The Scottish Government

DRAFT

REGULATORY IMPACT ASSESSMENT (PARTIAL) on a Veterinary Surveillance Strategy for the United Kingdom

1. Purpose and intended effect

(i) The Objective

The purposes of veterinary surveillance are

• to provide a highly sensitive and effective means of identifying, analysing and tracking animal related risks
• enable prompt and effective management so as to minimise as far as possible the probability of adverse effects on public health, food safety, trade in animals and animal products, animal health and welfare and the financial consequences of a major issue.

The scope of the veterinary surveillance strategy includes farmed, companion and wild animal populations as well as associated environmental and food safety factors which may affect or be affected by them. The strategy will build on the strengths and address the weaknesses of the current approach to veterinary surveillance. It will link to public health and food safety surveillance, and deliver better integration with research. It is not intended in itself to require the introduction of new regulatory burdens on business. Although no specific new regulatory burdens are intended at this stage, as the strategy develops a need for new powers may become apparent. These would be the subject of a separate RIA at that time.

(ii) The Background

In 1999, a review of the veterinary surveillance system was carried out by officials (Meah & Lewis (2000)). That report, which dealt mainly with the situation in England and Wales with brief references to Scotland and Northern Ireland, recognised the importance of veterinary surveillance and made a number of recommendations for improving its delivery. The report was issued for consultation and the responses received showed broad agreement with the objectives for veterinary surveillance. These are reflected in the proposed strategy. There was agreement that prioritisation could be based on risk and impact analyses, using health, welfare and monetary indicators, although the system needed to be flexible.

A Project Board including representatives of the Devolved Administrations, the FSA and independent members was set up to oversee the development of a veterinary surveillance strategy for the United Kingdom. This was unavoidably delayed by the outbreak of Swine Fever in 2000 and Foot and Mouth Disease in 2001. Since then, the draft strategy has been developed through a series of stakeholder discussions, including four large workshops in October 2002 to test and discuss the proposed strategic goals.

These goals are:

• to strengthen collaborations between the providers, users and beneficiaries of veterinary surveillance,
• to develop a transparent and open prioritisation process,
• to derive better value from surveillance information and activities,
• to share information more widely, and
• to enhance the quality assurance of outputs.

(iii) Risk assessment

Animal health problems have seriously harmed the livestock industry over the last decade. Food scares have undermined public confidence in the industry and the food that it produces. Major disease outbreaks have damaged the wider rural economy, with particular effect on tourism.

Veterinary surveillance should

• enable prompt recognition and appropriate response to disease outbreaks
• enable the effectiveness of control measures for diseases or infections to be assessed
• enable the early recognition of important trends to inform risk management policies

• enable the identification of new potential hazards
• fulfil our international disease reporting obligations
• enable us to confirm freedom from diseases for certification for international trade

Farmers, vets, and others in the livestock industry have important roles in surveillance and there is a need to work with the industry and the veterinary profession to explore how private veterinary surgeons can most effectively contribute.

The Veterinary Surveillance Strategy will identify laboratories that have a key role to play in diseases of national importance. The strategy will define the critical linkages required to laboratory service providers such as the Veterinary Laboratories Agency (VLA), Veterinary Sciences Division (VSD) laboratories in Northern Ireland, Institute for Animal Health (IAH) and the Scottish Agriculture College (SAC).

The Veterinary Surveillance Strategy will improve the coverage and integration of animal disease data by making links with data from other sources within Government and beyond including geographical information data. This will enable information about animal disease to be set in the context of the numbers and location of susceptible livestock. Animal populations at particular risk can then be identified and targeted for appropriate prevention and control measures.

(iv) Business sectors affected

Directly

The availability of information from veterinary surveillance is an essential requirement in meeting government's aim to protect public health and to ensure high standards of animal health and welfare.

The Strategy will have an impact on the livestock farming industry, the veterinary profession, and the food distribution chain. Both the State Veterinary Service and private veterinary surgeons will have a major part to play in the Strategy and its implementation, together with the related academic community.

Indirectly

More widely the Strategy will ensure that surveillance data produced are quality assured and can be relied upon. This will lead to more robust data being available for research, modelling etc, and hence improve the quality of the research outputs. It will further ensure that appropriate research is commissioned to meet priorities identified by the strategy.

(v) Issues of equity and fairness

The Strategy will not, in itself, impose specific changes in the way that data are collected or used. However, it is intended to identify gaps and duplications in the existing data, and thus identify a need to collect data in new or changed ways. It is also intended that both existing and new data should be analysed in ways which improve the information obtained from them. Benefits should then accrue to all stakeholder groups. These benefits should arise if the strategic goals are achieved.

One group who may be concerned at the prospect of data sharing is the academic community who will wish to own and publish their data to ensure academic recognition. Livestock producers may also be concerned if samples taken for one purpose are used for another. During consultation we wish to explore how these and other issues might be addressed so as to ensure that we achieve greater access to surveillance data.

Options

As explained in section 1(i) of this assessment, the Strategy will not have an immediate statutory impact or require new regulations to implement it. Once the framework has been agreed it will need to be developed to encompass statutory measures in force (for existing EU and international surveillance requirements) and for additional national surveillance requirements. Future measures and programmes of work will then be developed within this framework. Effectively we only have two choices.

Option 1: Do nothing and continue to work with a lack of strategic direction and without a structured mechanism for involving stakeholders.

Option 2: Develop and implement a strategy in partnership with industry and wider stakeholders which integrates and guides the development of enhanced veterinary surveillance work.

Benefits

Direct benefits of the Strategy will be difficult to measure.

Option 1: Do nothing

Government will face criticism if the clear recommendations on surveillance made by the independent inquiries into the foot and mouth disease epidemic in 2001 (Anderson, Royal Society, in Scotland the Royal Society of Edinburgh and in Northern Ireland Price Waterhouse Coopers) are ignored. Early discussions with stakeholders, including representatives of all key groups, have welcomed the proposed strategic approach to the collection of veterinary surveillance information.

Developing a strategy will, however, need significant resource and arouse the expectation of a commitment to increased expenditure on improved surveillance.

Option 2: Develop a strategy in partnership with stakeholders

By developing the strategy in partnership with stakeholders it should be possible to achieve greater commitment, understanding, and benefits to all participants, including better value for money for all stakeholders from the public funds which go into existing surveillance.

The approach would also benefit from a more aware industry. It would be hoped that the enhanced early warning system would lead to a reduction in the incidence of animal diseases and reduced public health risks by permitting improved disease prevention and disease control. This would increase consumer confidence and the benefit would be a stronger domestic and export market, as well as a significant reduction in the cost to the taxpayer in Government control and treatment of animal diseases. A reduction in the incidence of animal disease would also lessen the impact on the wider rural communities, the local environment and the costs to rural businesses.

Costs

Veterinary surveillance already takes place throughout the UK. The proposed strategy will help define priorities within existing expenditure and prioritise existing surveillance projects against new surveillance needs or budgetary constraints, so that decisions on maintaining, increasing or cutting expenditure may be made in a rational and transparent manner.

It is difficult to associate direct costs with the draft strategy, as these will be for measures agreed within the framework rather than the adoption of the Strategy itself.

Option 1: Do nothing

Risk of significant cost from new hazards not being identified in time, duplication of effort or surveillance expenditure which does not deliver useful information.

Option 2: Develop a partnership with industry and wider stakeholders

The introduction of a veterinary surveillance strategy will not, in itself, lead to additional costs. What it will provide is greater transparency of the rationale and basis for veterinary surveillance adopted as part of the strategy.

If approved, implementation costs would include the provision of the RADAR database which is proposed in the Strategy. This will be subject to a scoping study and business case to ensure this is the most cost effective way of achieving the greater integration of data.

Impact on Small Businesses

It is not envisaged that the surveillance strategy will have direct costs on small businesses. We will however work with the Small Business Service to identify a suitable test panel and take forward a more thorough assessment in this area.

Competition assessment

Enforcement and sanctions

The introduction of a strategy will have no direct legislative impact on farmers and stakeholders so the question of enforcement and sanctions do not arise. The veterinary surveillance needs of the strategy may require review of powers under animal health legislation to take samples for surveillance purposes and to allow sharing of data across animal health functions.

Monitoring and review

The Strategy Programme Board and stakeholder and expert advisory groups will carry out the monitoring and review of the Strategy based on the proposed draft framework. The Strategy will be a live document that will need to be annually reviewed and updated in response to the ever-changing risks to public health and of animal diseases.

Consultation

Stakeholders will be engaged throughout the development of the Strategy and its delivery.

i) Within Government

Defra DoH DTI

Scottish Executive DCMS ODPM

NAWARD CO LACORS

DARD No. 10 HSE

FSA HMT GO's

ii) Public consultation

Initial informal discussion with key stakeholder groups, together with a series of stakeholder workshops, have already been undertaken. The issues raised in these meetings have been used to inform the draft Strategy. Public consultation on this draft framework will take place from December 2002. The Strategy will then be refined and published in Spring 2003.

Timing

A provisional delivery plan is outlined in a table in the draft strategy document at paragraph 9.4. Milestones have been set for five strategic goals: collaboration; prioritisation; better value; sharing of information and quality assurance, on a 1, 2, 5 and 10 year basis. The milestones become progressively more tentative in the later years and will be dependent on the results of the initial RADAR scoping study and the availability of necessary resources.

Summary and recommendation

To do nothing would not impose any additional costs on stakeholders, however the current situation is unsustainable. At present veterinary surveillance is poorly co-ordinated and has no mechanism to prioritise conflicting needs, leading to gaps and duplication in the available information, and to the waste of resources. The main FMD Inquiries have recommended enhanced surveillance involving a wide range of stakeholders. The availability of improved veterinary surveillance information is a essential requirement to provide a highly sensitive and effective means of identifying, analysing and tracking animal related risks and manage these promptly and effectively so as to minimise as far as possible the probability of adverse effects on public health, food safety, trade in animals and animal products, animal health and welfare and the financial consequences of a major issue.

Declaration

[To be completed when the full assessment is carried out.]