Ref. Ares(2010)673619-07/10/2010,-.- + EUROPEAN COMMISSION * * HEALTH AND CONSUMERS DIRECTORATE-GENERAL * * * * Directorate F - Food and Veterinary Office DG(SANCO) 2010-8427 - MR FINAL FINAL REPORT OF A MISSION CARRIED OUT IN EGYPT FROM 07 TO 14 JUNE 2010 IN ORDER TO EVALUATE THE ANIMAL HEALTH CONTROLS AND CERTIFICATION PROCEDURES APPLICABLE TO EQUIDAE DESTINED FOR EXPORT TO THE EUROPEAN UNION In response to information provided by the Competent Authority, any factual error noted in the draft report has been corrected; any clarification appears in the form of a footnote.
Executive Summary The objective of the mission was to evaluate the animal health situation and controls in place for equidae in Egypt, from which the European Union (UE) authorises imports and temporary admission of registered horses, re-entry of registered horses after temporary exports, and import of semen collected from registered horses. Registered horses are occasionally sent from Egypt to various MS, but no there are no approved semen collection centres in Egypt. The lack of supervision and documentation of official controls at all levels renders those controls unreliable. Confidence in the health status of equine animals is affected by shortcomings in the management of suspected and confirmed cases of disease in the country. Passive disease surveillance is limited and active surveillance almost non-existent. Under these conditions, the certification of equidae does not meet the requirements for their entry to the EU. Recommendations were made to the competent authority of Egypt to address the shortcomings described in this report. I
Table of Contents 1 INTRODUCTION 1 2 OBJECTIVES OF THE MISSION 1 3 LEGAL BASIS FOR THE MISSION 1 4 BACKGROUND 2 5 FINDINGS AND CONCLUSIONS 3 6 OVERALL CONCLUSIONS 12 7 CLOSING MEETING 12 8 RECOMMENDATIONS 13 ANNEX 1 - LEGAL REFERENCES 15 II
ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT Abbreviation AHRI AHS AOH EEF CA CCA CEM EE EIA EU EVA FVO GOVS LVO MS OIE OIE code OIE manual OV RVO Explanation Animal health research institute African horse sickness Agricultural Organisation for Horses Egyptian Equine Federation Competent authorities Central competent authorities Contagious equine metritis Equine encephalomyelitis Equine infectious anaemia European Union Equine viral arteritis Food and veterinary office General Organisation for Veterinary Services Local veterinary office Member State World organisation for animal health OIE terrestrial animal health code (2009) OIE manual of diagnostic tests and vaccines for terrestrial animals (2009) Official veterinarian Regional veterinary office III
1 INTRODUCTION The mission was undertaken as part of the FVO's (Food and Veterinary Office) planned mission programme. The mission team comprised two FVO inspectors, and was accompanied at all locations by a representative of the competent authority (CA). 2 OBJECTIVES OF THE MISSION The objective of the mission was to evaluate the animal health situation and controls in place for equidae in Egypt from where the European Union (EU) authorises imports and temporary admission of registered horses, re-entry of registered horses after temporary exports, and import of semen collected from registered horses. In pursuit of this objective, the following sites were visited: Central competent authorities Regional competent authorities Local competent authority Border Inspection Post (BIP) Horse Registration Bodies Laboratories Holdings Private equine hospital Livestock market 2 2 1 2 2 2 6 1 1 3 LEGAL BASIS FOR THE MISSION The mission was carried out under the general provisions of EU legislation (legal references are provided in Annex 1), and, in particular: - Article 46 of Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules. - Article 17 of Council Directive 90/426/EEC of 26 June 1990 on animal health conditions governing the movement and import from third countries of equidae. - Article 17 of Council Directive 92/65/EEC of 13 July 1992 laying down animal health requirements governing trade in, and import into the Community, of animals, semen, ova and 1
embryos not subject to animal health requirements laid down in specific Community rules referred to in Annex A(I) to Council Directive 90/425/EEC. Legal acts quoted in this report refer, where applicable, to the last amended version, and can be accessed at the following internet site: http://eur-lex.europa.eu/en/index.htm 4 BACKGROUND Commission Decision 2004/211/EC establishes a list of third countries from which Member States (MS) authorise imports of live equidae, semen, ova and embryos of the equine species. In this Decision, Egypt is listed as a regionalised country from which MS authorise the imports and temporary admission of registered horses, re-entry of registered horses after temporary exports, and import of semen collected from registered horses. Imports to the EU are authorised from the follwing regions: Governates of Alexandria, Beheira, Krafr el Sheikh, Damietta, Dakahlia, Port- Said, Sharkia, Gharbia, Menoufia, Kalioubia, Ishmailia, North Sinai, South Sinai, Cairo (as Greater Cairo including Giza-town), Suez, Marsa Martrouh, Fayoum, Giza and Beni Suef, representing the Northern part of the country. Registered horses are occasionally sent from Egypt to various MS: according to TRACES, around 50 horses enter the EU from Egypt annually. Commission Decision 2004/616/EC lists the approved semen collection centres for import of equine semen from third countries: no such centre is listed for Egypt, and the CA confirmed that there are no approved equine semen collection centres in Egypt. In 2009, Egypt reported an equine population of 1 373 442 to the OIE. According to the numbers given to the FVO team by the CCA, in 2009 there were 1 326 310 equines and in 2010 1 184 939. The majority of these animals are donkeys. These data do not match the FAO database (http://faostat.fao.org/site/573/default.aspx#ancor) which reports a population of around 3 million equidae. The official situation regarding the health status of Egypt for diseases affecting equidae is (source: OIE, 2009): Last reported outbreak African horse sickness Anthrax Contagious equine metritis Dourine Equine encephalomyelitides Equine infectious anaemia Equine viral arteritis 1959 1974 never reported never reported never reported never reported never reported 2
Glanders Rabies Vesicular stomatitis 1928 1990 never reported 5 FINDINGS AND CONCLUSIONS 5.1 NATIONAL LEGISLATION 5.1.1 Legal requirements Article 12(2)(b) of Directive 90/426/EEC states that particular account shall be taken of the legislation of the third country in relation to animal health and welfare, in drawing up or amending the list of countries from which imports of equidae into the EU may be authorised. Health certificates for equidae to be introduced into the EU require that African horse sickness (AHS), dourine, glanders, equine encephalomyelitides (EE) of all types, equine infectious anaemia (EIA), vesicular stomatitis, rabies and anthrax, be compulsorily notifiable in the country of origin (Commission Decisions 92/260/EEC on animal health conditions and veterinary certification for temporary admission of registered horses, 93/197/EEC on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production, and 93/195/EEC on animal health conditions and veterinary certification for the re-entry of registered horses for racing, competition and cultural events after temporary export). 5.1.2 Findings The Egyptian legislation for animal health has not been updated for a long time and some of its provisions are no longer applied: Decree No. 32 from 1967 lays down a list of infectious and contagious diseases. Equine infectious anaemia and dourine are not included. Resolution No 47 of 1967 describing rules for import quarantine states that horses must be vaccinated against African horse sickness ("plague") before arrival in Egypt, but the Central Competent Authority (CCA) indicated that this legal requirement, although still valid, is no longer applied. The CCA explained that vaccination in Egypt against African horse sickness was discontinued in 1984 for the Northern region and in 1994 for the Southern region. There is no legislation requiring the notification of contagious animal diseases. There are no animal health requirements for the collection, storage, trade or use of equine semen in Egypt. The Law No 53 of 1966 (Agriculture law) details the sanctions for non-compliances with the animal health regulations. The levels of financial sanctions have not been revised since. The CCA informed the team that the animal health legislation is currently under review. 5.1.3 Conclusions 3
National legislation does not provide an effective basis to certify that the diseases cited in the EU certificates are compulsorily notifiable in Egypt. 5.2 COMPETENT AUTHORITIES 5.2.1 Legal requirements Article 12 (2) (c) of Directive 90/426/EEC requires that account be taken of the organisation of the competent veterinary authority and its inspection service, their powers, the supervision to which they are subject, and the means at their disposal (including staff and laboratory capacity) to apply national legislation effectively, in drawing up or amending the list of countries from which imports of equidae into the EU may be authorised. Requirements are laid down in Article 17 (4)(b) of Directive 92/65 for authorisation of imports of equine semen from third countries. 5.2.2 Findings Official Gazette Issue No. 21 from 24 May 1984 establishes the Veterinary Service (GOVS) as an organisation to be affiliated to the Minister of State for Agriculture, in charge of "the protection of animal health and the prevention of epizootic and infectious diseases, treatment of casualties and infertility which act adversely against livestock productivity". The total staff number of GOVS is about 11,000. The organisation is pyramidal, with 27 regional veterinary offices (RVO), which organise and supervise the field operations of local veterinary offices (LVO) within their regions, covering the whole territory. In the field, LVOs implement the official campaigns for eradication and control of diseases, and provide veterinary care to livestock and pets. LVOs send a weekly report on their activities to the RVO which in turn reports to CCA. Under Egyptian law, civil servants may not have any private professional activities. When the mission team questioned the private work performed by the official veterinarians (OVs) met, the CCA explained that this legislation had not been applied for more than 20 years, and that they give a choice to the OVs either to fully work for the official service, or to have some private activities, in which case part of their salary is withheld. No arrangement was in place to define, check on or prevent conflicts of interest. The Central Veterinary Quarantine Department is responsible for import and export of equidae. Surveillance, control and eradication of animal diseases affecting domestic equidae is performed by the Central Department For Preventive Medicine while the Central Department of Zoos supervises and controls animals diseases in non-domestic animals. In an RVO visited, copies of weekly reports of routine animal health control activities from the LVO were available. 5.2.3 Conclusions The designation of the CA in the field of animal health is clear but conflict of interests cannot be excluded in connection with private veterinary work done in addition to official tasks (see also section 5.7.2). 5.3 LABORATORY SERVICE 5.3.1 Legal requirements 4
Article 12 (2) (c) of Council Directive 90/426/EEC requires that particular account should be taken of the laboratory capacity of the third country. Article 12 (1) 3rd paragraph of Council Directive 90/426/EC on animal health conditions governing the movement and import from third countries of equidae specifies that relevant international standards should be used for the evaluation of how the CA applies and implements the animal health provisions. The relevant international standards for animal health are drawn up by the World organisation for animal health (OIE), recognised as a reference organisation by the World Trade Organisation. The OIE manual of diagnostic tests and vaccines for terrestrial animals indicates the standards of quality management programmes enabling laboratories to demonstrate that they operate a viable quality system, including validation of diagnostic assays. The OIE manual provides detailed descriptions of laboratory tests that can be used in a variety of applications for individual diseases, including diagnosis, disease control, surveillance, epidemiological studies and screening for international movement. Only those tests that are suitable for international movement testing are included in the OIE list of Prescribed and Alternative Tests. Equidae to be introduced into the European Union from Egypt must be tested for some diseases, including AHS, EIA, dourine, glanders and possibly equine viral arteritis (EVA) (health certificates "E" of Decisions 92/260/EEC on animal health conditions and veterinary certification for temporary admission of registered horses and 93/197/EEC on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production). 5.3.2 Findings The Animal Health Research Institute (AHRI) in Cairo is the national reference laboratory. It is the only official laboratory performing analyses on infectious diseases of equidae. The only analyses performed by the AHRI on equine infectious diseases in in the last few years were for equine influenza (related to outbreaks of epizootic proportions in 2008), and one import test for dourine (by direct examination of blood smear). The AHRI had also a few test kits available to perform antibody tests for AHS, EVA, EIA and rhinopneumonitis. Most of the kits were unused; some of them had expired or were kept at an inappropriate temperature. Although rabies is considered by the CA to be endemic, no tests for it had been performed in 2009 and 2010as the laboratory did not have the necessary capability. Neither the CA or the AHRI had arrangements for sending samples from equidae for analyses to other laboratories. In addition to the official laboratory, tests on diseases of equidae can be performed in private or University laboratories, or can even be sent abroad. Such testing is not controlled or supervised by the CA. 5.3.3 Conclusions The national capacity for official investigation of infectious diseases affecting equidae in Egypt is insufficient and is not compensated by alternative arrangements. 5.4 REGISTRATION OF HOLDINGS, ANIMAL IDENTIFICATION, MOVEMENT CONTROLS 5
5.4.1 Legal requirements Article 12 (2)(d) of Council Directive 90/426/EEC requires that assurances, which the CA can give regarding compliance with or equivalence to the relevant animal health conditions applicable in the EU be considered for drawing up or amending the list of countries from which imports of equidae into the EU may be authorised. Article 14 of Council Directive 90/426/EEC requires that equidae to be imported into the EU remain without interruption in the part of the territory approved, for a period to be determined. This period is three months for import (Decision 93/197/EEC on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production). For temporary admission, the traceability of residency of the registered horses must be of 40 days (Decision 92/260/EEC on animal health conditions and veterinary certification for temporary admission of registered horses), and for re-entry, the traceability must be for the full period since the departure of the registered horses from the EU (Commission Decision 93/195/EEC on animal health conditions and veterinary certification for the re-entry of registered horses for racing, competition and cultural events after temporary export). Article 2 (c) of Council Directive 90/426/EEC defines registered equidae. They are equidae registered by a breeding authority managing the studbook for this breed, or by an international organisation managing horses for competition or racing. Article 16 (1) of the same Directive requires the imported equidae to be identified by the required means of identification for their category. According to Article 4, second indent of Council Directive 94/28/EC laying down the principles relating to the zootechnical and genealogical conditions applicable to imports from third countries of animals, their semen, ova and embryos, and amending Directive 77/504/EEC on pure-bred breeding animals of the bovine species, and Article 1, third indent of Commission Decision 96/510/EC laying down the pedigree and zootechnical certificates for the importation of breeding animals, their semen, ova and embryos, the identification document accompanying imported registered equidae must be conform to the passport whose format is laid down in Commission Regulation (EC) No 504/2008 implementing Council Directives 90/426/EEC and 90/427/EEC on the zootechnical and genealogical conditions governing intra-community trade in equidae as regards methods for the identification of equidae. Article 3 (1) of Directive 94/28/EC laying down the principles relating to the zootechnical and genealogical conditions applicable to imports from third countries of animals, their semen, ova and embryos, and amending Directive 77/504/EEC on pure-bred breeding animals of the bovine species requires that the CA of the third country approves the bodies identifying registered equidae to be exported to the EU. Article 4 (6) of Commission Regulation (EC) No 504/2008 implementing Council Directives 90/426/EEC and 90/427/EEC as regards methods for the identification of equidae requires the CA of the third country to guarantee that these bodies issue identification documents as laid down in the Regulation, and that updated lists of such issuing bodies are communicated to the Commission. 5.4.2 Findings Holding registration and identification of equine animals is not compulsory in Egypt. The registration and identification of horses is carried out by two bodies: 1. For pure Arabian horses, the Agricultural Organisation for Horses (AOH) (reporting to the Ministry of Agriculture) 6
2. For sport horses, the Egyptian Equine Federation (EEF) (independent but financially subsidised by the Ministry of Youth The CA is officially in charge of identification of livestock and has not formally delegated this task to these bodies for registered horses and does not supervise them. The two bodies are internationally recognised: the AOH by the World Arabian Horse Association and the EEF by the Fédération Equestre Internationale. A passport is issued by the AOH to Arabian horses only when they are going to be exported. No arrangement was in place to ensure that the newly issued passport would contain information related to vaccination, testing or movement history of the horses. It currently does not include a description of the horse as required by Regulation (EC) No 504/2008. The AOH announced that there is a new passport currently in print which contains the missing information. The pure bred Arabian horses have the number of the stud and an individual number freeze-branded on their neck, in a coded form. All registered horses receive a microchip. All horses registered by the EEF were issued a passport by the EEF, in line with sections I to VIII of Regulation (EC) No 504/2008. In a decision of 1994, the CCA prohibited movement of animals from the Southern to the Northern regions. This regionalisation is not being applied: movements of equidae are not checked within the country. No measures are in place to give effect to the regionalisation described in Commission Decision 2004/211/EC. The AOH indicated that some holdings for thoroughbred horses were located in the Southern part of the country. 5.4.3 Conclusions Identification of registered horses is performed by bodies recognised by international horse organisations, but is not approved or supervised by the CA. Regionalisation is not being applied and therefore the conditions in Commission Decision 2004/211/EC for the import of horses from Egypt are not fulfilled. 5.5 ANIMAL HEALTH CONTROLS 5.5.1 Legal requirements Article 12 (2) (a) of Council Directive 90/426/EEC requires that particular account should be taken of the health status of equidae and other domestic animals and wildlife, and the environmental situation. Article 12 (2) (e) of Council Directive 90/426/EEC requires that particular account should be taken of the regularity and rapidity of the information supplied by the third country in relation to the existence of infectious diseases of equidae in its territory. Article 12 (2) (f) of Council Directive 90/426/EEC requires that particular account should be taken of the guarantees given by the third country to inform directly the Commission and MS of occurrence of diseases, animal health status, proposed changes in the national sanitary rules (in particular for imports of equidae) and, at regular intervals, of the animal health status of its territory concerning equidae; Article 12 (2) (i) of Council Directive 90/426/EEC requires that particular account should be taken of the rules on the prevention and control of infectious diseases in force in the third country and their implementation, including rules on imports of equidae from other third countries. 7
Article 17 (3) of Council Directive 92/65/EEC indicates that horse semen may only come from third countries able to provide guarantees equivalent to those contained in Annex D to the Directive (conditions related to the approval of collection centres, admission of donor males (including negative tests for EIA, EVA and contagious equine metritis (CEM)). The health requirements for import of semen are further detailed in Commission Decision 96/539/EC on animal health requirements and veterinary certification for imports into the Community of semen of the equine species. Article 13 of Council Directive 90/426/EEC requires that imported equidae come from a country, or, if decided so by the Commission, from part of a country which is free from AHS, and has been free from Venezuelan EE for at least 2 years, and from dourine and glanders from at least 6 months. Article 14 of the same directive requires that equidae come from holdings placed under veterinary supervision. Article 15 of the same Directive requires either the country to be free from vesicular stomatitis and EVA for at least 6 months, or the animals to be tested. According to Article 15 (a) of Council Directive 90/426/EEC, imported equidae must also comply with specific animal health requirements. These requirements are detailed in the various decisions and certificates, and include, in addition to the previous requirements, the absence of diseases in the holding of origin (6 months for EE, vesicular stomatitis, EIA until the infected animals are removed and two further clear tests performed three months apart on the remaining animals, one month for rabies, 15 days for anthrax), as laid down in Article 4 (5) (a) of Council Directive 90/426/EEC. Certification for permanent imports also requires a statement on the absence of suspicion of CEM. 5.5.2 Findings No active surveillance for diseases of equidae is in place. Passive surveillance is carried out by the OVs in local offices offering free treatments to sick animals and by some charitable animal hospitals in various parts of the country which they deliver care to the local equidae. Moreover, private veterinarians attend the registered equidae. Livestock markets are frequent; each village has a weekly market in which donkeys, mules and horses may be traded. Generally they take place without supervision by the CA, despite the legal requirement for such supervision (Article 131 of the Agriculture Law). No animal health procedures or precautions are in place in respect of gatherings of animals. No specific provisions are in place for the CA to inform the European Commission of disease outbreaks, of the general animal health status, or of any proposed changes to national animal health rules (in particular for imports of equidae). In the opening meeting the inspection team had been informed that there is no West Nile fever in Egypt. When visiting the veterinary laboratory of a University, the team was informed that the virus had been identified in equidae, and that it was a strain different from from the strains in the neighbour countries. When informed of this at at the final meeting, the CA confirmed they had not been aware of it. 5.5.3 Conclusions Animal disease surveillance is inadequate and does not target any disease of relevance for the EU. The absence of any active surveillance, and of routine laboratory investigation of sick equidae, means that the CA does not have information on the possible presence of diseases of horses of significance in respect of exports to the EU. 8
5.6 IMPORT CONTROLS 5.6.1 Legal requirements Article 12 (1) 3rd paragraph of Council Directive 90/426/EC on animal health conditions governing the movement and import from third countries of equidae specifies that relevant international standards should be used for the evaluation of how the CA applies and implements animal health provisions, in particular for the sanitary requirements for imports from other third countries. Article 12 (2) (i) of Council Directive 90/426/EEC requires that particular account should be taken of the rules on the prevention and control of infectious diseases in force in the third country and their implementation, including rules on imports of equidae from other third countries. 5.6.2 Findings Approval for import of equidae is based on an ad-hoc risk analysis by the CCA on the health situation of the country of origin as reported on the OIE website. Specific criteria (including the diseases of relevance), or reports on refusal or acceptance of import consignments were not available. The CCA indicated that import, admission or re-entry of horses was only allowed from European or Arabic countries. No model certificate is in place: the CA issues a standard list of requirements, whatever the country. These requirements, written only in Arabic, contain some conditions which are not of common understanding: for instance, according to the CA, a term translated as "syphilis", was interpreted either as EVA or as dourine. The CA does not require testing for diseases or pre-export quarantine in the country of origin. On arrival, the animals and certificates are checked at the Central Veterinary Quarantine Department. Lists of imports were available at the Central Veterinary Quarantine Department in Cairo airport. This border inspection post is open 24 hours daily, working in 3 shifts with a minimum of 1-2 veterinarians. The facilities for inspection or isolation of animals include 6 horse boxes. The team was shown a microchip reader to facilitate identity checks of imported horses. The OV indicated that due to the lack of clarity in their own animal health requirements, they could not effectively control the adequacy of the certificates accompanying the animals. Different types of certificates were issued by the exporting countries, which did not certify all points required by the CA. Nevertheless, they were accepted at import into Egypt. Horses are then transported to a stable that has been approved beforehand to be suitable for a ten day quarantine. During the ten day quarantine, the animals are checked by an OV several times before their release. Reports on these checks and documentation on the approval of the premises were available at the quarantine offices visited. The quarantine premises visited by the mission team were isolated and in good state, and some of them had nets and grids to protect the animals from vector insects. The import of wild animals is also under the responsibility of the Central Veterinary Quarantine Department and is subject to compliance with the Convention on International Trade in Endangered Species of Wild Fauna and Flora. The inspection team saw import documents of wild zebras from an African country which cannot be considered as free of Africa horse sickness according to the OIE code. The animals had not undergone any quarantine or laboratory testing before they entered Egypt. 9
5.6.3 Conclusions Animal health conditions and certification for the import of equidae are not adequately defined The obligatory 10 day quarantine gives some assurance that clinically sick animals will be detected before their release. 5.7 EXPORT TO THE EUROPEAN UNION 5.7.1 Legal requirements Articles 13, 14, and 15 of Council Directive 90/426/EEC lay down the requirements regarding the health status of the country of origin, the residency requirements of the equidae to be imported, and further animal health requirements. Article 16 lays down identification and certification requirements. The animal health conditions and veterinary certification for temporary admission of registered horses from Egypt are in the health certificate E of Decision 92/260/EEC on animal health conditions and veterinary certification for temporary admission of registered horses, whereas those for import of registered horses are detailed in the health certificate E of Decision 93/197/EEC on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production. The main differences between the requirements for the two types of import is that, in the former case, the residency certification is of 40 days (instead of 3 months in the country of dispatch for definitive import), the conditions of the isolation centre where the horses must spend 40 days before dispatch are not defined (whereas this centre must be approved and protected from vector insects in case of definitive import), and sampling for testing dourine and glanders must have been performed within 10 days of shipment (whereas it can be done within 21 days of shipment in case of definitive import). In all cases, the horses must be clinically examined by the OV on the day the certificate is signed, and they must be sent in a vehicle cleaned and disinfected in advance with a disinfectant officially recognized by the country of dispatch. Council Directive 96/93/EC establishes the rules, principles and controls on the certification of animals and animal products. Rules and principles applied by third-country certifying officers are expected to provide guarantees at least equivalent to those laid down in this Directive. The OIE Code (chapter 5.2) lays down certification procedure requirements equivalent to those established in this Directive. 5.7.2 Findings The CA does not organise, regulate, check or supervise the certification of animal health requirements of the country of destination. In practice, the mission team was informed that those animal health certificates were issued by non-official veterinarians, working for or on behalf of one of the identification and registration bodies. Almost no documentation related to the export certification was available at either place where certification was issued: a few laboratory results were presented (from a foreign laboratory), which were not related to any certificate and one copy of an export certificate was presented. No copies of certificates or laboratory test results could be found referring to any of the examples of notification of arrival of horses from Egypt at European Border Inspection Posts. Veterinarians at both bodies were exclusively using a certificate for permanent import. No system was in place to allow them to check the compliance regarding regionalisation or (national or 10
international) movement history. Veterinarians also indicated that they were not requiring isolation of the horses prior to export nor protection from vector insects. When animals arrive at the border inspection post at the airport, an identity check and a check for clinical signs of diseases is performed by an OV. An additional certificate is issued to certify these checks. The initial animal health certificate is not controlled, and no copy is kept. The national animal health certificates seen at the airport quarantine department are in a pad with individual page numbers, each in three sheets of different colours. The inspection team noted that the blank forms had all been pre-stamped with the official stamp. 5.7.3 Conclusions Due to lack of official supervision over the certification, to the shortcomings in the certificates, and the absence of records related to certification, the performance of pre-export operations was unacceptable. The isolation and tests performed on registered horses intended for export do not provide reliable guarantees on the health status of the registered horses, as they are not checked by the CA or documented. The internal system for the official pre-stamped certificates does not guarantee the integrity of certification. 5.8 CONTROLS OVER VETERINARY MEDICINAL PRODUCTS 5.8.1 Legal requirements All equidae, if no express indication of the contrary is given in Section IX of their passport, as established by Regulation (EC) No 504/2008 implementing Council Directives 90/426/EEC and 90/427/EEC as regards methods for the identification of equidae, are regarded as food-producing animals. Article 11 of Council Directive 96/22/EC indicates that third countries authorising stilbenes or thyrostatic substances for food-producing animals, may not be on any list of countries from which MS may import such animals. MS must also prohibit the import of farm animals to which beta agonists, or substances having oestrogenic, androgenic or gestagenic action have been administered, unless these substances meet specific conditions of approval and formulation, and the product is administered and recorded by a veterinarian. Article 29 of Council Directive 96/23/EC indicates that the retention on the lists of third countries from which MS are authorised to import animals shall be subject to submission by the third country concerned of a residue monitoring plan. In addition to individual testing, certification is required on the possible vaccination against certain diseases (AHS, EVA) (Certificate "E" of Decisions 93/197/EEC on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production and 92/260/EEC on animal health conditions and veterinary certification for temporary admission of registered horses). 5.8.2 Findings Although there is no specific legislation on the matter, equidae are not considered as food- 11
producing animals, and not slaughtered for human consumption in Egypt. There is no residue monitoring plan for equidae. Veterinary medicinal products must be registered by the Ministry of Health. It is not compulsory to keep records of medicinal treatment given to animals. Veterinary biological products and vaccines manufactured or imported into Egypt must be registered by the CA. The body in charge of Arabian horses had been vaccinating its horses since last year against three equine encephalomyelitides, including Venezuela encephalomyelitis, currently known to occur only on the American continent. This vaccine has not been registered in Egypt, but an import permit was issued by the CCA. The use of the vaccine is not recorded. 5.8.3 Conclusions In the absence of any known risk factor, and of reliable surveillance of neurological syndromes, the decision to allow unrecorded vaccination against encephalomyelitides without could create confusion as, when tested, vaccinated animals cannot be differentiated from infected animals. 6 OVERALL CONCLUSIONS The lack of supervision and documentation of official controls at all levels renders those controls unreliable. Confidence in the health status of equine animals is affected by shortcomings in the management of suspected and confirmed cases of disease in the country. Passive disease surveillance is limited and active surveillance almost non-existent. Under the current conditions, the certification of equidae does not meet the requirements for their entry to the EU. 7 CLOSING MEETING A closing meeting was held on 14 June 2010, at which the main findings and conclusions of the mission were presented to the national authorities. At this meeting, the CCA indicated that that the animal health legislation had been reviewed and an up to date plan of the legislation is currently being forwarded to the Parliament. The CCA also indicated that they would immediately discontinue vaccination against encephalomyelitis. 8 RECOMMENDATIONS The Competent Authorities of Egypt are invited to present an action plan describing the actions taken or planned in response to the recommendations of this report, including a timetable for their completion, within 25 working days of receipt of the report. 12
N. 1. Recommendation To update the legislation so that diseases of equidae cited in the certificates are compulsorily notifiable as laid down in Commission Decisions 92/260/EEC on animal health conditions and veterinary certification for temporary admission of registered horses, 93/197/EEC on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production, and 93/195/EEC on animal health conditions and veterinary certification for the re-entry of registered horses for racing, competition and cultural events after temporary export. 2. 3. 4. 5. 6. 7. To consider improving the knowledge of the health status of the country regarding the diseases of equidae by introducing targeted active surveillance, e.g. on diseases notified in neighbouring countries or on diseases of limited clinical expression in order to ensure that requirements of Art 13 of Council Directive 90/426/EEC on animal health conditions governing the movement and import from third countries of equidae are met. To reconsider the vaccination against exotic diseases, so that, when authorised, it is controlled and recorded and will not affect international health requirements or the animal health surveillance at national level. To apply appropriate and proportionate import requirements for live equidae to enable the CA to certify the requirements in the EU certification. To ensure that the principles and integrity of certification of animal health requirements as laid down in Articles 3 and 4 of Council Directive 96/93/EC on the certification of animals and animal products, are fully respected (certification only of matters in the personal knowledge of the official veterinarian or that can be ascertained by him, official veterinarians or certifying officers fully aware of the significance of each certificate, having a status ensuring their impartiality, no conflict of interests). To carry out official checks and controls to prevent the issuance of false or misleading certification (Article 5 of Council Directive 96/93/EEC on the certification of animals and animal products). To inform the European Commission of cases of disease outbreaks, of the general animal health status and of any proposed changes to national sanitary rules (in particular for imports of equidae) in accordance with Article 12, 2 (f) of Council Directive 90/426/EEC on animal health conditions governing the movement and import from third countries of equidae. The competent authority's response to the recommendations can be found at: http://ec.europa.eu/food/fvo/ap/ap_eg_2010-8427.pdf 13
ANNEX 1 - LEGAL REFERENCES Legal Reference Official Journal Title Dir. 90/426/EEC OJ L 224, 18.8.1990, p. 42-54 Council Directive 90/426/EEC of 26 June 1990 on animal health conditions governing the movement and import from third countries of equidae Dir. 92/65/EEC Dir. 94/28/EC Dir. 96/22/EC Dir. 96/23/EC OJ L 268, 14.9.1992, p. 54-72 OJ L 178, 12.7.1994, p. 66-68 OJ L 125, 23.5.1996, p. 3-9 OJ L 125, 23.5.1996, p. 10-32 Council Directive 92/65/EEC of 13 July 1992 laying down animal health requirements governing trade in and imports into the Community of animals, semen, ova and embryos not subject to animal health requirements laid down in specific Community rules referred to in Annex A (I) to Directive 90/425/EEC Council Directive 94/28/EC of 23 June 1994 laying down the principles relating to the zootechnical and genealogical conditions applicable to imports from third countries of animals, their semen, ova and embryos, and amending Directive 77/504/EEC on pure-bred breeding animals of the bovine species Council Directive 96/22/EC of 29 April 1996 concerning the prohibition on the use in stockfarming of certain substances having a hormonal or thyrostatic action and of ß-agonists, and repealing Directives 81/602/EEC, 88/146/EEC and 88/299/EEC Council Directive 96/23/EC of 29 April 1996 on measures to monitor certain substances and residues thereof in live animals and animal products and repealing Directives 85/358/EEC and 86/469/EEC and Decisions 89/187/EEC and 91/664/EEC Reg. 504/2008 OJ L 149, 7.6.2008, p. 3-32 Commission Regulation (EC) No 504/2008 of 6 June 2008 implementing Council Directives 90/426/EEC and 90/427/EEC as regards methods for the identification of equidae Reg. 882/2004 OJ L 165, 30.4.2004, p. 1, Corrected and re-published in OJ L 191, 28.5.2004, p. 1 Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls performed to ensure the verification of compliance with feed and food law, 14
Legal Reference Official Journal Title animal health and animal welfare rules Dec. 92/260/EEC OJ L 130, 15.5.1992, p. 67-83 92/260/EEC: Commission Decision of 10 April 1992 on animal health conditions and veterinary certification for temporary admission of registered horses Dec. 93/195/EEC OJ L 86, 6.4.1993, p. 1-6 93/195/EEC: Commission Decision of 2 February 1993 on animal health conditions and veterinary certification for the re-entry of registered horses for racing, competition and cultural events after temporary export Dec. 93/197/EEC OJ L 86, 6.4.1993, p. 16-34 93/197/EEC: Commission Decision of 5 February 1993 on animal health conditions and veterinary certification for imports of registered equidae and equidae for breeding and production Dec. 2004/211/EC Dec. 2004/616/EC Dec. 96/510/EC OJ L 73, 11.3.2004, p. 1-10 OJ L 278, 27.8.2004, p. 64-74 OJ L 210, 20.8.1996, p. 53-67 2004/211/EC: Commission Decision of 6 January 2004 establishing the list of third countries and parts of territory thereof from which Member States authorise imports of live equidae and semen, ova and embryos of the equine species, and amending Decisions 93/195/EEC and 94/63/EC 2004/616/EC: Commission Decision of 26 July 2004 establishing the list of approved semen collection centres for imports of equine semen from third countries 96/510/EC: Commission Decision of 18 July 1996 laying down the pedigree and zootechnical certificates for the importation of breeding animals, their semen, ova and embryos Dec. 96/539/EC OJ L 230, 11.9.1996, p. 23-27 96/539/EC: Commission Decision of 4 September 1996 on animal health requirements and veterinary certification for imports into the Community of semen of the equine species 15