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(Response to the Consultation Letter on DEFRA's new policy for AHS sent to firstname.lastname@example.org)
1. First, I am most grateful to DEFRA and to Brigadier Paul Jepson and the AHS Working Group for their work.It was very pleasing to see the AHS underlying principle that "We want to avoid control measures that involve mass slaughter." It is partially reassuring to read "No mandatory cull of animals on infected premises - unless the secretary of state chooses to request it"
2. It is good to know that a close eye is being kept on trials for the new inactivated vaccine currently taking place in AfricaPrevention is always so much better than "cure by killing" and where reliable vaccines exist (such as for foot and mouth) it is a great boon to be able to use them. While the vaccine question is still awaiting development, the UK draft plan does give the government powers from the controversial amendments to the Animal Health Act in 2002 to slaughter horses in the early stages of an outbreak of AHS and this letter wishes specifically to express some concern about this.
3. There must surely be concern at the idea of slaughtering suspect horses without benefit of rapid PCR testing."...compensation - which will only be paid for any horse killed which is subsequently shown to be free of the disease ..."
"... Government will act rapidly to kill infected horses, and those showing clinical signs of the disease on infected and contact premises."7.3.6 Culling of infected animalsUnlike the EU Directive (of nearly 20 years ago now) that allows slaughter on suspicion only at extreme need, the UK Draft Strategy does allow for the legal killing of horses suspected of being contacts without tests having been carried out and on the basis of visible clinical signs alone - if the Secretary of State decrees this. Will the Secretary of State's decision be based on veterinary advice? In the past we have, most unfortunately, seen political expediency lead animal health policy. The worst example- and one where the trauma even now continues - is the mass cull of FMD 2001.
Legislation must surely always be informed by genuine experts in the relevant animal disease - and thus encourage further advances in vaccine production and rapid in-the-field diagnosis.With a disease like AHS it should surely never be necessary to kill an animal who later turns out to have been uninfected. Increasingly available rapid RT-PCR diagnosis would surely be far less expensive than paying compensation to horse owners who will not only be financially affected but also emotionally aghast at the killing of their horse. In the present decade, advances in rapid diagnostics have been huge. Slaughter on Suspicion is unnecessary and outdated, given the availability of on-site RT-PCR about which DEFRA has sometimes seemed to be almost wilfully ignorant - and yet the AHS draft strategy allows for the killing of suspect horses without tests having been carried out and on the basis of visible clinical signs alone.
It is very much to be hoped that before the draft regulations go before Parliament, DEFRA makes quite sure that the issue of pre-slaughter testing is thoroughly investigated.
4.The UK is consulting on how best to "implement" the current EU requirements - but what seems remarkable is that in some respects the UK's ideas seem even more outdated than the Directive (which itself dates from about twenty years ago).
The EU Directive says that only in an "epidemic" can pre-emptive killing take place on suspected premises, based on "clinical signs and/or epidemiological results". Where the situation does not constitute an epidemic the Directive requires regular clinical examination of horses on suspect holdings together with any necessary testing.The new draft legislation seems to turn this on its head by allowing suspect horses to be summarilu slaughtered in the very early days of a possible epidemic.There is therefore a worry that the UK strategy may be gold-plating the Directive to provide the Secretary of State with the quick and easy option of pre-emptive killing without legal restraint even in an isolated outbreak of disease.
The Draft Strategy does not spell out what powers are available for the Secretary of State if he should seek approval for "additional measures if the disease is exceptionally serious". The 'additional measures' involve the most draconian measures of the Animal Health Act of 2002 - but, (as with what "exceptionally serious" actually means) the details are not made clear. It seems only right that these powers should be clearly stated.
There is a problem about relying on clinical signs of disease - as we saw during Foot and Mouth when UK and foreign vets were not experienced in dealing with such a rare notifiable disease. AHS is such a rare disease that few vets will have the expertise to be sure that clinical signs indicate AHS.5. AHS is not a contagious disease. Infected horses do not remain carriers of the disease if they survive.The legislation seems to intend to authorise killing of any other horse(s) with "clinical signs" on an infected premises without waiting for a test result and to extend this power to "dangerous contact" premises where there is only a suspicion of infection. But horses themselves do not infect each other. They are not carriers. The situation is similar to that of Bluetongue where only the culicoides midges are able to infect horses. Thus, killing horses is a draconian but also ineffective measure - except, of course, if their condition warrants euthanasia.Deep concern is felt in many quarters that there is a continuing mindset in DEFRA that uninfected animals (or animals that can recover) may be summarily killed in the name of disease control. The use of available diagnostic tests ought to be making such measures unnecessary and I do urge DEFRA and the Working Party to make every effort to investigate what assays are available to use on-site if AHS is suspected.