11 March 2007 Latest amendment
on
OIE dominating officers: “Importing countries do not need to know real
animal diseases’ occurrence in exporting countries” = supporting export/import
of non-healthy animals and non-pathogen-free animal products
(Provisional text)
V. Kouba
1. The most important role of the International Office of Epizootics (OIE) is to collect, collate and provide to member country governments the best possible information (in terms of quality and quantity) on animal diseases’ occurrence, including its grading, as required for anti-epizootic decision-making, first of all for identifying veterinary import conditions and measures to avoid the introduction of diseases/pathogens through international trade in animals and animal products.
The OIE dominating officers from the major exporting countries, not knowing real animal infection occurrence at home as well as having very weak government services unable to control effectively animal infections and unable to guarantee pathogen-free export, are behind the minimization of OIE animal health occurrence information to be available to importing countries. Instead to guarantee controllable sanitary quality of exporting commodities, they push through the OIE different tricks such as uncontrollable sanitary measures’ equivalence, not quantifiable risk assessment without information on exporting country sanitary situation. Their basic idea is to minimize active surveys and pre-export etiological investigations representing a risk to discover undesirable reality – animal-carriers and/or so-far unknown outbreaks complicating or making impossible the export. Therefore, they deliberately create false atmosphere that the knowledge of animal infections’ situation in exporting countries is for importing countries not necessary and refer to the possibilities to apply post-import recovery sanitary measures.
2. When studying
the OIE information systems from 1996 up to the “new” WAHID (World Animal
Health Information Database) lunched in April 2006 the author was surprised why
they contain minimum or zero information
on the most important factors for importing country governments‘ decision on the selection of
exporting countries and for the identification of sanitary import conditions
for animal commodities. At the same time the WAHID is extraordinary overloaded
by enormous number of data representing, not only for importing country
governments, unnecessary ballast not usable for practical follow-up
decision-making.
3. It is logical
that for importing country governments’ decision based on normal classical risk
assessment (not using the nonsense cunning tricky OIE Code methodology without
the key information on exporting country) is absolutely necessary to know as
best as possible animal diseases‘ occurrence situation, i.e. at least the true
(real) incidence and prevalence of internationally reportable diseases in places
of commodity origin, i.e. in the exporting countries.
4. If we study carefully the statements of some of the most
influential OIE “officers” about “no need” for information on the occurrence of
internationally reportable diseases in places of commodity origin then we can
understand better the OIE policy minimizing up to
avoiding informative value for the importing country governments of the OIE
“information system” (better to call it crafty “non-information system”) for
importing country governments’ decision about veterinary import conditions.
There is not any doubt that this “system” is confusing and “blinding” importing
country governments in spite of significantly improved forms of the OIE internet websites.
5.1 First indication of this antisanitary concept minimizing information on diseases’ occurrence the author met in the OIE Scientific and Technical Review, Vol. 12,
No 4, 1993 entitled “Risk analysis, animal health and trade”
coordinated by R.S. Morley (Canada) where in 16 papers were presented pure
theoretical methods for disease introduction risk assessment. One of the papers,
entitled “Risk analysis and the
importation of animals and animal products” based mainly on risk
quantification fantasy, was written by Dr
Stuard C. MacDiarmid (
5.2 The author had the chance to discuss this professionally
unacceptable concept with Dr MacDiarmid, the author or co-author of the “risk
assessment trickery”, during World Veterinary Congress in
Perhaps
his “concept” was linked with the fact that
.
The
full texts of two letters sent by the author to Dr MacDiarmid reacting to his
letters and discussion see in http//vaclavkouba.byl.cz/warnings.htm.
More
information on the same website in “OIE abuse of disease import risk assessment
method = facilitating disease export” – http://vaclavkouba.byl.cz/riskassessment.htm.
5.3 In 2004 Dr MacDiarmid
was “promoted” to the post of the
Secretary General, OIE Terrestrial Animal Health Standards Commission. His antisanitary opinions are reflected not
only in the OIE “new” information system (offering less regular data on all
internationally reportable diseases needed for importing country governments’
as a decade before) but also in the OIE Code preferring major exporting
countries at the expense of animal and human health in importing countries. Instead
of admitting importing country to require import of healthy animals and
pathogen-free animal products, the WTO/SPS and OIE Code imposed on these countries
the “duty” to justify “scientifically, transparently, logically, etc.” the
risk. There is generally known that theoretical risk assessment is not
quantifiable, i.e. not defensible theory. Therefore, the exporting countries have
got very favourable position facilitating and supporting export of also diseases/pathogens
when referring to the WTO/SPS and the post-SPS OIE Code.
6.1 Dr MacDiarmid is also the co-author of the OIE Handbook
on Import Risk Analysis for Animals and Animal Products, International Office
of Epizootics, 2004. The publication is based on pure theoretical
methods without any previous testing and any proof of practical feasibility for
member country governments. The governments could understand this publication
as a “pseudo-scientific fantasy”, in spite of the Director General demagogical Foreword
that it “will provide practical guidance
to Veterinary Services confronted with the need to analyse the risks posed by
import”. Practical risk analysis is an extremely complex process
considering non-quantifiable multi-aetiological biological phenomena influenced
by many factors, first of all disease
occurrence in exporting country, which the Handbook didn’t take into account at
all. Even every scholar knows that
any risk starts at the hazard location, i.e. in our case in exporting country !
6.2 The authors are 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 trying to
defend for any cost the relatively easy exports at the expense of health in
importing countries being supported by OIE Code antisanitary policy. 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 first full quality (100 %) standard and
to exclude from export those who are not able to guarantee required quality of
the goods !
6.3 The OIE Handbook “instructs” the importing country governments 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 diseases’ occurrence and control, on the independence of attest issuing veterinarians and on sanitary guarantees. Today importing country governments have minimum or no information at all on the occurrence of diseases in the exporting country and on other relevant factors. The OIE World Animal Health yearbook informs that many major exporting countries have no information on the majority of internationally notifiable diseases existing in their countries.
6.4 In the OIE Handbook it can be found also following sentence: “ The framework used in this model (
7. In the Handbook Foreword
Note: 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 !
8.1 "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
Prof.Dr
Vincenzo Caporale was Secretary General, OIE Foot and Mouth Disease and Other
Epizootics Commission and actually
President, OIE Scientific Commission for Animal Diseases. He is the Director
of Instituto Zooprofilattico
Sperimentale d’Abruzzo e del Molise “G.Caporale”, Teramo, Italy serving from
1989 as FAO Collaborating Centre for Veterinary Epidemiology and Informatics
(selected personally by the author of this paper when he was the Chief, Animal
Health Service, FAO after his visit on 23 February 1989 accompanied by Prof. Dr
8.2 The above statement
belongs among those preparing the “new” antisanitary policy of the WTO/SPS and
“new” OIE Code admitting diseases/pathogens spreading through international
trade. Thank this perverse “philosophy” the global epizootiological situation
has become much worse than before. This concept of “free circulation of animals and
their products” is reflected also in the policy “doing nothing” and
letting animal diseases to affect incalculable number of animal and human
beings being affected by imported pathogens. The question is why to have and to
pay an “intergovernmental” organization for diseases spreading causing mass
suffering and deaths burying population veterinary medicine.
The most
instructive example of this “concept” is the African swine fever introduced in
Italy (member of the European Union) in 1978 without any eradication up today
(after three decades), however the pork export is flourishing without effective
control, if any. This system letting disease spreading through international
trade without any sanitary guarantee has been applied in the European Union –
as diseases’ European regionalization instead of expanding animal populations
and territories free of specific diseases = “doing nothing” policy. Where are
the Italian
government, European Union, OIE Commission for
Europe, OIE HQs specialists, etc. ? More information on this deterrent example
see in http://vaclavkouba.byl.cz/orgglobalization.htm
- paragraph 2.10.
8.3 The above statement of
Professor Caporale is also behind the absurd reduction of the OIE international animal health information system
on diseases’ occurrence. According to this very dangerous “concept” the system would be not necessary at all and public veterinary services
as well as the OIE could be abolished saving money to member country
governments.
The
veterinary control inside of the EU is usually formal, minimal or zero
following the above mentioned “philosophy”. The border control disappeared as
well as the control of animal and animal product transfers among different
units located in different countries belonging to the same supranational
organization. The effective supervision by government services is almost non
existent, if any. E.g. The UK reported on 5 February 2007 an outbreak of highly
pathogenic avian influenza (start of event on 27 January 2007) in a turkey farm, Molton, Suffolk county
belonging to the poultry concern Bernard Matthews; the virus H5N1 was reported
as imported by turkey meat from a unit of the same owner in southern Hungary
where this disease was discovered before (start date: 19 January 2007, report
day: on 12 February 2007 and reported to the OIE on 13 February 2007; previous
occurrence was in June 2006). It is obvious that the weekly „internal“
transport of this commodity (within the concern organization structure and
circulation) was outside of government
service inspection. This case also demonstrates the delay in reporting to the OIE,
even in the case of extraordinary sanitary importance !
This case demonstrates the
consequences of the above anti-sanitary concept of free circulation of animal
commodities including pathogens of communicable diseases = irreparable mass
spreading even of the most dangerous diseases. This professionally unacceptable
approach is reflected also in „almost doing nothing“ to eradicate dangerous
animal diseases.
9.1 Dr A. Thiermann (
Example: In the WAHID website dated 1 June 2007 it can
be found following information, or better no information, on animal disease
occurrence in the USA - home country of Dr A. Thierman: “Animal health
situation in 2005 and 2006: “United
States of America – No information.”. “Country sanitary situation in 2005
and 2006: “There is no report for
9.2 Dr A.
Thiermann in his paper entitled „Adapting
veterinary infrastructure to meet the challenges of globalization and the
requirements of the World Trade Organization Agreement on Sanitary and
Phytosanitary Measures“ published in OIE Review Scientific and Technique,
Vol. 23 (1) April 2004 on “Veterinary institutions in the developing world:
current status and future needs” is
stressing, without any proof, how the implementation of this document is
and will be „maximizing the benefit of
globalization.“. This is the same trick as WTO/SPS promising preamble "Desiring to improve the human health,
animal health .. in all Members;" while in the whole document there is no one word for the health improvement (perhaps expecting
that “thousand times repeated lie becomes the truth”). On the contrary, WTO/SPS was written only to facilitate the export
of non-healthy animals and
non-pathogen-free animal products, i.e. diseases/pathogens’ export,
through converting original very useful OIE Code recommendations for free
decision-making into obligatory limits reducing importing country sanitary protection.
Dr Thiermann doesn’t document any benefit of the globalization
as far as animal health protection and improvement in importing developing countries
are concerned. Defending WTO/SPS is admitting spreading of animal diseases
through „unrestricted trade“ (!?). The WTO/SPS has caused incalculable numbers of newly
affected animals and persons by “legally” imported pathogens conducing to
disease globalization = man-made irreparable global sanitary and ecological
disaster. The author is uncritically repeating the provisions of WTO/SPS
without any objective (scientific) convincing arguments/facts and without any practical
recommendations beneficial to developing importing countries’ health. The globalization benefit of the mentioned document
is only for the exporting countries while this kind of “globalization” is
causing irreparable damage to the world
animal population and to importing countries in particular. The question is if
the OIE is still animal health protection organization or not. According to the
OIE Code impacts on animal health the answer is “not”.
There is only one way for „Adapting veterinary infrastructure to meet the challenges of globalization” : to strengthen significantly government animal health services to be able to protect healthy herds and populations, to control, eliminate and eradicate communicable diseases as well as to establish very strict uncompromised supervision of private veterinarians issuing export documents and thus to guarantee the export of healthy animals and pathogen-free animal products. Unfortunately, this logical requirements are contra all antisanitary efforts of the OIE in business service spreading animal diseases through international trade.
The author
doesn’t mention any practical steps for „Adapting
veterinary infrastructure to meet …. the requirements of the World Trade
Organization Agreement on Sanitary and Phytosanitary Measures“. This was
left only as theoretical statements steadily repeating the WTO/SPS provisions
not considering at all that they are not scientifically based, not transparent,
not convincing and without any assessment of the risk for animal and human
health and evaluation of their negative impact on the health during the last
decade.
9.3 Also according to Dr A. Thiermann importing country governments do not need information on real diseases’
occurrence in exporting countries. However, the OIE Code senselessly requires “convincing risk assessment”
to be elaborated by the importing countries having no information on the risk
factor in the origin of animal commodity. Above mentioned theoretical categorization
of a country/zone status represents from practical point of view a further OIE steps
avoiding to inform on diseases’ occurrence in exporting countries and thus to confuse
importing country decision-makers. However, the OIE is absolutely avoiding to mention terms “healthy animals” and “pathogen-free animal
products” and define their basic identification. Among many ten thousands of pages of OIE documents and
publications there has been even no once mentioned the need for trade in healthy animals and in
pathogen-free animal products !!!
9.4 The extremely very dangerous “philosophy” conducing to global irreparable
spreading of animal infections, as presented and promoted unscrupulously by Dr
A. Thiermann abusing his very high post in the OIE, is obviously not valid for
his home country being unable to control animal import *)! Latin proverb “Hic Rhodos, hic
---------------------------------
*)„The magnitude of the global movement of animals is
staggering. In terms of sheer numbers, 37,858,179 individually counting live
amphibians, birds, mammals and reptiles were legally imported to the
9.5 Dr A.
Thiermann biography documents his almost key role in international animal trade
policy facilitating the export without any guarantee for infection free animals
and their products conducing consciously to animal infection spreading and
globalization. He has been defending the interests of the major exporting
countries, mainly
9.6 Dr A. Thierman, belonging among the OIE
leading officers responsible for catastrophic irreparable spreading of animal
infections in the world during last two decades, has been still negatively
influencing global veterinary medicine. This time applying double meter for
animal health problem solution: At the World Pork Conference (2011) «he was warning that the African swine fever
in
----------------------
*) see http://vaclavkouba.byl.cz/WTOTEXT3.htm.
10.1 K. Ben Jebara, Head, Animal Health
Information Department, OIE in his paper ”Surveillance, detection and responses:
managing emerging diseases at national and international levels” published
in Rev. Sci. Tech. Off. Int. Epiz.,
Vol. 23 (2) August 2004 didn’t
consider that information on animal diseases’ occurrence
provided by the OIE is absolutely
insufficient. There is significantly less information than a decade ago, and that some very important
zoonoses such as food-borne diseases are not monitored at all by the OIE. In
spite of being responsible for the OIE animal health information system, he
continues in consciously publishing minimum data on animal diseases’ occurrence
to “facilitate” trade at the expense of animal health in importing countries.
He is trying to expand and improve the system only formally, i.e. using modern
computer methods and nice coloured websites, however without any improvement as
far as the key and decisive information on animal diseases’ occurrence ! Obviously,
he is of the same opinion as the above mention OIE officers, i.e. he is also supporting in practical way the “concept” that importing
country governments do not need for the decision on animal commodity import the
information on real diseases’ occurrence (risk sources) in exporting countries.
10.2 He stressed
the need to established at the central veterinary administration a “veterinary
epidemiology units” for surveillance and monitoring (this “need” has been
published by the OIE many times during last two decades). The question is what
kind of data it will process and report when the knowledge of epizootiological
situation is unknown or known only very superficially? For sending to OIE that
the disease occurrence = “+” and “…” i.e. “no information available”, there is
not any need for such an unit only for statistical calculation of not reliable
data (garbage
in, garbage out) and for producing paperwork for drawers. Practical
epizootiology or veterinary epidemiology as well as disease reporting are based
on field work and not on administrative activities. The absurd reduction of
disease reporting has nothing to do with real epizootiological
(epidemiological) work and makes almost impossible to assess disease situation
in exporting countries as basic information for any disease import risk
evaluation to be carried out by importing country governments.
11. Examples of not
respecting any suggestions to improve OIE information system: From the letter
of Dr Vallat, Director General, OIE
dated 20 December 2001 to Prof. Kouba: Subject – Improvement of the OIE Global
Animal Health Information System: “So
starting from January 2002, a new department will be dedicated to address the problems
mentioned in your letter (15/12/2001). I am pleased to inform you that your
letter was transferred to Dr Ben Jebara,
the Head of the Animal Health Information Department, and that I am sure
that many of your comments will be taken into account while developing the
activities of this new Department.”.
As usually before, when Dr Jean Blancou was DG OIE and Dr Tierry Chillaud was the responsible
officer for this field of the OIE HQs activities, no one of the recommendations
(including to correct professional nonsense) was accepted. It is obvious that there has not been any good will for improving
information system to provide necessary information for the decisions on import
conditions. Dr Ben Jebara obviously belongs among the OIE “armchair”
theoretical bureaucrats having not good idea what member country governments
need for their highly practical decision-making or serves consciously to
exporting countries’ lobby to keep his good job.
12. Now importing countries have much less regular information about
disease occurrence data for decision making than before ! The author’s letter protesting
against this unfair and not responsible decision about this non-interpretable
symbol “+” was answered by the letter of
Dr Jean Blancou, Director General,
OIE to Prof. Kouba dated 30 October 1998 that it was: "the result of
discussions by eminent specialists on risk analysis… to can standardize risk assessment”. (From "+" ??). It
was obvious that this “standardize risk assessment” couldn't be realized by the
member country governments for logical, professional and practical reasons,
i.e. = nonsense. The theoretical "eminent specialists" obviously
didn't understand practical problems of international trade needs what has been
proved dramatically during recent events (FMD, BSE, etc.) or had not necessary
knowledge on epizootiology (veterinary epidemiology) principles and practical
requirements targeted at the protection of animal and human health in importing
countries. They most probably implemented the “task”
of the major exporting countries and their lobby to avoid pathogen-free animal
export.
More information in http://vaclavkouba.byl.cz/oiecode.htm and http://vaclavkouba.byl.cz/globsurveillance.htm .
13. The OIE Code, as a bad example, is naturally strongly influencing import sanitary conditions for animal commodity trade at bilateral as well as multilateral levels. Instead of specifying the import quality conditions to be guaranteed and understandable to all users, there are used “cleverly” uncontrollable general formulations (often referring to currently not available documents) having minimal information value for importing countries and their farmers/consumers. How can importing countries assess the risk of infections/pathogens introduction, as required by the OIE Code, having no any data on specific infections in exporting countries? This type of camouflage represents other form facilitating easy and highly profiting export regardless of sanitary quality, i.e. guaranteeing nothing ! This type of very vague formulations is only a non-documented information not representing at all any sanitary guarantee. The farmers/consumers have not any chance to study the incredibly overcomplicated international documents, being almost not available and under permanent changes.
Deterrent example from a country belonging
in the OIE among the most influential ones (two key posts – OIE President
and Secretary General, OIE Code Commission]: New Zealand is exporting
meat to the European Union with “Animal and Public Health
Certificate” (TZ-2006/12-PRO2 New Zealand) having
following text: “The animal products
herein described, comply with the relevant New Zealand animal health/public
health standards and requirements which have been recognized as equivalent to
the European Community standards and requirements as prescribed in Council
Decision 97/132/EC, specifically, in accordance with the Food Act 1981, Biosecurity
Act 1993 and Animal Products Act 1999.” This is all !? No one word what is guaranteed, i.e. no any sanitary
guaranty ! How can the
importing country and the users understand if the commodity is free or not of
infection pathogens, namely of foodborne disease ones (e.g. is the commodity
free of Salmonella or not ?) ? To what
kind of etiological investigations the commodity was subjected? What about
their size (incl. the grade of
representativeness) and results ? Is the commodity free of all
infections, or only of all internationally reportable infections or only of
some selected infections (which ones) ? In the above mentioned “certificate”
there is not any answer expected by the importers and consumers. How can importing EU-member country government decides freely
about the import from opposite part of
the globe having not any information
for infection introduction risk assessment?
The “agreement” is “cleverly” formulated, in a form of deliberate camouflage, to avoid any doubt about
commodity sanitary status (no chance for the complaints) or the refusal due to
sanitary reasons or due to missing necessary infections occurrence information.
If we
look in the newest OIE global animal health information system (WAHID) for the
comparison of sanitary situation between any importing country and the New
Zealand as exporting one, then we can find for the year 2005: “There
is no report for New Zealand” (WAHID website dated 3 February
2007). The same system reported on animal health situation: “
14. The
result of the OIE activities, based on the above mentioned opinions of some
leading OIE officers, is the globalization of animal diseases and not
globalization of animal health as one would expect from an intergovernmental organization
established for animal health protection and improvement in the world. The OIE
has not any global programmes for controlling and eradicating any major animal
disease. The global rinderpest eradication programme has been organized by the
FAO while the other diseases are unfortunately propagated through international
trade thanks to the OIE antisanitary policy.
15. Any fair international
trade is based on practical very concrete information including convincing
absolute data on the commodity quality to be exported.
Only exception - unfair international trade is
applied by the WTO/SPS and OIE for animal commodities ! This
dangerous policy is based on abstract theory, estimates, speculations, modelling,
artificial classifications and definitions as well as on pseudoscientific non-quantifiable
assumptions, phantasy or hypotheses elaborated by “armchair” irresponsible
bureaucrats! They are “cooking up” new and new complications for importing
country governments to “facilitate the trade”!
The fair trade principles must be valid also
for the export of in animals and animal products as far as the sanitary quality
is concerned ! Unfortunately, this is not the case of the actual OIE in spite
of its self-declaration as “World Organization
for Animal Health”.