CFG
34/05 rev
February 2006
Main
Conclusions and Recommendations
Background information:
Avian influenza
Human flu
The regulatory framework
Outstanding concerns:
The safety and supply
of food
Human health implications
Poultry and wildfowl
registration
Avian disease management
Rationing vaccines
and treatment
1. Main
Conclusions and Recommendations
| 1.1 |
Foodaware is pleased that the Advisory Committee
on the Microbiological Safety of Food (ACMSF) is keeping a watching
brief on the potential food-related risks and considers that
their advice to the FSA should remain under review. |
| 1.2 |
The correct disposal of carcasses and animal waste
will be essential in the event of an outbreak of highly pathogenic
avian influenza (HPAI) to protect the environment and limit
cross contamination. Disposal of infected poultry, game and
wild birds must be effectively monitored and controlled. |
| 1.3 |
Foodaware supports the ongoing strategy of monitoring
the worldwide situation and of planning preventive measures
to protect people from mutation of the avian flu virus and a
possible human flu pandemic. Foodaware is concerned that key
workers in the poultry industry, vets, game and zoo-keepers
and those who come into regular contact with birds, should be
eligible for anti-viral flu drugs to reduce the risk of cross-infection
mutation between avian and human flu if the disease enters the
UK. The eligibility criteria should be amended to include all
those who come into contact with poultry and wild birds in their
work. |
| 1.4 |
Foodaware considers that research should be done
to identify and characterise any novel strain of virus that
may transmit from person to person as a matter of urgency. We
support partnership working between government agencies and
industry to ensure such research can be done urgently, and support
the search for cost-effective solutions to increase the capacity
for vaccine production to protect public health. |
| 1.5 |
Foodaware would not wish significant investment
in stockpiling Tamiflu to detract from investment in more pressing
needs, as this drug may not be effective against a newly emergent
strain. |
| 1.6 |
The public should be given appropriate advice
on how to boost their immune systems by good nutrition and be
encouraged to follow it. |
| 1.7 |
Foodaware believes that all commercial
flocks and game birds should be brought within the scope of
the new hygiene legislation at the earliest opportunity. |
| 1.8 |
Co-ordination between the EU, Defra and the administrations
in Wales, Scotland and Northern Ireland to plan for and implement
emergency action in the event of an avian flu outbreak must
be sustained. |
| 1.9 |
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 FSA
should take account of the adequacy of such provisions when
assessing the hygiene risk on premises. |
| 1.10 |
Foodaware would not oppose vaccination as part
of an effective control strategy, but would want assurance that
research had been undertaken to assess the safety of produce
from vaccinated flocks for human consumption. |
| 1.11 |
Foodaware urges decision-makers to continue to
take a measured, risk-based approach, monitor the developing
situation and be ready to act if the risk status changes. |
2. Background
information
More information has been disseminated on this subject than on virtually
any other zoonotic disease about which we have been concerned. Alarm
at the substantial spread of the disease arose in July 2005, and following
this imports from Russia were banned and the Dutch required all poultry
to be kept indoors contrary to EU rules. By the end of the year, this
reaction was replaced by a more measured, strategic approach and the
EU adopted a new Directive on avian influenza.
2.1 Avian Influenza
Avian influenza first appeared in Italy over 100 years ago. The disease
is caused by a number of different strains of virus that can be low
pathogenic avian influenza (LPAI) or high pathogenic avian influenza
(HPAI). The low pathogenic strains have circulated naturally and worldwide
in wild birds for centuries. Defra surveillance shows a very small
number of samples test positive for LPAI in the UK. LPAI does not
always cause disease, and the symptoms may be mild. The last UK outbreak
of HPAI was in 1992 but was of a different strain. HPAI is a serious,
highly infectious viral disease of many species of birds. Mortality
in domestic poultry is usually high (up to 100% over 2 to 3 days)
but this can vary. It can also affect mammals such as humans, domestic
pigs and cats but these are not usually involved in onward transmission
of the disease. The subtype H5N1 is a highly pathogenic strain and
has been responsible for many of the recent outbreaks in Asia, the
Far East and Turkey. The disease usually spreads through contact with
infected faecal material, but it can also be spread by indirect contact
with water, on clothing, footwear and vehicles.
The main risk from avian flu is to the wild fowl and poultry industries.
Although different species have differing levels of susceptibility
to different strains of the disease, those under threat include wild
birds, domestic and commercially farmed poultry, pets and backyard
flocks, game birds, exotic species in captivity, fancy breeds and
other pet species. The disease could be brought into the UK by people
who have been in close contact with wild or farmed birds abroad, by
migrating wild birds, or by legal or illegal trade, bird fairs and
shows.
The Department of health states that avian influenza has killed 80
people out of 148 cases between 2003 and 16 January 2006. These people
were in close contact with domestic or commercial flocks of poultry,
living and working in conditions that are very different from those
in the UK. Avian flu is not easily spread from poultry to humans and
those most at risk are those who are in close contact with the infected
birds.
2.2 Human flu
There is a possibility that an avian influenza virus could mutate
into a form that is highly infectious to men or women if it is allowed
to mix with a human form of the flu virus. This could result in a
rapidly spreading pandemic since humans would have no immunity to
the new infection. In parts of SE Asia and rural China poultry, pigs
and people often live and sleep in the same air space, thus providing
an ideal environment for cross infection. Mutation does not appear
to have happened yet despite numerous opportunities. There is currently
no effective human vaccine for the potential pandemic flu virus. The
Chief Medical Officer has a group looking at pandemic flu and keeping
in contact with WHO, the lead organisation for this issue worldwide.
2.3 The regulatory
framework
Many countries are currently reassessing their surveillance programmes,
options for preventing the spread of the disease, and the controls
available should disease be identified. In the UK, specific regulations
cover poultry diseases, avian influenza and Newcastle disease. HPAI
is a notifiable disease but LPAI is not. The EU legislation (Directive
92/40) that set up control measures for avian influenza was repealed
in December 2005 and replaced by Directive 2005/94/EU. This Directive
is reasonably comprehensive in scope. It retains the current reporting
and investigation requirements but allows flexibility for Member States
and Competent Authorities to introduce a variety of controls in the
event of a suspected outbreak depending on the circumstances and risk
assessments. The Directive extends the scope of previous legislation.
It covers high and low pathogenic strains and also applies to pigs.
This Directive is due to come into effect in January 2007 and is currently
being transposed into national law.
EU legislation (Directive 90/539) also covers the import of poultry
and eggs. Imports of live birds, poultry meat, and untreated meat
products from countries where avian influenza has occurred have been
banned in the EU since 2004. Untreated feathers are also banned. Agreement
has recently been reached on a framework decision to heighten biosecurity
and the revised Hygiene Regulations should also apply.
Under the EU legislation a range of measures is available to Defra
to prevent an outbreak and control its impact if an outbreak should
occur. Most large commercial producers in the UK are traceable and
reasonably controlled. About 85% of domestic egg production is governed
by the Lion code and 80% of poultry meat by Assured Chicken Production.
Risk of contamination to organic and free-range poultry from wild
birds may be higher than for poultry kept indoors but this risk can
be reduced by good biosecurity. There could be a particular challenge
if disease in wild birds spreads to backyard flocks. During a recent
outbreak of Newcastle disease in Surrey, there were as many as 250
backyard flocks of chickens within a 10 kilometre radius. Although
Defra is encouraging all keepers to register, keepers of less than
50 birds are not required to register them so this voluntary approach
is unlikely to be wholly successful.
The EU legislation makes provision for the use of avian influenza
vaccines in domestic poultry subject to the Member State agreeing
a plan with the Commission together with a risk assessment. However,
effective control is by eradication of infected birds together with
enhanced bio-security. Avian influenza is endemic in parts of the
world and in some countries, e.g. Mexico, vaccination is used as one
component of the control programme. There is a special arrangement
allowing vaccination in a high-risk area of poultry production in
the Po valley in Italy. The Dutch government is strongly in favour
of vaccination as part of the control strategy because they have very
intensive production areas in the south of the country and have had
recent outbreaks. There is no H5N1 vaccine with a marketing authorisation
in the UK.
At a recent workshop organised by Defra there was very little support
for vaccination to be introduced in the UK except in very limited
circumstances. Industry is concerned at potentially adverse consumer
reaction and there are problems with the suitability and efficacy
of different avian flu vaccines. These have to be individually injected
into the birds so are expensive to use; would require large numbers
of trained people to do it, and can mask the presence of disease.
If used they must be part of a wider control strategy to be effective,
and there must be strict surveillance to ensure that there is no active
virus in the birds. Defra’s view is that vaccination on its
own would not stop the spread in the midst of a serious outbreak and
its use has significant disadvantages. The disease itself can spread
very rapidly and decimate whole flocks overnight. Defra’s emphasis
is on prevention and planning, so it can act swiftly and decisively
if the disease arrives in the UK.
Defra’s policy is to try to ensure that the measures taken keep
the UK free from avian influenza. The main controls at present are
surveillance, biosecurity measures on farms, stamping out the disease,
and restrictions on trade in poultry products from those countries
that have confirmed disease. Defra has published a Biosecurity Code
for poultry keepers on its website, which includes keeping up-to-date
records so that produce can be traced through the food chain. Producing
a flock health plan, which includes minimising contact between poultry
and wild birds, controlling access to flocks, cleanliness and disinfection
(for vehicles as well as housing) and planning ahead in case it is
necessary to isolate the flock in the future, are also included. Common
sense advice has been issued for those who have domestic poultry,
the numbers of who are significant and unregistered. Overall Defra
has in place a range of preventive measures and controls from the
farms through to the suppliers including international trade. Foodaware
supports the need to keep these under constant review.
Defra is working on the assumption that wild birds will be a potential
source and are monitoring the migration patterns with assistance from
the British Trust for Ornithology and others. A small number of species
come to the UK from Siberia, the Danube delta and Turkey, but birds
from these areas could migrate to other parts of Europe such as Southern
Italy and spread disease into birds migrating north. The risk is thought
to be low. Following the advice of the Phillips Enquiry into BSE,
Defra is planning for the worst-case scenario.
The trade in caged birds and ornamental species for ponds and gardens
from tropical countries has raised questions about the adequacy of
controls on the pet industry. As a result of the concerns about the
risk from this activity, shows can now only be held under license
and where strict criteria are met. Imports of captive wild birds from
all third countries into the EU are banned until the end of May 2006.
3. Outstanding concerns
3.1 The safety and supply of
food
The FSA consulted the ACMSF which concluded that the risk of acquiring
avian flu through the food chain remains low and there is no direct
evidence to support this route of infection. It advised that consumption
of infected chickens has not been identified as a risk factor and
cooking poultry thoroughly will destroy any virus present in meat
or eggs. Acid in the stomach can also destroy the virus and infected
birds tend not to be able to lay eggs. This position should remain
under review and Foodaware is pleased that the ACMSF is keeping a
watching brief on this issue.
Rapid detection and immediate slaughter of infected birds and their
close contacts will be necessary if the disease arrives in the UK.
Foodaware members consider that the correct disposal of carcasses
and animal waste will be essential to protect the environment and
limit the potential for cross contamination. Disposal of infected
poultry and wild birds must continue to be effectively monitored and
controlled. The wide and comparatively rapid spread of the disease
in domestic poultry flocks in Central Asia has led to more than 140
million birds being destroyed. The UK industry includes: 28 million
table egg layers including free range and organic; more than 800 million
broilers; 20 million turkeys a year produced by 2 companies and 2
million traditional farm fresh turkeys reared specifically for the
Christmas market; and more than 30 million game birds. Since a major
feature of disease control is culling flocks, if the disease enters
the UK the price and availability of poultry and poultry products
would be affected.
3.2 Human health implications
Foodaware members support the ongoing strategy of monitoring the worldwide
situation and taking appropriate action to minimise the potential
for a pandemic to occur. The UK Departments of Health acknowledge
that there is a real risk of a pandemic but that it may not be inevitable.
Foodaware wants policy makers to continue their strategy to reduce
the risk of human and bird flu coming together so that the virus may
mutate into a form that is highly infectious for humans and spreads
easily from person to person. The classification of people eligible
for routine flu vaccines should be reviewed to reduce the risk of
cross infection between avian and human forms of the disease. We believe
that those eligible should include people who work in the poultry
industry or keep domestic flocks, vets, gamekeepers, zoo staff and
those who work on farms which are open to the public. Action should
be taken to vaccinate support workers who may come into contact with
infected birds against human forms of flu to reduce the risk of a
pandemic and protect the public at large.
We stated in our response to the FSA Science Strategy that we need
research on more rapid identification and characterisation of any
novel strain that may evolve the capacity to transmit from person
to person. Members strongly support the need for urgent research and
consider that the necessary funding should be made available as soon
as a new strain of the human virus is identified.
Foodaware also agrees that government agencies should assist in and
promote partnership working with industry in this area on grounds
of public health. Development of suitable human vaccines will be necessary
if a highly pathogenic strain develops from a combined avian and human
flu virus. Foodaware understands that Tamiflu may not be effective
against the HN51 strain and is concerned that, at the present time,
significant investment in stockpiling this drug may be unhelpful and
distort expenditure away from more pressing needs. Rapid action will
be necessary to avert the worst effects of a pandemic if one emerges
and to slow its spread. It appears that the worldwide capacity to
produce vaccines quickly in response to a new strain of virus is insufficient
and, therefore, Foodaware is pleased that the Government is seeking
appropriate cost-effective solutions to this problem as a matter of
urgency.
People should also be encouraged to improve their immune systems by
good nutrition, and appropriate advice should be issued now to help
them do so. Foodaware would be pleased to distribute such advice and
information to its members.
3.3 Poultry and wildfowl
registration
Holdings with more than 50 birds are being registered now and those
with smaller flocks may register if they wish. Foodaware considers
that Defra should build the evidence base of the number of premises
with more than 50 birds now, and then consider whether all birds bred
for sale for human consumption (including those on domestic premises)
should be registered. There is concern that those with domestic flocks
will not register voluntarily because they may be affected by a culling
policy in the event of an outbreak. This could be a serious loophole
in the controls and should be addressed. Foodaware believes that all
commercial flocks should be brought within the scope of new hygiene
legislation at the earliest opportunity.
3.4 Avian disease management
Senior personnel in the EU and Defra have been co-ordinating their
plans and seeking to ensure a co-ordinated and effective response.
Their approach needs, if it has not done so already, to involve their
equivalent departments in the devolved administrations in Wales, Scotland
and Northern Ireland. Decisions, such as those in the Netherlands
and Germany to bring all poultry indoors, are considered to be unnecessary
for the time being in the UK as experts consider there is a relatively
low risk from migratory birds. In the event of an outbreak it may
be necessary to require organic and free-range birds to be brought
indoors. As an added safety measure, poultry workers have been advised
not to work if they have flu-like symptoms. People visiting wild fowl
sanctuaries, farms and ponds need to follow strict hand-washing procedures
as for other diseases.
Foodaware strongly supports improvement to biosecurity measures on
farms in general, and the potential for avian influenza gives added
impetus to this cause. We believe that food assurance schemes have
a role to play in this and should extend the biosecurity requirements
under their existing codes. The adequacy of the different codes' requirements
should also be taken into account by the FSA in conducting risk assessments
of hygiene on different farm premises.
Members would not oppose a strategy that included vaccination of flocks
if it was shown to be effective in controlling the spread of disease
and did not adversely affect human health following consumption. We
recognise, however, that vaccination is not a panacea and would have
to be supported by other control measures and closely monitored. It
should only be introduced as a last resort if other measures are proved
to be insufficient to control the spread of disease in the UK. Foodaware
members would also want assurance that research had been undertaken
into the safety of produce from vaccinated flocks for human consumption.
3.5 Rationing vaccines
and treatment
The UK is stockpiling Tamiflu. High-risk groups will get priority
but there will be strict criteria for the use of anti-viral drugs.
At present we only have enough for 1 in 4 people. It is logical that
those who have the skills to treat the disease should receive preventive
vaccination first. This includes front-line hospital staff but at
present does not include the veterinary profession or key workers
in the poultry industry. Foodaware considers that all those who are
particularly at risk, including those who work with or transport live
birds, should be included. Vaccination of these groups against seasonal
human flu could help reduce the risk of mixing of avian and human
flu in the UK. The Chief Medical Officer (CMO) for England has warned
people against buying drugs they hope will protect against bird flu
on the internet as the products may be counterfeit or not properly
potent. It has been suggested that we need far more capacity to produce
the right vaccine and also anti-viral agents.
There are inevitable concerns for those at high risk, vulnerable populations
and those in social care. Foodaware members urge decision-makers to
continue to take a measured response in the light of up-to-date evidence
and scientific knowledge. We agree that people should not panic but
remain concerned, monitor the developing situation and be prepared
to act when the risk status changes.
March 2006
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