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
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
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.
---------------------------------------
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
Amendment on
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
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 (
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