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IT looks increasingly likely that the uk's rabies controls will change next year when a derogation that allows the uk to apply stricter controls than other eu member states comes to an end — all the more so following comments from the uk's Chief Veterinary Officer (cvo) and Chief Scientific Adviser last week that the current controls could be ‘over-precautionary’ (see p 534 of this issue). Changes to Britain's Pet Travel Scheme (pets) and quarantine arrangements seem inevitable. The question is just what will be changed, and by how much.
The European Commission (ec) is currently reviewing the rules on pet movements with a view to harmonising arrangements in eu member states and is expected to report soon. Meanwhile, in the uk, defra, too, is examining the issue, to see how far it might go in acceding to eu requirements. The outcome has still to be decided. However, it was clear even before the cvo and the Chief Scientific Adviser made their remarks last week that the Government does see scope for change (VR, February 3, 2007, vol 160, pp 137-138).
At present, the uk imposes stricter controls on pet ‘imports’ than most other eu member states, whether those animals are travelling from countries inside or outside the eu. Animals entering the uk from eu member states or approved countries outside the eu are eligible to travel under the pets, which requires that they be identified by microchip, vaccinated against rabies and tested for antibodies to rabies two to four weeks later. Following a successful blood test, they must then wait six months before entering the uk for the first time. They must also be treated for ticks and tapeworms 24 to 48 hours before entry. Animals from non-approved countries outside the eu must spend six months in quarantine.
Most other eu member states simply require that animals travelling from another member state or from listed countries outside the eu be microchipped, vaccinated against rabies and then wait 21 days before entry. Animals travelling from non-listed countries have to be microchipped, vaccinated against rabies and tested for antibodies up to 30 days later. Following a successful blood test, they must then wait three months before entry. Clearly, if the uk falls into line with the rest of the eu, its current arrangements will change substantially.
Both the ec (through the European Food Safety Authority [efsa]) and defra have recently undertaken risk assessments on the consequences of changing the rules and, while practical and political considerations will undoubtedly apply, full account must be taken of these as policies are devised. The risk assessments draw similar conclusions in a number of areas. They agree, for example, that rabies vaccines are highly efficient and that vaccination, coupled with identification of the animal by microchip, represents the most important measure for preventing the disease. They also agree that a three-month wait after successful vaccination should be sufficient to identify any animals that may have already been incubating the disease. However, they place different emphases on the value of serological testing, with defra's risk assessment arguing that the test provides confidence that an animal has been successfully vaccinated and that there has been good compliance with the pet movement rules in the country of origin (VR, February 3, 2007, vol 160, pp 137-138). The efsa's assessment, meanwhile, suggests that a second vaccination can provide assurance that sufficient immunity has been achieved and that such assurance is necessary only in the case of movements involving countries with a greater than negligible risk of rabies (that is, more than one or more cases per million pets per year). It further suggests that there is no rationale for imposing a waiting period beyond the time when protective immunity has been achieved, except in the case of imports for countries where the risk is not negligible (VR, March 10, 2007, vol 160, pp 313, 314).
There will be many factors to consider as the eu seeks to harmonise its pet movement rules, and the task will not be made any easier by the fact that, while most eu member states fall into the efsa's negligible risk category, some of them do not. At this stage it is not clear how far the uk Government can or will be prepared to go in the negotiations, but moves to abandon serological testing and a waiting period of at least three months after vaccination should be resisted. Rabies vaccines are highly efficient, but they are not 100 per cent efficient, and a ‘vaccinate and go’ policy will increase the number of animals travelling without necessarily being protected. By encouraging animal movements, such a policy would also increase the risk of exotic diseases other than rabies entering the uk and, with fewer checks in the system, there must inevitably be questions about compliance. These are not minor considerations. As defra's risk assessment remarks, ‘even a small risk of importation of rabies is of serious concern’, and the consequences of the introduction of rabies into the uk ‘though variable, are all severe’.
The requirements under the pets for animals to be treated for ticks and tapeworms before entering the uk — introduced on public health grounds — are also under consideration as part of the eu review; these have been the subject of a separate risk assessment by defra and are currently being considered by the uk's Advisory Committee on Dangerous Pathogens. The Government might be right in seeing some scope for amending the pets and quarantine requirements but, as discussions progress in Europe, it must not allow itself to be railroaded into changes that could put public health, animal health and animal welfare at risk.