24 March 2018 | Online since 2003

1 December 2017

Chief Executive's Comment - December 2017

At this point in time the NHS and Defra have one thing in common– both Government Departments are now preparing policy scenarios for winter flu viruses; and we are doing our bit to lobby Defra/APHA as to how they should deal with the avian versions.
Lobbying over the summer in Brussels to amend the EU egg marketing regulations has paid off in that we expect that EU legislation will be adopted which extends the free range marketing status derogation from 12 weeks to 16 weeks. And that 16 weeks will start when the pullets are placed in the shed rather than when the announcement is made by the UK countries’ Chief Veterinary Officers (CVOs). This will be a small but significant step forward when it is confirmed at the beginning of next month.
We now need to influence Defra and the devolved Agriculture Departments in how they interpret and execute the EU regulations, and the global rules under the World Organisation for Animal Health (the OIE  - Office International des Epizooties) .
The policy decisions that we need to influence in Defra and the devolved administrations, assuming an HPAI epidemic like last year, are:
  1. The requirements of a housing order (and the biosecurity requirements within an AI Prevention Zone - AIPZ)
  2. The start and finish dates of a housing order
  3. The geography of housing order, including the differentiated approach of Higher Risk Areas in England
  4. The pack labelling and egg marking of eggs from ‘free range’ hens after 16 weeks of enforced housing
  5. The treatment of backyard flock outbreaks so as to remove the restricted zones which impact the commercial poultry sector
  6. The surveillance and enforcement of AIPZ legislation for backyard flock keepers
Comments so far this autumn from the four CVOs in the UK suggest that there their HPAI policies will not differ markedly from last year, assuming a similar type of HPAI pressure. That is to say that the three devolved countries in the UK will do all they can to keep any housing order with the derogated period allowed for in the EU egg marketing regulations (hopefully 16 weeks) and would not differentiate between Higher Risk Areas (HRAs) and other areas. They would focus more on biosecurity requirements, rather than housing orders, and thus would not need to get involved in issues over pack labelling and egg marking for eggs from free range hens that had been housed for more than the derogated (16 week) period.
I will confine my comments from now on to England because it is fair to say that the devolved administrations in Wales, Scotland and N Ireland are a little more sympathetic to the commercial aspects of agricultural production. Our greatest issues are with England, so producers in the other UK countries sit back, turn over the page and read other, more interesting, stories in this mag.
Nigel Gibbens, the CVO for the UK and England, will to take a far more robust approach to HPAI than the devolved CVOs, knowing that if there is any challenge from the EU over the UK’s interpretation of the EU’s Regulations, it will fall on his desk rather than on the other 3 devolved CVOs. He also knows that any fine made by Brussels for infringements of the EU legislation will be sent to the UK Treasury, rather than the devolved equivalents. And the worst crime that any UK Government Department can do, according to the Treasury, is to lose money via EU fines, hence why the UK constantly gold plates its interpretation of EU legislation.
To be fair, England also had the greatest amount of HPAI outbreaks last year, so the CVO can argue that given the same circumstances as last year, he is justified in taking a more robust approach than the other UK countries. However there are indications from his comments at meetings and conferences that he is thinking of modifying last year’s policy this year in one or two respects.
Firstly, he has suggested that he may start with a regional approach via HRAs, rather than start with a national housing order. You may remember that last year, as HPAI approached from the continent, the CVO slapped a 30-day national housing order on 6 December before we had an outbreak and this was extended a month later after the first outbreak. HRA’s only appeared in Defra speak as the 12-week period for the free range egg marketing approached in February and was then applied from early March onwards.  
This year the CVO is hinting that he may reverse that approach and apply HRAs first with a greater regional or national housing order applying later. To add further complexity, he has also suggested that an AI Prevention Zone requiring enhanced biosecurity, as we saw in the devolved countries from March last year, may be the first port of call before any form of housing, including HRAs, is implemented.
The Government, via the CVO, seems wedded to the principle of HRAs. There seems to be two reasons for this: firstly it is part of the strategy that Member States must consider under EU legislation; and secondly Defra believes that it is securing the future of the free range sector by restricting housing to a small proportion (approx. 20%) of the national flock.
I believe there are better ways of protecting the free range sector. BFREPA remains opposed to HRAs as it is divisive within the industry and there is no evidence that it proved effective last year. This was largely due to the policy being ignored by backyard flock keepers and not enforced, and secondly most outbreaks that occurred after HRAs were introduced occurred outside of the HRAs.
Housing must remain a tool in the kit box to protect ourselves from HPAI but it must be:
  • enforced equally across both the commercial and hobby sectors,
  • applied when the risk assessments are at the highest threat of infection
  • covered by a free-range egg marketing derogation lasting 20 weeks
  • given labelling and egg marking solutions that provide consumers with adequate explanation of the ‘temporary housing’ aspect
  • implemented consistently across devolved UK countries given similar risk assessments
  • employed on an ‘all in’ and ‘all out’ basis
Let’s hope that HPAI does not affect us as badly this year. The long-term weather forecast is optimistic with above average temperatures in Europe driving less migratory waterfowl to our shores.
Cross fingers.