Reg255/97 2409

2024-09-15T16:53:20Z

PaulMc: Created page with "<center> The Poultry Veterinary Study Group of the EU </center> <HR>..."

<center>


The Poultry Veterinary Study Group of the EU


</center>
<HR>
8th August, 2023

Dear Sir/Madam,

On behalf of The Poultry Veterinary Study Group of the EU please find, linked below, our considered :

Response to PROPOSALS TO AMEND A REGULATION OF THE EUROPEAN PARLIAMENT AND OF
THE COUNCIL on the protection of animals during transport and related
operations, specifically by amending Council Regulation (EC) No 1255/97 and repealing
Council Regulation (EC) No 1/2005. .

[http://www.pvsgeu.org/uploads/Welfare_transport_2409_2.pdf CLICK HERE] for our response.

Yours Sincerely

Dr. Eva Berndtson

President of PVSGEU 

<hr>

<center>PVSG Working Group on Poultry Welfare (September 2024)

'''Daniel Parker (Chair)''',

Franz Sommer(Austria)
Eija Kaukonen (Finland),
Paivikki Perko-Mäkelä (Finland),
Gerard Leveque (France),
Boris Meyer-Kuehling (Germany),
Ronald Guenther(Germany),
Allan Ball (Great Britain),
Stephen Lister (Great Britain)
Laszlo Kőrösi (Hungary),
Greg Koulianos (Ireland),
Leonardo Vinco (Italy),
Suzanne Bosman (Netherlands),
Jose De Sousa Nunes (Portugal),
Miguel Valls (Spain),
Pia Gustavsson (Sweden),
Karin Kreyenbuehl (Switzerland),


<hr>
<big><big><big>
[http://www.pvsgeu.org/uploads/Welfare_transport_2409_2.pdf Click here for our Response]</big></big></big></center>
Yours Sincerely

Dr. Eva Berndson

President of PVSGEU

PositionPapers

2024-09-15T16:48:07Z

PaulMc:

{| class="wikitable width 100%"width: 80%;
|colspan="5" align="center"|'''Position Papers and Responses'''
|-
|}
{| class="wikitable sortable" width: 80%;
!'''Date'''!!'''Working Group'''!!'''Topic'''
|-
|13/09/2024
|Poultry Welfare
|[[Reg255/97 2409|Draft Proposal amending Council Regulation (EC) No 1255/97 and repealing]]
[[Reg255/97 2409|Council Regulation (EC) No 1/2005]]
|-
|24/04/2024
|Poultry Legislation
|[[DelReg2020/687_2404|Proposed change to Del.Reg.2020/687_2404 impacting duration of disease control zones]]
|-
|16/11/2023
|Poultry Legislation
|[[Salmonella_Confirmation_2311|Confirmatory Testing of Poultry for Salmonella]]
|-
|08/08/2023
|Poultry Welfare
|[[Welfare_Ducks_Geese_Quail_2308|Response to EFSA report on Welfare of Ducks Geese & Quail on Farm]]
|-
|27/04/2023
|Poultry Welfare
|[[WelfareLayers2304|Response to EFSA report on Welfare of Laying Hens on Farm]]
|-
|06/04/2023
|Poultry Welfare
|[[WelfareBroilers2304|Response to EFSA report on Welfare of Broilers on Farm]]
|-
|01/03/2023
|Avian Influenza
|[[AvianInfluenzaMarch23|Position Paper on Avian Influenza Vaccination]]
|-
|01/03/2023
|Poultry Welfare
|[[WelfareTransport23|Response to EFSA report on Welfare in Transport]]
|-
|25/10/2021
|Avian Influenza
|[[AvianInfluenzaOctober21|Position Paper on Avian Influenza]]
|-
| 21/06/2021
|Antimicrobials/Anticoccidials
|[[index.php?title=Media:Position ac 2106.pdf|Position Paper on Anticoccidials]]
|-
|}
<big>[[Main_Page|Return to the Main Page]]</big>

Constitution

2024-05-26T19:56:46Z

PaulMc: Protected "Constitution" ([Edit=Allow only administrators] (indefinite) [Move=Allow only administrators] (indefinite))

<big>'''Poultry Veterinary Study Group Europe'''</big>

<big>Currrent</big> from May 2025

== 1. Name ==
The name of the Group is the Poultry Veterinary Study Group Europe.

The Group may also be known as the PVSGE.

== 2. Objectives ==
The main objectives of the PVSGE are:

- To share practical experience and information regarding the sanitary situation in poultry and avian species of each country;

- To develop and maintain the scientific knowledge of members;

- To place a network of technical experts and alarm on diseases outbreaks at members disposal;

- To provide a friendly environment for free exchange of information in order to achieve these objectives.

The PVSGE may also undertake the following tasks:

- To set up ad hoc working groups, as and when necessary, to consider specific issues or disease problems;

- To lobby the EU Commission or other authority, or coordinate lobbying of individual memberships, on specific issues;

- To demonstrate, through its meetings, and web site, a continuing education resource for the benefit of all members.

== 3. Language ==
The leading language of the PVSGE is English.

== 4. Members and Membership ==

==== Numbers of members: ====
- The total number of full and retired members of the PVSGE should not exceed 100. Honorary members and observers are in addition to this number.

- Countries eligible for membership of the PVSGE are EU countries plus Norway, United Kingdom, and Switzerland. In special cases the Committee may also propose and decide membership for veterinarians working '''in other''' countries <s>outside the EU</s>.

- Countries eligible for the calculation of allocations are: the current EU countries, those countries whose date of entry into the EU is known, plus Great Britain, Ireland (Republic of Ireland and Northern Ireland), Norway, and Switzerland,

where the poultry production (chicken + turkey + duck meat and egg production) is greater than 0.20% of total European production, based on the average of the 5 last

years available.

- The number of full members eligible to represent each country in the Group will be based on the tonnage of chicken, turkey and duck meat and egg production of each country.

- Membership per country: This will initially be a minimum 1 allocation. Additional full members per country will be strictly proportional to the calculated poultry production of

that country up to a maximum of 8 additional full members. Therefore the maximum number of full members will be 9 allocations.

- Allocations according to production are recalculated every 5 years or, in exceptional circumstances earlier, as decided by the Committee.

==== Eligibility for Membership: ====
- Membership of the PVSGE is open to veterinarians working in countries of the EU, Norway, United Kingdom, or Switzerland, where the majority of their professional work (at least 50% and not less than an average of 20 hours/week) is actively involved in the areas of poultry disease diagnosis and prevention, production and/or pathology. Members may work in private practice or for a company actively involved in the poultry business of that country. Government employees cannot become Members. Membership is proposed by the Country Group on a majority decision basis.

- In special cases the Committee of the PVSGE may also propose and decide membership for veterinarians working outside the listed countries. These members have an observer status without a seat on the Committee but they must respect the same rules as full members. They may participate in the closed and open sessions of the Group under the same conditions as full members and may present a disease report for the country where they work

==== Applications for Membership: ====
Applications for Membership have to be proposed to and accepted by a clear majority of the Committee.

- The applicant must provide a full CV detailing his/her experience and posts held.

He/she must be able to demonstrate clearly what he/she can bring to the group and their ability to take an active part in meetings.

- An existing member of the PVSGE will present the application. This will either be the secretary of an existing country group, or another existing full member of PVSGE who

can demonstrate a good knowledge of the skills and suitability of the applicant. In any case the sponsoring existing member must support this application by a written

recommendation.

- CV and recommendation are sent to the Committee at least one month before the next Committee meeting where the application will be considered.

- A period of 1 year between the enrolments of 2 members of the same country is applied, except when at least one of these 2 enrolments comes after the resignation

or the cancellation of membership of one member of the country group.

- The Committee will accept, defer or reject the application. The applicant will be informed in writing of the decision of the PVSGE Committee. In case of rejection, the

applicant has a right of appeal.

- If accepted by the Committee, the new member will receive a mail from the Webmaster including his password and a request for information to update the database of the website. The new member is then welcomed to the next meeting of the PVSGE.

==== Obligations of Members: ====
- New members are expected to present a Country report or other introductory paper to the Group, within the first year of membership. At this occasion they give a clear

presentation about their activities in poultry industry.

- Each Member is enrolled as an individual and cannot represent a firm or a Veterinary Association. No one may attend in place of another Veterinarian. Split Memberships

are not accepted.

- Except for retirement, if a member is no longer employed according to the rules stated above, that will result in cancellation of membership. The Committee will make the

final decision.

- Non-attendance by a full or retired member at three consecutive Meetings, without valid reason, will result in cancellation of Membership. The final decision will be made by the

Committee.

- Resignation or cancellation of membership closes access to the member area of the website.

- A membership financial contribution is fixed in order to cover administration costs.

Open bookkeeping is applied. Further expenses incurred in organizing Meetings will be shared equally by the Members attending. Changes in Membership contribution

are decided by the Committee.

- It shall be the responsibility of each country group to develop and encourage candidate members with a view to ensuring that membership is as representative as possible of the professionals who operate in the area of poultry medicine in their country, who satisfy membership requirements and are interested in becoming members.

- ALL Country members have an obligation to contribute information to their country secretary so that the disease summary is representative of that country

==== Honorary membership: ====
- Honorary membership may be conferred on members who, in the opinion of the

Committee, have made an exceptional contribution and commitment to the PVSGE.

- Individual members or Country Groups may propose full members for consideration

for Honorary membership by the Committee. Such proposal shall be made in writing

to the PVSGE Secretary or President in advance of a Committee meeting.

- Honorary members are not obliged to attend all subsequent meetings of the Group

after their retirement from the poultry industry, but are encouraged to continue to take

an active part in the Group.

- Honorary members will not pay any further membership subscriptions.

- Honorary membership is in addition to the number of full member allocations of the PVSGE.

==== Retired membership: ====
Colleagues who are still working in our field of interest but do not meet the requirement of

full membership may apply to committee to remain as retired members for a period of up to 5 years after

cessation of full time qualifying activity or until they retire from work definitively, whichever

comes first. Their application should be supported by a majority of their country group.

- retired members may participate in all group activities and have the same responsibilities

as full members including payment of membership subscription and attendance at meetings.

- retired member numbers will count towards the limits for total membership of the group and there may be no more than 15 retired members at any time.

- retired members will not count towards the country allocation [so a full member becoming a retired member frees a space for a new member]

- retired members are eligible to serve as officers or for subsequent election as honorary members.

Granting of retired status will be subject to annual reconfirmation by committee, taking into account demand, and available places for retired membership.

== 5. The Committee ==

==== Members: ====
- The PVSGE is headed by a Committee consisting of five officers plus the Country secretaries for each country that is not represented by an officer. The officers of the

Group are: one President (Chairman) and two Vice-Presidents of different nationalities, a Treasurer and a Secretary. The Vice-Presidents are one Junior Vice-

President and one Senior Vice-President. - The mandate of the officers extends for a period of two years, at the end of which they

are eligible for re-election.

- The PVSGE Secretary is chosen by the President.

- The PVSGE Treasurer is a committee member elected by the Committee.

- Before leaving the presidency, the President suggests a new Junior Vice-President. Committee Members may propose other candidates. In this situation the Committee

must reach a decision by secret ballot and majority votes. In case of equal number of votes the President decides.

- Country secretaries: they are named or elected by the members of each country.

==== Missions of the Committee: ====
- The Committee meets on the evening before each meeting.

- The Committee promotes the value and objectives of the PVSGE and acts for the common good of the group.

- The Committee is competent to proceed to make any change of the Constitution but, if asked by a Committee member, decision is delayed to the next Committee meeting

in order to allow a consultation of the country members.

- The Committee is in charge of the administration of the PVSGE: in particular, it approves the secretary and treasurer reports at each Committee meeting and deals

with members and membership matters (resignations, applications, attendances), agenda, organization and calendar of meetings.

- Decisions are reported at the following closed meeting of the Group and are formally recorded in the minutes of each Committee meeting. Minutes are reported in the

place dedicated to each meeting on the website.

==== Missions of the officers and Country secretaries: ====
- The President: presides over and co-ordinates the works of the Committee. He prepares the agenda of the Committee meetings and ensures the continuity of the

works of the Committee. He works for the cohesion of the Group and consensus of the Committee. He reports general information and important decisions at the general

meeting.

- The Senior President helps the new President to achieve these objectives.

- The Secretary draws up the minutes of each meeting, which are submitted to the Committee before the next meeting and forwards these to the Webmaster after approval for placing on the PVSGE website. The Secretary is responsible for checking attendances at the meetings.

- The Treasurer collects fees and profits of the meetings and makes any necessary payments. He is in charge of the bookkeeping and reports at each Committee

meeting.

- The Country secretaries represent the members of their country. Should the occasion arise they forward for discussion to the members they represent any proposals made

by the Committee regarding a change in the Constitution. They inform the Committee about any change regarding membership of their group (new applications, job moving, resignations…), check the attendance and website update of their members, answer for the presentation of their country reports and collect the fees of their group. They facilitate the organization of the PVSGE meeting held in their country.

- The Country Secretaries will be responsible for submitting the disease table summary details for their country at least one week before the next meeting.

== 6. Meetings ==

==== Frequency, objectives and organization: ====
- Two Meetings are organized per year.

- The meetings are designed to achieve the objectives of the Group.

- The Meetings are held in different countries, on a rotational basis, as agreed by the Committee.

- Countries with few members can work together to organize meetings.

==== Sessions: ====
The technical part of a Meeting consists of three sessions:

- Committee Meeting.

- Closed session dedicated to the information of members regarding news and important decisions made at the Committee meeting, the presentation of country

reports by a representative of each country, special focus on important topics, reports of working groups. Closed sessions may only be attended by members in order to

keep the discussion as open as possible and free of constraints.

- Information presented in closed sessions is confidential to the Group, except where specific permission has been given for wider distribution.

- Open session is where invited speakers or members present papers, and this information is not regarded as confidential, unless specifically notified at the start of

that session.

==== Program: ====
- The meeting organizer of the host Country decides upon the program and invites the speakers.

- Members wishing to contribute a paper to a Meeting must notify the organizer in good time. Poultry Veterinarians or other professionals of the host Country may be invited to

attend the open session.

- Guests, other than mentioned above, can only attend the meetings with the agreement of the President.

- The closed session cannot be attended by non-members.

- The organizer of the host country may inform professional media about the agenda of the meeting and send them a brief summary, without confidential topics, after the

meeting.

== 7. Working Groups ==
The Committee may, from time to time, appoint Working Groups on certain projects or topics thought to be important to the Group or the wider poultry industry.

The Working Groups report to the Committee Meeting.

== 8. Communication ==

==== Communication to third parties ====
- Members are not allowed to use information gathered during the closed sessions for any reasons: e.g. information to the media, to the government, to (potential)

customers.

- Responsibility for communication outside the PVSGE lies within the committee.

- In principle communication outside the PVSGE will be done by the president.

- The president together with the committee may allow other members to communicate outside the PVSGE.

==== Role and working of website ====
- For information of members and non-members the PVSGE uses a website: www.pvsgeu.org

- The website consists of a member and a non-member part. Information about members and about closed sessions is confidential and will only be put in the member

part.

==== Rights and duties of sponsors ====
- In order to organise the 2-yearly meetings sponsors may be asked for help, financially or otherwise.

- In return sponsors can expect the possibility to attend the open session and/or the evening program. Only when sponsors have valuable new scientific or technical

information they might be allowed to give a presentation during the open part of a meeting. Publicity for the sponsors is limited to: announcement in the invitations as

sponsor, banner/announcement on our website during half a year, spread of commercial and/or scientific material to the members.

== 9. Management of the bank account. ==
The PVSGE treasurer manages the PVSGE bank account under the supervision of the President, the Junior and Senior Presidents, the Dutch secretary and the Dutch treasurer.

== 10. Revision History ==
4.1 - revised May 1997

4.4 - revised November 1997

Senior status - revised May 1998

4.1 - revised November 2000

4.1 & senior status - revised April 2004

4.1 - revised May 2006

1, 4, 5, 6 - revised, senior status - cancelled, 2 & 8 - created November 2007

4.4 - revised May-June 2011

4.4 - revised Nov 2011 - reduced interval from 2 to 1 year

4.4/5.4 revised Nov 2014

9 - new paragraph May 2016

4.1 - added United Kingdom, assuming non-EU member status from March 28th 2019 - October 2018

4.4 - removed clause re 5 years post retirement - October 2018

4.6 - new paragraph re retired members October 2018

All - changed name from Poultry Veterinary Study Group of the EU to Poultry Veterinary Study Group Europe from 4/11/2023. This version reflects this and adopts PVSGE as the short form (rather than PVSG) - May 2024

4.1-2 - Eligibility paragraphs changes from 'outside the EU' to 'outside listed countries'. "veterinary surgeons" changed to "veterinarians" - May 24

PaulMc: Created page with "<center> Poultry Veterinary Study Group Europe </center> <HR>..."

DelReg2020/687 2404W

2024-04-22T13:03:23Z

PaulMc: Final, transferred from member area draft

{| border="0" cellpadding="5" cellspacing="0" size = "20" width: 10%; height: 300px>
|colspan="3"style="width: 70%" |
|align="right"| [[File:Pvsglogo m.png|300x300px]]
|-
|colspan="4" align="Center"|'''Proposed amendment to Commission Implementing Regulation (EU) 2020/687 as regards rules for the prevention and control of certain listed diseases.'''
|-
|colspan="3" |
|Date : April 22nd 2024
|}

The Poultry Veterinary Study Group Europe (PVSGE) welcomes the opportunity to comment on the above topic.

The PVSGE is a formally constituted group of about 90 European specialised poultry veterinarians, with practical responsibility for the health, welfare, production and food safety aspects of most European poultry production. PVSGE has existed for over 50 years and the members are mostly working as private practitioners or are sometimes working for a company (breeding companies, integrations, hatcheries, pharmaceutical companies). Full-time government veterinarians are not eligible for membership. The following 23 countries are currently represented in the PVSGE: Austria, Belgium, Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Germany, Great Britain, Greece, Hungary, Ireland, Italy, Latvia, Netherlands, Norway, Poland, Portugal, Romania, Spain, Sweden, Switzerland. This document has been prepared by the PVSGE Legislation Working Group.

 PVSGE Legislation Working Group Insert date :Franz Sommer, Peter Mitsch (Austria), Koen Lycke (Belgium), Paivikki Perko-Mäkelä (Finland), Gerard Leveque (France),Thorsten Arnold (Germany), Boris Meyer-Kuehling, Matthias Voss (Germany),Sara Perez-Palacios, Paul McMullin, Stephen Lister (Great Britain), Pal Bajnóczi (Hungary), Ovsanna Mikhaylovskaya (Latvia), André Steentjes (Netherlands), Juan-Carlos Abad (Spain),Pia Gustavsson (Sweden)



==Background==

From 2006 to April 2021 measures for the control of avian influenza were laid down in Council Directive 2005/94<ref>[https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32005L0094 Anon (2005) COUNCIL DIRECTIVE 2005/94/EC of 20 December 2005 on Community measures for the control of avian influenza and repealing Directive 92/40/EEC https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32005L0094]</ref>. Detailed measures were laid down for protection zones and surveillance zones. Articles 29 and 31 laid down the duration of actions in zones as respectively 21 days (protection) and 30 days (surveillance), timing of the lifting of these zones from completion of preliminary cleaning and disinfection of infected holdings. This directive was replaced on 21/04/2021 by the general Animal Health Law<ref name=":0">Anon (2016) Consolidated Text: REGULATION (EU) 2016/429 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) (Current Consolidated version 21/04/2021) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02016R0429-20210421</ref>, and a supplemental commission delegated regulation 2020/687<ref name=":1">Anon (2019 ) Consolidated text: Commission Delegated Regulation (EU) 2020/687 of 17 December 2019 supplementing Regulation (EU) 2016/429 of the European Parliament and the Council, as regards rules for the prevention and control of certain listed diseases (consolidated version 3/5/2023) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02020R0687-20230503</ref> (DR687) dealing with rules for the prevention and control of the listed animal diseases. The rules are not specific to avian diseases but lay down general principles which affect control measures. Both Avian Influenza and Newcastle disease are included as listed diseases to which this regulation applies. The existing legislation is clear, in articles 39 and 55, that the intention was that zonal restrictions around cases would be lifted at 30 days after 'preliminary cleaning and disinfection' of the final case assuming no further cases were identified in the zones as a result of the required surveillance. The purpose of preliminary C&D is to avoid the spread of the Category A disease (DR687 Annexe IV para B) and thus should be equivalent to completion of the stamping out process as required by WOAH. It is equally clear that restocking on affected sites under EU regulations requires the enhanced 'secondary cleaning and disinfection' which requires the removal of litter or manure, and 2 process of disinfection separated by 7 days. Here we focus on the specific proposal made but we must recognise that decisions made in relation to this are very likely to impact the area of trade with third countries if they constrain the ability of EU countries in the closure of disease events for WOAH purposes. Reports to WOAH and notifications of country freedom have no impact on intra-EU trade and so should continue to be governed by the principle of subsidiarity<ref>Anon (accessed 2024) The principle of subsidiarity. https://eur-lex.europa.eu/EN/legal-content/glossary/principle-of-subsidiarity.html</ref>. Inconsistencies may arise between countries in relation to such reporting but this is a matter for discussion between stakeholders and their respective competent authorities and within WOAH.



==Proposal==

'''''Amendment proposed by the EU Commission in December 2023'''''

''Change of Article 55(1) of DR687:''

'''''To introduce new point (d) adding the condition to complete final cleaning and disinfection before lifting disease control measures.'''''

The justification given is " ''Add clarity and ensure consistency with Article 68 of AHL''<ref name=":1" />''.'' This article deals with "Maintaining disease control measures in restricted zones and delegated acts" and states in sub-para 1(b)

"the '''final''' cleaning, disinfection, control of insects and rodents, or other necessary biosecurity measures has been carried out as appropriate for:

(i) the listed disease referred to in point (a) of Article 9(1) for which the disease control measures have been applied;

(ii) the affected species of kept animals;

(iii) the type of production "



==Our Position==

''The PVSG'' '''strongly''' '''''opposes''' the proposed change in Art 55 of DR687''',''' given the success, over many years, of lifting zonal restrictions based on '''preliminary C&D''' .''

This proposal would, in fact, be inconsistent with article 39(1) of the same regulation. The real problem, we believe, lies with the inclusion of 'final' in relation to cleaning in Article 68 of the AHL<ref name=":0" /> sub-para 1(b)

''We would like to emphasize that affected sites after, preliminary C&D, are not producing significant disease risk since viruses do not grow in the absence of a host. In relation to the listed poultry diseases the affected sites are fully depopulated and so cannot contribute to any risk of spread (intra-EU or to 3rd country) of disease via products. It should also be noted that if EU-mandated control zones remain in place longer than necessary this sends a message to trading partners that the disease has not been effectively controlled, as well as making it difficult for member state competent authorities to properly comply with their obligations under the WOAH Terrestrial Code to ensure "the safety of international trade in animals and animal products, while avoiding unjustified sanitary barriers"''<ref>WOAH (2023) Terrestrial Animal Health Code , Foreward, paragraph 1

https://www.woah.org/en/what-we-do/standards/codes-and-manuals/terrestrial-code-online-access/</ref>''.''

''Our members would like, as an alternative to the Commission proposal, to '''call on the Commission to add a sub-paragraph to article 55, as follows :'''''

'''"d. Completion of preliminary cleaning and disinfection is regarded as the completion of the stamping out process, but movement restrictions must continue to be applied to the affected property, and any animals and type of production on it, until completion of final cleaning and disinfection."'''

Furthermore we propose the '''deletion of 'final' from Article 68, sub-para's 1(b)''' '''and 2(a''') of the AHL to remove the current inconsistency.

Poultry farmers around the EU have experienced serious implications for several years due to HPAI, in part as a result of the control mechanisms implemented under EU law. Where there is a complete ban for placing of day old chicks or hatching eggs for on farm hatching within 3 km, an outbreak does indeed cause serious economic damage to the farms/farmers situated within a zone. The current 21/30 days restrictions after preliminary C&D are more than sufficient for disease control purposes. This Commission proposal could easily extend zonal restrictions for 1-3 months, and sometimes much longer (depending on the type of farm and difficulty of achieving secondary C&D to the satisfaction of the competent authority), exacerbating the economic damage of the disease, for negligible benefit.

{| border="1" cellpadding="5" cellspacing="0" size="20" width: 100%
|signature
|signature TBC
|-
|Eva Berndtson
|Gerard Leveque??
|-
|President PVSGE
|Secretary, Legislation Working Group
|}



==Appendix 1 - Relevant legislation Extracts==

'''Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) '''

Article 68

1. The competent authority shall continue to apply the disease control measures provided for in this Section until the following conditions are met:

(b) "the '''final''' cleaning, disinfection, control of insects and rodents, or other necessary biosecurity measures has been carried out as appropriate for:

(i) the listed disease referred to in point (a) of Article 9(1) for

which the disease control measures have been applied;

(ii) the affected species of kept animals;

(iii) the type of production "

2. The Commission shall adopt delegated acts in accordance with Article 264 concerning detailed rules for the disease control measures to be taken by the competent authority, as provided for in paragraph 1, in relation to:

(a) the '''final''' procedures for cleaning, disinfection, control of insects and rodents, or other necessary biosecurity measures and, where appropriate, the use of biocidal products for those purposes;

'''COMMISSION DELEGATED REGULATION (EU) 2020/687 - supplementing Regulation (EU) 2016/429 of the European Parliament and the Council, as regards rules for the prevention and control of certain listed diseases'''<ref name=":0" />

Section 2

Disease control measures in the event of the official confirmation of a category A disease in kept animals

Article 15

Preliminary cleaning and disinfection and control of insects and rodents in the affected establishment

1. Immediately after the completion of the measures provided for in Article 12, and when relevant in Article 14, the competent authority shall order and supervise a preliminary cleaning and disinfection and, when relevant, control of insects and rodents, in the affected establishment in order to avoid spreading of the category A disease.

2. The preliminary cleaning, disinfection and control referred to in paragraph 1 shall be:

(a) performed in accordance with the procedures set out in points A and B of Annex IV using the appropriate biocidal products to ensure destruction of the relevant category A disease agent; and

(b) adequately documented.

3. When the competent authority grants one of the derogations provided for in Article 13(2) and (4), it shall order the preliminary cleaning, disinfection and the control referred to in paragraph 1 adapting the procedures referred to in point 2(a) to the specific situation without detriment to the control of spreading of the category A disease from the affected animals and affected establishments and locations to other unaffected animals or to humans.

4. In addition to the measures referred to in paragraphs 1 and 2, the competent authority shall order and supervise that the means of transport used for the transport of animals to and from the affected establishment are properly cleaned and disinfected and, where relevant, subjected to measures ensuring the control of insects and rodents

Article 16

Derogations and special rules for the preliminary cleaning and disinfection and control of vectors

The competent authority may grant derogation to the requirement regarding cleaning and disinfection and control of insects and rodents set out in Article 15 in the case of:

(a) pastures epidemiologically linked to the affected establishment, under specific procedures to ensure effective inactivation of the relevant category A disease agent taking into account the disease profile, the type of establishment and the climatic conditions; and

(b) manure, including litter and used bedding, from the affected establishment, under specific procedures to ensure effective inactivation of the relevant category A disease agent in accordance with scientific evidence.

Section 1

General disease control measures in the restricted zone

Section 2

Disease control measures in the protection zone

Article 39

Duration of the disease control measures in the protection zone

1. The competent authority may lift the measures provided for in Section 1 and 2 of this Chapter only if the minimum

period set out in Annex X has elapsed and the following conditions are fulfilled:

(a) the preliminary cleaning and disinfection and, where relevant, control of insects and rodents, has been performed in

accordance with Article 15 in the affected establishment; and

(b) in all establishments keeping animals of listed species in the protection zone, animals of listed species have undergone,

with favourable results, clinical and when necessary laboratory examinations in accordance with Article 26.

2. Where the relevant category A disease is transmitted by a listed vector, as referred to in Regulation (EU) 2018/1882,

the competent authority may:

(a) establish the duration of the measures in the protection zone on a case by case basis, taking into account any factor

influencing the risk of the disease spreading; and

(b) provide for the introduction of sentinel animals.

3. After the lifting of the measures referred to in paragraph 1, the measures provided for in Section 3 of this Chapter shall

apply in the protection zone for at least the additional period set out in Annex X.

CHAPTER III

Repopulation with terrestrial animals of establishments in restricted zones

Article 57

Conditions to authorise the repopulation of the affected establishment

1.

The competent authority shall only authorise the repopulation of the affected establishment if the following requirements are met:

(a) a final cleaning and disinfection and, when relevant, control of insects and rodents has been:

(i) carried out, in accordance with the procedures set out in points A and C of Annex IV, using the appropriate biocidal products to ensure destruction of the relevant category A disease agent; and

(ii) adequately documented;

(b) the monitoring period set out in Annex II for the relevant disease, calculated forwards from the date on which the final cleaning and disinfection provided for in point (a) was carried out, has elapsed.

2. The competent authority shall supervise that the final cleaning and disinfection and, when relevant, control of insects and rodents in the affected establishment is carried out in compliance with the requirements in paragraph 1(a).

3. The competent authority shall not allow access to a pasture of kept animals of listed species during the period of time during which it is considered contaminated; this period of time shall be established after carrying out a risk assessment.

4. Where for duly justified reasons the final cleaning and disinfection and, when relevant, the control of insects and rodents referred to in paragraph 1, have not been entirely accomplished in the affected establishment, the competent authority may authorise the repopulation by way of derogation from paragraph 1, provided that:

(a) a period of at least 3 months has elapsed since the preliminary cleaning and disinfection, as referred to in Article 15, was performed; and

(b) prior to granting the authorisation, the competent authority has assessed the risks deriving from that authorisation and the assessment indicates that the risk of spreading the category A disease is negligible.

Annex IV para B

Preliminary cleaning and disinfection

For preliminary cleaning and disinfection under Article 15, to avoid spreading the category A disease:

(a) entire bodies or parts of dead kept animals of listed species must be sprayed with disinfectant and removed from the establishment, in closed and leak-proof vehicles or containers for processing and disposal;

(b) any tissue or blood which may have been spilled during killing, slaughter or post-mortem examination must be carefully collected and disposed of;

(c) as soon as the entire bodies or parts of dead kept animals of listed species have been removed for processing or disposal, the parts of the establishment in which these animals were kept and any parts of other buildings, surfaces or equipment contaminated during killing or post-mortem examination must be sprayed with disinfectant;

('''d) manure, including litter and used bedding, must be thoroughly soaked with disinfectant;'''

(e) the disinfectant must remain on the treated surface for at least 24 hours;

'''(f) equipment, containers, consumption utensils, surfaces or any material likely to be contaminated after the washing and disinfecting must be destroyed.'''

ANNEX IV

PROCEDURES FOR CLEANING, DISINFECTION AND WHEN NECESSARY CONTROL OF INSECTS AND RODENTS

(as referred to in Articles 12, 15, 16, 39, 45 and 57 of this Regulation)

A. General requirements

1. The choice of biocidal products and procedures for cleaning and disinfection operations must take into account:

(a) the causal agent of infection;

(b) the nature of the establishments, vehicles, objects and materials which are to be treated; and

(c) the applicable legislation.

2. The conditions under which biocidal products are used must ensure that their efficacy is not impaired. In particular technical parameters provided by the manufacturer, such as pressure, temperature, required contact time or storage must be observed. The activity of the disinfectant must not be compromised by interaction with other substances.

3. Re-contamination of the previously cleaned parts must be avoided, in particular where washing is carried out with liquids applied under pressure.

4. The water used for cleaning operations must be contained and disposed of in a way that avoids any risk of spreading category A disease agents.

5. Biocidal products must be used in a way that reduces as much as possible any adverse impact on the environment and on public health that may arise from their use.

B. Preliminary cleaning and disinfection

For preliminary cleaning and disinfection under Article 15, to avoid spreading the category A disease:

(a) entire bodies or parts of dead kept animals of listed species must be sprayed with disinfectant and removed from the establishment, in closed and leak-proof vehicles or containers for processing and disposal;

(b) any tissue or blood which may have been spilled during killing, slaughter or post-mortem examination must be carefully collected and disposed of;

(c) as soon as the entire bodies or parts of dead kept animals of listed species have been removed for processing or disposal, the parts of the establishment in which these animals were kept and any parts of other buildings, surfaces or equipment contaminated during killing or post-mortem examination must be sprayed with disinfectant;

(d) manure, including litter and used bedding, must be thoroughly soaked with disinfectant;

(e) the disinfectant must remain on the treated surface for at least 24 hours;

(f) equipment, containers, consumption utensils, surfaces or any material likely to be contaminated after the washing and disinfecting must be destroyed.

C. Final cleaning and disinfection:

For final cleaning and disinfection for the purpose of Article 57:

# Manure, including litter and used bedding, must be removed and treated as follows:

(a) the solid phase of manure, including litter and used bedding, must either:

(i) undergo a steam treatment at a temperature of at least 70 °C;

(ii) be destroyed by burning;

(iii) be buried deep enough to prevent access by animals; or

(iv) be stacked to heat, sprayed with disinfectant and left for at least 42 days, during which the stack must be either covered or re-stacked to ensure thermic treatment of all layers;

(b) the liquid phase of manure must be stored for at least 42 days, and in the case of highly pathogenic avian influenza 60 days, after the last addition of infective material.

2. Buildings, surfaces and equipment must be thoroughly washed and cleaned by removing the remaining grease and dirt and sprayed with disinfectants.

3. After 7 days the establishments must be cleaned and disinfected again.



== References ==

DelReg2020/687 2404W

2024-04-22T13:02:04Z

PaulMc: Created page with " {| border="0" cellpadding="5" cellspacing="0" size = "20" width: 10%; height: 300px> |colspan="3"style="width: 70%" | |align="right"| F..."

{| border="0" cellpadding="5" cellspacing="0" size = "20" width: 10%; height: 300px>
|colspan="3"style="width: 70%" |
|align="right"| [[File:Pvsglogo m.png|300x300px]]
|-
|colspan="4" align="Center"|'''Proposed amendment to Commission Implementing Regulation (EU) 2020/687 as regards rules for the prevention and control of certain listed diseases.'''
|-
|colspan="3" |
|Date : TBC 2024
|}

The Poultry Veterinary Study Group Europe (PVSGE) welcomes the opportunity to comment on the above topic.

The PVSGE is a formally constituted group of about 90 European specialised poultry veterinarians, with practical responsibility for the health, welfare, production and food safety aspects of most European poultry production. PVSGE has existed for over 50 years and the members are mostly working as private practitioners or are sometimes working for a company (breeding companies, integrations, hatcheries, pharmaceutical companies). Full-time government veterinarians are not eligible for membership. The following 23 countries are currently represented in the PVSGE: Austria, Belgium, Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Germany, Great Britain, Greece, Hungary, Ireland, Italy, Latvia, Netherlands, Norway, Poland, Portugal, Romania, Spain, Sweden, Switzerland. This document has been prepared by the PVSGE Legislation Working Group.

 PVSGE Legislation Working Group Insert date :Franz Sommer, Peter Mitsch (Austria), Koen Lycke (Belgium), Paivikki Perko-Mäkelä (Finland), Gerard Leveque (France),Thorsten Arnold (Germany), Boris Meyer-Kuehling, Matthias Voss (Germany),Sara Perez-Palacios, Paul McMullin, Stephen Lister (Great Britain), Pal Bajnóczi (Hungary), Ovsanna Mikhaylovskaya (Latvia), André Steentjes (Netherlands), Juan-Carlos Abad (Spain),Pia Gustavsson (Sweden)



==Background==

From 2006 to April 2021 measures for the control of avian influenza were laid down in Council Directive 2005/94<ref>[https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32005L0094 Anon (2005) COUNCIL DIRECTIVE 2005/94/EC of 20 December 2005 on Community measures for the control of avian influenza and repealing Directive 92/40/EEC https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32005L0094]</ref>. Detailed measures were laid down for protection zones and surveillance zones. Articles 29 and 31 laid down the duration of actions in zones as respectively 21 days (protection) and 30 days (surveillance), timing of the lifting of these zones from completion of preliminary cleaning and disinfection of infected holdings. This directive was replaced on 21/04/2021 by the general Animal Health Law<ref name=":0">Anon (2016) Consolidated Text: REGULATION (EU) 2016/429 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) (Current Consolidated version 21/04/2021) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02016R0429-20210421</ref>, and a supplemental commission delegated regulation 2020/687<ref name=":1">Anon (2019 ) Consolidated text: Commission Delegated Regulation (EU) 2020/687 of 17 December 2019 supplementing Regulation (EU) 2016/429 of the European Parliament and the Council, as regards rules for the prevention and control of certain listed diseases (consolidated version 3/5/2023) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02020R0687-20230503</ref> (DR687) dealing with rules for the prevention and control of the listed animal diseases. The rules are not specific to avian diseases but lay down general principles which affect control measures. Both Avian Influenza and Newcastle disease are included as listed diseases to which this regulation applies. The existing legislation is clear, in articles 39 and 55, that the intention was that zonal restrictions around cases would be lifted at 30 days after 'preliminary cleaning and disinfection' of the final case assuming no further cases were identified in the zones as a result of the required surveillance. The purpose of preliminary C&D is to avoid the spread of the Category A disease (DR687 Annexe IV para B) and thus should be equivalent to completion of the stamping out process as required by WOAH. It is equally clear that restocking on affected sites under EU regulations requires the enhanced 'secondary cleaning and disinfection' which requires the removal of litter or manure, and 2 process of disinfection separated by 7 days. Here we focus on the specific proposal made but we must recognise that decisions made in relation to this are very likely to impact the area of trade with third countries if they constrain the ability of EU countries in the closure of disease events for WOAH purposes. Reports to WOAH and notifications of country freedom have no impact on intra-EU trade and so should continue to be governed by the principle of subsidiarity<ref>Anon (accessed 2024) The principle of subsidiarity. https://eur-lex.europa.eu/EN/legal-content/glossary/principle-of-subsidiarity.html</ref>. Inconsistencies may arise between countries in relation to such reporting but this is a matter for discussion between stakeholders and their respective competent authorities and within WOAH.



==Proposal==

'''''Amendment proposed by the EU Commission in December 2023'''''

''Change of Article 55(1) of DR687:''

'''''To introduce new point (d) adding the condition to complete final cleaning and disinfection before lifting disease control measures.'''''

The justification given is " ''Add clarity and ensure consistency with Article 68 of AHL''<ref name=":1" />''.'' This article deals with "Maintaining disease control measures in restricted zones and delegated acts" and states in sub-para 1(b)

"the '''final''' cleaning, disinfection, control of insects and rodents, or other necessary biosecurity measures has been carried out as appropriate for:

(i) the listed disease referred to in point (a) of Article 9(1) for which the disease control measures have been applied;

(ii) the affected species of kept animals;

(iii) the type of production "



==Our Position==

''The PVSG'' '''strongly''' '''''opposes''' the proposed change in Art 55 of DR687''',''' given the success, over many years, of lifting zonal restrictions based on '''preliminary C&D''' .''

This proposal would, in fact, be inconsistent with article 39(1) of the same regulation. The real problem, we believe, lies with the inclusion of 'final' in relation to cleaning in Article 68 of the AHL<ref name=":0" /> sub-para 1(b)

''We would like to emphasize that affected sites after, preliminary C&D, are not producing significant disease risk since viruses do not grow in the absence of a host. In relation to the listed poultry diseases the affected sites are fully depopulated and so cannot contribute to any risk of spread (intra-EU or to 3rd country) of disease via products. It should also be noted that if EU-mandated control zones remain in place longer than necessary this sends a message to trading partners that the disease has not been effectively controlled, as well as making it difficult for member state competent authorities to properly comply with their obligations under the WOAH Terrestrial Code to ensure "the safety of international trade in animals and animal products, while avoiding unjustified sanitary barriers"''<ref>WOAH (2023) Terrestrial Animal Health Code , Foreward, paragraph 1

https://www.woah.org/en/what-we-do/standards/codes-and-manuals/terrestrial-code-online-access/</ref>''.''

''Our members would like, as an alternative to the Commission proposal, to '''call on the Commission to add a sub-paragraph to article 55, as follows :'''''

'''"d. Completion of preliminary cleaning and disinfection is regarded as the completion of the stamping out process, but movement restrictions must continue to be applied to the affected property, and any animals and type of production on it, until completion of final cleaning and disinfection."'''

Furthermore we propose the '''deletion of 'final' from Article 68, sub-para's 1(b)''' '''and 2(a''') of the AHL to remove the current inconsistency.

Poultry farmers around the EU have experienced serious implications for several years due to HPAI, in part as a result of the control mechanisms implemented under EU law. Where there is a complete ban for placing of day old chicks or hatching eggs for on farm hatching within 3 km, an outbreak does indeed cause serious economic damage to the farms/farmers situated within a zone. The current 21/30 days restrictions after preliminary C&D are more than sufficient for disease control purposes. This Commission proposal could easily extend zonal restrictions for 1-3 months, and sometimes much longer (depending on the type of farm and difficulty of achieving secondary C&D to the satisfaction of the competent authority), exacerbating the economic damage of the disease, for negligible benefit.

{| border="1" cellpadding="5" cellspacing="0" size="20" width: 100%
|signature
|signature TBC
|-
|Eva Berndtson
|Gerard Leveque??
|-
|President PVSGE
|Secretary, Legislation Working Group
|}



==Appendix 1 - Relevant legislation Extracts==

'''Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) '''

Article 68

1. The competent authority shall continue to apply the disease control measures provided for in this Section until the following conditions are met:

(b) "the '''final''' cleaning, disinfection, control of insects and rodents, or other necessary biosecurity measures has been carried out as appropriate for:

(i) the listed disease referred to in point (a) of Article 9(1) for

which the disease control measures have been applied;

(ii) the affected species of kept animals;

(iii) the type of production "

2. The Commission shall adopt delegated acts in accordance with Article 264 concerning detailed rules for the disease control measures to be taken by the competent authority, as provided for in paragraph 1, in relation to:

(a) the '''final''' procedures for cleaning, disinfection, control of insects and rodents, or other necessary biosecurity measures and, where appropriate, the use of biocidal products for those purposes;

'''COMMISSION DELEGATED REGULATION (EU) 2020/687 - supplementing Regulation (EU) 2016/429 of the European Parliament and the Council, as regards rules for the prevention and control of certain listed diseases'''<ref name=":0" />

Section 2

Disease control measures in the event of the official confirmation of a category A disease in kept animals

Article 15

Preliminary cleaning and disinfection and control of insects and rodents in the affected establishment

1. Immediately after the completion of the measures provided for in Article 12, and when relevant in Article 14, the competent authority shall order and supervise a preliminary cleaning and disinfection and, when relevant, control of insects and rodents, in the affected establishment in order to avoid spreading of the category A disease.

2. The preliminary cleaning, disinfection and control referred to in paragraph 1 shall be:

(a) performed in accordance with the procedures set out in points A and B of Annex IV using the appropriate biocidal products to ensure destruction of the relevant category A disease agent; and

(b) adequately documented.

3. When the competent authority grants one of the derogations provided for in Article 13(2) and (4), it shall order the preliminary cleaning, disinfection and the control referred to in paragraph 1 adapting the procedures referred to in point 2(a) to the specific situation without detriment to the control of spreading of the category A disease from the affected animals and affected establishments and locations to other unaffected animals or to humans.

4. In addition to the measures referred to in paragraphs 1 and 2, the competent authority shall order and supervise that the means of transport used for the transport of animals to and from the affected establishment are properly cleaned and disinfected and, where relevant, subjected to measures ensuring the control of insects and rodents

Article 16

Derogations and special rules for the preliminary cleaning and disinfection and control of vectors

The competent authority may grant derogation to the requirement regarding cleaning and disinfection and control of insects and rodents set out in Article 15 in the case of:

(a) pastures epidemiologically linked to the affected establishment, under specific procedures to ensure effective inactivation of the relevant category A disease agent taking into account the disease profile, the type of establishment and the climatic conditions; and

(b) manure, including litter and used bedding, from the affected establishment, under specific procedures to ensure effective inactivation of the relevant category A disease agent in accordance with scientific evidence.

Section 1

General disease control measures in the restricted zone

Section 2

Disease control measures in the protection zone

Article 39

Duration of the disease control measures in the protection zone

1. The competent authority may lift the measures provided for in Section 1 and 2 of this Chapter only if the minimum

period set out in Annex X has elapsed and the following conditions are fulfilled:

(a) the preliminary cleaning and disinfection and, where relevant, control of insects and rodents, has been performed in

accordance with Article 15 in the affected establishment; and

(b) in all establishments keeping animals of listed species in the protection zone, animals of listed species have undergone,

with favourable results, clinical and when necessary laboratory examinations in accordance with Article 26.

2. Where the relevant category A disease is transmitted by a listed vector, as referred to in Regulation (EU) 2018/1882,

the competent authority may:

(a) establish the duration of the measures in the protection zone on a case by case basis, taking into account any factor

influencing the risk of the disease spreading; and

(b) provide for the introduction of sentinel animals.

3. After the lifting of the measures referred to in paragraph 1, the measures provided for in Section 3 of this Chapter shall

apply in the protection zone for at least the additional period set out in Annex X.

CHAPTER III

Repopulation with terrestrial animals of establishments in restricted zones

Article 57

Conditions to authorise the repopulation of the affected establishment

1.

The competent authority shall only authorise the repopulation of the affected establishment if the following requirements are met:

(a) a final cleaning and disinfection and, when relevant, control of insects and rodents has been:

(i) carried out, in accordance with the procedures set out in points A and C of Annex IV, using the appropriate biocidal products to ensure destruction of the relevant category A disease agent; and

(ii) adequately documented;

(b) the monitoring period set out in Annex II for the relevant disease, calculated forwards from the date on which the final cleaning and disinfection provided for in point (a) was carried out, has elapsed.

2. The competent authority shall supervise that the final cleaning and disinfection and, when relevant, control of insects and rodents in the affected establishment is carried out in compliance with the requirements in paragraph 1(a).

3. The competent authority shall not allow access to a pasture of kept animals of listed species during the period of time during which it is considered contaminated; this period of time shall be established after carrying out a risk assessment.

4. Where for duly justified reasons the final cleaning and disinfection and, when relevant, the control of insects and rodents referred to in paragraph 1, have not been entirely accomplished in the affected establishment, the competent authority may authorise the repopulation by way of derogation from paragraph 1, provided that:

(a) a period of at least 3 months has elapsed since the preliminary cleaning and disinfection, as referred to in Article 15, was performed; and

(b) prior to granting the authorisation, the competent authority has assessed the risks deriving from that authorisation and the assessment indicates that the risk of spreading the category A disease is negligible.

Annex IV para B

Preliminary cleaning and disinfection

For preliminary cleaning and disinfection under Article 15, to avoid spreading the category A disease:

(a) entire bodies or parts of dead kept animals of listed species must be sprayed with disinfectant and removed from the establishment, in closed and leak-proof vehicles or containers for processing and disposal;

(b) any tissue or blood which may have been spilled during killing, slaughter or post-mortem examination must be carefully collected and disposed of;

(c) as soon as the entire bodies or parts of dead kept animals of listed species have been removed for processing or disposal, the parts of the establishment in which these animals were kept and any parts of other buildings, surfaces or equipment contaminated during killing or post-mortem examination must be sprayed with disinfectant;

('''d) manure, including litter and used bedding, must be thoroughly soaked with disinfectant;'''

(e) the disinfectant must remain on the treated surface for at least 24 hours;

'''(f) equipment, containers, consumption utensils, surfaces or any material likely to be contaminated after the washing and disinfecting must be destroyed.'''

ANNEX IV

PROCEDURES FOR CLEANING, DISINFECTION AND WHEN NECESSARY CONTROL OF INSECTS AND RODENTS

(as referred to in Articles 12, 15, 16, 39, 45 and 57 of this Regulation)

A. General requirements

1. The choice of biocidal products and procedures for cleaning and disinfection operations must take into account:

(a) the causal agent of infection;

(b) the nature of the establishments, vehicles, objects and materials which are to be treated; and

(c) the applicable legislation.

2. The conditions under which biocidal products are used must ensure that their efficacy is not impaired. In particular technical parameters provided by the manufacturer, such as pressure, temperature, required contact time or storage must be observed. The activity of the disinfectant must not be compromised by interaction with other substances.

3. Re-contamination of the previously cleaned parts must be avoided, in particular where washing is carried out with liquids applied under pressure.

4. The water used for cleaning operations must be contained and disposed of in a way that avoids any risk of spreading category A disease agents.

5. Biocidal products must be used in a way that reduces as much as possible any adverse impact on the environment and on public health that may arise from their use.

B. Preliminary cleaning and disinfection

For preliminary cleaning and disinfection under Article 15, to avoid spreading the category A disease:

(a) entire bodies or parts of dead kept animals of listed species must be sprayed with disinfectant and removed from the establishment, in closed and leak-proof vehicles or containers for processing and disposal;

(b) any tissue or blood which may have been spilled during killing, slaughter or post-mortem examination must be carefully collected and disposed of;

(c) as soon as the entire bodies or parts of dead kept animals of listed species have been removed for processing or disposal, the parts of the establishment in which these animals were kept and any parts of other buildings, surfaces or equipment contaminated during killing or post-mortem examination must be sprayed with disinfectant;

(d) manure, including litter and used bedding, must be thoroughly soaked with disinfectant;

(e) the disinfectant must remain on the treated surface for at least 24 hours;

(f) equipment, containers, consumption utensils, surfaces or any material likely to be contaminated after the washing and disinfecting must be destroyed.

C. Final cleaning and disinfection:

For final cleaning and disinfection for the purpose of Article 57:

# Manure, including litter and used bedding, must be removed and treated as follows:

(a) the solid phase of manure, including litter and used bedding, must either:

(i) undergo a steam treatment at a temperature of at least 70 °C;

(ii) be destroyed by burning;

(iii) be buried deep enough to prevent access by animals; or

(iv) be stacked to heat, sprayed with disinfectant and left for at least 42 days, during which the stack must be either covered or re-stacked to ensure thermic treatment of all layers;

(b) the liquid phase of manure must be stored for at least 42 days, and in the case of highly pathogenic avian influenza 60 days, after the last addition of infective material.

2. Buildings, surfaces and equipment must be thoroughly washed and cleaned by removing the remaining grease and dirt and sprayed with disinfectants.

3. After 7 days the establishments must be cleaned and disinfected again.



== References ==

Main Page

2024-04-22T12:58:46Z

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2024-04-16T14:54:05Z

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Salmonella Confirmation 2311W

2023-11-18T19:39:17Z

PaulMc: Protected "Salmonella Confirmation 2311W": Final version of public paper ([Edit=Allow only administrators] (indefinite) [Move=Allow only administrators] (indefinite))

{| border="0" cellpadding="5" cellspacing="0" size = "20" width: 10%; height: 300px>
|colspan="3"style="width: 70%" |
|align="right"| [[File:Pvsglogo m.png|300x300px]]
|-
|colspan="4" align="Center"|'''<big>Confirmatory Testing of Poultry for Salmonella</big>'''
|-
|colspan="3" |
|Date :Nov 16th 2023
|}

The Poultry Veterinary Study Group Europe (PVSGE) welcomes the opportunity to comment on the issue of confirmatory testing of poultry flocks where a Salmonella of public health significance has been identified in routine testing.

The PVSGE is a formally constituted group of about 90 European specialised poultry veterinarians, with practical responsibility for the health, welfare, production and food safety aspects of most European poultry production. PVSGE has existed for over 50 years and the members are mostly working as private practitioners or are sometimes working for a company (breeding companies, integrations, hatcheries, pharmaceutical companies). Full-time government veterinarians are not eligible for membership. The following 23 countries are currently represented in the PVSGE: Austria, Belgium, Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Germany, Great Britain, Greece, Hungary, Ireland, Italy, Latvia, Netherlands, Norway, Poland, Portugal, Romania, Spain, Sweden, Switzerland. This document has been prepared by the PVSGE Legislation Working Group.

 PVSGE Legislation Working Group October 2023 :Franz Sommer, Peter Mitsch (Austria), Koen Lycke (Belgium), Paivikki Perko-Mäkelä (Finland), Gerard Leveque (France),Thorsten Arnold (Germany), Boris Meyer-Kuehling, Matthias Voss (Germany),Sara Perez-Palacios, Paul McMullin, Stephen Lister (Great Britain), Pal Bajnóczi (Hungary), Ovsanna Mikhaylovskaya (Latvia), André Steentjes (Netherlands), Juan-Carlos Abad (Spain),Pia Gustavsson (Sweden)



==Summary:==

Salmonella National Control Plans required under EU Regulation 2160/2003 and various pieces of subsidiary legislation have been rightly credited with achieving considerable success in reducing the prevalence of ''Salmonella'' of human health significance in farmed poultry in Europe and hence reducing the burden of an important zoonotic infection. PVSGE members are involved in contributing veterinary expertise to farms and industry bodies and frequently liaise with the competent authorities responsible for delivering these official controls. As with any testing programme there is the potential for both Type 1 (false positive) and Type 2 (false negative) testing results. Although prevalence of these is believed to be low the economic consequences of official controls on affected farms can be devastating. The legislation in place permits the use of confirmatory testing for both breeding chickens and commercial layers and this was frequently carried out prior to 2018. Since then FVO audits have exerted pressure to avoid confirmatory testing and most Competent Authorities (CA's) now carry out this procedure rarely. This paper reviews the relevant published literature with a view to provide advice applicable to reducing the risk of inaccurate results and minimising the public health and economic impact where they do occur. We offer specific actions applicable to farmers, laboratories and competent authorities and seek the cooperation of the EU Commission to encourage these measures.

==Legislative and Operational Background==

It is about 20 years since the EU set up a system of monitoring and controlling important zoonoses within the framework of the Zoonoses Directive 2003/99 and the Zoonoses Regulation 2160/2003. The implementation of National Control Plans by individual countries has provided a mechanism to deliver improved surveillance and control measures which has, no doubt, contributed to a significant reduction in human health burdens. The system relies mainly on bulk environmental swabbing using overshoes, and then predominantly classical microbiological testing using ISO6579-1 method <ref> Anon (2017) ISO 6579-1:2017(en) Microbiology of the Food Chain—Horizontal Method for the Detection, Enumeration and Serotyping of Salmonella—Part 1: Detection of Salmonella spp.; ISO: Geneva, Switzerland, 2017.</ref>. The diagnostic specificity of the test itself is considered to be 100%, and in practice it can detect <10 organisms amongst the millions of similar Enterobacteriaceae in a typical sample. This very high sensitivity does, however, mean that small defects in system operation can result in detectable positivity due to cross-contamination, whether of samples at collection, or during the multiple phases of processing. Some laboratories do not routinely carry out detailed serotyping when they obtain a positive result. This can lead to delays in identifying the occurrence of an unusual number of positive samples of a single serotype, which is often the first sign of a problem. Competent authorities will typically apply restrictions to a flock identified as positive as soon as they have confirmed the identity of a submitted isolate as a target serotype. This issue was recognised when the relevant subsidiary EU legislation was drafted (see appendix). This envisages confirmatory testing for layers and breeding chickens and this was applied routinely in most countries up to 2017. Since then CA's have become increasingly reluctant to conduct or even, in some cases, to allow confirmatory testing. Good evidence in favour of a Type 1 error can take many weeks to develop. Restrictions in egg and hatching egg use applied due to the positive finding, in contrast, have an immediate financial impact. With the prospect of mounting operational costs (in particular feed costs) and no saleable product the affected producer is forced to cull a productive, often young, apparently healthy flock. Though this happens only rarely, with the reduction in prevalence of true infection with target serovars the proportion of false positives rises. This has important ethical, economic and practical implications. Every case of an unnecessarily culled flock which is allowed to occur risks damaging the cooperation between the poultry industry and Competent Authorities, on which the substantial progress already achieved has been built.

==Literature Review==

Erroneous results do not commonly get reported in the scientific literature. In the case of Type 1 errors there may be a reluctance to publish details for reasons of client or laboratory confidentiality. Type 2 errors are only likely to be documented where they result in onward spread to other poultry flocks, or a human food safety issue is identified. Increasing use of whole genome sequencing has the potential to link wide-spread individual cases to a source flock, but only once it is confirmed to be positive. De Lappe ''et alii'' (2009) <ref>De Lappe, N, J O Connor, G Doran, G Devane & Cormican (2009) Role of subtyping in detecting Salmonella cross contamination in the laboratory. BMC Microbiology volume 9, Article number: 155|url=https://bmcmicrobiol.biomedcentral.com/articles/10.1186/1471-2180-9-155 </ref>of the Irish National Reference Laboratory (NRL) carried out a very detailed assessment of the risk of false positive Salmonella results. Over an 8 year period (2000-2008) they identified 23 incidents with 56 separate isolates of ''Salmonella'' Enteritidis and S.Typhimurium which were attributed to cross-contamination as a result as molecular sub-typing. In this series the probable sources of contamination identified were the laboratory positive control isolate (n = 13), other test isolates (n = 9) or proficiency test samples (n = 1). The subtyping used was phage-typing and, in the case of S.T. multi-locus variance analysis.

In contrast Pedersen ''et alii'' (2014)<ref>Pedersen, K, G. Sørensen, I. Szabo, H Hächler & S. Le Hello (2014)Repeated isolation of Salmonella enterica Goverdhan, a very rare serovar, from Danish poultry surveillance samples. Veterinary Microbiology Volume 174, Issues 3–4.https://www.sciencedirect.com/science/article/abs/pii/S0378113514004519</ref> reported on an apparent pseudo-outbreak of S.Goverdhan in Denmark in which poultry flocks were not confirmed to be infected on repeat testing This was associated with the use of non-sterile hospital gauze imported from outside the EU to make the overshoes.

Rasschaert ''et al.'' (2016) <ref> Rasschaert, G., K. De Reu, M. Heyndrickx & L. Herman(2016) Case report of Salmonella cross-contamination in a food laboratory. BMC Research Notes volume 9, Article number: 156 https://bmcresnotes.biomedcentral.com/articles/10.1186/s13104-016-1969-7 </ref> showed in a case report that the issue is not restricted to on-farm samples when they investigated the occurrence of ''Salmonella'' Rissen in exported Belgian chocolate, as reported by a food testing laboratory. They used 3 different sub-typing system to show that the source was in fact the same strain that had been isolated from a fish meal sample in the same laboratory 7 weeks previously.

McMullin (2021)<Ref>P. McMullin (2021) Salmonella testing carried out in support of National Control Programmes and industry requirements: Investigation of 8 incidents of probable false positivity (FP’s) Presented at the Annual Meeting of the Society of Microbiology, UK</ref> has reported on a series of 8 investigations of suspected false positive testing results from poultry samples in the UK, of which 3 were S.Typhimurium, 2 were S.Enteritidis (including 1 vaccinal) and one each S.Nottingham, S.Poona and S.Newport. Of these it was concluded that the sources of cross-contamination included 4 laboratory controls, 3 field samples and one proficiency test sample. Only 1 of the 8 submissions was of boot swabs, and 5 were bulk table egg samples tested as part of an industry control programme.

The most in-depth recent study on this topic was reported by Costa ''et alii'' (2021) <ref>Costa , E., A.Elbers, M. Koene ,A Steentjes, H. Wisselink, P. Wijnen, and J. Gonzales 1(2021) Qualitative Evaluation of Causes for Routine Salmonella Monitoring False-Positive Test Results in Dutch Poultry Breeding Flocks. Microorganisms 9(11)10.3390 https://www.mdpi.com/2076-2607/9/11/2215 </ref>. This group focussed on results from routine boot-swab sampling of poultry breeding flocks in the Netherlands. In addition to reviewing results of testing of Dutch poultry breeding flocks in a period in which routine confirmatory testing was required they conducted an opinion survey of PVSGE members in relation to the topic. They identified the various points that false positivity (or negativity) could arise and carried out detailed epidemiological analysis of the available data. They did not have access to detailed genotyping which would allow identification of likely source(s) of positivity. They also assessed the specificity of Salmonella testing based on proficiency test results. This showed that the proportion of false positive test results is, on average, 2.3% for the Dutch laboratories and 2.7% for laboratories in other countries. As not all participating laboratories carry out serotyping some of these will be incorrect identification of other organisms as Salmonella. Proficiency test samples have been identified as a source of false positivity in other cases so it may well be that the lack of competing organisms in some proficiency test samples results in high growth of the Salmonellae, facilitating cross-contamination. Nevertheless these data support the view that there is a significant risk of false positive results, which the authors assess as a medium risk in their environment. They also modelled their effect on the success of the Salmonella control programme. The post-test probability of infection or positive predictive value of the routine Salmonella test tends to decrease sharply at low prevalence, particularly below a prevalence of 0.2%. Supplementary materials were provided which detail a survey of PVSGE members, and sampling methodology of Dutch farmers at that time <ref>Costa , E. ''et alii'' (2021a) Supplementary materials- Survey questions and Method, procedures for farmer sampling and official sampling. https://www.mdpi.com/article/10.3390/microorganisms9112215/s1 (Zip File) </ref>. A high survey response rate was obtained from PVSGE members (67%) and this covered 21 of the 22 European countries represented in the organisation. Most respondents believed that cross-contamination could occur in the laboratory (94%) or on farm (90%), with fewer believing it could occur in transport (70%). A total of 92% of the respondents indicated that given the existence of false positive Salmonella results in practice, it is important that all initial positive Salmonella results from poultry farms are confirmed by resampling and retesting; that statement is made with an average certainty of 96%. These authors conclude that Salmonella prevalence in poultry breeding flocks in the Netherlands is low, and the positive predictive value (PPV) of an initial positive test is also low, which, in line with the retest findings of the Dutch competent Authority, justifies an official resampling and retesting by the competent authorities.

==Conclusions & Recommendations:==
It should be our common objective to minimise the occurrence of false reports, but we must also recognise that, given the nature of the samples tested, and the very high sensitivity of the testing methodology, Type 1 errors will occur from time to time. Clear evidence that they have occurred has often taken weeks to develop. Sadly this has resulted in unnecessary culling of uninfected poultry flocks, with the attendant ethical concerns, economic damage leading to increased cost in the food chain, and stress for all involved with the process.

Our review permits the identification of specific sources of Type 1 errors in relation to Salmonella testing of poultry flocks, and guides our proposal of specific measures to mitigate the risks. Table 1 lists issues and recommendations relevant to all samples and those associated with sampling. While sampling is not covered by laboratory accreditation, laboratories have a general duty to document anything which may affect the validity of its results. Table 2 covers, in turn, the issues which have been related to laboratory procedures.

{| border="1" cellpadding="1" cellspacing="0" size = "20" width: 100%;
|-
|colspan="3" align="Left"|'''Table 1 Salmonella False positivity: Sources and Mitigations relevant to All Issues, as well as Sampling and Transport'''
|-
|'''Source'''
|'''Mitigation'''
|'''By'''
|-
|colspan="3" align="Center"|All suspected cases of false positivity
|-
|All
|Laboratories should take care to document any concern with respect to an unusual result, investigate possible cross contamination, and cooperate with investigators. Having the ability to serotype all controls in use and target serovars rather than relying on third parties will help reduce the risk of multiple farms/samples being affected. Instances which, on the balance of probability, are false positive should be treated as a formal non-conformance and fully investigated with a view to early implementation of corrective measures. Where on-farm sampling, or sample packing may have contributed, the customer should be directed to a suitable source of advice to avoid repetition.
|Lab
|-
|colspan="3" align="Center"|Farm Issues
|-
|Contaminated sampling materials
|Obtain sampling materials as packaged kits from a reputable source. Ensure that they are stored in a clean, dry, dust-free area prior to use. Use sterile diluent, potable from farm service area (not hyperchlorinated or acid treated) or bottled, still water. Sampling materials, in particular diluents, should not be manipulated in laboratory areas where field samples are received or testing is being carried out.
|Farm/Lab
|-
|Within-farm cross contamination
|Follow good sampling practice - see [http://www.pvsgeu.org/uploads/Salmonella_sampling_protocol_23_en.pdf Sampling Protocol V1 2023]<ref>Anon, 2023 Salmonella Sampling Protocol V1, adapted and translated to English by PVSGE from a Dutch industry (Avined) document. http://www.pvsgeu.org/uploads/Salmonella_sampling_protocol_23_en.pdf</ref>
|Farm
|-
|Contamination of sample in transport
|Separate packaging of samples from each source. Ensure external surfaces are not contaminated with farm-origin organic material. Laboratory should log instances of poorly-taken or poorly packed samples and request re-sampling as required.
|Farm/Lab
|-
|}

{| border="1" cellpadding="1" cellspacing="0" size = "20" width: 100%;
|-
|colspan="3" align="Left"|'''Table 2 Salmonella False positivity: Sources and Mitigations -Laboratory specific issues'''
|-
|'''Source'''
|'''Mitigation'''
|'''By'''
|-
|colspan="3" align="center"|Laboratory Issues
|-
|Cross contamination from other samples
|Improved laboratory hygiene, and physical separation between culture phases. Special attention to hand hygiene, laboratory clothing, reusable pipettes, routine screening of the laboratory environment, and disposal of waste cultures (all phases)
|Lab/Quality Assurance Scheme
|-
|Cross-contamination from laboratory controls
|As above. Require laboratories to be able to serotype their internal control. Avoid use of target serovars as controls. Develop and provide laboratory controls with specific genetic markers.
|Lab/ Competent Authority/ Quality Assurance Scheme
|-
|Cross-contamination from proficiency test samples
|As above. Extra care is required with these as they commonly include target serovars and grow abundantly. If used for training inexperienced staff extra supervision of hygiene is required. C.A's should endeavour to produce more realistic test samples, and, where target serovars are included ensure that they can be readily identified as such. Require labs to serotype or have serotyped any positives - or at least any samples showing discrepancy with expected result.
|Lab/Competent Authority/Quality Assurance Scheme
|-
|}

Based on the above literature review and analysis we are pleased to support calls, from the poultry industry and respected academics, for the EU and Competent Authorities to review their policies with respect to confirmatory testing of poultry flocks for ''Salmonella'' spp. We understand that at least some CA's already allow confirmatory testing of layers and breeding chickens either in accordance with specified conditions<ref>Mapa, 2023 (accessed), Harmonized Protocol for the authorisation of sampling and analysis for confirmation of Salmonella on poultry farms. https://www.mapa.gob.es/es/ganaderia/temas/sanidad-animal-higiene-ganadera/protocolotestconfirmatoriospncs_tcm30-558107.pdf</ref>, or "on a trial basis"<ref>NVWA, 2023, Field test verification study Salmonella in Poultry.https://www.nvwa.nl/onderwerpen/salmonella-bij-pluimvee/veldproef-verificatieonderzoek-salmonella</ref>. In principle the options for confirmatory testing laid down in the legislation should remain available in all member states, and in trading partners required to follow EU rules, unless there is clear evidence that the result is accurate and there is an immediate public health risk which would preclude this. We recognise the need to be particularly precautionary with respect to breeding flocks given the potential for vertical transmission of at least some important serovars. If a likely source of cross contamination is identified, particularly where this is within-laboratory and supported by molecular typing of the 'false' isolate and the plausible source isolate, then the need for repeated retesting and follow-up can, and should, be minimal. In other circumstances every effort should be made to avoid unnecessary culling. Sometimes this culling is for sampling large numbers of carcasses, sometimes economics-led premature flock depletions. This must be minimised while still protecting both animal and human health. Achieving this may require both confirmatory testing and ongoing independent monitoring of suspect flocks and associated facilities. Routine environmental sampling of hatcheries and table egg packing stations is also very useful in identifying early indications of below-detection-limit infections in the breeding and egg-supply chains, and is to be encouraged. Even where such positives are not linked to a currently affected supply flock, they are helpful in focusing cleaning and disinfection activity to remove such residual contamination, and reduce the risk of spread both forward and backward in the production chain.

{| border="1" cellpadding="5" cellspacing="0" size="20" width: 100%
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|Eva Berndtson
|Gerard Leveque
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|President PVSGE
|Secretary, Legislation Working Group
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==Appendix - Relevant legislation==

Laying flocks (Table eggs)

Detailed sampling and controls based on results were laid down in EU Commission regulation 1237/2007<ref>Anon (2007) COMMISSION REGULATION (EC) No 1237/2007 of 23 October 2007 amending Regulation (EC) No 2160/2003 of the European Parliament and of the Council and Decision 2006/696/EC as regards the placing on the market of eggs from Salmonella infected flocks of laying hens. https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32007R1237 Reg 1237/2007</ref>
. Competent authorities were required to apply restrictions to flocks where there was evidence from outbreaks in consumers, or from sampling of the flocks that they were infected with Salmonella Enteritidis or Salmonella Typhimurium. It was recognised, however that there was a risk of false positivity in such designation, and that the competent authority may lift restrictions where the flock is not the cause of a food-borne outbreak, and it has been re-tested with negative results. The regulation specifies that one of 3 sampling options be used:

1. Faecal and dust samples (7 in total, with a sub-sample of 25 g being tested), as laid down in Commission Decision 2004/665/EC<ref>Anon, 2004,2004/665/EC: Commission Decision of 22 September 2004 concerning a baseline study on the prevalence of salmonella in laying flocks of Gallus gallus (notified under document number C(2004) 3512) https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32004D0665 </ref>

2. bacteriological investigation of the caeca and oviducts of 300 birds

3. bacteriological investigation of the shell and the content of 4 000 eggs of each flock in pools of maximum 40 eggs.

In addition to the sampling in point (b), the competent authority was expected verify the absence of the use of anti-
microbials, potentially affecting the result of the analyses of the sampling.

Chicken Breeding Flocks

The Salmonella monitoring programmes, as outlined in the EU Commission regulation 200/2010<ref>Anon (2010) Commission Regulation (EU) No 200/2010 of 10 March 2010 implementing Regulation (EC) No 2160/2003 of the European Parliament and of the Council as regards a Union target for the reduction of the prevalence of Salmonella serotypes in adult breeding flocks of Gallus gallus. https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32010R0200 Reg 200/2010</ref>
,asks for repeated sampling in order to ascertain progress in achievement of the EU target. According to Article 2.2.2.2.c of this regulation, states "In exceptional cases where the competent authority has reason to question the results of the testing (such as false positive or false negative results), it may decide to repeat the testing...". In the various member states, the competent authorities were resampling and retesting all initial positive samplings in breeding flocks for several years because of doubts about false positive initial test results.

==References==
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