OIE ABUSE OF DISEASE IMPORT RISK ASSESSMENT METHOD SUPPORTING INFECTIONS/PATHOGENS’ LONG-DISTANCE (INCL. INTER-CONTINENTAL) SPREADING

Book Review ACTA VET. BRNO 2004, 73: 549-551

Handbook on Import Risk Analysis for Animals and Animal Products, International Office of Epizootics, 2004

Volume 1 – Introduction and qualitative risk analysis – ISBN 92-90944-613-7

Volume 2 – Quantitative Risk Assessment – ISBN 92-9044-626-7

Attached: Amendment on 6. January 2012

The Handbook was elaborated by N. Murray (Ministry of Agriculture and Forestry, New Zealand - NZ) as the Chief Author together with Co-authors: S.C. McDiarmid (from the same Ministry), M. Wooldridge (UK), B. Gummow (South Africa), R.S. Morley (Canada), S.E. Weber (USA), A. Giovannini (Italy) and D. Wilson (Australia), Head, Department of International Trade, OIE, Paris.

The Volume 1 consisting of 57 pages has the following structure: the first chapter containing the introduction to import risk analysis is subdivided in: approaches to risk analysis, import risk analysis for animals and animal products, World Trade Organization (WTO) Agreement on the Application of Sanitary and Phytosanitary Measures (the SPS Agreement, 1994), Terrestrial Animal Health Code and Aquatic Animal Health Code. The second chapter on managing a risk analysis project deals with conducing the risk analysis, developing a risk communication strategy, determining the scope of a risk analysis, the OIE risk analysis framework, terminology, acceptable risk, transparency, uncertainty and variability, presenting the results, external risk analyses, updating risk analyses, quantitative methods complement qualitative methods, semi-quantitative methods and scenario trees. The third chapter on applying the OIE risk analysis framework describes hazard identification, risk assessment, release assessment, exposure assessment, consequence assessment, risk estimation, risk management and risk communication.

The Volume 2 consisting of 126 pages contains the following chapters: introduction to quantitative risk assessment, probability and probability distributions, theorem providing a basis for probabilistic risk assessment, useful probability distributions, probability processes and calculations, determining a distribution to represent a variable, introduction to second order modelling, and guidelines for developing a quantitative risk assessment. This volume is dedicated to a very sophisticated statistical theory not useful for normal practical assessment of disease import risk.

The publication is based on pure theoretical methods without any previous testing and any proof of feasibility for member country governments. The authors probably do not have a good idea about the reality in importing countries, in particular in the developing ones. The governments of some of these countries could understand this publication as a “pseudo-scientific fantasy”, in spite of the Foreword that it “will provide practical guidance to Veterinary Services confronted with the need to analyse the risks posed by import”. This publication risks the same fiasco of lacking practical applicability as other hundreds of theoretical papers on risk assessment published by the OIE (e.g. compendium “Risk analysis, animal health and trade”, 1993, of 334 pages; as usually, the authors were from the major exporting countries, including NZ - S.C. MacDiarmid and Canada - R.S. Morley). Practical risk analysis is an extremely complex process considering non-quantifiable multi-aetiological biological phenomena influenced by many factors that the Handbook has not taken into account at all.

The authors used as an instructive example a theoretical “risk assessment for the importation into NZ of horses infected with African horse sickness virus”. They did not consider disease occurrence and control in exporting countries and did not use any method described in the second Volume. Their methods are not even used by the authors’ home countries (double standard). For example, in January 2001 NZ prohibited import of beef from all countries of Europe not presenting any risk assessment document to these countries. According to OIE World Animal Health even the authors’ countries were unable, in spite of their risk assessments, to avoid disease import (e.g. BSE introduced in USA through legal import from Canada).

Original “zero risk approach” requiring to export healthy animals and innocuous products, i.e. pathogen-free, was causing serious difficulties to the major exporting countries due to many factors, such as lack of full knowledge of epizootiological situation, public services unable to control effectively this situation and trade being in the hands of almost uncontrollable private veterinarians, lack of successful control and eradication programmes, etc. These countries managed to find the “solution” through the WTO/SPS: if any importing country asks for healthy animals and their products to avoid disease introduction, it must present to exporting country risk assessment document to “justify scientifically” this normal quality requirement (!?). The OIE as follow-up changed its policy: “Import risk analysis is preferable to a zero risk approach.” (OIE Code 1997, article 1.4.1.1). The abused risk assessment requirements have become the main tool how to “facilitate export” of non-healthy animals and non pathogen-free animal products, i.e. without guaranteeing full sanitary quality. Handbook authors are even threatening importing countries that “zero risk importation policy would require the total exclusion of all imports” (!?).

A world wide campaign was started requiring importing countries to provide “scientific risk assessment” documents instead of requiring exporting countries to create conditions for exporting animal commodities in full sanitary quality. This policy started “legal” spreading of diseases through international trade favouring unilaterally to major exporting countries and discriminating the importing ones, first of all the developing ones. The Handbook belongs among documents supporting this very unfair anti-sanitary trade policy without regard to the health protection of animals and humans (consumers) in importing countries.

The Handbook “instructs” the importing countries how to elaborate “risk assessment” to convince exporting countries when demanding healthy animals and pathogen-free animal products. This publication does not consider at all that practical risk assessment needs first of all reliable data from exporting countries on occurrence and control of diseases, on the independence of attest issuing veterinarians and on sanitary guarantees. Today importing countries have minimum or no information at all on occurrence of diseases in the exporting country and other relevant factors. The OIE World Animal Health informs that many major exporting countries themselves have no information on the majority of internationally notifiable diseases existing in their countries.

The Handbook presents extraordinary demands on importing countries: “ The risk analysis must be well documented and supported by references to the scientific literature and other sources, including expert opinion, where used. It must also provide reasoned and logical discussion that supports the conclusions and recommendations. There must be comprehensive documentation of all data, information, assumptions, methods, results, and uncertainties.” The results’ presentation must: “explain the risk analysis model’s structure clearly with the aid of appropriate diagrams, such as scenario tree; document all the evidence, data and assumptions, including their references; use clearly labelled, uncluttered graphs, etc.“ Special attention is dedicated to the “titles, names and addresses, how to write the summary, how to write the text (using Oxford dictionary), references, tables and figures, etc.” Exaggerated requirements would need a special institution! There is no space for commenting other wordings such as “acceptable level of pathogens in food” (!?).

The simplest requirement for importing healthy animals and products does not need any “scientific justification”. On the contrary, the exporting countries, where the hazards exist, should 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” have not the right to decide freely about the purchase and to ask for full quality commodities. Thanks to abused risk assessment these countries must pay for imported commodities as for healthy also when they are non-pathogen-free.

This Handbook documents convincingly that the WTO/SPS and “updated” OIE Code were introduced with the only aim – to facilitate legal export at the expense 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 fair trade. The problematic risk assessment has been 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. The publication seems to be one of the most dangerous insidious trickery facilitating global man-made spreading of animal diseases. I wonder why the OIE has 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 no more valid ?). This conscious support of disease spreading represents a flagrant betrayal of Hippocratic oath of medical ethics based on restoring and protecting human and animal health.

Prof. MVDr Václav K o u b a, DrSc.

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P.S. :

The important role of New Zealand in preparation of the WTO/SPS and the “new” OIE Code avoiding zero risk trade and replacing it by theoretical risk assessment method to “facilitate trade” at the expense of importing country animal and human health (avoiding communicable disease-free export = starting “official” globalization of these disease) was reflected e.g. in the paper of J.A. Kellar (Canada) “The application of risk analysis to international trade in animals and animal products” published in OIE document “Risk analysis, animal health and trade”, Rev. sci. tech. Off. Int. Epiz., 1993,12 (4) :1035: “As a nation which is dependent on international trade, New Zealand has applied considerable effort over a number of years to risk analysis within both domestic and imported commodities. The country does not operate a zero risk importation policy … Instead, the more objective, analytical approach employed by New Zealand stands as a model for other nations. Through extrapolation, estimation and emphasis on the quantitative value of management techniques, New Zealand has come to grips with the issue of uncertainty. ..New Zealand feels that the sharing of methodologies through the OIE will facilitate the growth of theses applications.. ” Beside Dr MacDiarmid, who as the member of the OIE Working Group on Informatics and Epidemiology shares also the responsibility for significant reduction of global animal disease information system, other extraordinary influence had Mr Mike Moore, originally meat worker who became Prime Minister in 1990 ; as Trade Minister was very active in launching the Uruguay Round of GATT negotiations resulted in the WTO and in SPS document; in 1999 he became the Director-General of the World Trade Organization.

Amendment on 6 January 2012

Agricultura Tropica et Subtropica, Universitas Agriculturae Praga, 2012, Vol. 45, (1): 38-39

Book Review: The spread of pathogens through international trade, OIE Review scientific and technique, Vol. 30 (1) April 2011, ISSN 0253-1933, ISBN: 978-92-9044-837-2

The publication of 370 pages contains 26 papers edited by S.C. MacDiarmid from New Zealand, a key member of International Office of Epizootics (OIE) Terrestrial Animal Health Standards Commission. The title reflects the most important problem of global animal health - the mass spread of communicable diseases causing incalculable millions of sick and dead animals and humans due to pathogens introduced through international trade.

The document is subdivided in four blocks: international trade in animals and their products, risk characteristics, specific risks and how to mitigate the risk. The papers touch wide spectrum of trade in animals and their products, unfortunately without concrete data on the spread of pathogens through international trade and its analysis, i.e. the contents of this publication does not correspond with its title. The contributions are written by the authors from the major exporting countries dominating the OIE (USA 7, United Kingdom 6, New Zealand 4, France 3 etc.). The papers represent only compilations from selected publications uncritically supporting OIE trade policy facilitating spread of pathogens at the expense of health in importing countries. Publications and references critical to this policy are missing at all, thus confirming the absence of basic scientific principles such as audiatur et altera pars. The number of references fluctuate from 2 to 230 sources per paper. The minimum belongs to the paper of A.B. Thiermann, President of the OIE Terrestrial Code, with the same ideas repeated many times in previous publications and conferences, staunchly propagating World Trade Organization (WTO) policy conducing to spread of pathogens. One might get the impression that the OIE acts as in service of the WTO. Three articles are worth closer attention: A. Di Nardo et al. describing livestock trade pattern influencing routes of foot and mouth disease in Africa and Asia (with instructive maps), J. Watson et al. describing the 2007 outbreak and spread of imported equine influenza in Australia reflecting non-reliability of the „OIE risk assessment“ method similarly as the paper of A.J.M Garland and K. de Clerk informing on the 2001 foot and mouth disease spread from United Kingdom to Ireland, France and Netherlands using non-reliable „OIE model certificates“.

Not a single paper is seriously considering the natural ability of imported pathogens to reproduce and spread affecting enormous number of animals and humans of actual and future generations and thus multiplying all negative sanitary, economic, social and ecological consequences. The introduction of pathogens is relatively facile (even in one moment), however their eradication is very difficult if not impossible. No one paper is trying to analyze the important role of the OIE in spread of pathogens through international trade.

All authors, except one, refer to so called „risk assessment“ (5 papers have the „risk“ in title) when according to the „OIE standard“ the importing countries must present to the exporting ones scientifically based convincing justification of the risk if they refuse patogen-non-free import without full quality guarantee. Similar absurd requirement is unknown in any other commodity where the sellers must convince the buyers and not conversely. As the consequence the pathogen-non-free commodities imported obligatorily (even under threat of WTO penalty) are paid as for pathogen-free ones. It is known that this incredible trick, based on subjective estimate of non-quantifiable biological phenomenon, facilitating export of animal infection pathogens, was initiated by the Editor of this publication. He belongs together with R.K. Bruckner (author of two papers) to OIE group that eliminated in the middle of the 1990s international reporting on animal infections‘ import. In this way it was made impossible to analyze the spread of pathogens through international trade, to evaluate its causes and to expose or uncover the catastrophic “results” of OIE trade policy reminding of international terrorism. This artificial camouflage has prevented member country governments and world public from obtaining truthful information on global spread of pathogens through trade. Therefore, the authors could not present any new concrete data on the mass spread of pathogens through international trade and any scientifically based analysis of its causes. The same OIE group minimized reporting on occurrence of diseases (reduced to “+”) and making it impossible for importing countries to estimate realistically the disease introduction risk. This again facilitates the export of pathogens. At that time also government control services were minimized and were replaced by non-public ones generally known as less reliable and more susceptible to corruption. This fact multiplies the chance for the spread of pathogens through international trade.

No one paper comments on the „OIE standards“ not requiring trade in healthy animals and products (pathogen-free export), not requiring full quality guarantee certificates as it is normal in any other commodity, admitting and even supporting export of the pathogens. OIE model certificates require only sanitary information and not sanitary guarantee, i.e. guaranteeing nothing, and therefore the importing country cannot claim the introduction of pathogens and must solve the post-import losses itself. No one paper supports explicitly full sanitary quality export to avoid spread of pathogens through international trade.

We are witnessing a very well prepared trickery facilitating pathogen-non-free export at the expense of human and animal health in importing countries. The problem is not theoretically estimated uncontrollable “risk assessment” or its “mitigation” (i.e. admitting limited import of pathogens) as repeatedly mentioned in almost all papers. The problem is very practical - to avoid international spread of pathogens requiring to export healthy animals and their products, i.e. innocuous ones not creating post-import troubles. In spite of all my effort I could not find in the whole publication this normal requirement as well as even the words “pathogen-free animals” or “pathogen-free animal products”. On the other hand I could find many demagogical formulations such as “ensuring safe international trade” while it de facto means ensuring unsafe trade. The OIE benevolent trade policy facilitating export of pathogens has allowed in the majority of exporting countries to prefer the cheapest “doing nothing” strategy against animal infections worsening national animal population health.

The publication is exaggeratedly favourable to the OIE (“independent” inter-governmental organization outside of the United Nations) unfair trade policy conducing consciously to globalization of animal infections through international trade in contrast to the UN policy trying to improve global animal population health (e.g. global rinderpest eradication in 2010). The publication, reminding us of products of advertising agencies, as a whole supports without convincing arguments the OIE policy preferring export business before consistent protection of animal health against communicable diseases (OIE original basic duty) in spite of irreparable lasting disastrous sanitary impacts in the whole world. Conscious support or even organization of such spread of pathogens belong among criminal acts. Authors‘ warning and protesting letters see in http://vaclavkouba.byl.cz/warnings.htm. Scientific publications require well balanced approach based on objective truth supported by concrete data and not unilateral uncritical propagation of an organization (moreover, questionable) policy as it is in this case.

Václav Kouba