the OIE Code changing completely its previous useful concept.
Deterrent example see in http://vaclavkouba.byl.cz/orgglobalization.htm. in the paragraph 2.10.
10.22 The simplest requirement for importing healthy animals and products doesn’t need any “scientific justification”. On the contrary, the exporting countries, where the hazards exist, must guarantee the export to be innocuous for importing countries and document in transparent form the real sanitary status, i.e. the truth. For the first time in the history the paying importing countries “officially” has not the right to decide freely about the purchase and to ask for full quality commodities. These countries, thanks to abused risk assessment, must pay also non-pathogen-free commodities (animals and their products) ashealthy ones !
10.23 The Code risk assessment method, absolutely not suitable for importing country government trade decisions (therefore it must be eliminated from the Code that is addressed to member country governments), could be perhaps eventually partly used when considering some new import conditions for a particular disease to be published in the Code.
10.24 Disease risk analysis is an old current method to provide an orientation (not quantifiable certainty) for the decision-making on health protection and disease control. In general, the importing countries ask first of all for 100 % quality, i.e. the certainty = zero risk. This is valid also for the import of animals and food of animal origin.
10.25 The basis for the current normal import risk analysis is the knowledge of specific diseases characteristics (taught at all veterinary faculties and generally available in particular textbooks as well as in Internet) and the availability of necessary data on epizootiological situation and measures in exporting countries. Unfortunately, this was obviously deliberately omitted in the Code. Many exporting countries, according to OIE World Animal Health yearbooks, do not know their real sanitary situation. This was obviously the reason why the OIE has significantly reduced regular information system on notifiable disease occurrence to confuse importing countries. The disease import risk arises only when the situation in exporting country is not satisfactory and/or not under public veterinary service effective control and when diseases/pathogens-free export is not guaranteed and properly documented.
10.26 The original principle of the OIE Code before WTO/SPS was always to define the conditions for zero risk imports. The risk assessment, which was currently used in the past by importing countries as their internal problem, cannot be an integral component of international norms that must be concise and transparent identifying the best possible sanitary quality of the importing commodities !
10.27 The OIE Code must replace the theoretical assessment of the disease import risk section by a section of the methods for effectively avoiding disease export, i.e. avoiding disease spreading through international trade which is the main task of this international organization (or it was forgotten what this organization had been established for ?). The priority must be given instead of supporting the major exporting countries to the protection of importing countries against the introduction of the pathogens through legal trade. This means to stop serving as subordinate organization to WTO anti-sanitary policy conducing to the globalization of animal diseases. The OIE as an intergovernmental organization has the same legislation level. Unfortunately, its behaviour is not exploiting this favourable international position to the detriment of global animal health and veterinary medicine;
10.28 In the United Nations, including United Nations Development Programme (UNDP), FAO, WHO etc., all new project proposals for their clearance have always contained a part called “Risk” as an obligatory component:
“It is possible for a project in which the major elements are properly defined which has been carefully implemented nevertheless to fail. This is because no project operates in a vacuum but rather in an oftentimes difficult development environment in which risks arise which may seriously delay or prevent the achievement of the project’s outputs and objectives. It is important that these risks are to be explicitly addressed, in the first instance at the project formulation stage, and secondly during the project implementation.”
10.29 This basic principle being used when preparing any international programme was deliberately bypassed by the WTO and the OIE due to the fear that informing the governments about the true consequences on animal and human health would avoid clearance of the WTO/SPS and the “new” OIE Code. Up to now the WTO and OIE have not presented to member country governments any assessment of the SPS and Code risk for disease spreading and any analysis of their consequences ! The trick with deliberate concealing the truth has continued obviously thanks to export business lobby in both organizations.
Every normal institution, organization, professional, craftsman, medical doctor, farmer, factory worker, bricklayer, etc. evaluate their work’s results and practical impacts. The only international intergovernmental organization not being interested in the practical impact of its provisions and activities, i.e. not carrying any analyses of them, is the OIE, in spite of having “scientific” department (any applied science requires objective analyses).
10.30 Other provision, following the WTO/SPS, against importing country health protection is related to “hazard identification”. “..it is.. necessary to identify whether each potential hazard is already present in the importing country, and whether it is notifiable disease or is subject to control or eradication in that country and to ensure that import measures are not more trade restrictive than those applied within the country.”*) Long-term experience shows that the imported animals and their products represent an unknown sanitary phenomenon and risk, in spite of the OIE international certificate informing only on a few selected diseases test results without any real guarantee of the health quality. Therefore, the importing country must apply much more restrictive import measures than those applied within the country with known local epizootiological situation and conditions. The sanitary situation in the majority of exporting countries is not sufficiently known, as it is documented in the post-SPS OIE World Animal Health yearbooks providing on all internationally notifiable diseases, with some exceptions, minimum or zero information. This provision again confirms the OIE “policy” unilaterally favourable only to exporting countries regardless of the health protection in importing countries = deliberately organized diseases/pathogens spreading.
*) Note: The text reminds the statement of Dr MacDiarmid, actual Secretary General, OIE Commission for the Terrestrial Animal Health Code who wrote in the document “The Importation into New Zealand of Meat an Meat Products: A Review of the Risk to Animal Health”. Ministry of Agriculture and Fisheries New Zealand, 1992, page 21: “It is not reasonable to demand that an imported product meet more stringent zoo-sanitary standard than a locally-produced product.”
10.31 There is only one quantifiable risk, i.e. of false negative results of indirect, i.e. non-pathogen investigations of animal diseases. Unfortunately, these risk assessment data, indispensable for objective decisions on the import conditions, are missing in the OIE Code in spite of widely propagated OIE tricky risk assessment mania based on non-quantifiable data to “facilitate the export”. The current risk assessment of potential negative consequences, as it is normal in any international project and binding document, is missing in all OIE documents and thus demonstrating that the “procedure” in the Code is a dirty trickery targeted only at significantly reducing up to avoiding importing countries’ sanitary protection.
10.32 In the section of “Risk analysis” is a new chapter “Zoning and compartmentalisation” unknown in all pre-WTO/SPS OIE Codes similar as the whole section on risk analysis. This chapter is obviously the “work” of the irresponsible paper-bureaucrats overloading the Code by unnecessary details trying to minimize artificially the territories (animal population size) representing the threat for the exporting animals and their products and thus to “facilitate the export of risky commodities”. The authors obviously live in the air (closed in the offices) not having good idea about practical field reality or are sold to the animal commodity export business. Again, this chapter serves to complicate even more the life of importing country decision makers to be unable to orientate in the incredible jungle of the OIE Code provisions requiring enormous paper work and office exercises absolutely unknown in any other commodity !!!.
Again, this over-complex text serves to conceal the fact that the whole OIE Code is avoiding any provisions for the simple guarantee of pathogen-free commodities !
Behind the new theoretical complication is obviously S.C. MacDiarmid, Secretary General, OIE Code Commission, founder of the “abused risk assessment method” mania. According to the OIE publications the authors of so called “compartmentalization” are also again other known theoreticians defending WTO/SPS without any analyses and prove (e.g. C. Zepeda), defending the theory of free circulation of animal commodities (e.g. V. Caporale), applying nonsense mathematical models for the risk assessment (e.g. A. Giovannini and J.Kellar), etc. See their paper entitled “The concept of compartmentalization” published in Rev. sci. tech. Off. Int. Epiz. 2006, 26 (3), 873-879.
According to the OIE World Animal Health yearbooks, the majority of the major exporting countries (as well as of the OIE Code authors’ home countries) have officially no information on almost all internationally reportable diseases existing in these countries! What do they know on these diseases’ situation ? Minimum or zero. This is the reason why the OIE Code reduces the areas of animal commodity origin to a minimum = artificially increasing risk of pathogen export from affected territories !
Every case is different in place and time and therefore, it must be solved individually according to epizootiological situation, biological character of the etiological agents, disease development and conditions and first of all according to the requirements of the paying importing country. Let the importing and exporting countries to find the solution themselves !
The Code is changing also the terminology: in the previous issues it was used the term “regionalization”, now only “zoning”- “having the same meaning”.
10.33 Instead to simplify the Code provisions, the OIE has been continuously more and more complicating the sanitary problems related with the animal trade “in the interest of facilitating trade” !? The Code is getting more and more a form of mechanical inflexible stereotype absolutely not applicable on the commodities of dynamic and flexible biological character - potential carriers of dangerous pathogens.
10.34 The international trade in animals and animal products is a very practical, concrete, objective and quantifiable material reality with palpable impacts while the OIE Code is based on absurd abstract theoretical subjective and non-quantifiable approach deliberately imposed by so called “scientists – experts for risk assessment” having not any responsibility for global health and being in service of major exporting countries. The trade, and in particular when having impact on animal and human health and life, cannot be based on theory and subjective approach.
The incalculable number of the articles dealing with the disease risk assessment have documented that different authors have different opinion, methods and results. They can experiment at home as they wish, however they have not any professional and moral right to experiment with the health and life of human and animal populations in the whole world! This is valid also for the OIE Code! International animal trade cannot be depended on very doubtful, non-transparent and non-defendable procedures.
The OIE risk assessment method represents a predictive model. All these models as tactical decision support tools are limited by the innate unpredictability of disease spread. The model constitutes a theory, and a predictive model is therefore only a theoretical projection. It is not necessary to be mathematically literate to appreciate that no model will produce the right output when fed by the wrong input.
10.35 All the above mentioned “risk assessment” experts, together with the both DG of the OIE, its HQs staff and the members of the OIE Code Commission, share, consciously or non-consciously, historical professional and moral responsibility for catastrophic sanitary irreparable global consequences of the OIE Code application spreading massively animal diseases and pathogens. The mentioned “professionals” forgot (deliberately?) that the trade in animals and their products, in comparison with all other goods’ trade, influences directly the health and lives of global animal and human populations of more than one generation!
10.36 OIE Handbook on Import Risk Analysis for Animals and Animal Products, OIE, 2004, page 20 is even threatening importing countries that “zero risk importation policy would require the total exclusion of all imports” (!?).”. In other words, the country requiring healthy animals and pathogen-free animal products, to protect animal and human health, should be punished and eliminated from import of animals and their products ! The incredible threat represents a top impudence of irresponsible authors (headed by Dr Noel Murray and Dr MacDiarmid from New Zealand) trying to defend for any cost the relatively easy exports at the expense of health in importing countries being supported by OIE Code anti-sanitary policy. However, biological aspects and protection of animal and human health in importing countries would require the opposite, i.e. “zero risk importation policy would require the total exclusion of all animal exports from those countries that are not able to guarantee pathogen-free commodities”. The quoted perverse statement in the above mentioned OIE Handbook is unimaginable in any other trade commodities where the basic fair policy is to apply full quality (100 %) standard and to exclude from export those who are not able to guarantee required quality of the goods !
10.37 In the same OIE Handbook on Import Risk Analysis for Animals and
Animal Products can be found on page 2 in the part entitled “
10.38 The top irony (= top hypocrisy) is that the OIE itself has never presented to member country governments any risk analysis of its Code and of other published provisions and methods ! What about non-existing OIE policy analyses of its real consequences conducing to the worsening of global animal population health ?
11. Evaluation of Veterinary Services
11.1 In the chapter 1.3.3 Evaluation of veterinary services are missing the decisive management components such as government legislation, ministerial and CVO instructions and detailed mechanism (methodology and implementation) for consistent and uncompromising control/inspection mechanism (including penalty system) of the whole chain of animal commodities to be exported, beginning at the farm level. Without reliable government control cannot be avoided the corruption when investigating and certificate issuing private “accredited” veterinarians. The uncontrollable cheating and investigation results falsification can be carrying out at the whole food chain – “from stable to table”, i.e. at field investigation of animals and herds, during postmortem inspection, laboratory investigations (easy deliberate exchange of the samples), falsification of the result interpretations, issuing false certificate, etc. Without effective very strict systematic control/inspection of the government authorities any regulative provisions will be left only on the paper = a confusing theory.
The majority of the text is not related to the trade and should be published separately, e.g. in the OIE Bulletin and thus to reduce extremely wordy Code size.
11.2 Almost all the provisions and criteria (several hundreds on 22 A4 pages!) of this chapter belong to an other document than to international trade commodity “standard”. This chapter prepared obviously by globally irresponsible “armchair veterinary bureaucrats” of major exporting countries having no idea about practical reality and needs trying to cloud completely the most important aspect, i.e. the guarantee of exporting animal commodity sanitary innocuousness. The chapter is giving the same importance to exporting as well as to importing countries. The anti-epizootic international problems are in exporting countries ! Everybody knows that for the evaluation of exporting country veterinary services by importing country are missing reliable data. Why exporting countries should evaluate veterinary services of importing countries ? This incredible nonsense unknown in any other international trade document can be found only in the anti-sanitary OIE Code.
Note: The OIE has never elaborated any veterinary service standards such as minimum number of government veterinarians for the most important anti-epizootic activities, minimum time needed for anti-epizootic actions, food hygiene inspection, national and international trade control, minimum capacities for diagnostic laboratory, minimum knowledge and skills for the accreditation of private veterinarians, etc. To list simply different criteria is easy (and not helpful) than to recommend member country governments corresponding veterinary services’ norms (for different conditions) having influence also on financing and strengthening these services.
11.3 In theoretical methodology (nothing to do with practical life) are missing the most important criteria for international trade such as: ratios of public service veterinarians to the size of animal population and production and to the size of the export of animals and animal products, i. e. how far public service is able to control them and to guarantee full health quality of exporting commodities; the size and results of national disease surveys, diagnostic method used, results in controlling and eradicating diseases; the size of the investigations of animals, herds, products and territory for confirming specific diseases free status. Omitting these key criteria is favourable only to those exporting countries having difficulty with the above mentioned problems. Importing countries are interested to get sufficient information to be able to asses the reliability of veterinary attests guaranteeing the sanitary quality !
11.4 Among the priority belong: the legislation including diseases obligatory notifiable 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 a l l cases of trade important diseases, system of analysis for confirmation disease free animals, herds and territories as the basis for issuing veterinary guarantee attests; who is issuing these attests (in case of non-government veterinarians must be known their number, selection criteria, qualification - accreditation training and examinations); pre-export measures, reclamation system, etc. Supervision system of public service for inspecting (controlling) private sector is of priority importance, but obviously not for the OIE and its Code.
11.5 The chapter, overloaded by details having nothing to do with international trade, reflects the Code concept to avoid any duty of exporting countries to guarantee full sanitary quality of animals and their products. One cannot find one word on the most important criteria for international trade such as national disease real occurrence knowledge, control/eradication results, active surveys, average size of animal populations and trade per one public service veterinarian, etc. in the exporting countries.
11.6 Not respecting the extraordinary difference of dependency on producers and exporters, the Code deliberately doesn’t distinguish between government service and difficult to control private service. The reason is that the major exporting countries have often very weak government services unable to control effectively disease situation, to investigate exporting commodities and to issue international veterinary attests themselves. Following World Bank and International Monetary Fund policies, the Code has been degrading deliberately the role of government services, in spite of being the only organization initiating and organizing nation-wide animal disease control, eradication and surveillance. It is obvious that the private service is unable to organize any disease control/eradication programmes at territorial (national) level. Therefore, even the major exporting countries after the WTO/SPS stopped control and eradication programmes due to lack of necessary veterinary professional full-time staff and of money. The cheapest is doing nothing and exporting.
Deterrent example see in http://vaclavkouba.byl.cz/orgglobalization.htm in the paragraph 2.10.
11.7 Private veterinary service has completely different interests and approach requiring first of all enough disease cases to have work and income and not preferring reduction of these cases due to preventive, control and eradication territorial programmes. It is difficult to believe that the international attest issuing local private veterinarian is fully independent on local producers and exporters who provide him continuous chance (e.g. disease cases) for current income. Under these circumstances, there is always the chance for the corruption. The both services have mutually opposite approach, very often in conflict (due to natural conflict of interests), due to private service (supported by strong private veterinarians associations and trade/export organizations) not willing to be subordinated to strict supervision by usually weak government veterinary service. The OIE and the OIE Code consciously do not differentiate these two services camouflaging the reality that the exporting country governments are unable to guarantee full sanitary quality and that the international trade in animal commodities is practically in the hands of unreliable private sector being easily corrupt.
In August/September 2006 in
Germany (known as one of the countries with the best discipline in the world and
its OIE delegate is even the Vice-President of the OIE Code Commission) there were
discovered cases of spoiled meat (some was even four years old!) distributed
and consumed inside the country and exported
in nine European countries ! Only in the
11.8 In 1991 the FAO published „Guidelines for strengthening animal health services in developing countries“, translated it in French and Spanish, elaborated by the best experienced Chief Veterinary Officers of all continents giving priority to public veterinary services. However, the OIE “new” policy has been dedicating much more attention to strengthening private service (supported also by World Bank, International Monetary Fund, World Veterinary Association, banks, pharmaceutical industry, rich sponsors, etc.) in spite of not having any territorial anti-epizootic responsibility, instead to public veterinary services (depending only on government very limited budget). Only these services are professionally responsible for the protection of national animal population health, for sanitary aspects of national and international trade and for initiating, organizing, coordinating and implementing anti-epizootic control/eradication programmes at all managerial levels. The public veterinary services have for all anti-epizootic activities decisive role as their professional “motor”.
11.9 Significantly reduced public institutions, not only in developing countries, are not able to monitor and effectively control disease situation, supervise trade and private veterinary service as well as to resist risky disease import. The importing countries defence weakness is favourable to the major exporting developed countries unilaterally supported by WTO/SPS and OIE Code giving priority to “facilitate the export” instead to the protection of the health in importing countries.
Note: The weakness of public veterinary services in many developing countries has been deepened due to brain draining of some of the best veterinary specialists being offered much better living and working conditions in the rich countries.
11.10 The OIE did not present to member country governments any risk analysis and warnings to avoid dismantling of public veterinary institutions having the key irreplaceable role in any anti-epizootic activity (main task of the OIE) including the trade control. The OIE supported instead of protesting when the World Bank was imposing unscrupulously on not only developing countries to minimize up to dismantle government support and budget for public veterinary institutions, anti-epizootic programmes and sanitary trade control. Now, when is too late for revitalization of destroyed government services, the OIE and the World Bank, calling hypocritically for strengthening of veterinary service (!?), are the best “friends” (?) to the detriment of global animal health.
11.11 The OIE Code is not requiring full sanitary quality admitting export of diseases and pathogens what is reflected in minimal OIE interest in national control/eradication programmes and in strengthening government veterinary services “complicating the life” of profiting countries and their exporters.
11.12 There is not any other intergovernmental organization requiring extraordinary detailed (ad absurdum) evaluation of national services. This chapter belonged among the OIE Code provisions cheating importing countries making much more difficult (or avoiding at all) their correct decisions on the animal commodities import to protect animal and human health. The only purpose of this chapter is again to facilitate export of diseases/pathogens of animal origin.
11.13 Instead of simplify the paperwork and concentrate the attention at diseases/pathogens export, the OIE requires “mountains” of papers not only in this chapter about veterinary services but also in the provisions related to risk assessment nonsense methodology requiring incredibly enormous data not available even in the authors’ countries (the OIE World Animal Health documents that these countries do not know even the national situation in internationally reportable diseases – the most important data for international trade!), employment of grand number of public service veterinarians (missing in the field), months of work and a lot of money. The final result will be a big book of descriptive character only (not indicating problems’ solutions) for being shelved, i.e. wasting time and money.
11.14 The real intention of the OIE veterinary services evaluation
provisions was discovered on OIE websites: Press Release – 17-Mai-2006: “A second course is due to be held at the
OIE from 10 to
Examples: Millions of
animals lost due to foot-and-mouth diseases and many thousands of cattle lost
due to the BSE in the UK, millions of pigs lost due to hog cholera in the
Netherlands and Germany, inability of the West European countries to eradicate
African swine fever in Italy from 1978 (increasing pork export in spite of this),
export of FMD virus from the UK to France, from France to Netherlands, export
of paratuberculosis and dermatomycosis from France and Denmark, minimal
knowledge of real epizootiological situation in USA, New Zealand, Canada,
The author, according to his experience with the OIE “new” policy, has not any doubt that the veterinary service evaluation will be done in others than in “developed” countries having decisive role in the globalization of animal diseases and the evaluators will be mainly from the major exporting countries being themselves unable to cope effectively with the international tasks related to the export. The major exporting countries together with the OIE HQs staff create unjustified and artificial atmosphere of their superiority including their “first class” veterinary services (on paper and not in anti-epizootic results and trade sanitary practice what can be richly documented.) giving lessons (in spite of their bad experience and results) to the other countries of “second class” and “third class” veterinary services. The tragedy is that so called “developed countries” have taught many thousands of fellows from other countries (often using international funds, including UN funds) so called “veterinary epidemiology” based on paper, computer and armchair “epidemiology” isolated from practical solutions of animal population health and disease. The graduates know how to use the computers and calculate the data but are not prepared to investigate, analyze and solve difficult practical field problems at animal population levels in their home countries. Among this type of “education” belong also the OIE postgraduate training courses on risk assessment oriented how to facilitate export of non-healthy animals and non-pathogens-free animal products instead how to avoid diseases/pathogens spreading through trade (preparation of healthy animals and pathogen-free animal products for export, avoiding or minimize risky export, maximize local production to reduce risky import, strict etiological and epizootiological control of all imported animals and animal products, etc.).
Note: In the above OIE Press Release there is following text: “This action fails within the scope of the OIE’s objective relating to the worldwide improvement of governance so as to achieve better animal health”. However, the OIE real policy expressed in the OIE Code is exactly opposite when officially supporting globalization of almost all animal communicable diseases ! This is similar monstrous hypocrisy as in WTO/SPS "Desiring to improve the human health, animal health .. in all Members;" and in the whole document is no one word about the improvement of the health; in contrast with this statement it is concerned only how to "facilitate trade" at the expense of human and animal health !
There is a mode
(fashion) supported by the OIE and FAO to commend veterinary services in
Western countries and slander Central and East European veterinary services.
E.g. in the Report on TCP/RER/0066 Project –
Emergency Control of Transboundary of Livestock in Southern and Eastern Europe
(Ledi Pite, Consultant) are following sentences: “.. lack for appropriate surveillance and control strategies for the
major livestock diseases”, “There is disease passive surveillance”. “..
countries did not have a computerised database for animal health data
management.” “.. lack of adequate
veterinary service infrastructure and animal health information system” , “There are not scientifically based
surveys”..etc.. The full functioning public veterinary services of these
countries were destroyed during the nineties following WB and EU policy of
maximal reduction of government role being assisted by the OIE (the major
destruction was organized in Bulgaria by Dr Nikola Belev, Chief Veterinary
Officer being also long term President, OIE Commission for Europe and OIE HQs
Consultant for European region; he is continuously slandering East European countries
to please to his employer and today to West European countries) and by the FAO
HQs. However, the above mentioned countries even today, if we considered the
anti-epizootic programmes’ results, are not behind Western European countries (being given
always as the “examples” for the others in spite of epizootic disasters,
11. 15 This section is falsely presented as the OIE “standard”, however having nothing to do with real international “standards” identifying minimal requirements on the quality. In our case “the standard of veterinary services” should contain the norms for staffing, facilities, material, financial, transport and other necessary conditions for effective activities of government veterinary services. The priority in the OIE Code should be given to the activities related to international trade ! Minimal requirements on the animal health/disease activities should help Chief Veterinary Officers to convince decision-making government authorities to provide necessary funds and other support to achieve the desirable level of government service capacity to cope with all their duties. Above listed criteria (requiring a “mount” of paper) for so called “evaluation” are not helpful at all.
11.16 The OIE is not publishing the reports of the evaluation missions (in spite of publishing many thousands of pages) to provide information on the evaluated country problems, successes and failures, obviously not to offend any country. In this context they can be used as the examples the reports of the European Union missions evaluating animal health situation in selected countries. The most interesting are the reports from the most important animal commodity exporting countries dominating the OIE and the OIE Code Commission.
From the Final Report of the latest
12. Surveillance and monitoring of animal health
12.1 The chapter 1.3.5 Surveillance and monitoring of animal health is theoretically correct, however, it does not represent commodity quality trade standard and it should belong to a separate information manual or OIE Bulletin. Again the implementation of the methodology in practice of exporting countries is very problematic. Above mentioned examples demonstrate the big gaps in disease occurrence knowledge even in the countries with the major animal export. These facts demonstrate that the OIE methodology is not feasible at national level due to absence of necessary data even in the countries of the authors of the Code text. In the practice there were discrepancies between declaring disease free status and particular surveillance.
Example: 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 text: "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."(!!)
12.2 Particularly this section reconfirms once more that the OIE has become from neutral to an organization favouring unilaterally to major exporting countries. A question arises to whom the OIE serves – cui prodest ? The OIE as formerly independent inter-governmental organization outside of the United Nations was converted de facto into a filial (with exaggerated initiatives) of the WTO servicing to the exporting country business and not to consequent protection of animal health in the world (i.e. not to OIE original basic duty) and particularly in importing countries. The OIE is not behaving as an inter-governmental organization for animal health protection.
OIE behaviour reminds a voluntary international association or society or club, in this case of the Chief Veterinary Officers, having no any global responsibility for the consequences of their absurd anti-sanitary activities (based on subjective theory of so called “risk assessment scientists” isolated from the reality) and being dominated by the most influential members (reminding a mafia brotherhood) defending their egoist interests at the expense of the others. They can use any name and deal with any problems without any regard to
governments, farmers and consumers needs and opinion.
12.3 The Code doesn’t respect generally known fact that intravital and post-mortal visual detection of the majority of chronic communicable diseases is usually close to zero. Therefore, the majority of OIE reported data on animal health/disease situation in exporting countries are absolutely not reliable, i.e. not reflecting the whole truth = big intentional lie ! If we summarize globally all numeric data in OIE World Animal Health yearbook on disease occurrence and on lost animals then it looks that communicable diseases of animals are without any international importance in comparison with the global size of animal populations = far less than one per mil! The OIE reduced “information system” is killing population veterinary medicine loosing support for anti-epizootic programmes at national and international levels. Why to organize costly control/eradication programmes against diseases having, according to the OIE “scientific statistics”, minimal or zero economic importance ? The OIE has never analysed global economic consequences of animal diseases to “arm” national veterinary services by necessary arguments supporting their animal health preventive and control programmes.
Examples: The author, as that time the Editor-in-Chief, included in the FAO/WHO/OIE Animal Health Yearbook 1980 questionnaire indicators the data on death losses among main domestic animals. In selected representative countries there were reported following data on natural mortality: in cattle – 5,26 %, in pigs – 20.83 %, in sheep – 8.54 % and in goats – 9.45 %. Applying these percentages on the global populations then it was estimated following data on naturally dead animals: 64 million cattle, 128 million pigs, 100 million sheep and 43 million goats !
12.4 The OIE has minimized regular data on disease occurrence (it has abolished the majority of the indicators) to “facilitate trade” (!?). How can importing countries assess the risk of diseases/pathogens introduction ? The data published in the OIE World Animal Health yearbook on disease occurrence such as “+” and “… - no information available” are able to provide any literate person without university education. Previous FAO/WHO/OIE information system, abolished by the OIE, required to assess disease situation applying epizootiological criteria such as “suspected but not confirmed”, “exceptional occurrence”, “low sporadic occurrence”, “enzootic”, “high occurrence”, “ubiquitous”, “recognized in country for the first time”, “only in imported animals (quarantine)” etc. Numbers of ad hoc reported cases are seriously confusing importing country decision. No country knows exactly continuously changing number of diseased animals. The OIE system even doesn’t not distinguish data at a given moment and during a given period what is a gross error inadmissible in any epizootiological or epidemiological science and practice !
12.5 If we study carefully incredible anti-sanitary statements of the most influential OIE “officers” about the “no need” for information on animal disease occurrence then we can understand better the anti-sanitary OIE policy minimizing up to avoiding informative value of the OIE “information system” (better call it “non-information system”) for importing countries decision about veterinary conditions and confuse/blind them as much as possible.
-"If, for a particular trade, we have
available risk reducing tools (tests, treatment, whatever) … what does it matter what
starting risk was ?" (!?) - MacDiarmid (
- "The need to remove technical obstacles to
the free circulation of animals and their products"; "It is not longer
possible to apply the old system under which animals and animal products had to
come from specific free zones, and were subjected to isolation, quarantine,
inspection and diagnostic testing before and after export." (!?) -V. Caporale (
too much emphasis has been placed on how a country or zone can reach ‘disease
free’ status and then base the safety of its trade on such freedom”. “The OIE
is taking a new approach to setting standards and revising existing ones: the
categorization of a country/zone status is first based on the assessment of the
overall level of risk present in the country/zone or animal population, rather than on whether a disease has been reported
(!?) - A. Thiermann (
These statements reflect as an absolute underestimation (or the most probably deliberate arrangement to trickily “facilitate trade” following the OIE Code concept) of the importance of disease free status and of disease reporting for international trade ! In other words: “what does it matter what animal disease occurrence in exporting country is” ?
Then what is the reason for having the OIE non-informative “information system” on disease occurrence in exporting countries when the OIE Code has other priority criteria: “facilitating” (supporting) disease spreadings ? Then what is the reason for keeping the OIE as an intergovernmental organization supporting criminal globalization of communicable diseases of animals ?
The main reason of “no need” for international information on real occurrence of animal diseases is obviously the fact that the exporting countries do not know this reality !
Examples:“It is assumed, that for every
case of salmonellosis recorded in humans in the
12.6 The official OIE duty number one is to collect, collate and disseminate information on animal health/diseases situation in the world ! The intention of the OIE to minimize information on disease real situation in major exporting countries has been reflected also in the fact that DG OIE abolished OIE Expert Commission for Animal Health Informatics. The OIE concern is only how to improve the form, i.e. to apply new modern software, what is desirable. One would expect when applying the new technology to get more and more useful data on disease situation than before. The OIE managed to reduce the data and their informative value close to zero ! The member countries need to get professional information on disease situation regardless of data processing method (before, the countries got more and better regular information in spite of manual data processing).
All comments and justified suggestions how to improve international information system submitted by the author (based on personal experience as former Chief, Animal Health Service, FAO-UN, Editor-in-Chief, FAO/WHO/OIE Animal Health Yearbook and former national epizootiologist) to DGs OIE have not been considered at all.
12.7 Thanks to the reduction of disease occurrence information system, benevolence of the OIE Code, weak public services unable to control epizootiological situation, private veterinarians and trade, unable to apply effective surveillance and monitoring, the illegal trade (export/import) in non-healthy animals and non-pathogen-free animal products has favourable conditions facilitating diseases/pathogens international spreading.
More information in http://vaclavkouba.byl.cz/globsurveillance.htm.
13. Guidelines for reaching a judgement of equivalence of sanitary measures
13.1 Other unnecessary theoretical non-sense provisions requiring immense paperwork are represented by the “Code guidelines for reaching a judgement of equivalence of sanitary measures” not respecting the absolute lack of reliable data on true animal population health situation and on anti-epizootic measures in the countries. The OIE Code doesn’t respect at all that there are not two countries with the same animal health situation, with the same multi-diseases structure, occurrence, immunity and stage of development under the same conditions, that there are not two disease strains with the same characteristics, that the diseases represent a dynamic phenomenon in permanent change in time and place, etc. requiring different sanitary measures. These facts are not considered in the OIE Code based on pure bureaucratic approach not respecting at all scientific principles, biology, ecology and normal logic.
13.2 The sanitary measures are internal problems of any country. The non-quantifiable comparison (“artificial exercise”) of these measures is without any importance for fair trade requiring full sanitary quality of exporting commodities ! In no any other standard for international trade is included similar non-sense of “equivalence” as it is in the OIE Code.
13.3 The OIE Code doesn’t respect biological characteristics of animal diseases/pathogens. It doesn’t respect different types, subtypes of etiological agent strains, their resistance, ability to reproduce, spread and increase their pathogenicity through passages, it doesn’t distinguish between virulent, avirulent and conditionally pathogen strains, it doesn’t consider the risk of agents’ mutation, it doesn’t consider that the trade sanitary problems and measures are multi-etiological, etc. It doesn’t consider that the majority of communicable diseases are difficult to discover due to prevailing subclinical course.
13.4 This extremely wordy chapter represents other example how to replace the decisive information for international trade in animals and animal trade such as diseases’ occurrence in exporting countries by other non-sense “scientific” methodology to complicate even more disease introduction risk assessment for the importing countries. Obviously all provisions of the Code organizing man-made diseases/pathogens export have not been yet sufficient for the exporting countries and their profit to the detriment of the health in importing countries. It is absolutely unimaginable in all other commodities to require importing countries for something similar. International fair trade requires the guarantee for commodity quality and the other criteria such as measures are not decisive.
13.5 This trickery chapter represents a blatant discrimination of the importing countries. Instead to deal with equivalence of animal population health situation between importing and exporting countries, what is normal procedure when deciding on the import, the chapter deal only with sanitary measures - absolutely not the primary problem. One of the reason of this chapter inclusion, similarly as of the other chapters, is the fact that the major exporting countries do no know the animal health situation in their home countries ! Therefore, they try systematically, beginning by WTO/SPS, to deviate the attention from this reality using different dirty tricks to mislead importing countries. Unfortunately, the OIE is dominated by globally irresponsible bureaucratic officers servicing to the business instead to the health.
13.6 How can be assessed the equivalence of animal health situation and measures when the exporting countries report that the situation is unknown (“…” no information available) or exceptionally report simple occurrence (+) with minimal numeric data reported ad hoc ?. The OIE occurrence symbol “+” is absolutely without necessary information value: it can mean one exceptional imported case or millions of cases of specific disease panzootic (this kind of “report” can be done by persons having only basic education and can be repeated continuously every year till the very distant eradication, if any). The OIE, obviously to “facilitate trade” due to minimizing information on exporting countries situation, abolished the majority of very useful data for importing country decision-making.
14. Recommendations applicable to specific diseases
14.1 In the Part 2 “Recommendations applicable to specific diseases” are the texts of import conditions related to particular disease species (not distinguishing the types and abnormal strains of etiological agents). Below are comments on only very few of them due to contribution size limit.
14.2 In the OIE Code 2001 there were 81 diseases of the Lists of A and B. Diseases of the List C were missing at all (e.g. listeriosis, toxoplasmosis, intestinal Salmonella infections, filariasis, etc.). Only in a half of the diseases was the formulation “For the purpose of the Code, the incubation period for …… shall be … days.” This information is extraordinary important and it could be understood as guarantee period what, unfortunately, is not the case in the Code. This fact confirmed that there are great discrepancies also as far as formal trade aspects are concerned. In some diseases there are many details (particularly in those which could complicate the export due to difficulty to guarantee specific health status such as BSE) and in the other diseases there are minimum or almost zero requirement facilitating their “export”.
14.3 Chapter 2.1.12 African swine fever. This disease can serve as an example of double standard in the understanding of OIE Code import conditions and of developing country discrimination:
When in 1978
Other example of double standard: The author after
presenting his paper “Importancia de la
epizootiología en la economía de la sanidad animal” at a conference organized
by the Asociacion Espanola de Economia y
14.4 Chapter 22.214.171.124 Anthrax: The import conditions are absolutely insufficient when not requiring the zone of the origin of animals and products to be anthrax free during determined period. The text asks only that exported animals or products as well as the establishment of their origin to be free without any specification of these conditions. The Code conditions do not guarantee at all that the animals and the animal products are free of anthrax pathogens !
The Code only requires “the presentation of an international veterinary certificate attesting that the animals: showed no clinical sign of anthrax on the day of shipment; were kept for the 20 days prior to shipment in an establishment where no case of anthrax was officially declared during that period;” What about the suspect cases or not official declaration of existing anthrax zone ?
“Interesting improvement” of the previous OIE Codes. For example in the Code 1992 the conditions for animal products were as follows: “attesting that the products: originate from animals not showing clinical signs of anthrax and have been processed to ensure the destruction of both bacillary and spore forms of Bacillus anthracis”. However, in the Code 2006 this formulation is changed replacing “and” by “or” following by “in conformity with one of the procedures referred to in Appendix X.X.X. (under study).” The Appendix X.X.X. is not existing !!! Similarly are formulated the conditions for the import of milk and milk products where again the heat treatment is “under study”.
It is difficult to understand why the anti-anthrax treatments of animal products are still “under study” when the world alarm against bio-terrorism started in 2001, i.e. 5 years ago ! The OIE in 2006 produced an interesting publication entitled “Biological disasters of animal origin. The role and preparedness of veterinary and public health services”, however, the OIE itself is obviously not prepared when very important import conditions/measures are still “under study”. The Code is not considering at all that anthrax belongs among very dangerous biological weapons (or it is not so dangerous as generally declared = over-reaction?).
Incredible contradiction: OIE WAHID
Animal Health Situation (web March 2007):
Among the countries having the anthrax as not notifiable belong the
14.5 Chapter 2.2.6 - Paratuberculosis: no any
data on incubation period. Text: “Veterinary
Code 1986, chapter 126.96.36.199, page 161: “Veterinary Administration of importing countries should require: for domestic ruminants for breading or rearing the presentation of an international zoo-sanitary certificate attesting that the animals:
1) showed no clinical sign of Johne’s disease on the day of shipment;
2) come from a herd in which no clinical sign of Johne’s disease was officially reported during the five years prior to shipment;
3) showed negative response to the allergic test for Johne’s disease using Johnin or avian tuberculin during the thirty days prior to shipment;
4) showed negative response to the complement fixation test for Johne’s disease during the thirty days prior to shipment.”
The significantly reduced requirements in the Code 2001 obviously were still complicating the export and therefore the OIE “improved” (!?) the protection of importing countries by new text in the Code 2004: Article 188.8.131.52: “Paratuberculosis. Standard for diagnostic tests and vaccines are described in the Terrestrial Manual.”. This is all ! No one word more ! No more any protection of importing countries against this disease ! Title and empty page in a “international standard” is a curiosity never happened in the history ! Who gave the OIE the right for this scientifically unjustifiable and indefensible change without any OIE risk assessment damaging importing countries (it is doubtful that these countries consciously and voluntarily approved this dangerous provision). This case demonstrates once more that the OIE is dominated by those defending unfair trade without any regard to the others and that non-transparent process of adoption of the OIE documents such as the Code could be a swindle similarly as in the case of the WTO/SPS “to facilitate export” organized by the same exporting countries. Now the importing countries must “scientifically justify” the risk when asking for paratuberculosis free import according to the new nonsense provision of the Code or to accept its introduction ?! This fact demonstrates absolutely clearly the unscrupulous domination of the OIE Code by the major exporting countries consciously organizing disease spreading! One would expect in the following OIE Code 2005 the correction of this anti-sanitary “no-conditions”. Unfortunately, the empty page has continued also in following issues 2005, 2006, 2007, 2008, 2009, 2010, 2011 !!!
It could be the coincidence
when in the “OIE Handbook on Import Risk Analysis for Animals and Animal
Products”, Volume 1, 2004, page 33 the New Zealand Ministry of Agriculture and
Forestry indicated without any “scientific justification” that “Johne’s disease (Mycobacterium
paratuberculosis) was not identified as a hazard” (!?). According to the OIE
World Animal Health the
In this context it can be
mentioned the document of Dr C. MacDiarmid “The
This case confirmed once more that the OIE Code has nothing to do with scientific approach and with the protection of animal population health in importing countries and that it is only an “instrument” of major exporting countries for facilitating trade at the expense of animal and human health (including consumers) in importing countries. It documents that instead to control (or the country is unable to control effectively the situation) and to try to eradicate a disease which could complicate the export, it is easier and cheaper simply to stop the “notifiability” (not respecting international reporting system), to declare the disease as “no hazard”, to limit or stop specific investigations (= “situation unknown”) and to abuse impudently the OIE Code imposing this anti-sanitary risky trick on all the countries in the world.
Strong domination of the above
mentioned country can be documented also by the fact that the cover page of the
OIE World Animal Health 2002 presented full page “advertisement” of
In the Codes 2005, 2006, 2007, 2008 and again 2009 the
paratuberculosis was eliminated (again empty page even without the words “Under
study” as e.g. in leptospirosis empty page!)
opening its export from
countries unable to control it. The change was not scientifically justified and
without any assessment of consequences
in importing countries. This change has been supported even by the
The question erases about the role
of so called OIE Reference Laboratories, in this case about those for
The OIE and thhe above mentioned OIE Reference Laboratories, the Association and its members have historical professional responsibility for the irreparable global consequences caused by this dangerous disease !
Similar responsibility have the OIE Reference Laboratories for Leptospiroses (original OIE Code text was also abolished without any replacement !).
There are other major exporting countries, dominating the OIE, not reporting existing paratuberculosis (even not notifiable in their own country !) not to complicate the export, i.e. no need for control and eradication programmes !? They belong among the countries with major export of ruminants, i.e. with major export of paratuberculosis. In case of a conflict they can simply refer to the OIE Code and thus disarm the importing country sanitary defense.
The OIE is still searching the way, tactic and trick how to avoid any import conditions for the paratuberculosis which would complicate and even avoid actual relatively easy profiting export of ruminants = export of paratuberculosis. E.g. in the Final Report of 75th General Session, Paris, 20-25 May 2007, page 90 (para 367b) there is following sentence: “Based on advice from one of the disease experts *) , the Commission advised the Terrestrial Code Commission that tests for paratuberculosis continue to have serious limitation, and it would therefore be premature to consider a radical revision of the Terrestrial Code chapter” (revision of empty page ?). In other words, almost one century used specific diagnostic method has been a mistake and previous Codes’ authors were professional analphabets? Everybody knows, even the students of veterinary medicine, that indirect diagnostic methods in all diseases have not 100 % sensibility and specificity. Why these indirect methods, such allergic and serological ones, are used and recommended in all other OIE Code diseases (their Code pages will be also left empty for the same reason, i.e. as premature ?) with exception of paratuberculosis from 2005. According to the OIE logic we have to wait for next tens of years before identifying import requirements to avoid paratuberculosis export to be included in the OIE Code while letting the disease to be spread globally and irreparably. Then will be too late and the whole research of this disease could be thrown into basket. This is one of many examples of OIE laying down specific health for business profits. In the same Report on page 49 (para 272) there is a long description of paratuberculosis problems in wildlife stressing the importance of this disease and risk of its spreading (i.e. as a serious hazard requiring immediate actions and not further waiting): “Domestic cattle seem quantitatively to be the most important source of environmental contamination; wild ungulates can be infected from that source. Infection has been documented in a broad range of terrestrial wild animals, predominantly herbivores and their predators.”
*) An anonym (no space for his name, but enough space
for hundred and more times repeated sentences such as “thank .. and congratulated on
excellent presentation”) – obviously an “expert” for paratuberculosis
spreading and globalization following the “scenario” of the initiators (from
14.6 This example clear as daylight demonstrates once more that the majority of the Code provisions have not been scientifically justified, transparent, convincing, defensible, evaluated on sanitary risks and favourable to animal and human health !
14.7 This case reconfirmed once again that the irresponsible OIE bureaucrats do not respect not only the opinion of veterinary specialists and of the OIE reference centres but also importing country farmers’ interests similarly as importing country consumers’ health protection against zoonoses, namely foodborne diseases.
14.8 Chapter 2.2.3 - Echinococcosis/hydatidosis: “importing country should require…an international certificate attesting that the animals were treated against echinococcosis/hydatidosis prior to shipment, and that the treatment used is recognized as being effective.” Importing countries need the guarantee that the animals are free of this parasite and not only non-controllable information on some measures. This is typical formulation of the Code guaranteeing to exporting countries “easy job” (admitting export of non-healthy animals) and disarming importing country protection. This is typical formulation of the Code avoiding the possibility to reclaim the findings of the parasites in imported animals. No one word on import conditions for the meat ! According to the Code infested meat (liver) by hydatid cysts can be exported freely !?
14.9 Chapter 2.2.4 –
Leptospirosis. This chapter in the OIE Code 2005 and again in
the Code 2006 and 2007 represents other “novelty”:
Instead of the import conditions’ text, as in all previous Codes (two pages
with 5 articles), the page is left empty
with exception of the words “Under study”! It is incredible how the OIE has destroyed
(without any improve replacement) the very useful original Code conditions.
Obviously, the previous import conditions complicated in some influential
countries their animal export (similarly as the paratuberculosis in the
How long the OIE will “study”
the import conditions for the leptospirosis ? What five OIE reference laboratories for leptospirosis (in
In several major exporting countries this disease in not notifiable, i.e. no any reports available in the OIE information system = easy export ! Other artificial anti-barrier is the requirement to justify leptospirosis-free import by the OIE nonsense risk assessment methods !?
The result of the “Under study”: the OIE simply eliminated completely the leptospirosis from the OIE Code 2009 (even the empty page). The word “leptospirosis” disappeared at all from the whole extremely voluminous document! Through this criminal measure the OIE officially declared no to do anything for avoiding export of this dangerous zoonosis in spite of hypocritically stressing the OIE programme against dangerous zoonoses. The WHO and even the FAO do not protest accepting slavishly (as usually) the OIE policy in spite of damaging animal population health in the world,. This situation continues even up to latest 2011 Code.
14.10 Chapter 2.2.8
From scientific and practical points of view, there is not any logic to mix these two quite different species - Cochliomyia hominivorax and Chrysomyia bezziana having quite different biological and epizootiological characteristics, economic, sanitary and ecological consequences, requiring quite different preventive and eradication measures. They even belong to different genus – Callitroga and Chrysomyia. Therefore, they need to be reported separately and not together ! Mixing them is one of many “deliberate mistakes”(?) in the OIE Code facilitating export.
14.11 The above chapter is reflecting general approach of the Code to reduce the import requirements as much as possible, i.e. to narrow them to individual animals = clinically affected to leave at home and the rest (suspect and subclinical carriers) to export regardless of being from affected herds and zones. The authors either have no any idea on the epizootiology of the diseases or are in service of export business lobby opening way for disease spreading. Where is the “famous” OIE scientific convincing risk assessment ? This approach guarantees transboundary (up to intercontinental) spread and not its avoiding!
The above mentioned anti-sanitary approach reminds the words of Dr MacDiarmid (see comments in 10.2) that for the export the local disease situation is not important “when having risk reducing tools (tests, treatment, whatever)” !? Similar very dangerous anti-sanitary “philosophy” has other leading OIE officer - Prof.Dr Vincenzo Caporale (see comments in 17.2). From the epizootiological point of view just the local (zone) situation is the key factor in selecting animals or their products free of specific diseases/pathogens for the export. The selection of individual clinically healthy diseases from affected herds and zone is extremely risky what the OIE Code doesn’t respect! The most dangerous are the animals-carriers of etiological agents being without disease clinical manifestation (i.e. originated from affected herds and zones!!).
14.12 Chapter 184.108.40.206 Bovine brucellosis: The Code import conditions for bovine brucellosis declares as specific disease-free country or territory also when its occurrence was reported !? How can be a territory declared as free when the disease there exists ? It is professional and logical nonsense. The text: “Country or zone free from brucellosis shall satisfy following requirement – the entire cattle population of a country or zone is under official veterinary control and it has been ascertained that the rate of brucellosis infection does not exceed 0.2 % of the cattle herds in the country or zone under consideration;”. This is also an example of using camouflage to “facilitate export” declaring as free the territory where the disease still exists !!. Where is the professional logic and scientific, transparent and defensible justification ? This was again a gross camouflage to facilitate the export at the expense of animal and human health of importing countries.
Example: The author for the
first time met this strange definitions in
14.13 Similar non-sense formulation, declaring disease-free status in spite of disease occurrence (absolutely unknown in world scientific literature), can be found also in bovine tuberculosis (chapter 2.3.3), enzootic bovine leukosis (chapter 2.3.4), IBR/IPV (chapter 2.3.5), caprine and ovine brucellosis (excluding Brucella ovis) (chapter 2.4.2) etc. Where were the requirements for scientific approach the Code asked repeatedly importing countries that their risk assessment to be transparent, convincing and defensible ? This case reconfirmed once more that the OIE Code, mainly its risk assessment methodology, has been pure hypocrisy having nothing to do with scientific approach.
14.14 Chapter 2.3.3 Bovine tuberculosis. Other
prove that the Code is trying to minimize import conditions regardless of
exporting pathogens: “for fresh meat and
meat products of cattle should be required the presentation of an international
veterinary certificate attesting that the entire consignment of meat comes from
animals which have been subjected to ante-mortem and post-mortem inspection as
described in the
Other text instructs that the country where bovine tuberculosis exists cannot ask for cattle and buffalo “a certificate from an Official Veterinarians attesting that they come from a country, zone or compartment or herd free from bovine tuberculosis”, i.e. if the importing country is not tuberculosis-free it must accept animals from tuberculosis herds! This is other instruction for organizing specific disease propagation through international trade.
14.15 Chapter 2.3.9 on Bovine cysticercosis is admitting to export fresh cattle meat being infested after special freezing or heat treatment (at 60o C), i.e. not requiring the meat to be from cattle free of this parasitosis. Frozen or heat treated cysticerci must be very tasteful !? This chapter is de facto the instruction for not implementing field control/eradication programme against this disease in exporting countries. This is other example of the OIE policy against the interests of importing country consumers. This chapter again confirms that the OIE Code is not interested at all in exporting disease-free animals and pathogen-free animal products!
The Code is referring to the
methods described in the “Recommended
International Code of Practice for ante-mortem and post-mortem judgment of
slaughter animals and meat” – FAO/WHO
14.16 Meat import veterinary conditions are missing e.g. in chapter 2.3.1 Bovine brucellosis, in chapter 2.5.8 Glanders, in chapter 2.10.2 poultry salmonellosis, etc.; milk import veterinary conditions are missing in chapter 2.4.2 Brucellosis melitensis, etc. Fresh meat represents the most important vehicle for foodborne disease pathogens spreading through international trade. In spite of this, the Code is consciously and systematically omitting this very important condition of international trade.
14.17 Chapter 2.3.13 Bovine spongiform encephalopathy. This wordy part is over-combined one obviously due to helplessness to define BSE free status without laboratory investigations.. Instead of requiring documented guarantee that the exported animals and their products are free of BSE-pathogens, the Code try to avoid it presenting a pure theoretical “risk assessment” having nothing to do with practical feasibility. The Code tried artificially to subdivide the problem not respecting the reality and epizootiological characteristics of the BSE. List of the criteria for BSE status of a country or a zone (220.127.116.11) is based only on indirect, i.e. not decisive data, instead on the application of laboratory testing of also normally slaughtered animals of major age. All the classifications of BSE country or zone – free, provisionally free, with a low incidence, with a high incidence, etc. - are deliberately avoiding effective surveillance using postmortem laboratory testing also of normally slaughtered cattle of major age. The text contained complicated statistical deductions which was reconfirmed in the appendix 3.8.3 (similarly in the Codes 2002, 2003, 2004, 2005 and 2006). Instead to try to detect BSE reality, the Code recommended: “Random sampling of brains and spinal cords from normal cattle is not recommended.” Why ? To facilitate export ? Also in this case is valid that without active preventive etiological investigations at population level the situation cannot be known. Any artificial BSE classification of a territory is very problematic and could be abused by the exporting countries. To ask importing country for BSE risk assessment, when the OIE itself has been unable to recommend scientifically justified, transparent and defensible procedure, is at least very unfair nonsense. Unfortunately, up today the Code has continued similar approach unfavourable to importing countries facilitating BSE spreading through international trade. See also comments on the appendix 3.8.3.
The OIE “risk assessment” experts have continued in experimenting and every year have been published different more and more sophisticated theoretical statistical methods not applicable in trade practice. This demonstrates the serious confusion having nothing to do with scientific, transparent and convincing practical method! The OIE is helpless to formulate reasonable import conditions related to BSE. There is a conflict of interests: exporting countries try to minimize the sampling size e.g. introducing so called “surveillance point values of the samples collected” (= reducing the real number of samples), while the importing countries simply require the guarantee the imported animals or their products (meat) to be BSE-pathogen-free.
Dr MacDiarmid (
In May 2006 the OIE issued new
Code with “new” over-complicated surveillance methods to discover the BSE
proposed by the OIE Code Commission chaired by Dr Thiermann (USA) having Dr
The BSE surveillance system as far as the sample size seems to be theoretically correct *). However, the practical application is absolutely underestimated. The main problem is how to assure 100 % of random selection of the samples when the field conditions are usually very different, government services are relatively weak, private services are not always reliable and laboratory and financial support is not always available in full. The OIE BSE method, confusing seriously importing countries, is not applicable at national level even in the countries of the authors.
The most reliable is the system investigating the brain tissue of all slaughtered elder cattle as it was established in the European Union.
*) R.M. Cannon and R.T. Roe:
“Livestock Disease Surveys: A Field Manual for Veterinarians.” Australian
Bureau of Animal Health, Department of Primary Industry.
14.18 Chapter 2.4.2 is entitled Caprine and ovine brucellosis (excluding Brucella ovis). The OIE “pseudo-reformers” after the WTO/SPS abolished the scientifically correct term of etiological entity – Brucella melitensis. This term, without any scientific justification, has disappeared in a l l the OIE Code and in almost all OIE “scientific” publications! It is difficult to understand why the OIE changed the correct name used before: “Caprine and ovine brucellosis (Brucella melitensis)”. (e.g. in the OIE Code 1992, chapter 3.3.2, page 241). This nonsense change was obviously the “work” of somebody who had not any idea about the scientific international classification of diseases.
14.19 Chapter 2.10.2 Salmonella enteritidis and Salmonella typhimurium in poultry. The import conditions for poultry meat are systematically omitted. Similarly these pathogens are omitted in the OIE global information system. The chapter is referring to the article 18.104.22.168 regarding to regularly monitoring of the poultry establishments which is admitting Salmonella occurrence !
Article 22.214.171.124 Monitoring of poultry breeding flocks and hatcheries for salmonella: ”Total number of samples … is based on the random statistic sample require to give a probability of 95 % to detect one positive sample given that infection is present in the population at a level of 5% or greater.”
In the Code are missing import conditions against zoonotic Salmonella in poultry as well as in mammal meat opening wide path for their free spread through international trade !
The reasons why the OIE Code avoids the import conditions for the salmonellae letting them to be exported freely see in paragraph 6.2 informing on MacDiarmid information that “ it is impossible to obtain salmonella-free foods of animal origin.”(!?)
The OIE instead of trying to avoid global spreading of this extremely important foodborne disease pathogens has opened the way for their free spreading through international trade when applying the policy of “doing nothing” !
14.20 Interesting is the use of sampling methods admitting openly particular disease occurrence (up to 5 %) in the cases when the export should be specific disease free:
Chapter 2.5.5 – equine influenza: “Equine influenza free country… requirements: a serological survey has been carried out on a representative sample … sufficient to provide at least a 99 % level of confidence of detecting the disease if it is present at a prevalence rate exceeding 5 %.”
15. Epidemiological surveillance system
15.1 Section 3.8 "Epidemiological surveillance systems". First of all it cannot not be called as the "standard". It must be distinguished the surveillance for control programmes and surveillance as the basis for confirmation disease-free status for international trade purposes. The text written for the first purpose was deliberately abused to “facilitate export” and not for importing country protection. For the second purpose however, the sampling methods as described 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 Code was recommending something what is so “holey” ! Permitting to use for export the method able to detect the disease only if its occurrence was higher than 5 % calls for reducing or not applying necessary control measures and for exporting diseased animals and their products. Therefore, it must be eliminated from the Code at all or substantially corrected respecting fully scientific sampling for confirming disease free status (and not 5 % occurrence). This comment is applicable also on the article 126.96.36.199 (including Table II) which is "officially" permitting to export poultry salmonellosis !
15.2 Appendix 3.8.3 Surveillance and monitoring system for bovine spongiform encephalopathy represents other example of lacking scientific justification, transparency and logic. The appendix of the OIE Code 2001 contained contradictory and professionally non defendable statements.
“Table 1 indicates the minimum of clinical cases that should be subjected to diagnostic tests according to the total native-born cattle population over 24 months of age. As this sampling is not random, the numbers indicated in this table are a subjective interpretation..”. “Minimum number of annual investigations of animals showing clinical signs compatible with BSE required for effective surveillance according to the total native-born cattle population over 24 months age” – e.g. “for this population of 40,000,000 the minimum number of brains to examine = 433”. Because the BSE has almost always subclinical forms, all animals showing clinical signs compatible with BSE as well as the animals of the same subpopulation must be tested ! Avoiding random sampling is against scientific statistical principles. No testing has almost the same impact for the identification of BSE situation as that absurdly minimal size of testing.
This absolute nonsense table with the same numbers can be found also in following OIE Codes in 2002, 2003, 2004 and 2005 !
“Random sampling of brains or spinal cords from normal cattle is not recommended (!?) Since BSE is rare, even in countries with the highest incidence of disease, microscopic examination of brains or spinal cords from a random sample of the national cattle population is unlikely to detect a disease prevalence of 1 in 1,000,000 or more unless huge numbers of brains or spinal cords are examined.” Not recommending random sampling in this case confirms general endeavour of the major exporting countries to minimize or up to avoid disease testing due to its costs, risk of possibility to discover the truth and thus complicating up to avoiding the export of animals and their products. This is other example of OIE “facilitating trade” at the expense of animal health in importing countries and of stubborn refusing to include in the OIE regular global information system any numbers on specific investigations of animals (risk to discover the truth on insufficient preventive testing, surveillance and situation knowledge in exporting countries).
Example: Several years ago
European Union countries started mass laboratory investigations of slaughtered
cattle population facilitating to detect BSE even in the countries without
15.3 It is obvious that without active preventive investigations of all animals of exposed categories of susceptible species or of their random sample assuring high level of probability to detect affected animals, considering also epizootiological aspects, the declaration of specific disease free status cannot be reliable. In these cases the veterinary certificates based on the Code (chapter 1.2.2) that the situation has not been known are only information documents and not documents guaranteeing specific disease-free status. Also the reports for OIE World Animal Health yearbook on disease free status cannot be in these cases reliable. Epizootiological uncertainty is multiplied by illegal import and by minimal or zero capacity of weak public veterinary services to control effectively epizootiological situation and national and international trade in animals and animal products.
15.4 General tendency of the Code is, instead of significantly improving the surveillance ability to discover animal population health/disease reality, to minimize the size of investigations in exporting countries regardless of epidemiological and epizootiological needs. This is also one the OIE form how to “facilitate export”. Mass etiological investigations in exporting countries represent the risk to discover the reality, i.e. disease cases, and thus to complicate or avoid the export and profit.
15.5 Other anti-sanitary tendency of the Code is to limit the import conditions as much as possible applying different forms such as to reduce them on individual animals instead of herds of origin, individual herds instead of zone of origin, individual zones instead of region and country of origin etc.. The Code is not respecting threatening sources of diseases/pathogens, i.e. suspect animals, animals in contact with diseases/pathogens sources, and way of their propagation. The Code is not respecting fully the different grades of epizootiological characteristics of the herds, zones and territories.
15.6 Appendix 3.10.1 “Guidelines for the Control of
Biological Hazard of Animal Health and Public Health Importance through Ante-
and Post-mortem Meat Inspection” represents other unnecessary “component”
of the OIE Code. The OIE is trying to replace other international organizations
involved in food hygiene, in particular meat hygiene, such as FAO/WHO
The OIE is involved in the fields out of the OIE international particular responsibility, instead to implement its only duty, i.e. to protect and improve animal health in the world. The OIE is dedicating its very limited capacity to some relatively easy local-national problems which are already “covered” by other inter-governmental organizations. The OIE is leaving its international anti-epizootic duties what are much more important and demanding when defending animal health against enormous pressure from all sites, mainly from exporting countries and their business lobbies. The OIE is not performing its basic and its only duty!
15.7 As a further prove of the OIE Code deficiencies can serve also the references to not existing texts !
Examples: In the OIE Code 2006 in Chapter 2.2.1 on anthrax is referred to not existing Appendix XXX. In Chapter 2.2.13 (bluetongue) is three times referred to not existing Appendix 3.8.X.
16. International veterinary certificates
16.1 At the end of the Code there are models of international veterinary certificates for export. These models have the form of noncommittal information on pre-export measures only and not giving any guarantee for the health – sanitary innocuousness. This reflected the whole concept of the Code avoiding any guarantee for full health quality of exporting animals and their products.
16.2 The Model for “International veterinary certificate for meat of domestic animals - of bovine, bubaline, equine, ovine, caprine or porcine species or of poultry”. In the part “Attestation of wholesomeness” is following formulation: The undersigned Official Veterinarian certifies that: ..b) the meat is considered to be fit for human consumption;..” In no part of the Code it can be found any definition what is meant by “fit for human consumption”, i.e. everybody can understand it differently *). No any word about the investigations, sanitary situation and control. This extremely simple statement, without any explanation, on meat export (representing de facto the majority of global animal export value), e.g. if the meat is pathogen-free or not, is in drastic contrast to extremely wordy Code going into many very complicating details (to “facilitate export” through confusing importing countries?). If we considered that the meat innocuousness starts in primary production being generally under minimum or zero health control, then we have to expect mass spreading of diseases through difficult-to-control export and import of this commodity. To undersign this kind of attest is relatively easy and without any real responsibility. Therefore, the meat export is the most frequent way for diseases/pathogens international propagation and for easy profit of the exporters. The export of meat represents more than 50 % of animal export value in the world !
According to the OIE Code the veterinary certificates for exported meat and other animal products guarantee nothing as far as sanitary quality ! In this way the OIE has created the easiest export of animal infection pathogens !
*) This definition
in the FAO/WHO
Note: Dr C. MacDiarmid in “The Importation into New Zealand of Meat and Meat Products: A Review of the Risks to Animal Health”, published by the Ministry of Agriculture and Fisheries in 1992, presented on the page 20 following list of diseases of livestock which may possible be carried in carcasses, meat, offals or meat products: foot and mouth disease, swine vesicular disease, rinderpest, peste de petits ruminants, African swine fever, hog cholera, anthrax, Aujeszky’s disease, echinococcosis/hydatidosis, leptospirosis, Q-fever, rabies, paratuberculosis, brucellosis (B. abortus, B. melitensis, B. suis), tuberculosis (Mycobacterium bovis and Mycobacterium avium), cysticercosis (Cysticercus bovis, C. cellulosae), scrapie, bovine spongiform encephalopathy, African horse sickness, glanders, melioidosis, vesicular exanthema of swine, atrophic rhinitis, transmissible gastroenteritis, porcine epidemic diarrhoea virus, trichinellosis, listeriosis, toxoplasmosis, botulism, blackleg and other clostridial infections, Salmonella infections, mucosal disease/bovine virus diarrhoea, erysipelas, yersiniosis, campylobacteriosis, Sarcocystis species, tularaemia, viral hemorrhagic disease of rabits, fowl plague, Newcastle disease, duck virus hepatitis, duck virus enteritis, fowl cholera, fowl pox, fowl typhoid (Salmonella gallinarum) and pullorum disease (S. pullorum), infectious bursal disease, Marek’s disease, avian leucosis, egg drop syndrome ’76, goose parvovirus hepatitis, duck astrovirus, turkey rhinotracheitis, chicken anaemia agent, avian nephritis virus, big liver and spleen disease.
16.3 Using the word “considered” is non-committing formulation to provide necessary sanitary guarantee, i.e. it is again favouring exporting countries at the expense of importing ones, mainly developing ones.
Theoretically, if for this Code the meat import
conditions, so important for the global
trade, is sufficient only one short sentence then it could be also sufficient one short sentence for all animal commodities (including
live animals) exports, e.g. that “they
are considered to be fit for post-import use” (?!). Therefore, there is a need to elaborate properly the import
conditions for pathogen-free meat similarly as the FAO/WHO
16.4 It must be differentiated if the attest signature belongs to public service veterinarian or to private accredited veterinarian. This is of particular importance for the credibility of the document.
16.5 At the end of the set of individual Models of certificates, there is following sentence: “ These conditions are agreed between the Veterinary Services of the importing and exporting countries in accordance with the option provided in this code.” In view that the Code is unilaterally favouring to exporting countries, this formulation is “binding hand” of the importing countries limiting their decision on country protection. The word “accordance” to be replaced by “considering also”. The importing governments must have the right to consider a series of factors which are risky for their countries and not to be illogically limited by the Code where there are many non-transparent, not fully justified or at all missing provisions, not mentioning the benevolence for diseases/pathogens export.
16.6 In the OIE international veterinary certificates are missing the most important component - health guarantees. This fact is converting these documents into absolutely insufficient value for importing countries’ animal and human health protection. They need to get clearly formulated sanitary guarantee with full responsibility, i.e. the exporting country must guarantee full health = without diseases and pathogens or only partial one indicating which specific disease-free or pathogen-free status is guaranteed and which not. The importing countries must know full truth about sanitary status of the animal trade commodities and about the sanitary environment in place of origin!
16.7 The OIE international veterinary certificates do not guarantee anything having direct animal and human health importance ! Information on clinical status only and on some tests’ negative results doesn’t represent any guarantee of diseases/pathogens-free status. No guarantee = no responsibility for the consequences of diseases/pathogens export ! The OIE certificates serve de facto only for cheating importing countries on sanitary status of exporting commodities!
16.8 The tragedy
is that also FAO/WHO
In the Preamble
of the “Code of Hygienic Practice for Fresh Meat,
On the contrary, the exported meat must be safe and wholesome, i.e. pathogen-free, without any need for after-import sanitary recovery handling !
If this anti-sanitary philosophy is applied on life animals then the exported non-healthy animals (= non-pathogen-free) should be treated by importing country to convert them into healthy (= pathogen-free) animals ! The animals must be healthy, i.e. pathogen-free, without requiring any after-import health recovery treatment !
16.9 From sanitary quality point of view the OIE international certificates are formulated to guarantee nothing !
17. Other comments
17.1 In the Code is missing one the most important arrangement of fair international trade for the cases when there are exported commodities which are not of full quality or even are causing losses such as due to the spread of the diseases. The Code is consciously lacking the principles for the reclamation solution in cases of discovery of relevant diseases/pathogens among imported animals or animal products as well as in cases of the discrepancy between the importing country veterinary conditions and exporting country certificates. The reclamation solution agreed in advance can save a lot of troubles in conflicting export/import situation. This must be current component of veterinary conditions for import. Author’s suggestions how to amend the Code sent to Dr Jean Blancou, Director General, OIE were not considered at all.
17.2 The Code indicates that the OIE is behaving as a real “filial” of the WTO servicing to the trade business instead to consistent protection of animal health. The text of the Code, converted from useful recommendations into obligatory document according to WTO/SPS, was not cleared legally by member country governments. It represents a document based only on the consensus of the Chief Veterinary Officers without getting any acceptance by the target groups using imported commodities, such as farmers and consumers and their organizations. The text was prepared without using any official independent opponents, the best scientific and practical specialists. Cui bono ? Unilaterally favouring the major exporting countries and discriminating the majority of the member countries, the OIE had lost its original neutrality, not speaking about the absence of professional justification. The OIE is obviously no more serving to protect consistently and uncompromisingly the animal health in the world as it was originally established. What is its “raison d’être” ?
Example: "The need to remove technical obstacles to the free circulation of animals and their products"; "It is not longer possible to apply the old system under which animals and animal products had to come from specific free zones, and were subjected to isolation, quarantine, inspection and diagnostic testing before and after export." (!?) In: “Harmonization of activities of the veterinary services in Europe with special respect to principles of certification and to accreditation of European laboratories and the mutual recognition of analysis results”, 1994, document for the OIE European Commission and the OIE; author: Prof.Dr V. Caporale, Italy, former Secretary General, OIE Foot and Mouth Disease and Other Epizootics Commission and actually President, OIE Scientific Commission for Animal Diseases.
Then what to have the OIE Code for when letting free circulation of animals and animal products ?!
17.3 The WTO/SPS is not only damaging document replacing quality guarantee by non interpretable cheating “measures” but it is also superfluous. Without the WTO/SPS the OIE Code could continue with its original concept of very useful non binding recommendations and international trade in animals and animal products could apply the same fair principles as in all other commodities giving the priority to their full quality. On bilateral basis it can be found in many cases the agreements of certain tolerance by the importing country without any dictate or interference from outside. For importing country decision the most important is the open declaration what exporting country is guaranteeing and what not, i.e. which specific diseases or pathogens free status is guaranteed and which specific diseases or pathogens free status is not guaranteed.
17.4 The problems is very simple. Instead of camouflaging the exporting country reality abusing the nonsense OIE risk assessment methods, the importing countries need to know the TRUTH about importing commodity real sanitary quality, first of all about pathogen-free status !
17.5 General continuous tendency in the international trade is to increase the quality requirements. The trade in animals and their products must not be the exception as it is today thanks to the WTO/SPS and the OIE Code policy of deliberately reducing (minimizing) health quality requirements as never in the history.
17.6 The trade must be facilitated by improving the health quality of animal population and their products in exporting countries through disease reduction and eradication and not by imposing upon importing countries the "duty" to reduce their protection barriers against diseases introduction. Not speaking about the tendency to minimize (due to "economic reasons"?) government veterinary services and their control/inspection role in field, laboratory and trade instead to strengthen them.
17.7 The importing countries need to import without any undesirable post-import sanitary problems !
17.8 There is generally known the natural fact that the interests of the organizations defending the health and the organizations defending the business are very different = opposite. This is current and logical “conflict of interests”. Unfortunately, the OIE, instead of carrying out its only duty of defending consistently the animal health in the world, betrayed its principles and voluntarily surrendered under the pressure of major exporting countries, supported by their pseudoscientific theoreticians (reckoning themselves to be the best in the world not admitting any scientific opponent procedures), completely to WTO anti-sanitary business policy.
17.9 It seems that the authors of the OIE Code have never experienced the practical life of government veterinarians defending animal population health at field or managerial levels fighting almost continuously for the application of anti-epizootic principles and legislation (i.e. prohibiting or dictating measures, investigating, inspecting, etc.) against the natural resistance of animal owners, producers and exporters (due to necessary anti-epizootic measures complicating production process and trade and increasing the cost) as well as against the economists and politicians (due to necessary anti-epizootic measures complicating their “programmes”).
Private accredited veterinarian is not interested in “fighting” for animal population health applying necessary anti-epizootic measures often against the natural interests (mainly economic ones) of local animal owners, producers and exporters who provide him long-term chance for work and income. Therefore, there is an urgent need to distinguish in the OIE Code the role of public and private veterinary services having different priorities and even opposite “missions” and interests.
17.10 The author fully agrees with the following statement: “The OIE Code was basically written to protect the health of livestock in developed countries.’’ In: FAO website dated 27.5.2002 in the Spotlight "World livestock trade".
17.11 The OIE, after supporting the significant reduction up to dismantlement of public veterinary services, continued by deforming information system on disease occurrence (= significantly less regular information than before), abolishing collection of data on disease import, using texts masking support of disease export (overloading Code provisions by very wordy secondary statements to avoid or to cloud the key principles for importing country health protection), abusing fraudulently risk assessment, avoiding Code provisions’ impact analyses, concealing the truth on disastrous consequences from importing country governments and world public, etc..
17.12 The Code doesn’t respect at all the opinion of importing country farmers and consumers and decides irresponsibly about health, life and death of incalculable millions of animals and humans exposed to “legally” imported pathogens.
The OIE in business service is imposing its criminal anti-sanitary policy and provisions “over dead bodies” (this is not any metaphora, this is the reality).
17.13 Who gave the OIE the right to support the disease spreading ? Why importing countries have to pay the membership of an organization which harms them not respecting its basic duty to protect animal population health ?
17.14 The Code is characterized by several historically unique features unimaginable in any other international trade standard. The Code is unilaterally favouring to exporting countries not respecting importing countries’ interests in consequent protection of animal and human health. The Code doesn’t admit the importing countries to demand full sanitary quality of animal commodity and to guarantee for it; on the contrary, it imposes the duty to accept non-healthy animals and non-pathogen-free food of animal origin. Exceptionally, the importing country can require specifically healthy animals or specific pathogens-free food only if this is “scientifically justified” in writing to convince the exporting country (if this perverted logic would be applied e.g. on motor cars, then importing country cannot require normal fully functioning cars without written “scientific justification” !?).
The Code absolute instability and unreliability are reflected in publishing every year a new issue with many amendments without marking their emplacements. The Code instability is reflecting the lack of scientific and transparent defensible approach when every year the import conditions have been changed without any published convincing justifications (including risk assessments of the provisions). The instability is reflecting instead of objective the subjective approach influenced by individual powerful exporting countries and not as the result of scientific research, practical experience and anti-epizootic logic. Normally, the international standards are relatively stable, i.e. revised and published after a period of 5 or 10 years and in case of the need particular amendments are available. Nobody knows what is still valid and what not, what is the new and what is out of the use and how long will the provisions be in effect, etc.. The OIE Code demonstrates that the OIE doesn’t care at all about practical use and impacts of its provisions on importing country animal and human health !
Issuing new edition of the OIE Code every year means to replace previous year edition (price – 55 є), i.e. “to throw it out of the window” as not more valid !
17.15 Relatively easy unpunished export of animal diseases/pathogens without full sanitary guarantee, thanks to the Code, has caused the stop of almost all diseases’ control and eradication programmes in exporting countries due to the loss of economic motivation for diseases/pathogens-free export. The most “effective” veterinary strategy supporting animal export has become the “doing nothing” letting the local diseases to spread what is also the consequence of the OIE post-1995 anti-sanitary policy.
Example: European Union, following the OIE policy, is not organizing any all-member country disease eradication programme. Deterrent example is represented by the African swine fever (the most dangerous killing swine diseases) occurrence in the Island Sardinia being left during three decades without its eradication. More information on this case see in http://vaclavkouba.byl.cz/orgglobalization.htm in the paragraph 2.10. If we consider the OIE definition of the “regionalization”, than the whole territory of the EU should be understood as affected by this disease with the consequences for the trade. The EU obviously continues to apply also in this case the cheapest and simplest anti-epizootic policy of “doing nothing”. This case reconfirms the fact that a disease introduction is relatively easy but its eradication is often extremely difficult, if feasible at all.
17.16 The OIE Code de facto has abolished the main motivation for animal population health protection, disease surveillance and monitoring, disease control and eradication programmes in exporting countries !
The OIE irony: the less or zero animal population disease investigations (risk to detect troublesome truth – disease), control and eradication programmes, the better chance for export and profit !
Minimal inputs = maximal profits of exporting countries and of businessmen involved to the detriment of the animal and human health in importing countries, this is the basic philosophy of the OIE Code!
17.17 Thanks to the WTO/SPS and the OIE Code the exporting countries are saving money due to “doing nothing” for effective control and for the eradication of communicable diseases to can export animal commodities of full sanitary quality while importing countries must pay the losses and post-import measures due to diseases/pathogens introduction through international trade. The OIE Code is de facto punishing importing countries !
17.18 Relatively easy and unpunished export of diseases/pathogens without full sanitary guarantee, thanks to the Code, has caused minimizing or the stop of active surveys to discover animal population health/disease reality in exporting countries due to the loss of economic motivation for diseases/pathogens-free export.
17.19 The OIE Code anti-sanitary policy causes serious discrepancies between exporting countries giving advantage to those not applying effective control and eradication programmes, often demanding and expensive, conducing to lower price of exporting animals and their products in comparison with other exporting countries. The Code is supporting unfair concurrence among the countries. The OIE policy is punishing the countries with intensive and costly control/eradication programmes as well as specific diseases-free countries.
17.20 The OIE Code anti-sanitary policy causes serious discrepancies between exporting countries also due to giving advantage to those not carrying active nation-wide surveys, very often demanding and expensive, to discover and report sanitary reality (diseases’ occurrence) in animal populations and their products. The OIE system is punishing the countries with intensive systematic multi-disease surveillance. The OIE is deliberately avoiding, in spite of urgent requirements by the author and by the others, to include in global information system data on type and size of investigations of animal population health/disease and animal products pathogens. It is necessary to show how far the disease occurrence data are based on active specific diseases/pathogens surveillance or only on ad hoc discovery confusing the importing countries. It is obvious that this unfair reporting had unfair impact on international trade concurrence among the countries.
17.21 The OIE Code doesn’t care about this injustice favourable to major exporting countries with very weak public veterinary services. Theoretical comparing of two exporting countries with the same animal health/disease situation: First country: No investigations = saving money = no diseases/pathogens discovery = reporting “no diseases/pathogens” = easy export with major profit. Second country: Investigations = spending money = diseases/pathogens discovery and reporting = difficult or zero export. The OIE irony: the less investigations and controls in exporting countries, the better chance for export and profit!
Example: In 2006 the European Union finished the analyses of salmonellosis occurrence in poultry industry. The countries systematically investigating the poultry flocks and reporting fairly the finding were presented as the worse; in the countries without necessary investigations reporting “falsely” minimum or zero occurrence were presented as the best giving them better chance in the export. (EU is “copying” the OIE Code policy).
17.22 According to the OIE anti-sanitary policy, the international trade fairness doesn’t pay. The OIE favoring to exporting countries without guaranteeing the health is supporting dirty concurrence in international trade in animals and their products, in spite of its hypocritical OIE Code provisions on the ethics.
17.23 OIE documents are full of terms “science”, “scientific”, “scientifically justified” to stress scientific standard of the organization. However, scientific approach is alien to it what is demonstrated by the fact that it doesn’t admit any critics or critical analyses of its activities, documents and publications. Without objective analyses, exact testing and independent evaluations of practical impacts, the Code problems cannot be solved in a “scientific” and feasible manner. The OIE documents and texts of the leading OIE officers are full of demagogy replacing missing concrete convincing data arguments and quantificated international impact of the OIE activities – their scientific justifications and risk assessments are absent at all (for the OIE HQs obviously not applicable or quite unknown terms) !
17.24 The OIE Code has become an instrument for organizing animal disease spreading through international trade what can be de facto understood as conscious support of international bioterror causing daily incalculable number of cases of animal and human suffering and deaths due to “legally” imported pathogens. Has the OIE become even an “inter-governmental” terrorist organization unique in the world history?
This type of terror has major consequences than individual isolated sudden “classical” local visible individual terror acts. The multiplying consequences of the above mentioned bioterror for human health and life can be long-term (or lasting) spreading almost uncontrollably (invisibly) to many places (territorial up to global terror) and even to the following generations. The bioterror effect is major in those importing countries (mainly poor developing ones) being unable to detect imported diseases/pathogens in time and to eradicate them before their spread into uncontrollable size.
It cannot be any justification referring to human errors when all protests, logical and reasonable suggestions and comments sent to DGs OIE have not be respected at all and thus confirming the lack of any interest to correct this anti-sanitary policy carried out consciously and deliberately. All the letters of the DGs, OIE and DG WTO answering author’s critical letters asking to abolish immediately the WTO/SPS and all anti-sanitary provisions of the OIE Code were uncompromisingly defending the mentioned documents conducing de facto to international bioterror. Ergo, why corrective actions when international trade business “goes smoothly” bringing high undeserved profit to exporting countries?!
17.25 In spite of being real international bioterrorism, under the “umbrella” of the OIE, having catastrophic global consequences for animal and human health, the world mass information media, similarly as the OIE, are silent about it, obviously not to threaten the profit of exporting powerful countries. Alarm and massive mobilization of the world public against some specific diseases (BSE, avian influenza – H5N1 strain, etc.) has been organized only when threatening the interests of the major countries dominating global animal trade. The serious consequences of these very important diseases are however absolutely incomparable with the enormous immeasurable consequences of the horizontal and vertical spread of other diseases/pathogens, including those killing millions of animals and humans. These consequences are much more serious among less resistant human populations suffering by the hunger and other diseases, mainly in poor developing countries, thanks to pathogens’ import supported by the unfair anti-sanitary international trade organized by the OIE and the WTO/SPS. Uncontrolled spreading of imported diseases facilitates the extinction of many wild animal species. The mentioned consequences strengthen other negative global devastating influences on our planet life such as the greenhouse effect.
17.26 The streams of animal diseases/pathogens, including foodborne ones, run mainly from major exporting countries to the importing countries of the “third world” having very weak government veterinary services unable to resist the pressures of the OIE Code and the WTO/SPS as well as of foreign and national profiting traders, to properly investigate imported commodities to detect in time and to control/eradicate effectively imported diseases/pathogens. It is generally known that thanks to the passages the pathogens can increase their virulence and cause major losses.
The imported diseases or pathogens, if not eradicated (usually), spread horizontally and vertically (to following generations) and remain in the country for long period or even for ever. The eradication requires disease discovery in time, immediate isolation of new outbreak(s), availability of feasible methods and necessary manpower, material and financial resources.
17.27 In the Code 2006, Section 3.10 Animal Production Food Safety, Appendix 3.10.1 are included “Guidelines for the control of biological hazard of animal health and public health importance through ante- and post-mortem meat inspection”. The text is professionally correct, however, has nothing to do with the export/import of the meat, i.e. no any definitions of veterinary conditions for this commodity import. The OIE is avoiding consistently to identify full sanitary quality – pathogen-free status as the condition for international trade without pathogens spreading. For the OIE it is easier to deal with internal problems of the member countries (= no any OIE responsibility) than to deal with much more difficult international problems such as sanitary innocuous trade what is the main task of the OIE having global anti-epizootic responsibility. Again, there is forgotten that the decisive stratum for sanitary quality of meat is at the farm level (= requirements for animal population health protection and restoration complicating today’s unlimited export) and not at the abattoirs.
17.28 Many importing countries, managing in the past to eradicate a series of dangerous animal diseases suffer, due to “new” OIE policy favouring exporting countries, by the reintroduction of the same diseases through international trade not guaranteeing the full health status of exporting commodities. Successful programmes, very often expensive and long-term, went to waste ! The question arises, if to start again or not the demanding eradication programme with doubtful perspective of the new reintroduction, i.e. letting the disease to spread ? Under the “new” OIE policy supporting animal disease spreading through trade and of minimization of public veterinary services to start eradication programmes again is very risky.
The OIE itself doesn’t organize any global anti-sanitary programme to improve animal health situation and eradicate selected particular communicable diseases, and on the contrary it lets unconcernedly continuous deterioration of global epizootiological situation. The OIE paperwork without global practical field action = zero positive effect. The OIE Code global negative consequences are not compensated by any adequate global eradication programme. The only global eradication programme is organized only against the rinderpest under the umbrella of the FAO (the eradication is planned to be reached in 2010). Unfortunately, that time the global situation in all other communicable diseases will be even much worse and no longer reparable.
17.29 The OIE Code approving process is contrary to all democratic principles. The actual consensus means simple public voting, if any, when individual importing countries have minimum chance to get through with their opinion or proposals against the “wall” of the major exporting countries dominating the OIE. It is obvious that the OIE and its Code are dominated (“dictate” ?) by a small group of the powerful member countries. It seems that the OIE is strongly influenced by the level of financial contributions by individual member countries (following the model of the World Bank and International Monetary Fond where the weight of individual country vote depends on the financial contribution = not applying normal democratic principle (“one country – one vote of the same weight” ?). The “stability” in the post of Director General being always (from the very beginning in 1924 – world record) of French nationality documents that is something wrong having nothing to do with current nationality rotation of top level officers applied as absolutely normal in all global inter-governmental organizations (exception -World Bank headed only by the USA representatives). It is obvious that the OIE has serious deficit of real democracy.
If we take the mathematics then the number of the countries in political/economic blocs is higher than a half of the OIE member countries: majority from 53 members of the British Commonwealth of Nations, majority from 49 countries - members of Organization Internationale de la Francophonie (Wikipedia 2006); almost all of which are former territories of the British and French Empires. Other political/economic block is represented by 27 European Union countries who must vote uniformly. The members of these blocs are bound to keep publicly the unity not to have economic or political difficulties with the leading countries. It must be added some other OIE member country delegates being eventually corrupt by massively lobbying lobbyists of the major international exporters. It cannot be avoided the influence of the representatives or leaders of other involved international organization, e.g. Chiefs, Animal Health Service of the FAO, Head of the WHO Veterinary Public Health Unit and Director General of the WTO, all have been from the same country similarly as the Director General of the OIE, i.e. all of French nationality. More information in: http://vaclavkouba.byl.cz/tradefactors.htm.
On the other hand, if the Chief Veterinary Officers do not protest in spite of their official responsibility to protect home country animal health against disease introduction, then is the question “why ? ”. Due to not being properly informed on or not being aware of the OIE Code negative consequences, or due to weak position at home against import business lobby, or due to weak knowledge of official international language, or due to the lack of staff and time to study all the OIE papers of about thousand pages (without marked and properly justified changes) sent for comments, or due to the fear of not to convince the others and the OIE staff (+commissions) creating a barrier against other opinion and suggestions (censoring), or due to succumbing to international lobby always present during the OIE General Sessions, or due to being too polite to Code authors and OIE HQs staff, or due preferring not to risk loosing job in fighting for the animal health against the more powerful decision-makers and organizations, or due to character weakness to resist corruption (e.g. not to be in conflict with the DG OIE who finances the CVOs’ meeting attendance from OIE budget), or due to psychological pressure, or due to being inexperienced beginner, etc.. Other reasons could be characterized by Latin proverbs “Si tacuisses, philosophus mansisses.” (“If you had kept your silence, you would have stayed a philosopher”) and “ Qui tacet, consentire videtur.” (“Who is silent seems to agree”).
The farmers and consumers are too far from the CVOs having not any penal responsibility for disease import. The author remembers the last courageous opponent of the OIE proposals from scientific aspects, usefulness and practical feasibility – Prof. Dr Luigino Bellani, Chief Veterinary Officer, headed Italian delegation at the OIE General Sessions from 1967 till 1991.
17.30 The Code has nothing to do with really scientific approach respecting consequences, logic and practical feasibility. For the decision about so important document such as the OIE Code it must be applied only secret voting and fully respected the weakest link (weakest importing country) of the problem chain. Scientific objective approach based on thorough protection of importing country health must be decisive !
The demagogy based on lie, semi-lie, cheating, concealing, pressure, corruption, lack of convincing arguments, lack of risk assessment and on dictate cannot be decision process form ! One of the cheating forms is the extraordinary complication (mixing non-important with important mostly pure theoretical provisions) of overloaded OIE Code text by enormous ballasts having nothing to do with sanitary innocuous trade to avoid the attention to the main problem = consistent protection of animal and human health in importing countries .
The OIE Code doesn’t known (recognize) at all the trade in healthy animals and pathogen-free animal products, i.e. full sanitary quality !!! It only recognizes the risky trade = in non-healthy animals and in non-pathogen-free animal products !!!
17.31 The OIE Code is not based on scientific analyses and the best possible international opponents’ positive position but only on personal view of irresponsible “armchair experts” of some OIE influential exporting countries and together with the OIE bureaucrats. Audiatur at altera pars is obviously for the OIE an unknown principle (see http://vaclavkouba.byl.cz/warnings.htm). The OIE Code text, in spite of its extraordinary importance for global health, has not been submitted not in the least to any critical scientific opponent procedures normally used for current critical evaluation even of veterinary faculty students’ diploma thesis!
The OIE has not been interested at all in global negative consequences of its anti-sanitary policy and has continued producing further “pseudoscientific” theoretical documents facilitating international spreading of animal diseases. The OIE has been producing more and more documents and “mountains” of papers not considering at all the real situation in the member countries possibilities (e.g. very weak government services spending almost all time in the offices mostly at the computers) and material, facilities, funds, transport, economic, etc. conditions. The OIE is not considering at all the practical field feasibility of their non transparent and not convincing and not proved by pilot testing results “scientific methods” very often having the character of pure theory. These can be possibly correct but from practical application aspect are considered as absolute nonsense.
17.32 The sanitary consequences of the OIE Code step into almost all inhabitants’ life on our planet and therefore the clearance cannot be the subject of consensus of only a small group of nominated Chief Veterinary Officers (not legally elected and not always objective officials) having not full responsibility and competence for such extremely important and sensitive decisions.
The OIE and its Director Generals have been repeatedly declaring that the “measures published in the Code are the results of consensus among Veterinary Authorities of OIE Member Countries” (i.e. not governments). This confirms the fact that about the life and health of animals and humans is deciding a small group of irresponsible bureaucrats not considering at all importing countries’ farmers and consumers’ interests and opinion.
The Code must be cleared by the governments themselves as responsible for the health of national human and animal populations !!!
Unfortunately, the member country g o v e r n m e n t s are deliberately not informed at all or not properly about the real OIE activities and consequences !
17.33 The absurdity of the OIE Code can be demonstrated by the theoretical application of its provisions on international trade in inanimate commodities *) following the OIE dogma that ” Import risk analysis is preferable to a zero risk approach.”:
- could not refuse offered commodity without providing exporting country written well documented convincing scientifically justified risk assessment (e.g. if selected one from several exporting countries of similar sanitary situation offering the same commodity – all others must obtain this risk assessment), i.e. not respecting the right to select freely the most suitable country;
- could not require at all full quality, e.g. fully usable/functioning product without any post-import troubles;
- could not require better quality than extremely benevolent international “standard” – the exception would be possible only if this country would provide exporting country with written well documented convincing scientifically justified risk assessment;
- could not require quality guarantee document (instead it must accept a simple information “certificate” on some tests’ results without any material-financial responsibility of document issuing person or organization for untrue or incomplete data; e.g. not investigating on the deficiencies = not knowing about them = “confirming” that deficiencies are not existing);
- could not require the commodity to be free of particular defects if these already would exist in this country (e.g. defected car breaks), i.e. it could not refuse this commodity without written well documented convincing scientifically justified risk assessment;
- should accept (could not refuse) the commodity not free of defects;
- should pay imported commodity as for 100 % quality regardless of real quality grade;
- should pay the commodity not free of defects as for defect-free one , i.e. full price;
- should repair defected commodities itself to minimize their negative effects and even pay for the negative post-import consequences, i.e. losses;
- could not reclaim defected imported commodity - exporting country would be divested of responsibility due to non existence of legally binding quality guarantee documents;
- should discard defected irreparable commodities which could not be returned to exporting country due to missing quality guarantee and pay for it itself (the commodity to be sent e.g. to “ rubbish damp or scrap yard”);
- should accept inspectors from exporting country to assess the reason for demanding import conditions or import refusal, i.e. to evaluate national systems of importing country (services, control, etc.) going into deep details (using several hundreds of criteria), etc.;
- should accept exporting country to use statistical sampling admitting major proportion of defected commodities.**).
According to the OIE Code provisions the requirements for full quality commodities or to insist on guarantees as to the absence of defects would be even irresponsible and contrary to the principles of encouraging international trade !!! ***)
OIE Handbook on Import Risk Analysis is even threatening importing countries that “zero risk importation policy would require the total exclusion of all imports” (!?).” (See paragraph 10.36).
These theoretical examples reconfirm the OIE Code concept unscrupulously favouring exporting countries at the expense of the importing ones.
*) Inanimate goods = transport means, equipment, instruments, tools, , mineral raw and processed products, chemical products, books and other printed maters, medicaments, communication and information technology components, all other industrial products, etc.
**) Among the OIE Code provisions are also minimal requirements on statistical methods admitting major proportion of defected goods. E.g. in particular case the number of the random statistic samples is based on the requirement to give a probability of 95 % to detect one positive sample given that defect is present among the investigated commodities at a level of 5% or greater.”
***) OIE Code User Guide (paragraph 4.3):“It would be irresponsible and contrary to the principles of encouraging international trade to insist on guarantees as to the absence of commonly found infections that are present in the importing country”.!?!
17.34 The OIE Code incredible absurdities of perverse logic, conducing not only to internationally organized spreading of animal disease pathogens affecting and killing animals and humans in importing countries but also to incredible internationally organized robbery of importing countries, representing de facto internationally supported crime against global human and animal health, food production and hygiene.
17.35 The OIE cannot compensate catastrophic consequences of its irresponsible anti-sanitary international policy through “new” orientation towards local problems (without international responsibility) being in the competence of national governments such as animal welfare, food hygiene, service organization etc.
17.36 The OIE Code reflects the OIE behaviour not respecting not only any international principles of legislation, democracy, trade fairness, social aspects, ethics, sustainable development but also any principles of real professionalism, scientific approach, normal logic, protection of human and animal health, environment protection, food hygiene, medical principles, etc.
18.1 The OIE Code following anti-sanitary WTO/SPS policy became the tool of facilitating export to the detriment of animal and human health in importing countries, i.e. facilitating and supporting disease spreading through international trade. Actual OIE Code concept is contrary to all international programmes requiring protection and improvement of animal and human health as basic conditions for sustainable development, food hygiene, consumer protection, human welfare, animal welfare, ecology, ethics, etc. ! This fact cannot be changed by many demagogical and hypocritical OIE proclamations of “supporting animal health” (e.g. self-declaration as “World Organization for Animal Health” ?!). The shameful voluntary degradation of the OIE will not be forgotten.
18.2 The OIE itself, in spite of repeatedly calling for “convincing scientific risk assessment” to be elaborated by the importing countries, has never carried out and presented to member country governments any “risk assessment” analysis of the Code of its practical impact on disease spreading through international trade ! The OIE even “cleverly” abolished useful information system including disease import, obviously due to the fear to discover the truth that it has been converted into an organization supporting consciously international spreading of the overwhelming majority of communicable diseases, including almost all zoonoses and foodborne disease pathogens (= “well prepared” internationally supported crime).
18.3 The previous very useful pre-WTO/SPS OIE Code was converted, thanks to irresponsible trickery with the “risk assessment” and so called “sanitary measures” replacing original zero risk concept, into the most dangerous international document for global animal population health in the history of veterinary medicine ! Normally, everything what causes damages should be either corrected or abolished ! This is valid also for the OIE and its Code.
18.4 The OIE, also in the interest of its “surviving”, must return to its original duty, i.e. to assist in the best possible way to member countries providing information and advise needed for responsible decision on measures to protect healthy populations avoiding disease spreading and improving animal health expanding populations and territories specific diseases free.
The OIE to fulfill again its original role as animal health intergovernmental organization protecting consistently animal health:
a) must eliminate from all its official OIE documents, in particular from the OIE Code, all texts which admit or support directly or indirectly animal diseases spreading (= robbery of importing countries, mass suffering and deaths of animals and humans – murders due to “legally” imported pathogens, dissemination of international bioterror) and thus also restore original OIE prestige (all documents damaging global animal health to be abolished or corrected);
b) must find the courage and refuse WTO dictate conducing to diseases/pathogens spreading through international trade what is contrary to all principles of fair trade, to all efforts of world community to protect and improve human and animal health and environmental conditions, to support sustainable economic and social development, etc. ;
c) must stress unambiguously the right of importing country authorities responsible for animal and human health protection to decide where, when and under which conditions to import animals and their products without any interference or dictate from abroad;
d) must declare clearly that the main obstacle to animal trade are not the measures to protect health in importing countries but the diseases/pathogens in exporting countries and thus to motivate these countries to carry out effective diseases/pathogens’ control and eradication programmes combined with consistent active nationwide surveillance ;
e) must support, as basic principle, the trade in pathogen-free animals and their animal products avoiding disease spreading through legal international trade (it doesn’t mean that the countries cannot agreed on exceptions, however it cannot be the basic principle as it is unfortunately today);
f) must restore its original Code as a very important recommendations to member countries when agreeing conditions between importing and exporting countries on bilateral or multilateral basis (as it was before the WTO/SPS);
g) must in the Code define first of all the “health standards” for particular (individual) animal commodities – healthy animals of individual species and categories and innocuous animal products as minimum health quality, i.e. define pathogen-free status guaranteeing avoiding disease export; in this context to consider the introduction of animal health quality grading to can be reflected also in price policy (prices according to sanitary quality and guarantee);
h) must in the Code require the exporting countries to declare the guarantee of full sanitary quality, i.e. pathogen-free status or to declare openly which disease-free status is or not guaranteed (basis for import refuse, conditions adjustment or lowering the price) and additionally to describe the sources used for guarantee declaration (test types, numbers, results, investigated target populations, their size, diseases’ history, proof of investigators’ independence, etc.);
i) must in the Code remove the section dealing with nonsense “OIE risk assessment” method admitting disease spreading and must replace it by a section of methods how to avoid disease introduction through international trade; similarly to be deleted in separate documents all chapters and provisions having nothing to do with international trade being the subject of internal solution of the member countries; the Code as international standard must be concentrated on sanitary conditions of trade being not merged in many other topics of non-trade importance;
j) must in the Code respect fully biological characteristics of particular disease species and their etiological agents diversity (including abnormal, e.g. resistant and newly arising strains) and dynamics in space and time considering that every case is different and consider the possibility of emerging diseases; therefore the OIE Code must be flexible and not rigid formal bureaucratic stereotype, often non-transparent and non-defensible, as it is today not respecting medical (epizootiological) approach and uncritically copying the WTO/SPS tricks and professional nonsense;
k) must in the OIE Code include also post-import guarantee period (normal in fair trade) and explicitly name specific diagnostic methods (in the OIE Manual in all indirect diagnostic methods must be mentioned the sensitivity grade, i.e. expected false negative results);
l) must in the Code respect first of all the normal structure of international trade, i.e. according commodity species and types;
m) must inform truthfully all member country governments and through global mass media the consumers and farmers about the reality of unfair trade spreading diseases, including transmissible to man, and about the future measures to avoid it;
n) must analyze critical situation in public veterinary services and recommend to member country governments (not only to Chief Veterinary Officers having not necessary authority and resources) to strengthen them significantly to be able to cope with new animal health tasks under new trade conditions;
o) must regularly analyze practical consequences of its policy, in particular of its Code, on global animal population health and present it to all member country governments with respective recommendations.
In the case of not changing the OIE policy back to protecting fully the health, then for the world animal and human populations’ health safeguarding it will be the only solution: to abolish this dangerous anti-sanitary organization (saving member countries’ money and avoiding duplicities) and to let the global animal health problems to the United Nations organizations responsible anyhow for global animal health – Food and Agriculture Organization and for global human health - World Health Organization.
The self-declared “World Organization for Animal Health” applying anti-sanitary policy in business service could continue only as a non-governmental private society or club financed by the members themselves.
18.6 The tragedy of the Code is that it is consciously avoiding to provide certain sanitary standard of the most important components of international animal trade, i.e. animal products, first of all food of animal origin, obviously not to complicate this kind of unilaterally profiting trade (the easiest trade in comparison with non-animal commodities) !
18.7 Commenting on the Code there is important not only what is written but also what is missing. This is much more important from the viewpoint of importing country health protection what is unfortunately absolutely underestimated confirming the basic anti-sanitary concept of the Code. Among the missing components belongs also sanitary conditions for food of animal origin (mainly foodborne diseases).
18.8 Considering the new conditions much more favourable for international propagation of animal diseases/pathogens than before, veterinary import conditions require to be much more demanding than in the past. Unfortunately, the post-SPS OIE Code has been made much more benevolent than before, i.e. exactly in opposite manner. Considering the increasing risk of the propagation through international trade of communicable diseases/pathogens able to reproduce and spread provoking diseases in animals and man, i.e. having multiplying negative effects, the veterinary import conditions require to be much more demanding than import conditions for inanimate commodities having not any similar dangerous characteristics. Unfortunately, the post-SPS OIE Code has been made much more benevolent than the import conditions for inanimate objects, i.e. exactly in opposite manner.
18.9 If the major exporting countries would be able to export epizootiologically healthy (i.e. pathogen-free) animals and pathogen-free animal products then WTO/SPS and the anti-sanitary OIE Code would never come into the world !
In this theoretical case the OIE could have the programme of globalization of animal specific health instead of today’s globalization of animal communicable diseases through OIE Code for international trade ! In this case the exporting countries would be motivated to control and eradicate animal diseases of trade importance (at least internationally notifiable), intensify disease monitoring, surveillance and reporting as much as possible to inform importing countries (to convince them about reliability of health guarantee documents), strengthen government animal health services to be able to investigate consistently exporting commodities and to issue relevant health guarantee documents themselves. Shortly, to apply normal fair international trade on bilateral agreement based on full (required) quality guarantee issued by professional fully independent on the producer/exporter where the final word has the importing country - purchaser.
The extremely wordy (many tens of thousand words) OIE Code doesn’t know the words “healthy animals” and “pathogen-free animal products” ! These terms in the Code do not exist at all = documenting that the OIE actual policy is not interested in consistent protection of animal health in importing countries!
18.10 Nobody having fair intentions wants the next generations to blame our generation for worsening animal population health global situation with non-reparable, multiplying and long-term up to lasting sanitary and ecological negative consequences. The exception is represented by the OIE (even self-declared as the “World Organization for Animal Health” – probably it would be more appropriate “World Organization for Animal Diseases Spreading and Globalization”) ! It seems that the OIE has become an important component of uncontrollable power of the richest countries and supranational monopolies over the powerless countries. It is obvious that the OIE has been in business service and not in the health service.
18.11 The result of the OIE policy is the spread of almost all animal communicable diseases from exporting countries due to incredible benevolence of the OIE Code, not requiring full sanitary quality, i.e. pathogen-free export. The spread of diseases introduced through trade in importing countries which are usually unable to control and eradicate them. As the consequence of this anti-sanitary policy the animal population health in the world has been significantly worsened, specific disease-free populations and territories have been significantly reduced and
globalization of animal communicable diseases has become irreversible !
PRIMUM NON NOCERE !
First, do not harm !
OIE Animal Health Codes for International Trade:
First Edition, 1968
Second Edition, 1971
Third Edition, 1976
Fourth Edition, 1982
Fifth Edition, 1986
Sixth Edition, 1992
Special Issue 1997
Seventh Edition, 1998
Eighth Edition, 1999
Ninth Edition, 2000
Tenth Edition, 2001
Eleventh Edition, 2002
Twelfth Edition, 2003
Thirteenth Edition, 2004
Fourteenth Edition, 2005
Fifteenth Edition, 2006
Sixteenth Edition, 2007
Seventeenth Edition, 2008
Eighteenth Edition, 2009
OIE (1996-2005): World Animal Health yearbooks, OIE, Paris
FAO/WHO/OIE (1980-1995): Animal Health Yearbook, FAO,
Acha P.N., Szyfres B. (1987): Zoonoses and Communicable Diseases Common to Man and Animals. PanAmerican Health Organization, Washington. 700 pp.
Kouba V. (1996-2003): Warning letters. http://vaclavkouba.byl.cz/warnings.htm
Kouba V. (2003): Factors facilitating animal disease spreading through international trade. http://vaclavkouba.byl.cz/tradefactors.htm
Kouba V. (2003): Comercio internacional y la globalizacion de las enfermedades animales.
Kouba V. (2004): Abuse of disease import risk assessment method facilitating disease export. http://vaclavkouba.byl.cz/riskassessement.htm
Kouba V. (2004): Book Review “Handbook on Import Risk Analysis for Animals and Animal Products”, OIE. Acta Veterinaria Brno, 73: 549-551
Kouba V. (2005): Book Review “Terrestrial Animal Health Code 2004”. Acta Veterinaria Brno, 2005, 74 (1):161-1963. http://www.vfu.cz/acta-vet/vol74/74-161.pdf
Kouba V. (2007): Book Review “Terrestrial Animal Health Code 2005”. Acta Veterinaria Brno, 2006, 75: 481-483.
Kouba V. (2007): The OIE – International Organization for Animal Infection Globalization ? http://vaclavkouba.byl.cz/orgglobalization.htm
Morley R.S. (Editor) (1993): Risk Analysis, animal health and trade. OIE Revue scientific and technique, vol. 12, No 4, 390 pp.
Toma, B. et al. (1999): Dictionary of Veterinary Epidemiology, Iowa State University Press Ames, p.147.
Thiermann A. (2004): “Emerging diseases and implications for global trade.” Rev. Sci. Tech. Off. Int. Epiz., Vol. 23 (2).
Zepeda C., Salman M., and Ruppaner R. (2001): “International trade, animal health and veterinary epidemiology: challenges and opportunities” .Preventive Veterinary Medicine, 48: 261-271
1. The author is sometimes using the terms “crime” and “criminal” for man-made conscious support of spreading of communicable animal diseases and their pathogens through international trade causing deaths and suffering of humans and animals in importing countries.
These terms fit when comparing the OIE Code conscious consequences of imported pathogens killing continuously incalculable number of innocent human beings in all the world with local momentaneous assassination of individual persons (criminal murderer is punished somewhere even by death penalty). The OIE Code policy consequences could be compared with mass murders and human casualties during to the wars.
Similar comparison could be applied on the OIE Code continuous consequences in a form of mass suffering and deaths of millions and millions of animals affected by imported pathogens with individual cases of locally affected animals.
The worse is that the OIE HQs staff and the responsible OIE officers know very well about this reality (they have been many times warned about this and can get all information on the OIE Code criminal consequences). They have been doing absolutely nothing to stop this anti-sanitary policy and instead they are defending this criminal policy of conscious disease globalization using untruthful demagogical “arguments”. In spite of false tricky declarations, they are not interested at all in protecting and improving global animal population health ! Therefore, the illegal self-nominated as “World Organization for Animal Health” (!?!) is de facto real World Organization for Animal Disease Spreading. There is no doubt that the irresponsible well paid authors are thick-skinned and that they sleep tranquilly (why bother about the future ? “pereat mundus!”). There is one Latin proverb which could be applied in this case: “Piscis primum a capite foetet.” (Fish stinks from the head first.). How the irresponsible OIE officers could be “judged” ? The answer is left to the reader !
In this context, there is also a question about the behaviour of the responsible officers of the other international organization such as WTO, FAO and WHO knowing about the mass spreading of diseases through international trade and doing nothing to block it ? How the irresponsible officers could be “judged” ? The answer is left to the reader ! (In civilized countries even the refuse the help to urgently needed wounded person is classified as a crime.)
What about the treachery of the OIE original anti-epizootic policy replaced illegally by anti-sanitary post-SPS programmes supporting (even organizing) the overwhelming majority of animal diseases/pathogens to be spread through international trade. The OIE has been sold to international trade business.
2. This website has been used due to the fact that the OIE has not considered any critical scientifically justified analyses, comments and recommendations sent during previous years to its Directors Generals (see “warnings” on the same website). There is a taboo for any critics which could “offend” the WTO/SPS and follow-up OIE policy. Sending letters to the WTO and OIE asking to correct this unfair anti-sanitary trade policy contributing to disease spreading and globalization has proved as “banging head against a brick”. The barrier is too strong. Almost all leading WTO, OIE and FAO posts related to international trade in animals and animal products are in the hands of the experts from the major exporting countries. The amount of global legal animal trade has reached more than 100 billion US$. This doesn’t need any comments. Under actual conditions is almost unimaginable that the OIE would accept and publish any critical analysis of the Code. The principle “audiatur et altera pars”, i.e. to respect the opinion of non-OIE experts, importing countries, their farmers and consumers, is obviously for the OIE without any importance. The fear of the truth, what would complicate actually relatively “easy” and highly profiting animal trade of major exporting countries being unable to guarantee pathogen-free animals and animal products, is too great. The same is valid for relevant international journals in the hands of major exporting countries.
Also the suggestions the author was sending almost every year to DG OIE to correct a series of professional nonsense, such as confusing rinderpest in cattle with enterovirus encephalomyelitis in pigs published in all World Animal Health yearbook issues from 1997 up today (2004), have been left without any attention. This is other reason why the author decided to use his own website.
Author’s critical analyses and comments hold the “mirror” up to the OIE (in particular the OIE Code), when it itself is not willing at all to carry out its own critical autoevaluation (as it hypocritically requires from the member country governments) due to the fear of discovering its conscious damaging of global animal health in business service.