National OJD Management Purpose of this Paper Sheepmeat Council of Australia (SCA) and WoolProducers Australia (WPA) are committed to developing the most effective national management plan for Ovine Johnes Disease (OJD). This is a discussion paper developed by the two peak bodies which proposes new amendments to the National OJD Management Plan and addresses the key areas of producer concern around current and proposed arrangements. The National OJD Management Plan is proposed to take effect from 1 July 2013. The proposal outlined below has been revised from the plan circulated in 2012. The amendments are the result of extensive consultation over the last six months with industry, state and national regulatory authorities and state governments. The proposed amendments include: A simpler management system that relies on producers and industry (including agents) taking a risk management approach to management of OJD. Encouragement for producers to collectively develop their own Regional Biosecurity Plans (RBPs). No control or protected areas. These have now become untenable because of the lack of any formal approval process for RBPs by government at the state level. Continuation of Sheep Health Statements but the removal of the ABC point scheme. SCA and WPA are inviting producers to consider the amendments and respond to the points raised in this discussion paper. Comments will be received up until close of business 1 March 2013. A final policy paper will then be developed and communicated to the industry for implementation from 1 July 2013. 1 Background Ovine Johne’s disease (OJD) has become endemic in some sheep production areas of Australia but in other areas the disease does not exist or exists at a very low level. The OJD Management Plan (2007-12) – the current plan – was to cease in 2012. SCA and WPA conducted a review and consultation process throughout 2011-12 to evaluate the plan and make a decision on future national management arrangements. The review identified that some regions of Australia have been effective in delaying the spread of the disease between flocks and / or in reducing within flock prevalence. However, in other regions, the plan had failed to meet the objective of minimising the risk to properties and areas that appeared to be disease-free, as OJD has continued to spread into a number of previously low prevalence areas. This meant that some change was necessary – it was not appropriate for the current plan to continue. Through an extensive process a revised plan was developed. A key part of this was working with state governments to develop Australia-wide uniform entry requirements and resolve various technical issues about the disease. Throughout the entire process SCA and WPA worked hard to achieve a compromise in balancing the widely divergent and differing needs of producers across the nation – from those where the disease was endemic to those areas where the disease has yet to be observed. Some issues were easy and received wide support. There was clear agreement that there should be a national program and that research and development should continue to be funded. Other activities were seen as important but had constraints in the way they were currently undertaken, including abattoir monitoring and the use of the Sheep Health Statement and the ABC system. It was proposed the ABC system be removed as producer feedback indicated it was confusing and not well understood, and therefore ineffective. In late 2012 it became clear that there continued to be confusion and conjecture about the benefits of the revised national plan. In light of this it was decided to extend the transition phase to 1 July 2013 so that this could be addressed. SCA and WPA are now seeking comment on the things that might need to change in order to unite industry. 2 Proposed Management Plan from 1 July 2013 SCA and WPA remain committed to delivering a national management plan and to provide funding for a number of elements which will assist producers manage biosecurity and OJD. The 2013-2017 national plan – the revised plan – will have the following objectives: 1. Minimise the risk of infection by Mycobacterium paratuberculosis (Mptb) OJD spreading to properties and regions that currently appear disease free 2. Reduce the financial impact and adverse animal health and welfare effects of the disease on individual flocks, and on the sheep industry as a whole. Under the revised plan, funding will be provided for: 1. Extension/communication activities to provide producers with information about biosecurity and management of OJD. 2. Developing and refining risk assessment tools, such as the national Sheep Health Statement (SHS) to assist producers make informed decisions when trading sheep. 3. Developing an effective abattoir program as a tool for monitoring individual flock OJD control programs and for use as an assurance tool in low-risk flocks. The intention is that this be eventually moved into a generic animal health and production feedback system. 4. Ongoing research and development to help producers minimise the impact of OJD on their businesses. 5. Contributing to the cross-species National Johne’s Disease Control Plan, including SheepMAP The revised plan will continue to encourage vaccination and a regional approach to OJD. Vaccination is the best tool we have for reducing the clinical expression of the disease and for significantly reducing the level of shedding by infected sheep. In one long term trial involving twelve flocks, shedding was not detected in two flocks at their last sampling. A regional approach to biosecurity is more effective than an individual approach and hence producers will be encouraged to address OJD, and all animal health issues, through a regional biosecurity approach. Vaccination and a regional approach will not be provided with financial support by the revised plan. Both result in primarily private good outcomes, and socialised funding is not justified. The ABC Scheme will no longer be a part of the national plan. Whilst it provided a simplified measure of the level of risk through a numerical point score, it was not well understood by most producers. Producers did not appreciate the need to supplement the Scheme with their own assessment of risk, especially on the vaccination history of sheep. 3 The national approach will increase efforts to provide producers with information on the different levels of risk associated with the vaccination history of the property from which sheep originate. Zoning The plan SCA and WPA put forward late last year provided for the development of Regional Biosecurity Plans (RBP). This was for groups of producers in areas where the prevalence of the disease was low and who wanted to minimise the risk of entry or further spread of OJD. Meeting certain criteria, as evidenced in the RBP, could have allowed the geographic area covered by the plan to gain ‘protected’ area status. If an area was not covered by a RBP then it would have, by default, been a ‘control’ area. The review of the OJD Management Plan conducted in 2011-12 highlighted that inconsistent entry requirements across Australia were detrimental to trade and played a role in noncompliance with state trading regulations. In developing the revised plan during 2012, SCA and WPA had a fundamental desire to gain uniform entry requirements so that ‘protected’ areas could have been able to trade between each other with minimum impediments. The national OJD plan has been underpinned by state laws and regulations, including enforcement of interstate (or inter-area) entry requirements. This is because the states have the responsibility for domestic animal health issues. Government representatives have indicated that they do not have a role in the approval process of RBPs. SCA and WPA do not consider that they have a mandate to ‘approve’ plans. Therefore without a formal approval process and without state regulation, compliance with protected area conditions cannot be enforced. This means that zoning, that is ‘protected’ and ‘control’ areas, would no longer exist with legal status. However, the concept of RBPs remains sound in providing producers with a mechanism for joint action to address OJD (and other animal health issues). Regions which have developed an RBP may wish to claim a certain status, although this may not have any legal affect in states where there is no regulatory support. Industry needs to further consider whether or not there should be formal recognition for regions that implement an RBP, and who would be the appropriate body to do this. It is anticipated that producers in some regions will want to actively manage the disease and continue to have a plan or program in their region or state. Regional Biosecurity Plans will outline how groups of producers will be able to detect, control and manage the disease with the aim of minimising the spread of OJD. Further, by actively managing disease risk, producers will need to negotiate trading opportunities with those states and regions with biosecurity plans in place. 4 Non-financial support will be provided for groups of producers who wish to implement regional biosecurity plans to minimise the risk of introduction of OJD and other diseases. This could include technical assistance through the OJD Management Committee (OJDMC). Like previous plans producers will need to manage their own risk and tools will be provided for this including SHS, RBP guidelines and business rules and advice. There is a potential of regions having inconsistent entry requirements, which will require negotiations to ensure a national sheep health statement is available. Addressing industry concerns Over recent months SCA and WPA have been talking with and listening to stakeholders and are aware there are a range of issues producers are concerned about. SCA and WPA have taken these concerns on board and believe the amended management plan presents the most effective approach to minimise the spread of OJD. The concerns and responses of SCA and WPA are summarised below. Industry concerns SCA and WPA response Industry should maintain the status quo Some regions of Australia have been effective in delaying the spread of the disease between flocks and / or in reducing within flock prevalence. However, in other regions, the current system failed to meet its objective of minimising the risk to properties and regions that appeared to be disease-free, as OJD has continued to spread into a number of previously low prevalence areas. This means that some change is necessary. Vaccination alone should be sufficient to allow trade of sheep anywhere in Australia. Scientific evidence suggests that vaccinated sheep may continue to shed OJD bacteria; however vaccination is an important tool against OJD and significantly reduces the impacts of clinical disease. The movement of vaccinated sheep from regions where OJD is present into regions of nil or low disease, presents a risk of disease spread. The national approach will increase efforts to provide producers with information on the different levels of risk associated with the vaccination history of the property from which sheep originate, and on ways to increase the assurance that sheep are not infected, for example by testing. State governments and individual landholders will then be able to determine acceptable entry requirements. Industry should get rid of From 1 July 2013 it is proposed that zones no longer exist. Some 5 zoning. states and individual properties can continue to implement movement restrictions based upon their assessments of acceptable risk. Biosecurity is an effective tool in managing the risk of animal health diseases. The National plan will encourage individual producers and groups of producers to implement biosecurity plans to minimise the risk of diseases entering their region or property. The National plan cannot remove the individual’s rights to make business decisions. Industry should remove all controls for OJD and allow complete deregulation. As a result of the majority of state governments deciding not to be involved in the approval process for RBPs, the management of OJD has effectively been deregulated. Individual producers and RBP areas will be supported by industry in managing their own risk and in making informed decisions when trading sheep. Industry should retain the ABC scheme. The ABC Scheme was poorly understood, misused and an ineffective tool. Whilst it provided a simplified measure of the level of risk through a numerical point score, producers did not appreciate the need to supplement the Scheme with their own assessment of risk especially on the vaccination history of sheep. As a result it has been decided to rely on Sheep Health Statements to inform sound trading decisions. The emphasis on collective producer action through regional biosecurity plans will also assist in minimising the spread of OJD. Accuracy of Pooled Faecal Culture of 350 sheep (PFC350). The estimated sensitivity (ability to detect infection) of PFC for a single infected animal is about 50-55%. This is why PFC is used as a flock test only and is not used to screen individual animals. For a PFC of 350 sheep from a flock, there is a 98% confidence of detecting infection if it is present in the flock at a prevalence of 2% or more. Used in this way, it is a highly effective test for flock screening. Accuracy of abattoir monitoring. Abattoir testing is excellent for monitoring individual flock OJD control programs and for use as an assurance tool in low risk flocks. The estimated sensitivity for abattoir monitoring increases with the number of animal tested. This is why abattoir monitoring is used as a flock test and to determine estimated prevalence of OJD in regions. For example an abattoir test of 150 sheep (Ab150 test) with a sensitivity of 50% has a confidence level of 78% and is 6 a useful tool for providing assurance for low risk flocks. Ab350 provides >95% confidence level of detecting prevalence of 2% within a flock. Ab500 provides equivalent sensitivity as a PFC350 (i.e. 98% confidence of detecting infection if the flock has a prevalence of 2%). Opportunity for Industry Comment Over the next four weeks, SCA and WPA will be meeting with producer and industry groups to further explain how the proposed amendments would operate. Those organisations or producers wishing to make a formal submission for consideration by SCA and WPA as part of the policy discussion are invited to do so in writing. Alternatively please contact your State farming organisation, producer group or breed society. These comments should be submitted by mail to PO Box 942 Broadway NSW 2007 or by email to [email protected] Copies of this discussion paper can be requested by calling 1800 332 312. All comments should be received by COB 1 March 2013. This discussion paper is available on the WPA website www.woolproducers.com.au as well as www.ojd.com.au. 7
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