EN Official Journal of the European Union C 151/13

Opinion of the European Economic and Social Committee on the Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on a new Animal Health Strategy for the European Union (2007-2013) where ‘Prevention is better than cure’

COM(2007) 539 final

(2008/C 151/05)

On 19 September 2007, the European Commission decided to consult the European Economic and Social Committee, under Article 262 of the Treaty establishing the European Community, on the:

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on a new Animal Health Strategy for the European Union (2007-2013) where ‘Prevention is better than cure’

On 25 September 2007 the Bureau of the European Economic and Social Committee made the Section for Agriculture, Rural Development and the Environment responsible for preparing the Committee's work on the subject.

At its 441st plenary session, held on 16 and 17 January 2008 (meeting of 16 January), the European Economic and Social Committee, in view of the subject's urgent nature, appointed Mr Nielsen rapporteur-general and adopted the following opinion by 108 votes in favour with two abstentions.

1. Conclusions

1.1 Serious contagious livestock diseases represent an increasing risk for animals and people, and the EU should increase its efforts as regards prevention, supervision and control. The EESC supports the Commission's proposed strategy and appreciates the latter's thorough preliminary work. However, efforts should be stepped up vis-à-vis non-EU countries and indicators should be developed as one of the first priorities, since this is of fundamental importance.

1.2 The EU's rules may be expected to have a knock-on effect on the rest of the world and the EC should aim at membership of the World Organisation for Animal Health (OIE). The Commission should work towards achieving a clear understanding of new EU legislation in the relevant non-EU countries and, as part of the proposed export strategy, use expertise and resources in the Member States in connection with solving the crisis.

1.3 Veterinary border controls should be based on an overall assessment of the actual risk and should include spot checks, not least along the border, in order to deter illegal trading.

1.4 Despite the need to have a smoothly functioning internal market, it should be possible to have zoning and compartmentalisation in the form of harmonised criteria and a requirement for testing and/or quarantine arrangements in accordance with the OIE/Codex.

1.5 Management is a key factor in the prevention of infection and in animal welfare, and this should be targeted by requiring the provision of training and advice.

1.6 In order to minimise the risk of infection spreading, consideration should be given to limiting the transport of live animals.

1.7 The veterinary fund and the economic responsibility of the EU should be maintained, and to prevent distortions of competition a firm, harmonised framework should be introduced for national co-funding. The relevant actors should be involved in designing the funding system and its implementation through the Animal Health Advisory Committee.

1.8 In the interests of public acceptance, among other things, vaccination should be used to combat disease outbreaks if it can advantageously replace or supplement the culling of healthy animals. However, as the Commission points out, this should be done in the light of a series of closely defined criteria and in the context of the actual situation.

1.9 The transfer of knowledge is crucial for the incorporation of research findings into production, advice and controls and the ‘Research Action Plan’ mentioned by the Commission should also focus on prevention.

2. Summary of the Commission communication

2.1 EU policy is laid down in more than 300 directives, which were largely adopted in the period 1988-1995 in connection with actual disease outbreaks. Severe outbreaks now occur more rarely, but at the same time we are confronted with new and serious risks, such as foot-and-mouth disease, blue tongue and avian influenza. In addition, trade has increased considerably, which has brought with it an increased risk of infection.

2.2 At the same time scientific and technological development, and the institutional framework, have made it possible to have a new, more rational and ambitious strategy, which it is proposed to implement for the period 2007-2013 under the slogan ‘prevention is better than cure’. The aim is to have a high level of public health and food safety, reduce the occurrence of disease, ensure the free movement of goods and prevent outbreaks among livestock. The strategy comprises a prioritisation of EU intervention, a common animal health framework, measures concerning prevention, surveillance and readiness and the involvement of science, innovation and research. Concrete measures will be developed in a partnership having the form of an animal health advisory committee, with representatives of industry, consumers and governments, which will provide guidance on the appropriate/acceptable level of protection, the optimal form of measures, etc.

2.3 Prioritisation consists of categorising biological and chemical risks, assessing the level of risk and how to manage it, establishing an ‘acceptable level of risk’ and clearly allocating responsibility for the various measures involved. Such categorisation will also be the basis for establishing resource needs and allocating responsibilities and costs.

2.4 The proposed animal health ‘framework’ would consist of a set of rules with high standards and common principles. EU legislation is already based to a large extent on the OIE/Codex recommendations/standards and fulfils the obligations in the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement) but the EU, in the Commission's view, should align itself even more closely on these standards. Provided that sufficient scientific justification is present, the EU can in certain cases introduce or maintain requirements at a higher level and the Commission will seek to have the EU's standards applied in the OIE/Codex. The strategy implies providing better information to the EU's trading partners as regards imports into the EU and strengthening the EU's negotiating position on export issues.

2.5 Prevention, surveillance and readiness include measures on farms, electronic identification as well as a combination of elements in the traceability system for living animals. Biosecurity at borders is to be improved and the EU should provide professional assistance to certain developing countries to combat exotic diseases. Situations of crisis should be handled immediately and efficiently, which, among other things, requires the prioritising of supervisory efforts, the establishment of indicators, data collection, networks among the actors concerned, risk analyses, public information and training for those involved.

2.6 Science, innovation and research are to be strengthened by networks among EU agencies and national bodies. The Commission will prepare an action plan to identify shortcomings in existing instruments for supervision, diagnosis, vaccination and treatment, and provide the necessary economic resources through public-private partnerships. In addition, support is to be provided for research in non-EU countries through international cooperation, particularly as regards exotic diseases of major importance or zoonoses which have serious consequences for the countries concerned.

3. General comments

3.1 Serious contagious livestock diseases represent an increasing risk worldwide for animals and people as a result of the constant rise in population and livestock, added to more trade and increasing international communication, and climate change causes changes in geographical distribution. Zoonoses and other diseases are spread in this way or are turning up again and there is a constant risk of a pandemic, for instance in connection with avian influenza. The EU should therefore give greater priority to prevention and combating such threats both within the EU and internationally, not least in developing countries.

3.2 As the representative of organised civil society, the EESC feels that it is necessary to implement the best possible strategy in this area to counter the risk of serious economic and social consequences, and pledges itself to work actively towards this wherever possible. The EESC appreciates the thorough preliminary work of the Commission and can by and large go along with the proposed strategy, which is broadly accepted by the parties concerned. A partnership-based approach is crucial to achieving good and sustainable results in veterinary matters, where responsibility is of necessity spread among a number of actors. The EESC feels that such a model could also be considered in other areas, where it is appropriate to involve sections of civil society.

3.3 The core elements of the strategy, including its aims and visions, risk assessments as a central tool, focusing on general and risk-related communication, together with an increased focus on border controls, are crucial to preventing the outbreak and spread of contagious livestock diseases. Communication with specific target groups is essential, not least in crisis situations, since mistaken perceptions affect business, the supervisory authorities and the political system, with a resulting boycott of products and the introduction of unjustified or over-stringent measures. For example, steps should be taken to avoid market conditions being adversely affected by unfounded doubts about meat from vaccinated animals.

3.4 However, if the relevant EU rules are to be respected, the EU institutions and Member States should respect their own decisions and deadlines for the publication, adoption and implementation of concrete provisions, which has rarely been the case.

4. Specific comments

Prioritising of measures

4.1 The establishment of priorities for EU measures is of crucial importance for a risk-based strategy focusing on the threat to public health and the economic consequences of individual diseases. A substantial challenge for partnership will consist of defining an ‘acceptable level of risk’ and there must be a strong need here for professional and scientific expertise. Applying the precautionary principle to new threats that have not been fully described is important and necessary if swift action is to be taken, but it is just as important to establish a procedure for an exit strategy if the threat ceases or new knowledge justifies such action.

4.2 The indicators for measuring, assessing and prioritising should be clear, understandable, operational and measurable, and should be made part of the process as soon as possible in view of their fundamental importance. They should therefore be developed as one of the first priorities during the involvement of the designated partnerships. Simple and reliable result indicators will also make it easier to measure the progress made as regards achieving the goals of the strategy.

Common legislative framework

4.3 The EESC fully supports the proposal for a common legislative framework in the form of a more visible and transparent set of rules that defines common principles and requirements. As the EU becomes more important, it is also appropriate to aim at convergence with current international standards and to influence the future rules of the OIE as far as possible, not least as regards application of the precautionary principle. The Commission has pointed out that the EC should aim at membership of the OIE in the longer term, as this would improve convergence with the OIE's standards, guidelines and other rules. In addition, the EU's own rules should be expected to have a spin-off effect on the outside world that will help to raise the level of health care and counteract inappropriate restrictions of competition. At the same time the EU should assist certain developing countries in such areas and help bring about a clear understanding of new EU legislation in the relevant non-EU countries.

4.4 The enlargement of the EU and the internal market has brought with it an increased risk of disease outbreaks over larger areas. The UN Food and Agriculture Organisation (FAO) several years ago warned against the increased risks resulting from long animal journeys, new transport routes to countries outside the EU, more contact with countries where conditions are unstable and the continued concentration of animal stocks in certain areas of the EU. According to the communication, the Commission wishes to ensure a correct balance in animal transport, so that freedom of movement is related to the risk of diseases being introduced and spreading and to the welfare of animals during transport. As regards the risk of diseases spreading and animal welfare, the EESC feels there is a need to consider limiting the transport of live animals.

4.5 Financing is a fundamental element in EU legislation and it is important to maintain joint responsibility for funding veterinary policy. The veterinary fund and the economic responsibility of the EU should be maintained. The incentive to report immediately any suspicions about or cases of disease outbreaks should not be delayed by uncertainty about the reimbursement of direct and indirect costs. The intention to provide an ‘effective and responsible cost-effectiveness model’ raises a number of questions and there is a need to prepare more concrete proposals as a basis of assessment, not least of a harmonised funding model.

4.6 To prevent distortions of competition, national co-funding should continue with a firm, harmonised framework for co-funding the industry. When allocating costs according to uniform principles in the Member States, the costs, the division of responsibility and the relationship between them have to be specified. Other issues in the equation are whether to involve the relevant actors by way of consultations or joint decision-making and how to use resources for preventing and fighting outbreaks. As has been the case up to now, the industry will, of necessity, have to pay out a series of costs for preventing and combating disease and so it should, among other things, be involved in questions about funding arrangements through the Animal Health Advisory Committee.

4.7 The proposal to introduce ‘non-legislative instruments’ implies, among other things, a need for disease prevention measures and forms of collective responsibility and insurance schemes that in themselves will provide motivation for better risk management and limitation of the economic consequences. The EESC recognises the need for reflection on such matters but finds it is not possible to comment on the proposal as not enough information is available.

4.8 The possibility of regionalisation is important when combating diseases, even though a smoothly functioning internal market is also an obvious prerequisite in veterinary matters. One or more Member States should thus be able to eradicate a disease, with the special status resulting from it, through harmonised criteria and the need for tests and/or quarantine regulations in accordance with the OIE/Codex for zoning and compartmentalisation, provided that restrictions are scientifically well-founded and proportionate to the disease risk involved.

4.9 Acute crises in connection with exports have so far been solved in dealings between the relevant Member State and third country. A quick and effective solution is needed here, in which there should always be a possibility for individual negotiation. Under the Commission proposal locally based teams drawn from the Commission, national embassies and organisations would contribute towards strengthening the EU's role in negotiations on export requirements. Even if the Commission, among other things as part of the proposed export strategy, ensures that EU policy is better understood, so that in practice fewer cases of doubt occur, it should be clear from the detailed action plan that the Commission will make use of expertise and resources in the Member States.

Prevention, surveillance and readiness

4.10 All experiences show that management is one of the most important factors in disease prevention and animal welfare, and future provisions should include a requirement for training and consultation. The basic rules of biosecurity on individual farms should be set out in legislation, including the requirements for setting up new production facilities, with the resulting consequences as regards compensation in the event of a disease outbreak. Additional criteria and more specific rules should, however, be implemented in the form of guidelines for the different forms of production and as an information campaign with the cooperation of the authorities and the industry. Hobby farmers should be targeted in order to promote understanding of the need for preventive measures. They should also be registered and be subject to the requirements concerning animal turnover and access to herds.

4.11 As regards the Member States' setting-up of effective veterinary border controls, there should be an overall assessment of the concrete risk of a disease being introduced and the possible consequences, together with spot checks in order to deter illegal trading. There should also be better coordination between veterinary and customs authorities and a more flexible border control system, with a more risk-based approach so that attention can be turned rapidly to new risks.

4.12 In the interests of public acceptance, among other things, vaccination should be used in connection with combating disease outbreaks if it can advantageously replace or supplement the culling of healthy animals. However, as the Commission points out, vaccination should be carried out in the light of the concrete situation and be based on recognised principles and factors, such as the accessibility and effectiveness of the vaccine, valid tests, international guidelines and possible trade barriers, cost-effectiveness and the possible risks related to the use of vaccines. There is also a need for further research and development in this regard.

Science etc.

4.13 Science, innovation and research are crucial to achieving the goal of the strategy. It is assumed that research can be incorporated into production, advice and controls, in which there should be more possibilities for transferring knowledge. This also applies to the Commission's Research Action Plan.