ANIMAL HEALTH: LEGISLATION AND CONTROLS FOR TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES
L.O. Mascitelli
National Agrifood Health and Quality Service (SENASA), Argentina
The very favourable health status enjoyed by Argentina for Bovine Spongiform Encephalopathy (BSE) and Scrapie has enabled the country to maintain an excellent position in the international trade markets and be considered a reliable exporter of animal products.
The many actions adopted as of 1990 seek to preserve the current health status and prevent the entry of BSE and scrapie by establishing stringent controls and a follow-up for imported animals, reproductive material, products, and animal products and by-products that could be a challenge to animal and public health. These actions are complemented by an active and passive epidemiological surveillance and testing of concentrates.
Argentina's actions, which were adopted much before any of the affected countries implemented any measures, were questioned and objected to by its trading partners. Yet, it was these actions that, as a result of the events in the UK at the end of 1995 and that gained international attention after the crisis in March 1996, qualified Argentina to be internationally recognised as a risk-free country for BSE and scrapie. As a result, Argentina's animal health status was not questioned by any country and thus, no export markets were closed to its products.
The Animal Health laws include general and specific regulations.
The general rules serve to prevent the entry of exotic diseases. The first one of this kind, was the Animal Health Enforcement Law passed in 1900, which has been updated with amendments. Decree 4238 passed in 1968, and its amendments, required inspection at all slaughtering plants and facilities that process animal products and by-products.
The specific rules for Transmissible Spongiform Encephalopathies define:
Preventive measures to avoid the importation of BSE and scrapie were adopted in 1990 with the enactment of Resolution 429. The rule established a ban on all imports from the UK of live animals, genetic material (semen/ova and embryos) and by-products of bovines, sheep and goats, and implemented the necessary measures to ensure compliance.
The restrictions were enforced, and in 1995, as a result of the concern caused by the greater knowledge about the diseases and their consequences, new rules were established requiring animal feed and import controls, in addition to an epidemiological surveillance program.
These rules, such as Resolution 252, established a ban on the use of bovine and/or sheep MBM as ruminant feed, as stated in the OIE recommendations. Although the causal agent was not present in the country, the ban ensured no possibility of the agent entering the feed chain of ruminants and provided additional guarantees to our buyers.
Resolution 382 and its amendment, Resolution 294, restricted imports of live animals, semen, embryos, meat and meat by-products, and milk and dairy products from countries with a different health status for BSE. The resolutions classified the countries into four categories according to their animal health status: a) Countries with epidemic outbreaks, b) High Risk Countries, c) Low Risk Countries, and d) Free Countries. They also required Country Risk and Product Risk assessments from the exporting countries, when applicable, prior to the approval of the importation.
A free country is one in which no cases of BSE or Scrapie have been reported, and whose risk assessment for BSE and scrapie has been approved by SENASA. Countries that have had cases in imported animals and that have eliminated the affected animals and all contact animals, are also classified as free countries.
The Stock Book for Imported Breeding Animals was created by Resolution 471/95. This rule required identification and continuous surveillance of ruminant breeding animals from the date of their importation until their death, as well as compulsory elimination of their carcasses, quarantine requirements, sampling, etc.
Due to the extended incubation period of BSE and scrapie, the follow-up and elimination of the carcasses ensures no transmission of the agent to native animals, in the hypothetical case that the agent were to enter the country via imported breeding animals.
In 1996, and with the BSE crisis in the public eye, SENASA issued Resolution 203 to protect public health. This rule approved the Country Risk and Product Risk classification for all imports of ruminant products. The countries were classified - based on their risk for BSE - as: I) with epidemic outbreaks, II) with reported cases (a - in native animals, or b - in imported animals), III) with unknown status and/or under evaluation, IV) free countries.
Ruminant products were classified according to their risk of transmitting BSE as: I) High Risk, II) Medium Risk, and III) Low Risk.
Resolution 562 later amended the Country Risk criterion III) Unknown status and/or under evaluation, to read III) with no reported cases, subdivided into a) with trade-related risk, and b) under evaluation.
A multidisciplinary Honorary Advisory Committee was formed to analyse the actions that should be put in place for imports of material that could present a challenge to animal or public health. Contacts were made with international experts.
As a result, and by Resolutions 456 and 457, the Scientific Advisory Committee (that includes foreign and Argentine experts) and the Technical Advisory Committee (of Argentine experts) were formed to present recommendations to the Secretary of Agriculture, Livestock, Fisheries and Food (SAGPyA) on the measures that should be adopted given the new scientific knowledge on Transmissible Spongiform Encephalopathies. This clearly demonstrated Argentina's interest in continuing with the analysis, updating its knowledge and receiving recommendations to prevent the entry of the diseases.
The Scientific Advisory Committee has convened annually. The first meeting was held in Buenos Aires between April 7 - 9, 1997, the second one in El Calafate, Province of Santa Cruz, during the week of April 21 - 24, 1998, and the third one was again in Buenos Aires between August 9 and 11, 1999.
As a result of additional controls for animal feed, Resolution 252/95 was amended by Resolution 611/96, to authorise the use of bone ash (processed at > 600°C) in bovine feed as a source of phosphorous in areas with phosphorous deficient soil.
To improve the epidemiological surveillance, a National Epidemiological Surveillance System for Animal Diseases was implemented by Resolution 234/96. The system complements the existing scheme with the participation of SENASA and private veterinarians, as well as national, provincial and municipal institutions and bodies. The National Animal Health Emergency System was approved by Resolution 357/96.
The need to continuously update the rules as a result of new scientific knowledge and risk management criteria, and following the Scientific Advisory Committee's recommendations to maintain Argentina's zoosanitary status and provide guarantees to our trade partners, Resolution 30/98 was enacted to modify the classification of semen stated in Resolution 203/96. As a result, semen was reclassified from Medium Risk to Low Risk.
Following the reclassification of imported semen, the rules were amended to include the requirement of presenting a risk analysis prior to importing semen, if considered necessary.
After semen imports were reclassified, a surveillance and follow-up program for imported reproductive materials and the offspring derived from them was implemented by Resolution 107/99. The rule requires all farmers that use such material from ruminants to report Artificial Insemination or Embryo Transfer data, including the recipients' identification and that of the offspring derived from them. The farmer and the veterinary physician responsible for the procedure are liable for the information included in the statement.
The reclassification of semen, among other actions, demonstrates Argentina's interest in updating its animal health regulations based on the new knowledge on Transmissible Spongiform Encephalopathies, the OIE Animal Health Code requirements, and the recommendations of the Scientific Advisory Committee of SAGPyA. The new animal health requirements for imported semen are based on the Free Country status, as defined in the last version of the BSE Chapter published by the OIE, and establish the category "Country with Low Incidence".
In line with these actions, other resolutions - including Resolution 429 which was the first specific resolution passed in 1990 - shall be updated to include the challenge presented by milk, dairy products and semen imported from the UK.
Lastly, it is of utmost importance that the rules be applicable to the work effectively carried out in all the areas involved in the study of Transmissible Spongiform Encephalopathies, and based on the most recent and standardised technical criteria applied to define the zoosanitary status of other countries. The ultimate goal being to protect Argentina's health status yet allow a safe and active trade.
As the animal health conditions are always dynamic and never permanent, the rules quickly become outdated. Adjusting to the international context is indispensable, but preserving Argentina's health status is paramount.