a European Community Animal Health Policy (CAHP) Strategy (2007-13)

European Community Animal Health Policy (CAHP) Strategy (2007-13)

CFG 30/06 final

Foodaware policy paper on a European Community Animal Health Policy (CAHP) Strategy (2007-13)

Conclusions and recommendations
Background information

Evaluation of specific policy areas:
  Intra-Community trade
  EU control and eradication programmes
  Border controls and imports
  Monitoring and surveillance
  Financial issues

Looking to the future
A consumer perspective

Our members acknowledge that early consultation with consumers is good practice and are pleased to have the opportunity to comment on Community thinking in this area.

Conclusions and recommendations

Foodaware members support the need for a strategic focus in the EU which establishes a coherent approach to animal health and places a high priority on controlling risks to human health. The EU is committed to a high level of consumer protection, and protecting individual health and safety are consumer’s highest priorities. A strategic focus would allow zoonotic diseases to be more effectively monitored and compared, and appropriate policies implemented to reduce disparities between Member States to the benefit of all. A coherent strategy should take account of the issues from farm to fork and must ensure appropriate linkage to existing Community rules.
The first priority should be to reduce the level of zoonoses, concentrating particularly on those diseases that cause serious infections in animals and human beings. The pace of change to date in the Community has been too slow and the entry of additional Member States increases the urgency for action.
Foodaware members take the view that measures to prevent animal disease are vital as are control measures once disease has been found. We support a risk-based approach but particularly recognise the value of prevention and believe that EU strategy should support preventive measures.
Producers are under a legal obligation to supply safe and wholesome food and therefore must carry the primary responsibility for ensuring their animals’ health and welfare, and implementing appropriate management systems on farms in slaughterhouses and in processing plants.
Farmers also carry responsibility for developing appropriate biosecurity measures and ensuring they are applied rigorously in the context of a farm health plan.
Since public health is at risk from the spread of diseases between animals and human beings, public funds at national and European level should be made available for prevention measures, monitoring disease status, compensation (where appropriate) and enforcement. It would be reasonable to divert CAP resources and/or regional funds to support disease control programmes and improvements in biosecurity. Indeed, members consider that such funds should be made available as a matter of priority in order to reduce the risk and cost of controlling avian flu and equally serious diseases where they impact on the social and economic viability of some rural communities.
Foodaware, therefore, supports the principle of cost and responsibility sharing but recognises that there is considerable work to be done to determine the balance between taxpayers and suppliers and possible methods of approach. This work should include cost-benefit studies and an assessment of price and consumer implications. Consumers would be concerned if, as a result of raising standards within the EU, supermarkets sourced more produce from outside the Community without informing consumers of the different standards which apply.
Foodaware members also recognise that farmers need incentives to report disease outbreaks early, and systems of insurance or compensation where infection is unavoidable and slaughter programmes the most appropriate method of preventing further spread of disease. Compensation for loss of animals can act as an important consumer protection measure both in providing an incentive to report cases early and to prevent diseased animals entering the food chain.
Foodaware accepts the value of flexibility in the implementation of Community rules within Member States to take account of the differing levels and nature of disease, variations in climatic conditions and farming methods and particular local circumstances affecting outbreaks. However, Member States must abide by an agreed baseline, a common approach to risk and Community rules on how particular problems should be dealt with.
Given the different levels of disease in the Community, members consider new diseases and strains should be tackled at source, that is in their country of origin, as this is likely to be more cost-effective. However, obligations should be placed on those Member States where there are high levels of infection in farm animals and poultry to reduce the prevalence on farms or face stringent marketing controls./li>
Since the spread of animal disease cannot be contained within national boundaries or indeed within the EU itself, the public need to be informed of the changing risks and what actions they can take to prevent exposure or unnecessary risk. The strategy should include policies on openness and communication with consumers about the risk profile and disease status of different Member States.
Foodaware members recognise that animal disease can affect trade and have experienced the varying disease control policies applied to people travelling in different parts of the world. It is acknowledged that the risks associated with legal trade are well known and controlled, but there remains significant concern about illegal trade particularly in meat which poses a high risk to consumers and especially those on low incomes.
While we recognise that antibiotics have an important role in the treatment of animal disease, we strongly oppose their inappropriate and prophylactic use. In view of the growing problem of antibiotic resistance in human and animal populations, controls should be introduced to remove financial incentives for veterinarians recommending and using these products.

Background information

The European Commission is committed to introduce a new Animal Health Strategy to cover the period 2007-13 with the stated intention of improving the prevention and control of animal disease in the EU. This is also of considerable significance for consumers who suffer adverse health effects from zoonoses (those diseases which cause illness in human beings as well as in animals) and who contribute through taxes and potentially higher prices to the cost of disease control. In preparation for the new strategy, the Commission had an extensive evaluation¹ carried out of its animal health activities in the previous decade, and the Commission and Finnish Presidency held a conference to share the results and consult with stakeholders about the way forward.

To date, the EU’s policy in this area has mainly comprised a range of specific (vertical) measures to control individual diseases e.g. Salmonella, BSE, Avian Influenza, Foot and Mouth Disease. The approach has been largely crisis driven, but the overall effect has been increasingly successful in reducing the prevalence of the major diseases in Europe. The prime object of the policy between 1995 and 2005 has been to contain outbreaks of disease and control animal movements in the event of an outbreak, but the EU approach is also relevant for animal identification and traceability which are of importance to consumers too.

Animal health policy plays a key role in facilitating the trade in animals and animal products both within the EU and with third countries outside the Community. It determines the criteria for importing animals and animal products, and establishes the rules governing health inspections at EU borders. Consultation has illustrated:

the complexity of the subject;
the interdependence of the issues; and
the wide range of interested stakeholders.

The evaluation suggested that the policy to date has operated under a large umbrella of legislation but without any overarching strategy. Given the wide scope of the activities, there is felt to be a need for balance between the objectives of disease control and the importance attached by the Heads of Government to maintaining international competitiveness. This was referred to several times by participants at the conference as ‘not exporting our domestic industry’, that is, replacing domestic production by imports of lower quality and price. Subsidiarity was considered to be a central theme for the future allowing flexibility at Member State, regional and local level to deal with the differing impacts and different diseases, but with a crucial role identified for the Commission in enforcing a common approach and standards.

Evaluation of specific policy areas

1. Intra-Community trade

Free circulation of food and animal products has largely been achieved and, in the main, the Community has managed to contain specific disease outbreaks. But there is concern over the lack of uniformity in certification procedures and veterinary checks across the EU, and a division of opinion exists about whether additional guarantees are necessary or desirable. Live animal movement is recognised as a major risk factor contributing to disease spread which could be mitigated by more uniform animal health status across the Community or additional guarantees for those diseases which are of human health significance perhaps.

2. EU control and eradication programmes

diseases targeted and a significant expansion in disease-free zones. However, the results vary between diseases and regions and for some, such as TB which is of public health concern, the results are mixed. As a result, Member States and DG SanCo since 2000 has pressed for a more regional focus and improved monitoring. Looking to the future, it is recognised that there is a lack of measures to assess the efficiency of the steps taken and the effectiveness of expenditure on some programmes. Limited results in some cases are felt to indicate the need for more effective guidance and sanctions from the Commission. There is also an issue about the lack of appropriate diagnostic tools or vaccines and a recognised need for more EU funded research. Since diseases are not confined by national boundaries, actions at Community level can offer significant added value, but DG SanCo needs more resources if it is to co-ordinate action effectively. It is recognised that eradication is significantly harder to attain than a reduction in the prevalence of disease and, as targets are raised, reductions in disease become more difficult to achieve. Some people question whether programme targets are too ambitious.

3. Border controls and imports

The Community system is rigid and mainly geared towards declared imports. Illegal and fraudulent imports are a major source of concern although the link between this activity and disease risk is difficult to prove. The current system is not considered to be adequately addressing this. The system is weakened by deficiencies in legislation and MS implementation. Co-operation between competent authorities and the application of border controls are considered uneven across the EU. There are limited resources in DG SanCo for recording establishments in third countries and the products they are supplying to the Community. Very limited data is available.

Third country certification works reasonably well and has provided an incentive for them to upgrade their standards, but the reliability of the procedure is a key prerequisite for public confidence and disease control. Some concerns about this have recently been raised.

4. Monitoring and surveillance

There is effective and rapid detection and the Community is able to respond to exotic diseases and newly emerging risks. Effectiveness depends on the disease however – contrast avian influenza with the 2001 Foot and Mouth Disease epidemic. It is recognised that some diseases, such as Bluetongue and African swine fever, are technically difficult to control but it is thought that the surveillance network and notification provisions are adequate. Crisis management, supervision of Member State’s emergency plans and quick mobilisation of experts by the Commission need to improve. Resources available for emergency work attract a significant share of resources and when EAGGF funds are added they dwarf the CAHP budget which raises questions about efficiency and whether this acts as a disincentive to preventive action in Member States.

A range of views exists on the effectiveness of vaccination depending on the disease. Consumer acceptance and the threat of trade blocks are still major issues. There has been a lack of cost-benefit analysis on vaccination although in future this will be systematically incorporated in EU funded research.

Overall it is felt that, in the future, the EC role will increase in the context of globalisation and increases in trade volumes.

5. Financial issues

There is clearly concern about resources and the disproportionate expenditure on emergency measures and the lack of focus on prevention. Regional imbalance is also an issue, and there are clearly concerns among some Member States that those who do least to control disease benefit most from the Community programmes. For example, 85% of expenditure from the ‘Veterinary Fund’ was spent in just two Member States during the period from 1997-2005.

Looking to the future

The Commission plans to present the preliminary draft consultative Communication on an EU strategy that incorporates an action plan early in 2007. A final version is planned for publication in the middle of the year. Among the recommendations from the consultants is that there should be a coherent strategy with a stronger preventive focus which would provide a framework for the Community work in this area. They suggest that human health, economic growth and competitiveness should be included as global objectives, and welfare should be included with animal health as an intermediate objective. There should be specific objectives to ensure free circulation of goods, which is interpreted as meaning that animal movement should be restricted to what is necessary for trade, and to achieve single market objectives. Reducing the incidence of zoonoses in humans and reducing the biological and chemical risk in food of animal origin would be expected to be covered alongside measures to reduce animal disease, thereby supporting farm incomes and the rural economy. Operationally, it is recognised that a new strategy must link with the CAP and other EU policies, but there should be more focus on the human health implications. The Commission text will be submitted to the Council and European Parliament with the aim of completing discussions by the end of 2007 so that implementation can begin in 2008.

When one considers the specific policy recommendations, improved biosecurity is recognised as fundamental for disease control. This may be bound up with support at farm level from CAP funds. Controversially, in the context of limited resources, the Commission is likely to propose a harmonised framework for ‘cost and responsibility sharing’ focussed on those diseases which have high public relevance and potential human impact. The proposals may seek to penalise behaviour which increases risk, and develop a harmonised framework for cost sharing to minimise any distortion of trade. It is argued that there is no level playing field between farmers in the EU because of their different contributions to disease control, and that those who benefit from compensation should also contribute either by a levy, insurance, or some other means. Late reporting of disease might also be penalised. Several Member States, including the UK, believe this approach will be essential, and there seems to have been support for the approach from stakeholders at the November conference. However, there will be significant debate about how this might work in practice, if harmonisation can be achieved and over what time scale. The potential benefit is considered to be in involving producers in prevention and control but it is expected that they would need incentives to do this. Also important is the focus on disease prevention and risk management so that funds can be better targeted and actions prioritised. Early detection of exotic, new and emerging diseases is recognised as necessary, and controls on illegal entry of potentially risk carrying products are acknowledged. A gradual move to electronic identification and improved certification procedures is identified for further consideration, as well as improving the alignment of EU and international standards.

A consumer perspective

In the past, Foodaware has supported the Commission’s proposals for monitoring and control of zoonoses, and the involvement of the European Food Standards Agency in this area. European legislation to prevent zoonoses is an important element of food safety and Foodaware values the importance placed by the European authorities on monitoring the agents which cause disease. Consumers cannot necessarily observe pathogens in food and have to rely on suppliers and enforcement authorities to maintain appropriate standards, undertake necessary tests and ensure legislation is complied with.

We have been critical that the pace of change has been too slow in the European context. But even in the UK not all zoonotic diseases are notifiable under Public Health legislation, and it is recognised that recorded cases of infection represent only the tip of the iceberg because many patients do not seek medical attention or their doctor does not request a laboratory investigation². Therefore Foodaware members support the need for a new Community Strategy.

A strategic focus, which provides for a coherent approach to animal health and places a high priority on ensuring human health risks are also addressed, is to be welcomed and would provide a more effective basis for Community policy. The EU is committed to establishing a high level of consumer protection, and protecting individual health and safety are consumers’ highest priorities. Such an approach would allow the extent of the problem of ‘diseases and infections transmitted naturally between vertebrate animals and man’³ (zoonoses) throughout the expanded Community to be more effectively monitored and compared, and appropriate policies implemented to reduce the differences in disease and contamination rates between Member States, prioritise actions, and ensure consumers are informed of particular risks and outbreaks. A coherent strategy should take account of the issues from farm to fork and must ensure appropriate linkage to existing Community rules.

In our response to the England Implementation Group on the UK Animal Health and Welfare Strategy (CFG 01/06) we said that the first priority should be ‘to reduce the level of zoonoses, concentrating particularly on those diseases that cause serious infections in animals and human beings such as Salmonella, Campylobacter, E. coli, BSE and TSEs’. Prevention of diseases which can damage human health should also be the Community’s priority. Qualitative research carried out for FSA in 2005 indicated that while food safety was not as high a concern in the UK as it had been in the past⁴, it remains an important issue for consumers who generally expect their food to be safe⁵. Those concerns, which people identify unprompted, are issues such as BSE, Salmonella in poultry or contamination incidents which are of direct relevance to the animal health issues under discussion.

The cost of zoonoses imposes a considerable burden on society through taxes, compensation payments and the suffering which accompanies animal and human disease. A report by the Public Health Laboratory Service in 2002 estimated that in 2000 there were 1,388 million cases of foodborne infection acquired in England and Wales, 20,759 hospital admissions and 480 deaths. The most important pathogens were Campylobacters, Salmonellae, Clodstridium perfringens, E. coli, cryptosporidia and Listeria monocytogenes. The estimated cost to the NHS in England and Wales of treating illness caused by Salmonella and Campylobacter alone was £27.8 million in 1999. Some people in rural communities continue to experience mental health problems as a result of the Foot and Mouth Disease epidemic of 2001.

Trade between Member States carries additional risks, and populations in countries with high standards of disease control in relation to Salmonella, such as Sweden, Finland and the UK, face additional risks if produce, which may be freely traded within the Community, has been produced to lower standards and carry potential sources of infection.

In a recently published survey of Salmonella, contamination in eggs produced outside the UK and on retail sale in England, Salmonella was estimated to be in 3.3% of boxes. Of the 1,744 boxes of eggs sampled, Salmonella was found on the shells of eggs in 157 boxes and inside the eggs of 10. The eggs came from 8 countries but much of the Salmonella was found in eggs from Spain, although most of these came from 1 farm⁶. This is illustrative of the types of problems which can arise for consumers. Salmonella levels in UK poultry and eggs have been significantly reduced by vaccination, independent certification (the lion scheme), and improved biosecurity in the context of EU and national measures. Defra states that the UK infection rate is among the lowest third in Europe based on a study by the EFSA, but this study still indicated that contamination was found in 12% of the 454 poultry houses surveyed⁷. The survey will be used as a benchmark for the EU to set obligatory reduction targets.

In the past Listeria has posed problems in unpasteurised cheeses and brought about enhanced European control measures. Milk, which comes from cattle which do not carry brucellosis-free status, has to be pasteurised to remove any risk to human health.

The spread of animal disease cannot be contained within national boundaries and people increasingly travel within the EU and beyond its boundaries. As risks change, the public need to be informed of those risks so that they can take appropriate actions and make choices if they wish to avoid certain types of food. Foodaware supports a risk-based approach to animal health issues. The new EU Directive on the monitoring of zoonoses and zoonotic agents is being implemented in the UK in the Zoonoses (Monitoring) Regulations 2006. These will strengthen current monitoring systems designed to identify new and existing strains of diseases which spread from animals and humans. The Regulations will enable specific surveys to be conducted and grant powers to enter premises where disease is suspected, take samples and help trace any spread.

We have pressed for a HACCP approach to food hygiene risk and accept that a risk-based approach for this area would be valuable, but allowing necessary flexibility to Member States to take different actions as provided for in the Avian Influenza Regulation. However, it is essential that the Community agree a minimum baseline for Member States and appropriate targets for disease reduction within the context of National Plans for those geographical areas or Member States where existing levels of animal disease are unacceptable. While special measures may be necessary in the short term in some countries, it is important that those which take action and improve their disease status are not penalised by a lack of action by others.

In the past⁸, we have expressed concern about the limited range of pathogens covered by the Community’s Zoonoses Directive 2003/99/EC, e.g. there are no specific controls in farm livestock for Campylobacter infections which are the main cause of food poisoning in the UK. While a procedure has been laid down to set targets for this and other pathogens, and for animal populations other than poultry which harbour Salmonella, no programme has been adopted as yet, and the Salmonella controls are being extended on a gradual basis e.g. broilers from 2007, turkeys and breeding pigs in 2008. Marketing restrictions on table eggs will not apply until 2008 and poultry meat will not have to comply with set microbiological criteria until 2009. These requirements have taken far too long to implement. Climate change is thought to be causing diseases such as Bluetongue, for which the consequences for human health are unclear, to move into northern areas which were previously free from infection. Control measures for some pathogens in livestock, such as Verocytotoxin forming E. Coli (VTEC), are not considered possible at Community level at present. In these cases, action has been limited to providing guidance particularly for those who visit open farms. The Community should have more flexible scope to require emergency action to be taken in Member States and an agreed approach to deal with serious or unexpected eventualities.

Foodaware members remain concerned about differing levels of enforcement between Member States, about the extent of the challenge facing new Members as the Community enlarges, and the reliability of third country certification schemes. We believe that the Commission should set minimum enforcement standards and ensure sufficient resources are available for regular Community checks on national programmes. We have expressed particular concerns that monies must be earmarked for horizon scanning for new and emerging problems but should not detract from the need to deal with existing problems. Foodaware also considers that the Community should fund more research to underpin the priority setting process.

One of the drivers for changing the Commission’s approach is the increasing cost of disease control. Foodaware has long argued for reform of the Common Agricultural Policy away from subsidies for food production. We have previously said that a transfer of resources from pillar 1 of the CAP (production and price support) to pillar 2 (rural development and environment) could help farmers to improve practice through better training, for example. We also think that it would be entirely appropriate for CAP resources or regional funds to be diverted to support disease control, on farm improvements in biosecurity and compensation where culling is thought to be the most effective control measure. Such funds should be made available as a matter of priority where outbreaks of serious diseases such as avian flu pose a significant threat to the viability of rural communities.

There is a risk that higher standards of animal health in the European Union would lead supermarkets to source more produce from outside the Community in an effort to keep prices down. Consumers need to be informed of the origin of animal products sourced from outside the Community and the standards of husbandry and methods of production which are applied. We appreciate the value of retailer’s quality assurance systems and private standards arrangements which embody independent inspection, but consider that imports into the EU will need to be monitored on an equivalent basis, not just through the Commission’s evaluation of national control programmes, but by regular spot checks in the exporting countries by the Food and Veterinary Office (FVO). Farm assurance should help sustain quality and improve compliance but, at present, there are significantly different approaches between schemes and different requirements for the frequency and content of inspections and the standards that have to be met even in the UK. The European Commission should put pressure for more effective co-ordination in standard setting which is largely viewed by the industry as an area for competitive advantage not necessarily consumer protection or quality. It should also ensure that there is an effective strategy for informing consumers about the risks prevalent in different countries and their disease status.

Foodaware supports the principle of cost and responsibility sharing. While farmers and suppliers already have a legal obligation to supply safe food and must take primary responsibility for disease prevention and eradication in their stock, there are also public health benefits to which the taxpayer should contribute. It is as yet unclear how cost and responsibility sharing can be applied in Community policy and how the respective obligations on governments and producers should be measured. Foodaware would like the EU to undertake cost-benefit studies to look at the potential price and consumer implications of different approaches as part of the preparation for cost and responsibility sharing.

The use of antibiotics in animal production has been associated with the ongoing problem of resistance to antibiotics in the treatment of humans and animals. We have said that the ban on the use of antibiotics as growth promoters in animal feed needs to be followed up with a complete ban as part of the strategy to control zoonoses. Antibiotics have an important role in the treatment of animal and human infections but we are concerned that veterinarians have a financial incentive to promote their consumption which is not the case in prescribing human medicines. The Commission should look at ways in which these incentives could be removed.

Finally, how will the strategy ensure that good practice is followed and best practice identified and shared? Partnership working can provide a means of providing education, information and sharing best practice but the different functions of education and enforcement should not become confused. This approach to sharing good practice should be encouraged across the Community. Indeed, it is arguable that the Community objectives cannot be achieved without a more collaborative approach between the various stakeholders affected by animal health and welfare issues.

¹ Evaluation of the Community Animal Health Policy (CAHP) by the Food Chain Evaluation Consortium funded by DG SanCo and presented to the Conference on Community Animal Health Policy Strategy (2007-13), Brussels, 7 Nov 2006
² Zoonoses Report UK 2004, Defra 2005 p.7
³ Zoonoses Report UK 2004, Defra p.6 - Who Definition
⁴ FSA Survey 2001 showed 63% of the UK population were concerned about food poisoning.
⁵ Food Scares and Food Safety Regulation, Cragg Ross Dawson qualitative research for FSA, 31 January, 2005
⁶ FSA press release, 15 November 2006
⁷ Defra news release, 14 June 2006 Ref: 262/06
⁸ CFG 10/01 rev Monitoring and Control of Zoonoses