Background Paper
PUBLIC AND ANIMAL HEALTH
Note: The views expressed in this background paper do not purport to reflect the views of the Minister or the Department of Agriculture, Food and the Marine
Maintaining Confidence in the Food Chain
The Department of Agriculture, Food and the Marine continues to place huge emphasis on animal health and welfare, public health, safety and quality. Over many years the Department has provide the impetus to improve standards and has contributed to the international recognition of Ireland as a centre of excellence for food production, quality and safety.
Food Safety Governmental Bodies
There is continued collaboration between Departments and relevant agencies on the development of food safety policy and legislation. The following are the main bodies involved with Food Safety issues in Ireland:
· The Food Safety Authority of Ireland (FSAI) is a statutory, independent, science based agency dedicated to protecting public health and consumer interests in food safety and hygiene.
· Sea Fisheries Protection Authority was established in 2007. It has functions in relation to the enforcement of food safety legislation in respect of fish and fish products.
· The Food Safety Promotion Board, now known as Safefood[1] was established in 1999 to foster and maintain confidence in the food supply on the island of Ireland by working in partnership with others to protect and improve the public’s health.
· At EU level, The European Food Safety Authority (EFSA) is an independent European agency dedicated to improving consumer confidence by providing independent scientific advice and clear communication on all matters related to food safety.
Where are we now?
The main responsibility for farm animal health and welfare, and for the safety of foods of animal origin (including the control of residues) is vested with the Minister of Agriculture, Food and the Marine. The Department of Agriculture, Food and the Marine, (DAFM) advises the Minister on matters of animal health and disease, zoonoses, and public health in so far as it relates to food and products of animal origin. It assists in the preparation, implementation and enforcement of European Union and National legislation, implements control measures to protect the health of the animal and human populations, and provides certification for animals and animal products intended for export.
The Food Safety Authority of Ireland (FSAI) under the aegis of the Department of Health and Children was formally established on 1st January 1999 with responsibility for the regulatory functions of existing agencies (relevant Departments, Health Service Executives, Local Authorities, etc.) The principal function of the FSAI is to take all reasonable steps to ensure that food produced, distributed or marketed in the State meets the highest standards of food safety and hygiene, and to ensure that food complies with legal requirements and, where appropriate, with recognised codes of good practice.
While many of the activities of the Department’s staff is to some degree on food safety, there are four main areas of responsibility for food safety – meat, milk and milk products, fish and seafood, eggs and egg products and pesticides. These are the areas in respect of which the Department have a service contract with the FSAI for the delivery of a wide range of food inspection services.
Authorised officers are authorised under the relevant legislation to enforce EU and National measures relating to animal health and welfare, including legislation concerning the control of animal disease, veterinary medicines, and the hygienic production of foods of animal origin, by routine inspection and sampling, by investigation and the acquisition of evidence, and by legal process in the courts, often in co-operation with the Garda (police) and Customs officers.
Certain measures relating to EU veterinary legislation, in particular, controls on compound feeds for livestock, zootechnics, and dairy products, are implemented by the Department’s Agricultural Inspectorate, which is headed by the Chief Agriculture Inspector.
Regulatory controls to address known hazards in the food chain
Almost all of the legislative controls on the food chain in Ireland are ultimately derived from Brussels. EU legislation to ensure the safety of the food chain has been extensively revised to ensure the safety of the food chain. It has been consolidated over the past couple of decades in order to ensure harmonisation of standards across member states, facilitate free movement of goods within the community and the establishment of a customs union and address specific food crises. The diagram in annex 1 illustrates: (i) the complexity of the food chain for foods of animal origin; (ii) the multiplicity and range of recognised biological and chemical hazards that may arise along its length and (iii) specific legislative measures to address these known hazards (major primary legislation and specific concerns that are legislated for). In EU law, Food business operators are primarily responsible for food safety (178/2002) whilst public bodies such as the FSAI and DAFM are given specific responsibility for oversight and inspection to ensure that regulatory controls are properly implemented (882/2004). Food business operators (FBOs) must comply with food legislation. FSAI, SFPA and DAFM are parties to a multi-annual national control plan (MANCP), which a risk-based approach prescribes the number and type of inspections of FBOs and farming enterprises that are to be undertaken each year and the parameters that are to be considered at each.
Whilst regulatory controls (e.g. meat inspection, residue monitoring, animal disease controls) are focussed on addressing areas of greatest risk with most impact, obvious limitations relate to their imposition after-the-fact (i.e. usually only after a risk has become manifest) and the fact that by definition, controls prescribed in legislation are inflexible and do not generally provide safeguards against new and previously unforeseen risks. In addition, the EU cannot legislate for all known hazards to the food chain – i.e. (i) where a unique set of circumstances may attach to a single member state (e.g. in Ireland increased grass-based cattle production as envisaged in Food Harvest 2020 and increased reliance on private wells for supply of untreated drinking water to rural households poses a particular risk to public health) or (ii) where a one-size-fits-all approach and fixed rules are not appropriate (e.g. one might provide sensible, step-by-step guidelines to facilitate sustainable and profitable expansion of dairy enterprises but it is hard to imagine how such measures could be codified in law).
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Annex I
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Animal Health
A key component of food safety is the health of the animals which the food is derived. To provide confidence to consumers with food safety in mind, a number of national schemes is in place to ensure the identification and traceability of animals/meat. These systems provide further assurances to consumers of the safety of Irish meat and have benefits in terms of disease control and monitoring.
In Ireland, the Department of Agriculture, Food and the Marine operates the control and eradication measures for BSE, Bovine Tuberculosis and Brucellosis. This involves a combination of testing, routine inspections and investigations and mandatory and voluntary reporting and codes of practice. DAFM is also a significant stakeholder and funder of Animal Health Ireland (AHI), established in January 2009, which is an industry-led, not-for-profit partnership between livestock producers, processors, animal health advisers and government. Its remit includes diseases and conditions of cattle that are endemic in Ireland, but which are not currently subject to regulation and coordinated programmes of control. A decreased burden of these diseases in the national cattle herd benefits consumers and the industry by reducing the need for veterinary treatments and by improving the process ability of animal products.
There has been a continued improvement in the overall disease situation in recent years as illustrated in Figures 1 to 3.
The incidence of BSE has fallen dramatically in recent years (Figure 1). More importantly there have been no cases identified in any animal born since 2004 which confirms that the control measures adopted in the mid-nineties were effective in reducing the exposure of cattle born after that time.
Ireland is free of Brucellosis in sheep, pigs and cattle. There has been no outbreak of Brucellosis in cattle in Ireland since April 2006 and Ireland obtained Official Brucellosis Free status in July 2009, following which a controlled reduction in Brucellosis testing requirements is being implemented with significant savings for farmers. The main changes made to the testing regime since the attainment of Brucellosis free status are as follows:
· the age threshold for annual round testing has been increased to 24 months;
· the validity period of the pre-movement test has been increased from 30 days to 60 days;
· the age-limit for the pre-movement test has been increased from 18 to 24 months;
· from 1 January 2013, only 20% of all herds with eligible animals are required to be tested every year for the round test;
The one movement per test rule was abolished as from 1 January 2013.
Following the above changes, the number of samples tested for Brucellosis in 2013, as part of the annual round test was 1.2 million. It is estimated that the level of testing will continue at this level until Northern Ireland declares OBF.
With regard to bovine TB, the incidence of this disease has been on a sustained incremental downward trajectory over recent years. Herd incidence in 2013 was 3.85% compared with 5.88% in 2008 and 4.21% in 2012. The number of TB reactors in 2013 was 15,618 compared with 29,901 in 2008 which was 15.3% lower than in 2012.
Actual expenditure on the TB and Brucellosis programmes in 2013 was €32m compared with €38m in 2012 and €40m in 2010. The reduction in expenditure since 2010 was mainly due to a decrease in TB reactor numbers, reduced compensation payments, higher prices paid by meat factories for reactors and changes to the Brucellosis testing arrangements.
Veterinary Medicines
Veterinary medicines and vaccines play a crucial role in ensuring that Ireland’s animal population, particularly those animal species which are a source of food, remains healthy and prevent the transmission of animal diseases to humans. They ensure a safe food supply by maintaining the health of agricultural animals. An effective and up to date legislative code is in place to ensure that only authorised medicines are used and that the specifications governing their distribution and use are observed. A further important safeguard for consumers is provided by the National Residue Plan under which extensive monitoring of animals and animal products takes place. Tests are carried out for a wide range of substances, including banned products, violative residues of authorised products and environmental contaminants.
In a typical year, in the region of 20,000 samples are tested. The overall safety of Irish food is demonstrated by the fact that levels of positives have consistently been at very low levels over a number of years (less than 1%). In the case of each residue breach identified, a consumer risk assessment is carried out by the Food Safety Authority of Ireland to evaluate any threat to human health and to assess if food should be withdrawn from the market. In addition, all positive results are followed up to the farm of origin to determine the cause and enforcement action, including a penalty on the farmer’s Single Farm Payment or legal action, is taken as appropriate.
Ireland’s Animal Health Status
Ireland’s farmed animal population of 6.5 million cattle, 3.5 million sheep and 1.5 million pigs have a high animal health status. This is underpinned and supported by systems and legislation to ensure that this status continues. Our geographical location confers an additional natural protection from disease threats in mainland Europe, North Africa and the Middle East. In recent years, outbreaksof diseases such as foot and mouth disease, avian influenza, bluetongue and African swine fever, within or close to Europe have clearly illustrated the increasing threat posed from suchdiseases.Vigilance against disease introduction is a priority for the Department and previous experiences have demonstrated the absolute necessity of properly regulating trade, high levels of biosecurity, continued vigilance, contingency arrangements and robust legislation to deal speedily and effectively with disease threats and outbreaks.
The recently implemented Animal Health and Welfare Act 2013 provides a robust legal framework to enforce modern biosecurity and disease preventative measures aimed at reducing risk. This legislation is enforced through the network of some 300 state veterinarians supported by over 1,000 private veterinarians nationwide.
In terms of infrastructural systems, the Department’s Animal Health Computer System (AHCS) contains a database of premises where cattle, sheep, pigs, goats, poultry and horses are kept to support the Department’s animal health and welfare programmes. It is closely integrated with a number of the Department’s other computer systems such as the Animal Identification and Movement (AIM) system; Corporate Customer System (CCS); Agriculture Field and Inspection Testing System (AFIT) and the Laboratory Information Management System (LIMS). Private veterinary practitioners in approximately 440 veterinary practices throughout the country also use AHCS on a daily basis as part of the operation of the national Bovine TB and Brucellosis eradication programmes.
Exotic disease threats
Exotic diseases are those that are external to Ireland but which if introduced would have very significant negative consequences. In seeking to ensure that such diseases are not introduced requires very significant discipline on the behalf of the industry generally and requires the development of contingency plans with regard to a response if such diseases occur in Ireland. Among the most significant risks are the following;
1. Foot and Mouth Disease (FMD)
FMD is a highly contagious disease of cloven-hoofed animals including cattle, pigs, sheep and certain wildlife species. The disease can cause massive economic losses when introduced into countries which are free from the disease generating negative effects due to reduced animal productivity and restrictions on international livestock trade. The FMD epidemic that occurred in the United Kingdom (UK) in 2001 had an estimated cost of around 12-14 billion of Euros to the economy with a total of about six million animals destroyed. Unless firm precautions are in place, FMD can be readily re-introduced into disease-free regions/countries mainly via trade of animals and animal products. Once the disease is introduced, the virus can spread rapidly in the area/region in the absence of rapid detection, containment and response.