Letter dated 26 April 2006 from Foodaware to Navjit Mudhar, Emergency Preparedness & Exotic Disease Control Team, Defra:

Dear Ms Mudhar

Defra Consultation on plans to implement Council Directive 2005/94/EC on the Control of avian influenza

Foodaware has been following closely the progress of this disease from the Far East to Europe, and is aware of the ongoing risk that high pathogenic strains of avian influenza (HPAI) may in the future be found in wild birds, farmed poultry, pigs and game in the UK. If this happens there are recognised risks to the public of a human flu pandemic, of disruption to supply of poultry (a comparatively cheap and valuable source of protein) and of serious economic consequences for the poultry industry and rural communities. We have supported the ongoing strategy of monitoring the worldwide situation and of planning preventive measures which can be implemented immediately the disease is detected. Since transmissibility between people might arise either by mutation, or by genetic re-assortment between avian and seasonal human flu, we suggest that regulations, perhaps at European level, should make vaccination against seasonal influenza obligatory for people working with poultry, including vets, to protect the public at large.

We recognise, however, that it is essential for Defra to have a range of powers available so that it can take appropriate action quickly when the disease appears in the UK (as in the recent isolated incident in Scotland) and to remain vigilant while the risk is significant. To that end we welcome and support the implementation of the EU Directive, which will provide additional powers to control the disease and a degree of flexibility in how they are used, depending on the circumstances in which avian influenza is found and the strain of virus. As the Directive has already been adopted by the European Community, we believe that it should be implemented in its entirety in the UK. We note that the date by which the UK must comply is July 2007 but consider it is essential that this legislation is implemented as quickly as possible, if practical, so that it can have immediate effect.

It is intended that the powers embodied in the Directive can be used where appropriate. Vaccination may be permitted subject to agreement with the Commission on a plan. Consumers will wish to participate in the ongoing discussions about how the legislation is to be applied in practice, and particularly the circumstances in which vaccination may be considered appropriate, as a preventive or protective measure in domestic or farmed poultry and other animals. Foodaware does not oppose vaccination where necessary as part of an effective control strategy, but would want to know that it would only be used where its effectiveness is assured, there are no risks to human health from use of the vaccine, and there is no preferable alternative. There should also be further discussion on the need for, and potential to, control low pathogenic strains of AI (LPAI). LPAI has already been found at very low levels in the wild bird population in the UK and is also covered by the Directive.

We note that the EU Directive requires infected animals to be slaughtered in certain circumstances and support the clarification in UK legislation that the power given to Ministers should only apply ‘in the relevant circumstances’. We understand that ring fencing, for example, may be necessary and access to areas and farms restricted but it is not a power which we expect to be exercised lightly.

Co-ordination between the EU, Defra and the administration in Wales, Scotland and Northern Ireland to plan for and implement emergency action in the event of an outbreak must be sustained as the disease will not respect administrative boundaries.

Foodaware strongly supports improvement in biosecurity on farms and would like the relevant provisions in farm assurance plans to be strengthened and effectively implemented. The additional powers which Defra seeks, in order to introduce preventive measures which would require separation of poultry from wild birds if a risk assessment shows a significant risk that the disease may spread, seem eminently sensible. A balance will need to be struck between the requirement to slaughter and other preventive measures. For example, while we recognise that there will be practical difficulties and welfare implications of requiring poultry to be kept indoors, this may be preferable to the uncertainties associated with vaccination, depending on the circumstances. If it becomes necessary to house birds to control the spread of disease, some poultry may lose its organic status but we believe that disease control must take precedence and the integrity of organic systems should not be compromised by changing the standards in the event of an outbreak. There may also be implications for labelling and distribution systems so that the public is not misled about the status of poultry for retail sale.

The power to ban gatherings of birds subject to risk assessment and a licensing system is also appropriate and may be necessary. Movement restrictions and power to close footpaths within a protection zone may also prove necessary as part of biosecurity precautions in the event of an outbreak. They should only be applied when absolutely necessary because of their impact on rural life. The veterinary risk assessment should be undertaken on an area or locality basis within the context of the national strategy.

Foodaware is content for this response to be made publicly available.

Yours sincerely

Susan Knox
Chairperson