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
Date: 2008-01-16
Institutions: European Economic and Social Committee
Subjects: animal disease, animal health, animal welfare, disease prevention, health legislation, health policy

17.6.2008

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 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’

the Council,

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

Serious

represent

contagious

livestock diseases

1.1
an
increasing risk for animals and people, and the EU should
increase its efforts as
supervision and
control. The EESC supports the Commission's proposed strategy
and appreciates
thorough preliminary work.
However, efforts should be stepped up vis-à-vis non-EU coun-
tries and indicators should be developed as one of the first prio-
rities, since this is of fundamental importance.

regards prevention,

latter's

the

The EU's rules may be expected to have a knock-on
1.2
the world and the EC should aim at
effect on the rest of
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 compartmen-
talisation 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.

1.7
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 intro-
duced for national co-funding. The relevant actors should be
involved in designing the funding system and its implementa-
tion 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

EU policy is laid down in more than 300 directives,
2.1
which were largely adopted in the period 1988-1995 in connec-
tion 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 consider-
ably, which has brought with it an increased risk of infection.

In order to minimise the risk of

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

At the same time scientific and technological develop-
2.2
ment, 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

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Official Journal of the European Union

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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 prioritisa-
tion 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 categori-
sation will also be the basis for establishing resource needs and
allocating responsibilities and costs.

The proposed animal health ‘framework’ would consist
2.4
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 Phyto-
sanitary Measures (SPS Agreement) but the EU, in the Commis-
sion's view, should align itself even more closely on these stan-
dards. 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 nego-
tiating 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 profes-
sional assistance to certain developing countries to combat
exotic diseases. Situations of crisis should be handled immedi-
ately and efficiently, which, among other things, requires the
prioritising of supervisory efforts, the establishment of indica-
tors, 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 shortcom-
ings in existing instruments for supervision, diagnosis, vaccina-
tion and treatment, and provide the necessary economic
In addition,
resources
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.

through public-private partnerships.

3. General comments

Serious

3.1
an
increasing risk worldwide for animals and people as a result of

livestock diseases

contagious

represent

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 coun-
tries.

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 preli-
minary 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 consid-
ered in other areas, where it is appropriate to involve sections of
civil society.

The core elements of the strategy, including its aims and
3.3
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 situa-
tions, 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.

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

4. Specific comments

Prioritising of measures

The establishment of priorities for EU measures is of
4.1
crucial
importance for a risk-based strategy focusing on the
threat to public health and the economic consequences of indi-
vidual 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 knowl-
edge justifies such action.

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C 151/15

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 indica-
tors will also make it easier to measure the progress made as
regards achieving the goals of the strategy.

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.

Common legislative framework

4.3
The EESC fully supports the proposal for a common
legislative framework in the form of a more visible and trans-
parent set of rules that defines common principles and require-
ments. As the EU becomes more important, it is also appro-
priate to aim at convergence with current international stan-
dards 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
inappropriate
raise the level of health care and counteract
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 rele-
vant 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 trans-
port, so that freedom of movement is related to the risk of
diseases being introduced and spreading and to the welfare of
the risk of diseases
animals during transport. As
spreading and animal welfare, the EESC feels there is a need to
consider limiting the transport of live animals.

regards

Financing is a fundamental element in EU legislation and
4.5
it is important to maintain joint responsibility for funding veter-
inary policy. The veterinary fund and the economic responsi-
bility 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 propo-
sals 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

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.

The possibility of

4.8
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 quar-
antine regulations in accordance with the OIE/Codex for zoning
and compartmentalisation, provided that restrictions are scienti-
fically 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 nego-
tiations on export
the Commission,
requirements. Even if
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

factors

important

in legislation,

farms should be set out

All experiences show that management is one of the
4.10
most
in disease prevention and animal
welfare, and future provisions should include a requirement for
training and consultation. The basic rules of biosecurity on indi-
vidual
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
forms of production and as an information
the different
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.

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4.11
As regards the Member States' setting-up of effective
veterinary border controls, there should be an overall assess-
ment 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.

In the interests of public acceptance, among other
4.12
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 incor-
porated 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.

Brussels, 16 January 2008.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the Proposal for a regulation of the
European Parliament and of the Council establishing common rules concerning the conditions to be
complied with to pursue the occupation of road transport operator

COM(2007) 263 final — 2007/0098 (COD)

(2008/C 151/06)

On 16 July 2007 the Council decided to consult the European Economic and Social Committee, under
Article 71 of the Treaty establishing the European Community, on the

Proposal for a regulation of the European Parliament and of the Council establishing common rules concerning the
conditions to be complied with to pursue the occupation of road transport operator

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 18 December 2007. The rapporteur
was Mr Barbadillo.

At its 441st plenary session, held on 16 and 17 January 2008 (meeting of 16 January), the European
Economic and Social Committee adopted the following opinion unanimously.

1. Conclusions and recommendations

1.1
The EESC is pleased to note that the Commission is in
favour of regulating access to the occupation of road transport
operator by means of a regulation, thus avoiding differences in
the transposal of legislation by the Member States. Adopting
this regulation would mean repealing Directive 96/26/EC.

The new regulation falls

in line with the Action
1.3
Programme for Reducing Administrative Burdens in the Euro-
pean Union, updating the rules on access to the occupation of
road transport operator by introducing electronic registers.

The Committee welcomes this proposal, as it will harmo-
1.2
nise rules on access to the occupation of
road transport
operator and to the road transport market — for both passen-
gers and goods — helping to achieve the aims of the Lisbon
Strategy with clear, simple and enforceable rules, which will lead
to fairer competition.

1.4
The regulation introduces the concept of the ‘transport
manager’ who is the person who continuously and effectively
runs the undertaking and who is required to be more highly
trained. Stricter rules governing the transport manager's links
with the company are also laid down. The EESC would like the
practice of hiring qualifications to be eliminated in cases where
a firm is headed by a natural person who is not suitably quali-
fied.