CFG
10/01 rev.
February 2002
Comments by Foodaware
on the EU Commission proposals for monitoring and control of zoonoses
Foodaware welcomes the fact that the Commission is revisiting the
problem of zoonoses. An estimated 166,000 people in the EU were infected
with human salmonellosis in 1999 and 127,000 with Campylobacter.
The real figures are much higher because of underreporting. In a
recent survey, 63% of the UK population mentioned concerns about food
poisoning [1].
The estimated cost to the NHS in England and Wales of treating illness
caused by Salmonella and Campylobacter was £27.8 million in 1999 [2].
The proposal to monitor a wide range of zoonoses and zoonotic agents,
as well as to co-ordinate the monitoring and publication of data with
the involvement of the European Food Safety Authority, is very welcome,
as is the proposal to monitor antibiotic resistance in zoonotic organisms.
The EU needs clear data on food poisoning on which to base its action.
Foodaware is quite concerned about the proposal to control salmonella
and other food-borne agents, however. Many member states failed to
implement previous legislation of this nature. Action needs to be
taken to ensure compliance at this time. The priority should be public
health. It is simply not acceptable to put contaminated food into
the food chain.
The Commission should, therefore, set a minimum enforcement standards
and be sure to allocate sufficient resources for regular Community
controls on national programmes. For example, we note that the Food
and Veterinary Office report on its series of missions to examine
salmonella in poultry meat is still to be finalised. The Commission’s
proposed timetable for action is too relaxed and needs to reflect
the urgency of the public health problem.
The proposed system of certificates for salmonella status is very
welcome as part of the pressure that needs to be applied to raise
standards. Third country imports will need to be monitored on an
equivalent basis, not just through evaluation by the Commission services
of national control programmes, but also through regular spot controls
in the exporting countries by the FVO.
Foodaware is seriously concerned that the proposed Community legislation
on food hygiene does not make it compulsory for farmers to implement
the HACCP system. A policy on the prevention of zoonoses cannot be
successful without the implementation and control by independent authorities
of good hygiene practices at the level of primary production. A transfer
of resources from pillar 1 of the common Agricultural policy (production
and price support) to pillar 2 (rural development and environment)
could help farmers to improve practice through better training, for
example.
Foodaware is very concerned at the limited scope of the regulation,
which should include a wider range of pathogens and animal populations.
For example, pork has also been shown to be a major source of salmonella,
and bacteria like Campylobacter and E.Coli are serious sources of
human disease.
Furthermore, the directive was written before 11th September
and needs now to take account of the possibility of malign development
and dissemination of zoonoses. New zoonoses may also appear as a
result of global warming, transfer of animal parts and increased travel.
Finally, Foodaware welcomes the mention of antibiotic resistance in
the proposal. It has been demonstrated that the use of antibiotics
in animal production contributes to the growing problem of resistance
to antibiotics in the treatment of both humans and animals. The ban
in 1998 of four antibiotics used as growth promoters in animal feed
was a good start and needs now to be followed up rapidly with a complete
ban as part of the strategy to control zoonoses.
Ann Davison
7th February 2002
1Food Standards Agency, 2001
2 Food and Drink Federation, February 2002
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