Opinion of the Economic and Social Committee on:the Proposal for a directive of the European Parliament and of the Council on the monitoring of zoonoses and zoonotic agents, amending Council Decision 90/424/EEC and repealing Council Directive 92/117/EEC, andthe Proposal for a regulation of the European Parliament and of the Council on the control of salmonella and other food-borne zoonotic agents and amending Council Directives 64/432/EEC, 72/462/EEC and 90/539/EEC
Date: 2002-02-20
Institutions: European Economic and Social Committee
Subjects: EU financing, animal disease, disease prevention, food inspection, health legislation, research body, veterinary inspection

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Official Journal of the European Communities

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Opinion of the Economic and Social Committee on:

— the ‘Proposal for a directive of the European Parliament and of the Council on the monitoring
of zoonoses and zoonotic agents, amending Council Decision 90/424/EEC and repealing
Council Directive 92/117/EEC’, and

— the ‘Proposal for a regulation of the European Parliament and of the Council on the control
of salmonella and other food-borne zoonotic agents and amending Council Directives
64/432/EEC, 72/462/EEC and 90/539/EEC’

(2002/C 94/06)

On 12 September 2001 the Council decided to consult the European Economic and Social Committee,
under Article 152 of the Treaty establishing the European Community, on the above-mentioned
proposals.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 29 January 2002. The rapporteur
was Mrs Davison.

At its 388th plenary session on 20 and 21 February 2002 (meeting of 20 February), the European
Economic and Social Committee adopted the following opinion by 85 votes to one with seven
abstentions.

1.

Introduction

1.1.
Zoonoses are diseases or infections that can be trans-
mitted from animals to humans. Infections usually happen as
a result of eating products of animal origin. Salmonellosis is
the most reported zoonotic disease in European countries.
Salmonella comprises more than 150 serotypes and can be
found in a whole series of food products such as raw eggs,
poultry, pork, beef, other meat products and dairy products.
Familiar symptoms and their severity vary according to the
serotypes. They are diarrhoea, fever, headaches, vomiting.
Nevertheless salmonellosis is a serious illness and sometimes
can even be fatal. Complications can affect everybody, but
babies, older persons and pregnant women are particular risk
groups.

Salmonella is just one zoonotic agent. The second
1.2.
‘most common’
is Campylobacter. The main
symptom is diarrhoea, but Campylobacter infection can some-
times lead to a nerve disorder and paralysis in rare cases. It is
mainly found in chicken meat.

in humans,

Listeria and certain types of E.coli are also the zoonotic

1.3.
agents for two other common infections (1).

2.

Impact of zoonoses on human health

2.1.
There are no reliable and comparative figures on the
number of cases of illness or death in the EU as a result of

(1) Listeria monocytogenes, Escherichia coli

(10),
Proposal for a directive on the monitoring of zoonoses and
zoonotic agents).

(Source, recital

is

to

be

estimated

responsible

zoonoses. National reporting systems differ and only a small
proportion of the number of cases of illness are reported.
Campylobacter
for
127 000 reported cases of food-borne illness in 1999 (2).
According to data published by the Office for International
Epizooties (OIE), in 2000 (3), more than 219 141 human cases
of salmonella infections in humans were reported in the EU
countries. The European Commission is collecting data too,
published yearly in an annual report on salmonellosis (4). It
provides an estimate of a total number of 165 569 cases
of human salmonellosis in 1999. However, the wide and
inexplicable differences in data between Member States indicate
failures in both monitoring and co-ordination.

2.2.
In addition to personal suffering and premature death,
zoonoses are responsible for major healthcare expenditure and
loss of working hours. According to WHO (5), cost estimates
per reported case of human salmonellosis range from approxi-
mately EUR 1 100 to EUR 1 500 in Europe. The UK Food and
Drink Federation has estimated that the cost to the health
service of England and Wales of treating illness caused by
Salmonella and Campylobacter was UK£ 27,8 million in 1999.

(2) Source: EU Commission report on the measures to be put in force
for the control and prevention of zoonoses, COM(2001) 452
final.

(3) Source: OIE, Handistatus/OIE, website: www.OIE.int.
(4) According to the EU Commission, the report (COM(2001) 452
fin) has to be carefully interpreted. For certain zoonotic agents,
comparable or uniform surveillance plans are not applied in the
European Union. Data may not necessarily derive from national
plans with specific and statistically planned sampling.

(5) WHO Fact Sheet No 139, January 1997.

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2.3.
The Committee therefore recommends a much more
robust and rapid approach than the Commission is proposing.

2008 onwards). Poultry meat will also have to comply with
set microbiological criteria from 2009 onwards. A procedure
is also laid down to set targets for other animal populations or
zoonotic agents other than salmonella.

3. Outline of the European Commission’s proposals

On 1 August 2001, the European Commission adopted
3.1.
two proposals to review current legislation and to improve the
prevention and control of zoonoses: a proposal for a Directive
on the monitoring of zoonoses and zoonotic agents, amending
Council Decision 90/424/EEC and repealing Council Directive
92/117/EEC; and a proposal for a regulation on the control of
salmonella and other food-borne zoonotic agents and to
amend Council Directives 64/432/EEC, 72/462/EEC and
90/539/EEC. The two proposals are part of the follow-up to
the White Paper on Food Safety (1).

The proposed directive obliges Member States to put
3.2.
in place improved and better co-ordinated monitoring systems.
It lays down a system for monitoring certain zoonotic agents
throughout the human food and animal feed chain. In addition,
Member States will be required to take part in co-ordinated
monitoring programmes in order to establish baseline values
on the level of most important zoonotic infections in each
Member State. These programmes will be co-financed from
the Community budget. The new monitoring requirements
also include the collection of data on the incidence of zoonotic
diseases in humans, on the prevalence of food-borne outbreaks
and the monitoring of antimicrobial resistance in certain
zoonotic agents.

3.3.
The proposed regulation sets out a framework for
pathogen reduction to reduce the prevalence of these organ-
isms by setting Community-wide targets for zoonotic agents
in specific animal populations, and possibly at other stages
along the food chain. Community targets for this reduction
policy are to be set progressively on the basis of scientific
opinion, according to a fixed timetable. Salmonella is identified
as the priority target, especially in poultry products and eggs.

The targets are to apply from 2005 onwards to
3.4.
breeding flocks of chicken, from 2006 onwards to laying hens,
from 2007 onwards to broilers, from 2008 onwards to turkeys
and breeding pigs. After a transitional period marketing
restrictions will apply to table eggs from flocks suspected or
confirmed of harbouring specific types of salmonella (from

To achieve the reduction targets, Member States will
3.5.
need to adopt national control programmes and encourage
the private sector to collaborate. For trade between Member
States in relevant live animals and hatching eggs, certification
of salmonella status will be made obligatory according to the
above time schedule. With respect to third country imports
into the EU, equivalent certification measures will be required
following the same schedule. The proposal gives the Com-
mission the option to exclude certain control methods to be
used against zoonoses such as the use of antibiotics or
vaccination in animal populations, or to decide on conditions
for their use.

4. Existing Community legislation

4.1.
Council Directive 92/117/EEC seeks to establish a
reliable reporting system on the prevalence of zoonoses
generally, and to bring about also monitoring, control and
ultimately eradication of some invasive serotypes of salmonella
in poultry breeding flocks. It also provides for the development
of control measures for other zoonotic agents than salmonella.

Currently the control measures cover only two types

4.2.
of salmonella in poultry breeding flocks.

4.3.
Directives 90/667/EEC and 92/118/EEC and the corre-
sponding Commission Decisions cover the control of zoonotic
agents in animal waste and feed processing.

brucellosis

tuberculosis

4.4.
Provisions on the control of certain zoonoses at farm
level have been laid down in various Directives regarding
animal health conditions in trade of live animal, e.g. provisions
on bovine
in Directive
and
64/432/EEC. Furthermore, there are rules in certain hygiene
Directives providing for the control of zoonoses at farm level,
e.g. in Directive 92/46/EEC regarding dairy herds. Measures on
the control of zoonotic agents in processing and distribution of
foodstuffs of animal origin are provided in the corresponding
hygiene directives. This legislation is currently being restruc-
tured and revised in order to establish a coherent and
consistent body of hygiene rules, based on an integrated
approach applied at every stage in the food chain (Opinion on
Hygiene of foodstuffs) (2).

(1) COM(1999) 719 final.

(2) OJ C 155, 29.5.2001, pp. 39-46.

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Community legislation on the monitoring and control
4.5.
of
the zooonoses has been developed gradually and to
varying degrees in different Member States. Experience shows,
however,
that not all Member States were able to fully
implement the system foreseen by the ‘Zoonoses’ Directive.
Only seven Member States (DK, IRL, FIN, S, A, F, NL) have
been recognised as fully implementing the provisions on
salmonella control of breeding flocks. The European Com-
mission indicates that authorities have taken effective measures
against salmonella and other zoonotic organisms in all Member
States either alone or in co-operation with private businesses.
The Committee regrets that these measures are not detailed in
the Commission’s report.

5. Recommendations

General recommendations

5.1.
In April 1999, the EESC adopted an opinion on
zoonoses (1). The Committee supports all the points adopted
in 1999, many of them being still relevant to the current
situation. In particular, we prioritise public health, regret the
delays in implementing EU legislation and propose a high
profile conference involving all the players in order to create
political and economic resolve.

5.2.
The publication of the European Commission pro-
posals is much welcomed. The prevention of zoonoses is an
important element of food safety. In addition, as stated above,
zoonoses are responsible for major individual suffering and
premature death, as well as major healthcare expenditure and
loss of working hours. The Committee strongly believes that
the prevention of zoonoses should be a top priority for the EU
and the Member States and that appropriate resources should
be devoted to this end.

The Committee starts from the proposition that food
5.3.
supplied to consumers should be safe. Recent food scares have
resulted in loss of consumer confidence and decrease of
consumption in products concerned. The Committee feels that
Public Authorities failed to ensure the effective implemen-
tation, control and enforcement of the legislation as well as
certification process.

The Committee therefore believes that it is in the
5.4.
common interest of all parties involved in the food chain and
Public Authorities to ensure the implementation of, and
compliance with high safety standards throughout the food

(1) Opinion of the EESC on the Proposal for a Directive amending
Directive 92/117/EEC concerning measures for protection against
specified zoonoses and specific zoonotic agents in animal and
products of animal origin in order to prevent outbreaks of food-
borne infections and intoxications, 28 April 1999, OJ C 169,
16.6.1999.

chain. This will also contribute to ensuring the competitiveness
of European farming at international level, which must remain
associated with high quality standards and production
methods.

5.5. Member States will bear the greatest responsibility in
the establishment of the national control programmes and
their application. Reports have clearly shown
control of
that Directive 92/117/EEC has been poorly implemented in
Member States. The deadlines set in Directive 92/117/EEC
have not been respected and the Committee feels that the
Commission should have taken action much sooner on this
issue. This situation and its negative impact on food safety,
consumer protection and EU trade has been strongly criticised
by the EESC in the 1999 Opinion on zoonoses (1). We
therefore express concern about the implementation of this
new proposed regulation, which places further requirements
on Member States, when the
the
92/117/EEC Directive is still not completed. We agree that
Member States have the main responsibility for implementing
the proposed regulation but we ask the Commission to allocate
appropriate resources for regular Community controls of
national programmes,
in particular through the Food and
Veterinary Office (FVO) in order to put more pressure on the
Member States. Only recently, FVO inspected salmonella
during a series of missions on the production of poultry meat.
But the report still has to be finalised. A priority for the FVO
should also be to encourage the Commission to use the
infraction procedure, which has never been used in the area of
legislation on zoonoses.

implementation of

5.6.
The European Commission proposals refer to anti-
biotic resistance, which is welcome. The prevention of zoonos-
es and antibiotic resistance are two interconnected issues.
Zoonoses in domestic animals lead to increased use of
antibiotics, which has been identified as a major cause for the
development of bacteria resistant to antibiotics. Therefore
the prevention of zoonoses is an important element of
a comprehensive strategy for the prevention of antibiotic
the problem of
resistance. The Committee is aware that
antibiotic resistance must take account of human healthcare,
veterinary medicine and animal husbandry as part of the same
eco-system (2). The fight against antibiotic resistance will only
be successful if comprehensive policies are adopted, covering
areas such as antibiotic usage in humans and animals, monitor-
ing of antibiotic usage, surveillance of antibiotic resistance,
research, etc.

(2) Opinion of the EESC on the Resistance to antibiotics as a threat

to public health, OJ C 407, 28.12.1998.

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6. Monitoring of zoonoses and zoonotic agents

6.1.
The proposed directive on the monitoring of zoonoses
and zoonotic agents would oblige Member States to undertake
action in monitoring zoonotic organisms in general and ensure
a better co-ordination of the monitoring and publication of
data. As mentioned by the European Commission, the collec-
tion of human data on the incidence of zoonotic disease is of
paramount importance to base food safety legislation on
scientific advice and to obtain feedback on the effectiveness of
the control applied.

6.2. We welcome inclusion in the monitoring of a wide
range of zoonoses and zoonotic agents as recommended by
the Scientific Committee on Veterinary Measures relating to
Public Health (1). In view of the importance of the issue, all
operators in the food chain should be involved in monitoring
zoonoses, feed producers included.

The Committee notes that

6.3.
the proposal does not
specify which animal species the monitoring is to cover. The
‘new’ directive must clearly indicate that monitoring includes
all sorts of domestic animal populations since the objective is
to obtain sufficient knowledge for the preparation of specific
prevention programmes. Also the proposal must confront the
issue of multi-resistant bacteria.

6.4.
The Committee stresses the importance of reliable and
efficient monitoring of zoonoses. New zoonoses are emerging
as a result of many factors, such as increased and freer
movement of people and animals, global climate change,
grafting organs or tissues, etc. The EU must be ready to
identify, prevent and face these new zoonoses.

6.5. Member States shall prepare yearly reports on trends
and sources of zoonoses, which they must transmit to the
Commission and the future European Food Safety Authority
(EFSA). The EFSA shall compile a synthesis report.
is
important that both national and Community reports are
made publicly available. The collection of national reports and
the preparation of synthesis reports, must be one of EFSA’s
priorities as well as the collection and dissemination of
information on zoonoses. The Committee insists on full
transparency of reporting procedures. Consumers and interest-
ed parties must have easy access to the information provided
by Member States. This is an important element of information
and of control of measures taken at national level.

It

6.6.
Finally, we fully support the proposal to include the
monitoring of antibiotic resistance in zoonotic organisms
within the proposed directive. As already noted by the
European Economic and Social Committee in its September
1998 Opinion on antibiotics (2), antibiotic resistance is a
growing human and animal health problem, and needs to be
rigorously attacked.

7. Control of salmonella and other food-borne zoonotic

agents

7.1. With regard to the proposed regulation on the control
of salmonella and other food-borne zoonotic agents, the
creation of a framework for pathogen reduction policy is very
much welcomed but we have many concerns regarding the
practical implementation of the proposal.

7.1.1.
The proposal would cover, in principle, all zoonoses.
However, the specific control requirements cover only certain
types of salmonella, especially in poultry products and eggs.
We question the limitation of the scope of the regulation,
which should include a wider range of pathogens and animal
populations. For example, it is demonstrated that meat prod-
ucts, pork in particular, are also a major source of salmonella.
And bacteria like Campylobacter and E.Coli are serious sources
of human disease.

Community pathogen reduction targets for selected
7.1.2.
zoonotic agents in selected farming animal populations will
be set according to a fixed timetable. The Committee supports
the Commission proposal and the approach adopted but feels
that the deadlines proposed for new measures are much too
long. It is concerned that the first targets for the reduction of
prevalence (3) will only be established by the end of 2003 for
all salmonella types with public health significance in breeding
flocks, and up to end 2006 for all salmonella types with public
health significance in breeding herds of pigs. Mandatory testing
and certification for trade will not apply before 2005 for
salmonella in breeding flocks and 2008 for salmonella in
breeding herds of pigs. The Committee feels that this is not
acceptable. Zoonoses are a very serious problem that needs to
be addressed urgently through a comprehensive set of
measures. Reducing the prevalence of zoonoses is the interest
of all operators of the food chain, from farmers to consumers.

(1) Opinion on food-borne zoonoses, 12.4.2000.

zoonoses.

(2) Opinion of the EESC on the Resistance to antibiotics as a threat

to public health, CES 1118/98, OJ C 407, 28.12.1998.

(3) See Annex I of the proposed regulation on the control of

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7.1.3.
One reason for urgent action is to solve the problem
of trade within the EU. The various zoonoses profiles between
the different EU countries lead to distortions of competition.
Countries with stricter policies against zoonoses want to
demand guarantees with regard to imports from other Member
States. This must be resolved for the good functioning of the
internal market with respect for the highest safety standards.

7.2. We welcome the certification system on salmonella
within the EU. With respect to third country imports, we
demand that a strict control of the application of ‘Equivalent
measures’ be applied. This system is mainly based on evaluation
by the Commission services of national control programmes,
or on declarations made by the third countries. It must also
include thorough spot controls by the FVO. The Committee
insists that products imported from third countries comply
with the same standards as products produced within the EU.
This is in the interest of producers as well as consumers and
cannot be guaranteed just by declarations from the exporting
countries. A system of control must be put in place that
complies with international trade rules.

7.3.
The proposed regulation refers to the Community
legislation on food hygiene (1). The Committee has urged that
the implementation and full application of the principles of
the HACCP (2) system, at every stage of the food chain, is a
fundamental element in the control of zoonoses. The HACCP
system prescribes a number of logical steps to be followed by
operators throughout the production cycle in order to allow
— through hazard analysis — the identification of points
where control is critical with regard to food safety.

7.4.
The Commission’s proposed regulation will not achieve
its objectives if HACCP principles are not implemented right
through the food chain. In March 2001, the Committee stated
that ‘The same hygiene rules and the same control methods
must apply at all stages in the food chain — from primary
production to delivery to the final consumer.’, and that ‘Each
operator at each stage in the food chain remains fully
responsible for the safety of his or her products’ (3).

(1) COM(2000) 438 final, OJ C 365, 19.12.2000, p. 132.
(2) HACCP: Hazard Analysis Critical Control Points.
(3) Opinion on 5 Commission proposals concerning hygiene rules,

OJ C 155, 29.5.2001, p. 39-46.

Brussels, 20 February 2002.

trade and distribution.

7.5. With regard to hygiene and good practices, the Com-
mittee reiterates its concern that action for the prevention of
zoonoses must be taken at every stage of the food chain,
feed and food
covering primary level producers, animal
manufacturers, slaughterhouses,
In
particular, progress could be made quite rapidly by means of
action to ensure stricter hygiene conditions in slaughterhouses,
where contamination often occurs due to salmonella in
contaminated animals spreading from the throat and intestine
to the meat. Consumers have their share of responsibility too:
food preparation hygiene is also very important. Consumer
education must be stepped up and co-ordinated at EU level.
This could be encouraged, for example by building on the
European campaigns on Food Safety, and the Annual Young
Consumer competition organised by the European Com-
mission.

7.6.
The Commission’s proposal concerning the hygiene of
foodstuffs (1) refers to the possibility of using decontamination
methods. The Committee is very concerned about the use of
such methods, which should not be used to restore safety in a
product that has been produced under poor hygiene con-
ditions. The use of decontamination methods must be strictly
controlled and in any case clearly labelled on the final product
including imports.

7.7.
Since 1996, the Committee has called twice on the
Commission and other interested parties for a conference to
create determination to take action on zoonoses. The Com-
mittee is actively engaged in activities aimed at raising public
awareness on the issue of zoonoses, the scale of the problem
and the need for urgent action. If the players in the food chain
decided on a concerted response, the incidence of zoonoses
could be reduced quite rapidly.

7.8.
A comprehensive policy on the control of zoonoses
should also address the issue of encouraging good agricultural
practices across the board. Good quality management in farms
will greatly contribute to the reduction of zoonoses. The CAP
should aim at raising awareness on the issue and provide
training and support to farmers willing to improve their
production methods in order to respond better to consumer
demand and contribute to the highest food safety level.

The President

of the Economic and Social Committee

Göke FRERICHS