Published by Ontario Veterinary College (519) 824-4120, Ext. 54401

December 14, 2006

OVC responds to OMAFRA discussion paper

The Ministry of Agriculture, Food and Rural Affairs discussion paper “Developing an Animal Health Strategy to Support Ontario’s Agri-Food Industry” sets out four questions as guides to responses by stakeholders. The questions posed in the discussion paper are shown in italics.

The Ontario Veterinary College (OVC) is pleased that OMAFRA is undertaking this discussion and submits the following comments.

Demographics and Key Issues

a. To what sector(s) or group do you or the organization you represent belong? (e.g. agricultural production, agri-food industry (processing, retail, etc.) veterinary, public health, non-agricultural animal/species, government, academia)

The OVC represents veterinary science, including veterinary education, research, consultation and service, and animal health aspects of agricultural production, non-agricultural species and public health. These areas include all the animal health sectors except agri-food industry and government that were identified in the discussion paper. Hence the animal health strategy to be developed is of enormous importance to the OVC, as a major partner in animal health along with government, industry, and commodity groups.

b. If you identified yourself as part of the agricultural production sector, what species are of particular interest to you? (e.g. dairy cattle, swine, chickens)

The OVC concerns itself with all agricultural animal species including fish, as well as wildlife, and companion animal species. The College provides professional and graduate education as well as research, clinical and consultation services on food animals, companion animals and wildlife. Much of the College’s activity in wildlife diseases involves participation in the Canadian Cooperative Wildlife Health Centre (CCWHC).

c. What are the top five key animal health issues that you believe should be addressed by a provincial animal health strategy?

The top five key animal health issues that should be addressed by a provincial animal health strategy, in the context of prevention, detection, and early and effective response to disease, are:

1. Animal health infrastructure
Infrastructure is needed to adequately support animal health in order to enhance the province’s competitiveness in various markets and to improve our readiness to meet the threat of zoonotic infections in humans. This infrastructure includes:
a. public and private sector organization working in harmony for optimal use of resources through close integration of government and private sector activities,
b. laboratory services in support of diagnosis and animal disease surveillance. Laboratory diagnostic services are an essential part of monitoring animal disease, including foreign animal diseases zoonotic diseases and diseases which are responsible for significant levels of production loss. Laboratory services involve not only diagnostic capability but also expertise in epidemiology related to disease surveillance and outbreak investigation.
c. research and educational facilities to develop the knowledge base required to assess impacts of interventions and conduct risk analyses, to provide consultation and disease investigation, and to educate. The research and educational facilities need to include a level 3 animal isolation facility for research on level 3 zoonotic agents.
d. a system for dead stock and offal disposal that will serve all agricultural sectors. Such a system should be designed to meet routine as well as emergency needs (e.g. when needed to control a major outbreak of disease) and should be recognized as being in the public interest because of the serious potential consequences of improper disposal of dead animals.
e. a scheme to attract and retain food animal veterinarians. Personnel are a critical part of the infrastructure. Food animal veterinarians are essential for biosecurity, disease prevention and the maintenance of animal health, and are an important part of the animal health system. The scheme that operates in Quebec appears to be successful in attracting and retaining food animal veterinarians in that province and this scheme should be examined and considered for implementation in Ontario.
f. support for personnel development and maintenance of the bank of animal health expertise in the province extended to include post-graduate education in the animal health sciences (e.g. epidemiology, health management, public health).
g. plans, personnel, and authority to engage in eradication of infection for public health purposes or for elimination of production-limiting diseases.

2. Animal disease surveillance
Good passive and active surveillance is dependent on a well organized system of collection, analysis and reporting of data on animal disease and infections. Such a system can contribute to our understanding of the importance of various diseases and infections and their impact on agricultural production as well as the risk to human health. Information from such data will be valuable as an aid in determining research priorities and in deciding on the steps to be taken to reduce the risk of infection and disease. Surveillance is critical for early detection of infection and a rapid response.

3. Enhanced co-ordination of animal health activities of provincial and federal governments, academia, commodity organizations, and producers
It is clear that the federal government (CFIA) has responsibility for handling foreign animal diseases and named diseases. However, for these diseases the interval between occurrence of an infection and diagnosis of that infection is critical and may make the difference between a rapidly contained disease and an extensive outbreak that lasts for a prolonged period. Managing activities during this interval so as to minimize the damage caused by these infections requires close coordination between the provincial and federal government agencies. There is also a requirement that the province has in place the capacity to detect, respond to, and contain these infections before handing over to the federal government. This capacity will also be required for responses to infections that are not a federal responsibility but of public health and/or agricultural importance. The provincial organizations need to be vested with the appropriate authority to enter premises and undertake disease investigation and containment.

4. Improved co-ordination and collaboration between the animal health sector and the public health system.
With the formation of the Ontario Agency for Health Prevention and Promotion (OAHPP), the coordination and collaboration are beginning to take shape but the OAHPP initiatives need to be pursued vigorously. The University of Guelph has recently formed a Centre for Public Health and Zoonoses (CPHAZ), which is located at the OVC and has a mandate to increase collaborative activities between the University and other organizations. This Centre is ready to work with groups in both the animal health and human health sectors.

5. Animal health research and development
The province of Ontario has recognized the value of a knowledge-based economy through its support for innovation, particularly in areas of biotechnology. The province’s animal health strategy must also emphasize the importance of knowledge and expertise in the animal health sector. This can best be done through support of animal health research and education. Ontario can be an exporter, rather than an importer, of animal health expertise, laboratory services and consultation, and can grow industrial spin-offs from animal health research, given the appropriate research and development environment.

Co-ordination and Roles of the Animal Health System
a. Are there suggestions for improving the coordination of the animal health system in Ontario?

The appointment of a Chief Veterinarian is an important step towards improved co-ordination of the animal health system in Ontario. The Office of Chief Veterinarian should provide a central point of co-ordination which is needed for effective integration of the activities of the many groups in Ontario that play a role in animal health. If this initiative is to be effective, then this Office must be vested with the authority, responsibility, and resources to make the changes necessary to improve the effectiveness of operation of the various animal health groups within OMAFRA. At present it appears that the various groups that offer veterinary services operate with little co-ordination. These groups include the Office of the Chief Veterinarian for Ontario (OCVO), the AHL, the Health & Welfare veterinarians in Fergus, the poultry veterinarian located at OVC, and meat inspection veterinarians. Despite arguments that matrix management is effective and crosses all branches, these groups have disparate goals and insufficient co-ordination, which is detrimental to the animal industry of Ontario. Co-ordination of veterinary services within OMAFRA would substantially improve the returns from the investment. OMAFRA should establish a veterinary health group in a single unit, reporting to the CVO. This would increase efficiencies and improve services. This could be done without waiting for an Act and would be cost neutral. However, to effectively carry out biosecurity and other disease investigation and containment functions the unit would require authority provided by the Act.

OMAFRA should be the lead ministry for animal health and should ensure that there are clear lines of responsibility and communication related to animal health activities in the various ministries, such as the Ministry of Natural Resources, Ministry of the Environment and the Ontario Ministry of Health and Long Term Care. The OCVO would be the logical organization in OMAFRA to carry out these coordinating functions.

It would be useful to establish an independent annual animal health forum to involve stakeholders so that they may review the state of animal health in the province, identify issues that need to be addressed, and develop and modify forward-looking plans for animal health in Ontario. If the forum is to be effective it will need to maintain a careful watch on outcomes and regularly assess its efficacy.

b. What do you think the provincial government’s role should be in the animal health system?

The responsibility of the provincial government is to play a leadership role in the animal health system, develop strategies, coordinate activities among provincial and federal governments and between the provincial government and stakeholders, provide infrastructure in support of animal health, and ensure that resources are available to achieve agreed upon objectives for animal health in Ontario. Stakeholders would include members of the public in view of the importance of a safe and viable animal agriculture sector to the nutrition and well-being of the public.

The government needs to support a knowledge-based animal health system in Ontario. This includes a commitment to development of excellence in research and development, and a recognition that, although it is difficult to place a dollar value on what might happen if we are lacking in knowledge capacity, there are good examples (High Pathogenicity Avian Influenza in British Columbia, BSE) of the enormous cost of animal disease including lost production, increased production costs, cost of imports, general social and economic costs, human health costs, and loss of export markets.

c. What role would you or the organization you represent be willing to play in a co-ordinated animal health system?

The OVC is keen to increase its contribution to the animal health system in Ontario. The College is the only one in Ontario that educates veterinarians and is very interested in working with OMAFRA and producer organizations to ensure that veterinary graduates are available to meet the needs of the province. The College is renewing its physical infrastructure and plans to continue to do this so that it will maintain and enhance its reputation for quality. With assistance from OMAFRA, producer groups, and other agencies, the OVC has animal health research programs that address health issues in a wide range of animal species, fundamental research that leads to new understanding, and animal-related public health problems.

The OVC is interested in making its intellectual resources available for consultation on policy issues and disease control. The College collaborates with the AHL and OMAFRA in animal disease surveillance and plans to develop these collaborations more extensively.

The College is interested in being a contributor to disease investigation teams that might include the AHL, epidemiologists, clinicians, and infectious disease personnel from the College.

Potential Legislative Changes to Improve the Animal Health System

a. What do you believe potential animal health legislation in Ontario would need to address or accomplish?

OMAFRA should develop an Ontario Animal Health Act, designed to ensure that there is legislative authority where it is needed to deal with diseases and infections prior to federal government involvement and diseases that do not fall under federal authority but are considered of importance to the province. It would be valuable to work closely with the Canadian Food Inspection Agency in developing such legislation. Input from producers, producer organizations and other stakeholders would also be necessary. In particular, the legislation may wish to examine privacy issues and the extent to which they may impede access to information and rapid responses.

The Act should include provisions for setting of standards for biosecurity, authority to enter properties, collect samples, and take action necessary for containment of disease.

The Act should provide for appropriate compensation of producers for losses and for collection of data for surveillance.

b. Are there ways other than legislative changes that could be considered to enhance Ontario’s ability to safeguard animal health?

It may be useful to consider not only legislative changes but also the possibility of memoranda of agreement between OMAFRA and various groups to ensure that the animal health system operates optimally.
Support for a strong OCVO will aid in improved co-ordination of animal health activities within the province and with agencies outside the province.

Resources to implement the Animal Health System

a. How would you allocate resources to improve the animal health system in Ontario?

OMAFRA needs to ensure that it secures a budget for the animal health system that reflects the economic and public health importance of animal health. Resources need to be allocated based on established priorities for the animal health system in Ontario.

b. What would you identify as the current top three priority areas for investment in animal health in Ontario?

Currently, the top three priorities for investment in animal health in Ontario are:

1. Animal health infrastructure
As noted earlier, the infrastructure includes personnel and facilities. This is a sound investment in the knowledge industry that will have long-term benefits and will provide continuous protection that will minimize the threat of animal disease. A level 3 animal isolation facility, for example, will allow the province to safely diagnose animal infections with level 3 agents, to conduct research into the interactions of these agents with animals, to attract faculty with expertise in these agents, and to educate graduate students who are interested in working with these agents.

Support of the AHL and CCWHC in the wildlife sector, needs to be a central piece in the Ontario animal health strategy. These laboratories have roles in disease diagnosis, collection of data for disease surveillance, and development of new diagnostic tests to better serve agriculture and the environment.

The organization of multi-disciplinary disease investigation teams would enhance the province’s preparedness to respond to diseases that threaten agriculture, the environment, and the public.

2. Animal disease surveillance
There are several data bases within OMAFRA and outside OMAFRA that are valuable for their contribution to animal disease surveillance. Additional databases may be necessary to effectively survey the animal population in Ontario. Good information management systems and arrangements to deal with sensitivities over ownership/sharing of data are needed in order to optimize the analysis and use of these data.

3. Programs that assist producers to contribute to the animal health system
The speed with which an initial diagnosis is made is critical to the rapid control of a foreign animal disease or to the elimination of an animal source of a dangerous zoonotic disease. Producers need to operate in an environment in which fear of heavy financial losses does not result in reluctance to have suspicious animals examined by a veterinarian. Veterinarians need to be readily available and to be competent in the diagnosis of such diseases and the laboratory facilities and personnel need to be in place. Animal health monitoring programs therefore need to be established, involving cooperation among producers, producer organizations, veterinarians, the AHL, OMAFRA, and the OVC.

c. What types of animal health programs would address your priority areas?

We need a co-ordinated animal disease surveillance program involving collection and analysis of data from a wide range of sources. Such a program would depend primarily on passive surveillance involving data from the Animal Health Laboratory, practicing veterinarians, and the CCWHC, but would also involve active surveillance for selected disease agents. Sentinel swine herds are presently being monitored and similar programs could be developed for other animal species.
There should be a program for regular assessment of the infrastructure needs of animal health and a system for ensuring that this infrastructure is available. Specific infrastructure that needs to be considered includes a level 3 animal isolation facility and facilities for disposal of dead animals.
There should be programs aimed at prevention / control / eradication of infection and disease in animals. Diseases to be addressed under such programs include production-limiting diseases and diseases that constitute a threat to humans. These programs need to be designed and audited so that there can be a level of confidence regarding any implied status of the flock or herd.
There should also be programs to educate and inform the various animal health sectors including producers and commodity groups on issues such as biosecurity. These programs should aim to create supportive and informed producers who will appreciate the importance of rapid reporting and of cooperation with the animal health system. Support for the producers should be in place to ensure that fear of massive financial losses does not contribute to reticence to report possible infection or disease.

d. What is the best way to ensure that all who benefit from an animal health system share the costs?

Although the benefits to producers and processors may be the most obvious and direct, the public at large and the public health system benefit enormously from an animal health system. Funding for the animal health system should therefore come from producers, processors, and the government.
Rapid and extensive urbanization in the province has removed massive numbers of people from proximity to animal agriculture. There is inadequate recognition by city people of their dependence on agriculture for safe food, good nutrition, and freedom from infections that arise in animal populations. It may be necessary for OMAFRA to establish programs to remind the population at large about the critical importance of agriculture to all of us and the responsibility that we all share in maintaining a good animal health system.