DEFRA'S REVIEW OF RABIES DISEASE IMPORT CONTROL POLICY
Passports for Pets' response & suggestions to be considered in DEFRA's Rabies Review
1. The Pet Travel Scheme (PETS} has worked well since its inception in 2000 : domestic animals now flow relatively smoothly into and out of the UK and there is little or no demand to re-introduce compulsory quarantine. It appears unlikely that the EU will want to undertake a fundamental reform of the system established in 2004. Now that it falls within the framework of EU law the main drive will be to iron out the anomalies and reduce or eliminate national exemptions. It would require a very strong case to defend successfully any of the British exemptions : assuming, as we must, that the Commission’s proposals will be geared towards uniformity, we should require a qualified majority in the Council to overturn them or any part of them. It is not apparent where such a majority would come from
2. Looking in turn at some of the key points where current practices are likely to be challenged :
a) THE BLOOD TESTING REQUIREMENT We are not aware of other vaccinations which are routinely tested in this way. The normal assumption for both animals and humans is that vaccinations work. There was a fear at one time that owners would cheat and not have the vaccination done at all, but the vet’s signature on the certificate or passport is surely a sufficient guarantee. Vaccinations occasionally fail to take but one does not as a matter of routine double-check them all.
b) The six-month wait to guard against pre-incubation is also an anomaly. It presumably does not arise in a rabies-free country. Elsewhere it could be used as a safeguard on an ad hoc basis if there were thought to be evidence of contact with rabies in the relevant period before vaccination.
In any event the 6 month period should be re-examined - it was based on evidence from a handful of dubious cases in British quarantine kennels. Elsewhere 3 months is now generally regarded as adequate.
c) TICK TREATMENT The role of pets in transmitting ticks has been exaggerated. Vets and owners are familiar with them from experience with our domestic specimens. Richmond Park is probably as dangerous as the French Riviera. Millions of British people frequent both areas with few apparent ill effects. The 24/48 hour time window imposed for the treatment does not seem to relate problems in tick treatment and was presumably selected to suit the tapeworm. Any sensible owner takes protective measures against ticks when abroad (and at home.) Vets might do more to educate their clients, but the present treatment regime does not merit a battle in Europe.
d) TAPEWORM TREATMENT The echinococcus worm is more difficult. We would certainly not want it established in the UK but have seen no recent scientific assessment of the risk. That is an urgent requirement.
It would be worth consulting the veterinary authorities in Calais to see whether echinococcus has established itself there following defecation by thousands of dogs over the past 6 years (before entry into the UK.) We would urge that this time there should be a genuinely independent assessment by qualified experts, not by a committee representing diverse occupations and interests. In any event even if it were decided that the tapeworm treatment must be retained ( and in the unlikely event that the EU agreed) the timing of the treatment must be revised. The present timetable (24/48 hours before boarding) is a serious obstacle to travel (e.g. if returning to the UK on a Monday/Tuesday it requires the traveller to find a vet in France during the preceding weekend which is sometimes impossible.) Given the need for prior bookings and the uncertainties of travel times the “window” is often a nightmare for travellers. It still accounts for a high proportion of the failures at check-in. The original justification for the window was that after treatment the pet dog or cat (and presumably now ferrets too) must stay more than 24 hours in order to defecate on foreign soil but less than 48 hours since it might catch another infected vole and be re-infected. We doubt whether this is a realistic scenario for a family pet : and inhabitants of infected areas on the Continent take few such precautions. If their veterinary authorities took our system seriously they would presumably object strongly, since if it worked it would systematically infect their port areas.
If a new assessment of the risk points to the need to try to retain some form of protection one possibility might be to adopt the Swedish rules, with echinococcus treatment given in the 10 days before travel rather than in the 24 hour window. This would greatly alleviate the problem for travellers and simplify the checking procedures, since it would involve days not hours or even minutes.
If the Irish opted for the same solution, the UK, Sweden and Ireland might together attract more support. (We have no recent information on whether Malta, the fourth country with its own practices, will still wish to stand apart from the EU rules).
4. A decision by the UK to subscribe fully to the EU rules would be well received. It would accelerate progress towards general agreement and create credit which could be used elsewhere in the agricultural field. Conversely a decision to hang on to each aspect of the derogations would generate ill will, with little prospect of avoiding an eventual adverse vote.
5. TO SUMMARISE Passports for Pets would support the adoption of the normal EU rules, without derogations. If a new risk assessment on echinoccocus confirmed the alarming picture painted in 2000 we should suggest seeking a limited derogation but with the time window extended to 10 days.
6. There are four other points we would like to raise in the context of the review:
a) Qualified search and rescue dogs should be given carte blanche to go to any country (even if not on the approved list) where they can save human lives. Their owners should not have to face the prospect of subjecting their highly trained dogs to six months quarantine if they respond to an appeal by the British Government or directly from the country in distress to save lives. They could be required to have a yearly (not 2 yearly) rabies vaccine. Other EU rescue dogs are not penalised as the UK dogs are. The owners would certainly ensure that they were not involved in dangerous contact with local strays.
b) Under the present EU rules a pet has a 3 month wait following a successful blood test before entering from a non- approved country (instead of the 6 months required to enter the UK.) The test has to be carried out in an approved laboratory in the EU. If the animal is subsequently coming on to the UK it has to go back to square one with the 6 month wait. It would seem more reasonable if the 3 month wait before entering the EU (with the test in an EU laboratory) could count towards the 6 months.
c) The rules relating to airline travel derive from UK not EU requirements. They do not allow small pets to travel to the UK in the cabin even if the airline normally permits this. They also require a pet to be carried as manifest cargo not as excess baggage. The effect is that the cost to the traveller is as much as 3 or 4 times more on the inward journey to the UK than the outward journey. A further effort should be made to remove or reduce this anomaly.
d) Arrivals by private planes still pose problems and there should be at least one major airport equipped to handle them. The individuals concerned will be in a position to meet the costs.
February 2006
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