UK’s Rabies Laws to be overhauled?
By NICK MAYS
THE UK’s long-standing Rabies Prevention Laws may be facing a radical overhaul in the coming months, including a reduction in quarantine periods for animals entering the UK from countries not incorporated as part of the PETS Travel Scheme, thanks to a new Government review of the existing rabies prevention policy.
Veterinary risk assessments and consultation comments informing the review into the UK ‘s current rabies prevention policy have been published by DEFRA this month.
Veterinary risk assessments were commissioned into the risk of rabies and other exotic diseases entering the UK. These have been completed and independently peer reviewed.
Fred Landeg, DEFRA’s Deputy Chief Veterinary Officer said: ‘We need to ensure that our controls on rabies and other exotic diseases are proportionate to the risk of these diseases entering the UK, whilst always considering the primary aim of protecting public health.
‘Our disease control policies are always based on the principles of risk and proportionality. However, it is important that the science on which we base our policies is sound and stands up to scrutiny.’
Minister for Animal Health and Welfare, Ben Bradshaw said: ‘I welcome the opportunity to take a fresh look at our rabies controls. I note there is some support from external stakeholders for change in rabies controls where this can be based on the evidence. I also acknowledge their concerns about the risks of other diseases entering the UK.
‘The evidence received so far from government vets, officials and the veterinary risk assessments raises very important questions about our current approach. It indicates that our current controls may no longer be proportionate to the risk of rabies entering the UK and we may need to consider modernising processes and regulation in this area. Our controls must also be consistent with current thinking on better regulation.
‘I will be seeking further views before I reach conclusions. Meanwhile, our current rabies prevention policies remain firmly in place.’
The list of organisations consulted by DEFRA included the Kennel Club, the Governing Council of the Cat Fancy (simply listed as ‘Cat Fancy’). Dogs Trust, Guide Dogs for the Blind Association and British Veterinary Association.
On 17 November 2005, comments were sought from the various parties and ‘stakeholders’ listed on DEFRA’s rabies disease import control policy review. The consultation period closed on 9 February 2006. The purpose of this consultation at the outset of the review was to give stakeholders organisations the opportunity to comment on, and influence, the future direction of policy.
DEFRA invited 124 external stakeholder organisations to comment and received a worrying low total of 31 responses as well as eight responses from private individuals.
The Department of Agriculture and Rural Development (DARD) in Northern Ireland carried out their own consultation, inviting 88 organisations and Northern Ireland’s MPs and MEPs to comment – a pathetically low six responses were received.
Amongst the general comments received were:
• Current quarantine controls (including derogations) have kept UK rabies free and should remain unless evidence shows other options are as effective.
• UK’s derogations under the EU Pet Movement Regulation will require strong scientific justification to retain one.
• Support policies based on risk assessment, proportionality and sound science.
•Consider impact of a rabies outbreak in wildlife on the countryside, public attitudes to the countryside and costs of controlling a wildlife outbreak.
• Current rules are confusing and difficult to enforce.
• Review needs to establish the facts e.g. Is there any evidence of domestic animals carrying rabies across land borders and infecting wildlife.
• Other exotic diseases which may infect animals should be considered as important as rabies.
• Quarantine has served as a deterrent to travel and thus prevent entry of other exotic
• Disease surveillance of exotic disease and monitoring of imports is required.
• There should be a DEFRA funded companion animal surveillance scheme. The zoonotic potential of parasites should be considered alongside animal health and welfare status. This should be viewed independently as a distinct area of zoonotic threat and a potential animal welfare issue.
• A database of all PETS animals/imports under PETS is required to aid enforcement and tracing.
• Consider impact of other exotic diseases, or a case of rabies, on the welfare of animals and the possible change in public attitude to dogs which results.
• Controls need to be rigorously enforced with border checks.
• There should be as a minimum a form of health certification for rodents imported through a list of approved points of entry. As there are no controls, this regime is open to abuse by some commercial dealers.
The Pet Travel Scheme (PETS) was considered specifically by many respondents, and amongst the comments on the future of the scheme were:
• Current policy has led to a sustainable and workable system allowing easier movement of companion animals without leading to outbreaks of rabies.
• The six-month waiting period after vaccination under PETS is difficult to justify. The rationale for this rule that an animal may be incubating rabies is not supported by evidence.
• Would welcome a move from a six-month to a three-month waiting period. Three months is regarded as adequate in other countries.
• Support a 28-day wait to allow for a blood test to be carried out.
• Should carefully assess risk before reducing six-month waiting period, bearing in mind that there is minimal scientific evidence available.
• The six-month waiting period before a vaccinated and blood tested animal can re-enter the UK could be dispensed with without significantly increasing the risk of introducing rabies.
• Numerous problems with microchips mean this requirement is not perfect. DNA testing seems the most obvious and safest solution if a microchip fails.
• The blood test is an important safeguard.
• Consider data on vaccine failure and efficacy of vaccines.
• A (small) proportion of animals fail to meet the required level of antibodies after vaccination.
• Blood test provides definitive evidence an animal has been vaccinated.
• Concerned if blood test removed without evidence and risk assessment.
• Should check efficiency of enforcement.
• Deregulation of the approved route system should be considered provided 100% post-entry checks remain.
• Rules on non-compliant animals too harsh. Quarantine unnecessary for a non-compliant animal as long as it is correctly identified, vaccinated and blood tested.
• Support scheme as it has significant welfare advantages over quarantine.
• Consider harmonising UK and Scandinavian requirements related to the timing of blood tests and waiting periods. This would allow the EU to develop consistent rules for movement to rabies free areas (requiring a blood test in accordance with WHO recommendations).
Quarantine was considered also:
• Quarantine should be reduced to three months because signs of infection are obvious long before six months. Quarantine periods should be more representative of the progression of the disease as defined by experts. Rabies incubation periods usually much shorter than three months.
• Quarantine kennels should be controlled by statutory regulations rather than a voluntary code of practice.
• Concern about the stress caused to animals during quarantine, and about the conditions in certain quarantine premises.
• As PETS has been successful for cats and dogs, quarantine requirements should be removed for more species.
• Object to the continuation of the quarantine requirement, as it is both cruel and now redundant in the fact of the combination of blood testing and microchipping as accepted in the rest of the EU.
• Quarantine should remain for countries that are not rabies-free.
Exemptions from quarantine (including zoos, guide dogs and SAR dogs):
• Qualified Search and Rescue (SAR) dogs should be given carte blanche to go to any country (even if not on the approved list) where they can save human lives. Should be spared six-month quarantine, and required to have a yearly rabies vaccine. Owners would ensure that the dogs were not involved in dangerous contact with local strays.
• Special dispensation should be given to exempt SAR dogs as in the rest of the EU. Such animals are subject to a high standard in adhering to working practices adopted by parent organisations.
• PETS rules should be extended to all exotic mammals imported into zoos in place of quarantine.
• More dogs are imported following introduction of PETS, so there is a greater risk to public health [risks unspecified by respondent].
• Pet owners have a duty of care to their pets, including regular administration of products/medicines to prevent and/or treat disease.
• Continuing concern over veterinary pathogens especially leishmaniasis.
• Quarantine rules historically minimised the exposure of domestic animals in the UK to diseases such as leishmaniasis.
• PETS has led to entry of animals infected with serious infected diseases. Alternative protocols suggested in the past should be considered again.
Tick and tapeworm treatment requirements:
• UK derogation for tick and tapeworm treatment should be retained.
• UK would become more vulnerable to new diseases if requirement for tick and tapeworm treatment were dropped.
• Practical difficulties with the requirement for the pet to be treated against ticks and tapeworm, and, in particular for this treatment to be administered 24-48 hours before check-in. Timing of treatment must be revised to ensure increased owner/veterinarian compliance.
• Increase the time period for tick and tapeworm treatment to ten days (as it is in Sweden). This would alleviate problems for travelers (including frequent travellers wanting to avoid over-treating their pets) and simplify checking procedures.
• Under current requirements, it is possible that live ticks will be imported on dogs. Should be double treatment for external parasites and tapeworms with a significant interval between them, i.e. 21-28 days before entry, and then 1-24 hours before entry. This would be easier to implement for pet owners and reduce likelihood of dogs contracting exotic disease.
• Would like to see whole of EU introduce requirement for tick and possibly tapeworm treatment.
• Concerns about regular treatment with tick products for frequent travellers, where products recommend monthly treatment.
• Central register of all mammals legally brought into the country would be a great aid to enforcement officers to help them detect illegal.
The veterinary risk assessments, and a summary of the views received from the initial consultation with external stakeholder organisations, are now available on the DEFRA website at: www.DEFRA.gov.uk/animalh/diseases/notifiable/rabies/index.htm