Paper by Dr. Roger Breeze, CEO, Centaur Science Group (formerly, Associate Administrator, United States Department of Agriculture, Agricultural Research Service), Washington DC.
Industry Cost Sharing
In the US, the Golden Rule is that he who has the gold makes the rules. That the British government is now looking to the livestock industry to share the costs of epidemic disease control is a welcome change, because when the government had all the gold and set all the rules, the results were demonstrably not to anyone's liking. Cost sharing offers industry a chance to sit at the table as a partner to make sure that when it pays what is asked, it gets what is promised. In this context, I use "industry" to mean those concerned with the raising, processing and sale of livestock and poultry from farm to fork in the UK, including all zoo and commercial animals and birds (from which commerce or profit is derived) regardless of species. There are other private sector industries that I will identify later in the narrative.
To be a partner in a real negotiation, the industry has to know what it wants so that proposals from the government can be assessed in terms of how well they advance or retard what industry wants to see as the outcomes. Industry cannot negotiate meaningfully if its "negotiation" comments are only responses to proposals and goals of the government.
The following comments are directed at all foreign animal and poultry disease emergencies but particularly for foot and mouth - one cannot detail all possibilities here.
Industry desires might be as follows:
1. FMD does not occur in the UK or the EU.
2. The only way FMD virus can become a livestock problem in the UK is if someone accidentally or deliberately brings the virus, live infected animals or infected animal products into the UK.
3. The industry has no powers to prevent accidental or deliberate FMD introduction - this is an essentially governmental function. The industry recognizes that a portion of the costs of keeping FMD and other infections out of the UK should be borne by those passing across the country's borders or importing animals or goods that might carry these infections.
i. Plans should be developed for effective screening of persons, conveyances (cars, trucks, boats, planes) and goods of all kinds arriving in the UK to ensure that illegal imports of animals and animal products that might carry foreign pathogens of concern are detected.
ii. Performance Benchmarks should be established - what proportions of passengers, conveyances and goods will be examined, how they will be examined and how results will be reported. When possible, robotic automated devices should be employed to screen the maximum numbers of potential targets.
iii. Industry accepts that it is not possible to examine all travelers, goods or conveyances and will agree with government what an acceptable fraction should be. Later, there might be redirection of inspection resources based upon risk assessment and experience. A case can be made to inspect a greater proportion of travelers, containers and goods coming from countries in which FMD and other diseases of concern are known to be present than from disease-free countries, thereby encouraging countries to eradicate disease within their borders.
iv. A fee should be assessed on all travelers, conveyances, shipping containers and goods entering UK to pay for an agreed share of the increased costs of inspection. This fee would be greater for conveyances carrying live animals or animal products and for imports of live animals and animal products - but inspection should not be restricted only to these since the declared manifest might be incorrect. Reduced fees might apply to those meeting higher standards of validation as to the nature of the import and country of origin. ALL sector components should contribute - the shipping companies as well as the shipper - to ensure that all are vested in the outcome. There should be real and significant penalties on the boat, truck or airline industry members found to be carrying illegal imports to discourage illegal imports at the point of loading in a foreign country.
v. On a non-disclosure basis, the government should make available to industry representatives the records on how well Performance Benchmarks are being met - the government should have the necessary resources to meet these benchmarks from tax revenues and user fees and be prepared to demonstrate that it is meeting its Performance promises.
vi. Laws and regulations on penalties for failing to comply with importation requirements should be reviewed to ensure that penalties are commensurate with the likely degree of economic consequence.
vii. Through differential fees, the government should encourage adoption of importation practices that minimize fraud and maximize effective inspection, such as source validation, unalterable product seals, electronically verifiable certificates of origin, and lifetime tracking of the imported products in ways that can be validated in real time by the customs inspector at the point of importation.
viii. The purpose of the above program component is to ensure that all those engaged in entering the UK, with and without products or animals that might carry infection, contribute towards the costs of an effective program with measurable impact on preventing illegal importations.
ix. The above comments do not address deliberate introduction (see below).
4. Government has chosen to retain all powers to diagnose FMD and to respond to an introduction by vaccination and other health interventions and by release of vaccine to livestock owners. The industry is willing to share the costs of an agreed and effective diagnostic and response system in which government meets agreed Performance Benchmarks that will limit industry losses should FMD occur. By "livestock" below I also intend zoo, game and other non-farm animals and birds.
a. Early reporting of suspicious cases is critical to limiting any subsequent epidemic. Through education and training, the government should ensure that livestock owners and those employed in the industry know what to look out for and how to report suspicious cases. An inducement scheme might be adopted to encourage reporting. This component should have Performance Benchmarks.
b. Within 6 hours of notification by a veterinary surgeon of a suspicious case, government should have made a definitive detection of the foreign animal disease by transporting samples to Pirbright or by examining samples in regional laboratories or on the farm. This component should have Performance Benchmarks.
c. In cooperation with the livestock industry and the Royal College of Veterinary Surgeons, the government shall have in place an emergency communications capability to inform directly all UK livestock owners and veterinary surgeons or a defined subset of them immediately (within 1 hour) after a definitive diagnosis. This communication system might be by telephone or other electronic means. This component should have Performance Benchmarks.
d. Through education and training, the government shall ensure that all livestock owners and veterinary surgeons know what preventative measures they should employ under their farming circumstances when disease is diagnosed. This component should have Performance Benchmarks.
e. Within 24 hours, government should have determined the strain or subtype of the pathogen and ordered the production of the most efficacious vaccine from stockpiled antigens. This component should have Performance Benchmarks.
f. The government will maintain a stockpile of vaccines (in the form of frozen antigen of indefinite shelf life) to protect UK livestock against all strains of the pathogen circulating in the world. The numbers of doses of each vaccine may not be the same as the total number of susceptible animals or birds but the government shall fully compensate owners for whom vaccine is not available in the event of an outbreak.
g. The government will have a plan and capability to deliver sufficient vaccine for all susceptible livestock to their owners at pre-determined distribution points starting 72 hours after definitive diagnosis and being complete by 144 to 168 hours. This component should have Performance Benchmarks.
h. The government shall ensure that sufficient laboratory capability and capacity exist to perform all diagnostic and differential diagnostic tests during and after an outbreak in a timely manner.
i. All components of the livestock production and animal product processing industry and the retail sector should pay a share of the above costs not borne by government because all components benefit from animal agriculture - this includes auctions, retail stores and slaughter plants. The consumers' portion is paid by government tax revenues.
j. The purpose of the above program component is to ensure that all those benefiting from production, processing or sale of animals and animal products of UK origin and those similarly benefiting from imported animals or animal products contribute towards the costs of an effective program for earliest detection and most rapid effective response to foreign animal and poultry disease threats and are actively engaged in such a program should disease occur.
5. When a disease outbreak occurs during a period in which the government is not meeting its Performance Benchmarks for importation security, the industry shall not have to pay its share of disease control and compensation costs stemming from failure on the government's part.
6. When a disease outbreak occurs during a period in which the government is not meeting its Performance Benchmarks for diagnosis, vaccine deployment and preparedness, the industry shall not have to pay its share of disease control and compensation costs stemming from failure on the government's part.
7. Livestock owners will be compensated for the value of stock slaughtered in the period before vaccination has occurred and disease control measures are fully implemented - this might be as long as two weeks after definitive diagnosis. The first owner to report a suspicious case that proves to be an infection of concern shall be compensated at four times the value of the stock; those subsequently reporting suspicious cases that prove positive within the first two weeks after a definitive diagnosis shall be compensated at twice the value of the stock. Owners of stock deemed to be infected more than two weeks after definitive diagnosis shall not be compensated from government funds, although insurance against such an eventuality shall be offered in advance. This scheme is intended to promote industry-wide vigilance and immediate diligent attention and response after disease is diagnosed.
8. With all Performance Benchmarks met, by government and industry, the goal is to snuff out an outbreak in two weeks after diagnosis by active commitment of all sections of the industry and related industries.
9. The issue of who should pay what in the event of deliberate introduction of disease is difficult. Deliberate introduction will be either a crime or a terrorist attack - deterring and responding to either of these are inherently governmental functions. I have argued that changing the way government responds to FMD and other foreign infections can reduce or remove the terrorist threat since it is the drama and visual theater of mass slaughter and destruction that the terrorists seek to have shown on al Jazeera and BBC World News. This is why I assume vaccination above, not mass slaughter. I am not sure of UK law on insurance against terrorist attack - if terrorism causes damage, does the liability fall to government not the insurer? Who paid for the physical damage to the London Underground? Was it insurance or the government? Seems like a similar principle would hold for deliberate disease attack.
August 5, 2005
CEO, Centaur Science Group (formerly, Associate Administrator, United States Department of Agriculture, Agricultural Research Service), Washington DC.