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THE European Union (eu) is in the process of reviewing regulations governing the movement of pet animals and the results of that review, which could lead to changes in the uk's Pet Travel Scheme (pets), are due shortly. In the meantime, in the uk, defra has been conducting its own review of pets and other rabies prevention policies to inform the uk's response to the eu review and determine whether the existing uk controls are proportionate and sustainable. As things stand, the import controls imposed by the uk are stricter than those applying in other eu member states; this has been made possible by a derogation to the eu legislation, but one result of the eu review is that this could be removed. In November 2005, defra issued a consultation document seeking views on the desirability of any changes to the existing arrangements and announced that it would be commissioning veterinary risk assessments into the likelihood of rabies and other exotic diseases being brought into the uk. A document summarising comments received during that consultation has now been published on defra's website, together with two qualitative risk assessments — one on rabies, from the Veterinary Epidemiology and Economics Research Unit at the University of Reading, and one on other exotic diseases, from the Veterinary Surveillance Team at the Central Science Laboratory*. defra says it has still to reach conclusions on this issue, and will be seeking further views. However, the signs are that it does see scope for change. On publication of the documents last week, the animal health minister, Mr Ben Bradshaw, said that he welcomed the opportunity to take a fresh look at the uk's rabies controls, and that ‘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.’
The two risk assessments make interesting reading, not least because they point to potential inconsistencies in the arrangements as they stand. This is most notable, perhaps, in the document on rabies, which draws attention to the different rules applying to animals entering the uk from countries that qualify for the pets and those that do not, and differences in the rabies status of qualifying countries. At present, animals coming to the uk from countries where rabies is considered to be a significant problem have to undergo six months' quarantine, whereas animals coming from qualifying countries, where rabies is considered to be a less significant problem, can enter under the pets. However, the document points out that some of the qualifying countries have ongoing problems with rabies, and that, in such cases, the level of compliance with the requirements of the scheme seems to be the crucial factor. It comments that, if a high level of compliance can be achieved, it seems that any country can be acceptable under the pets, but also draws attention to the difficulties associated with ensuring compliance. It points out that ‘A key criterion in making any decision about whether to apply pets regulations for import, or to require quarantine within the uk, is the level of confidence than can be achieved in compliance with the pets regulations. If compliance is doubtful, perhaps because of poor veterinary regulation in the overseas country, then the lower risk option is to require quarantine within the uk.’
The document highlights the value of vaccination as a rabies prevention tool, suggesting, for example, that, for animals travelling out of the uk and back again, ‘vaccination (with other safeguards), rather than quarantine on return, would be suitable for most trips of any length to any country’. It also describes vaccination against rabies as the most important measure to protect an animal before entry to the uk. Discussing each of the pets requirements in turn, it notes that microchip identification is important as it gives confidence that vaccination and blood tests relate to the animal presented for import, and that serological testing provides confidence that an animal has been successfully vaccinated and that there is good compliance in the country of origin. It describes a waiting period after vaccination and testing before entry as being vital if quarantine after importation is not used, but suggests that the six-month waiting period required under the pets is longer than necessary and that the four-month waiting period stipulated in the current eu regulations would be acceptable. It says that tick and tapeworm treatment with veterinary certification 24 to 48 hours before entering the uk is ‘a useful control point’, because it provides an opportunity to check that the other requirements of the pets have been met, especially in view of the fact that certification checks may not be carried out on all animals at the port of entry. It notes that border control at the port of entry is also a useful control point if it is efficiently implemented, by both the carrier and immigration officials.
While important in terms of safeguarding public and animal health, the requirement to treat animals against ticks and tapeworms 24 to 48 hours before entry into the uk has proved problematic in practice, and the separate risk assessment on diseases other than rabies recommends that this aspect of the pets be changed. Instead, it advocates extending the window for tick and tapeworm treatment to one to 10 days. This, it suggests, would help address potential compliance failure, with increased compliance outweighing the risk associated with extending the treatment window. It also recommends that pet owners should be given clear advice on avoidance and control of animal disease problems during the time spent abroad and be strongly advised to repeat tick and tapeworm treatments on return to the uk. This risk assessment provides a useful overview of diseases which could and have been introduced into the uk under the pets, highlighting both what is known and areas where information is lacking. It makes sound recommendations for improving the available knowledge base, arguing that more detailed data are needed on the specific movements of animals before entry to the uk under the pets, and calling for more active disease surveillance of livestock, companion animals and wildlife.
It will be interesting to see how defra's policies develop as a result of its own and the eu review but, if it does decide to change things, and the minister's comments suggest that it might, there are important points to bear in mind. First, as the rabies risk assessment points out, ‘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’. Secondly, although there might be felt to be some ‘belt and braces’ aspects to the current regime, the various control measures are interlinked and any adjustments must be considered with great care. In areas such as surveillance and ensuring compliance there is scope for the arrangements to be improved. The Government needs to tread carefully. It must not put itself in a position of adopting or having to adopt changes that allow greater movement of pets at the expense of human health and animal health and welfare.