Prescribing a market…

Prescribing a market disruption within the definition of “hazard” and updating appendices listing notifiable hazards in O. Reg. 277/12 (Reporting of Hazards and Findings) under the Animal Health Act, 2009.
OMAFRA Proposal Summary
To support animal health and enhance preparedness, OMAFRA is proposing a new regulation to prescribe that a provincial surplus of livestock or poultry due to a border-related disruption would be added to clause (c) of the “hazard” definition,

The Feather Board Command Centre (FBCC) appreciated the opportunity to discuss OMAFRA’s proposal to broaden the definition of “Hazard” under the Animal Health Act to include the animal health and welfare concerns of surplus livestock related to a border-related disruption. Several of the FBCC Board members provided input.

Due to time limitations of the consultation, it was not possible for all 8 poultry industry boards and organizations represented on the FBCC Board to formally discuss this written response. Therefore, I am making this submission as a veterinary epidemiologist expert who is manager of the FBCC. My previous position in OMAFRA, as Director of the Animal Health and Welfare Branch when the Animal Health Act was developed, gives me some appreciation of the importance of this regulatory proposal for livestock emergency management.

Strengthening preparedness is essential for both government and industry. The risk of border closures is real and potentially imminent. Both government and industry need as many tools as possible in place to respond quickly to this threat. As described in the OMAFRA proposal, this broader definition of “Hazard” would not compel deployment of AHA response authorities. The Proposal goes on to state that the government would first seek to work with industry to address a surplus livestock situation caused by a border closure. Only as a last resort would government exercise its powers under the Animal Health Act. Presumably holding this power to intervene legally will serve to motivate appropriate animal health protection measures by industry members and the informal sector, thereby minimizing the actual use of any coercive power.

The Proposal Summary cites, as examples, three foreign animal disease situations where trading partners could impose trade restrictions. However, it should be noted that non-disease situations such as ice storms, floods, food safety risk, arbitrary trade actions, terrorism etc. can also result in border closures. Would the proposed regulation change also apply to the surplus livestock created in these situations?

This regulation amendment as currently described would primarily benefit livestock sectors that are export dependent. Unlike the supply managed sectors, these commodity organizations lack authority to control marketing; neither does the government unless an emergency is declared. Currently OMAFRA’s role in these situations would be limited to facilitating discussions with industry stakeholders to manage issues and identify options to deal with the border closure situation. Clearly OMAFRA will be able to offer more industry support with this Regulation change.

It is expected that these regulation changes would facilitate OMAFRA’s use of AHA powers during a Highly Pathogenic Avian Influenza outbreak by assisting in preventing disease spread. For example, in the 2015 AI outbreak in Ontario, the inability to regulate the non quota poultry sector as well as show birds and auctions represented a vulnerability that could have contributed to an even longer border closure.

However, the proposed regulation change is far too narrow in its scope. The authorities of the Animal Health Act should be applicable to all surplus livestock crises even in the absence of a border closure. Examples of these scenarios include:
1. situations where the supply chain is disrupted due to partial or complete processing plant shutdowns from work stoppages, civil disobedience, human health epidemics, other acute labour shortages or transport disruptions and
2. Natural disasters such as floods, fires, where livestock and livestock products are unable to move to market.

In respect to proposed amendments to the Appendices containing lists of Immediately Notifiable Hazards (Appendix A) and Periodically Notifiable Hazards (Appendix B) in Ontario Regulation 277/12 (Reporting of Hazards and Findings);

FBCC is confident in the consultation process whereby poultry veterinarians and feather organizations are suggesting additions, recategorization or deletions to the immediate and periodical notifiable disease lists as part of the consultation process. Thank you for the invitation to be part of the subsequent Veterinary Expert Panel.

FBCC understands the value of OMAFRA having ready access to all immediately notifiable diseases diagnoses, to conduct appropriate risk assessments and inspect the higher risk situations. The poultry industry also relies on this information for certain diseases deemed actionable eg ILT. More frequent availability of aggregate data from periodically notifiable diseases would facilitate improved surveillance and potential disease control programs by industry.

As manager of the Feather Board Command Centre, an experienced epidemiologist and former senior public animal health veterinarian, I support OMAFRA’s suggested inclusion of new hazards to the lists of “Periodically Notifiable Hazards’ namely Reovirus variants, Infectious Bronchitis and necrotic enteritis.
I also endorse the Chicken Farmers of Ontario recommendations that fowl adenovirus (IBH) enterococcus cecorum and infectious coryza be added to that same list. All these diseases have the potential to cause significant economic impact and should be included in disease management and surveillance programs.

In addition, I would like to suggest that Pigeon Paramyxovirus-1 (PPMV-1) be considered as an “immediately notifiable disease” in the new regulation for the following reasons:
• virus has caused recent high mortality in pigeon industry in Ontario, BC and other countries eg racing and hobby flocks
• clinically indistinguishable from Newcastle Disease (ND) in poultry
• this virus requires lengthy laboratory pathogenicity testing to distinguish from ND, a highly contagious federally reportable disease
• literature suggests that there is a non-negligible risk to poultry
• no treatment
• limited access to vaccine
• potentially zoonotic as it can cause conjunctivitis in humans
• rapid international growth of domesticated pigeon “industry”
• listing would allow OMAFRA to notify pigeon owners
• listing would allow industry to notify poultry farmers to take precautionary measures