European Association of Zoo and Wildlife Veterinarians
EAZWV
The European Association of Zoo and Wildlife Veterinarians (EAZWV) represents over 500 veterinarians working in 40 different countries.
ID: 158270723530-82
Lobbying Activity
Response to Professional qualifications recognition of veterinary surgeons - training requirements update
21 Oct 2024
The European Association of Zoo and Wildlife Veterinarians endorse the ECCVT feedback statement and proposals on the minimum training requirements for veterinarians (attached).
Read full response30 May 2018
EAZWV welcomes the Commission Delegated Regulation (EU) amending the list of diseases set out in Annex II to Regulation (EU) 2016/429 of the European Parliament and of the Council on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‛Animal Health Law’). We agree that aligning this disease list with those listed by the OIE, the World Organisation for Animal Health will improve coordination of animal disease surveillance and control across the European Union. We do however have some concerns with some of the new listings particularly if some of these contained diseases go on to inform veterinary legislation applicable to the approval of confined establishments (as per AHL draft doc SANTE/7016/2019 supplementing Regulation (EU) 2016/429, and Annex C of 92/65/EEC).
Our concerns are as follows:
1. Inclusion of Low Pathogenic Influenza (LPAI).
LPAI’s are not an OIE-Listed diseases and in particular LPAI strains in wild bird species fall out with the remit of the OIE Terrestrial Animal Health Code 1.
Many LPAI strains are considered endemic in wild bird populations and are rarely associated with clinical disease in humans and in wild and domestic birds. As such LPAI fails to meet the European Commission criteria of causing “significant negative effects on animal health or public health or the economy or the environment or biodiversity”.
We are assuming that the request to add LPAI to the list comes from the commercial poultry sector as they may find it useful to screen their intensively farmed flocks for exposure and that their unique high density methods can bring about circumstances where conversion to virulence could occur.
We do not see that adding LPAI is relevant to non poultry (captive birds and wild birds) and its inclusiont, despite it not meeting the criteria, would lead to significant issues in the non-poultry sector.
We are also unclear as to
a. What screening regimes might be required. Many member states do not currently allow screening in the absence of clinical suspicion.
b. What the relevance would be of screening considering the endemic nature of many of these strains AND the longevity of many zoo birds of >30yr.
c. What actions might be required and whether these actions are commensurate with risk.
2. Broadening the tuberculosis listing from M. bovis to MTB complex
We have a number of concerns about the change from listing of only M.bovis to M. tuberculosis complex (M. bovis, M. caprae and M. tuberculosis)
a. What is the basis for including these additional species? They are not OIE-Listed diseases or disease agents?
b. We find the listing unclear. M.tb complex includes at least seven more Mycobacteria species than M. bovis, M. caprae and M. tuberculosis. As an example M. pinnepedia is part of the M.TB complex and has been seen in zoo pinnepeds. Is the intention to include this as well? If so what measures would be put in place for diagnosis and control?. If the commission feels there is sufficient evidence that warrant the addition M. caprae and M. tuberculosis to the current TB listing of M.bovis this should be done as three separate diseases rather than under the heading MTB complex. Leaving it as is, could easily complicate and confuse future implementation decision making2.
c. The practicalities of widening the scope of the list to include M TB complex also need to be carefully considered.
There is insufficient space to continue, our further concerns and supporting references are given in the attached document
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