Terrestrial animal Health Standards Commission Report



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Terrestrial animal Health Standards Commission Report

September 2009

Chapter 3.2.

Evaluation of
Veterinary Services

Article 3.2.1.



General considerations

1. Evaluation of Veterinary Services is an important element in the risk analysis process which countries may legitimately use in their policy formulations directly applying to animal health and sanitary controls of international trade in animals, animal-derived products, animal genetic material and animal feedstuffs.

Any evaluation should be carried out with due regard for Chapter 3.1.

2. In order to ensure that objectivity is maximised in the evaluation process, it is essential for some standards of discipline to be applied. The OIE has developed these recommendations which can be practically applied to the evaluation of Veterinary Services. These are relevant for evaluation of the Veterinary Services of one country by those of another country for the purposes of risk analysis in international trade. The recommendations are also applicable for evaluation by a country of its own Veterinary Services – the process known as self-evaluation – and for periodic re-evaluation. These recommendations should be used by OIE experts when facilitating an evaluation under the auspices of the OIE, following a request of a Member. In applying these recommendations on the evaluation, the OIE Tool for the Evaluation of Performance of Veterinary Services (OIE PVS Tool) should be used.

In carrying out a risk analysis prior to deciding the sanitary/zoosanitary conditions for the importation of a commodity, an importing country is justified in regarding its evaluation of the Veterinary Services of the exporting country as critical.

3. The purpose of evaluation may be either to assist a national authority in the decision-making process regarding priorities to be given to its own Veterinary Services (self-evaluation) or to assist the process of risk analysis in international trade in animals and animal-derived products to which official sanitary and/or zoosanitary controls apply.

4. In both situations, the evaluation should demonstrate that the Veterinary Services have the capability for effective control of the sanitary and zoosanitary status of animals and animal products. Key elements to be covered in this process include resource adequacy of resources, management capability, legislative and administrative infrastructures, independence in the exercise of official functions and history of performance history, including disease reporting.

5. Good governance is the key to cCompetence, and integrity and are qualities on which others base their confidence in individuals or organisations. Mutual confidence between relevant official Veterinary Services of trading partner countries contributes fundamentally to stability in international trade in animals and animal-related products. In this situation, scrutiny is directed more at the exporting country than at the importing country.

6. Although quantitative data can be provided on Veterinary Services, the ultimate evaluation will be essentially qualitative. While it is appropriate to evaluate resources and infrastructure (organisational, administrative and legislative), it is also appropriate to place emphasis on the evaluation of the quality of outputs and performance of Veterinary Services. Evaluation should take into consideration any quality systems used by Veterinary Services.

7. An importing country has a right of assurance that information on sanitary/zoosanitary situations provided by the Veterinary Services of an exporting country is objective, meaningful and correct. Furthermore, the Veterinary Services of the importing country are entitled to expect validity in the veterinary certification of export.

8. An exporting country is entitled to expect that its animals and animal products will receive reasonable and valid treatment when they are subjected to import inspection in the country of destination. The country should also be able to expect that any evaluation of its standards and performance will be conducted on a non-discriminatory basis. The importing country should be prepared and able to defend any position which it takes as a consequence of the evaluation.

9. As the veterinary statutory body is not a part of the Veterinary Services, an evaluation of that body should be carried out to ensure that the registration/licensing of veterinarians and authorisation of veterinary para-professionals is included.

Article 3.2.2.

Scope

1. In the evaluation of Veterinary Services, the following items may be considered, depending on the purpose of the evaluation:

o organisation, structure and authority of the Veterinary Services;

o human resources;

o material (including financial) resources;

o veterinary legislation and functional capabilities and legislative support;

o animal health and veterinary public health controls;

o formal quality systems including quality policy;

o performance assessment and audit programmes;

o participation in OIE activities and compliance with OIE Members’ obligations.

2. To complement the evaluation of Veterinary Services, the legislative framework, organisational structure and functioning of the veterinary statutory body should also be considered.

3. Article 3.2.14. outlines appropriate information requirements for:

o self-evaluation by the Veterinary Authority which perceives a need to prepare information for national or international purposes;

o evaluation by a prospective or actual importing country of the Veterinary Services of a prospective or actual exporting country;

o verification or re-verification of an evaluation in the course of a visit to the exporting country by the importing country;

o evaluation by third parties such as OIE PVS experts or regional organisations.

Article 3.2.3.

Evaluation criteria for the organisational structure of the Veterinary Services

1. A key element in the evaluation is the study of the organisation and structure of the official Veterinary Services. The Veterinary Services should define and set out their policy, objectives and commitment to quality systems and standards. These organisational and policy statements should be described in detail. Organisational charts and details of functional responsibilities of staff should be available for evaluation. The role and responsibility of the Chief Veterinary Officer/Veterinary Director should be clearly defined. Lines of command should also be described.

2. The organisational structure should also clearly set out the interface relationships of government Ministers and departmental Authorities with the Chief Veterinary Officer/Veterinary Director and the Veterinary Services. Formal relationships with statutory authorities and with industry organisations and associations should also be described. It is recognised that Services may be subject to changes in structure from time to time. Major changes should be notified to trading partners so that the effects of re-structuring may be assessed.

3. Organisational components of Veterinary Services which have responsibility for key functional capabilities should be identified. These capabilities include epidemiological surveillance, disease control, import controls, animal disease reporting systems, animal identification systems, traceability systems, animal movement control systems, communication of epidemiological information, training, inspection and certification. Laboratory and field systems and their organisational relationships should be described.

4. To reinforce the reliability and credibility of their services, the Veterinary Services may have set up quality systems that correspond with their fields of activity and to the nature and scale of activities that they carry out. Evaluation of such systems should be as objective as possible.

5. The Veterinary Authority alone speaks for the country as far as official international dialogue is concerned. This is also particularly important to cases where zoning and compartmentalisation are being applied. The responsibilities of the Veterinary Authority should be made clear in the process of evaluation of Veterinary Services.

6. The Veterinary Authority is defined in the Glossary of the Terrestrial Code. As some countries have some relevant roles of the Veterinary Authority vested in autonomous sub-national (state/provincial, municipal) government bodies, there is an important need to assess the role and function of these Services. Details of their roles, relationship (legal and administrative) to each other and to the Veterinary Authority should be available for evaluation. Annual reports, review findings and access to other information pertinent to the animal health activities of such bodies should also be available.

7. Similarly, where the Veterinary Authority has arrangements with other providers of relevant services such as universities, laboratories, information services, etc., these arrangements should also be described. For the purposes of evaluation, it is appropriate to expect that the organisational and functional standards that apply to the Veterinary Authority should also apply to the service providers.

Article 3.2.4.

Evaluation criteria for quality systems

1. The Veterinary Services should demonstrate a commitment to the quality of the processes and outputs of their services. Where services or components of services are delivered under a formal quality systems programme which is based on OIE recommended standards or, especially in the case of laboratory components of Veterinary Services other internationally recognised quality standards, the Veterinary Services undergoing evaluation should make available evidence of accreditation, details of the documented quality processes and documented outcomes of all relevant audits undertaken.

2. Where the Veterinary Services undergoing evaluation make large use of formal quality systems in the delivery of their services, it is appropriate that greater emphasis be placed on the outcomes of evaluation of these quality systems than on the resource and infrastructural components of the services.

Article 3.2.5.



Evaluation criteria for human resources

1. The Veterinary Services should demonstrate that their human resource component includes an integral core of full-time civil service employees. This core must include veterinarians. It should also include administrative officials and veterinary para-professionals. The human resources may also include part-time and private sector veterinarians and veterinary para-professionals. It is essential that all the above categories of personnel be subject to legal disciplinary provisions. Data relating to the resource base of the Veterinary Services undergoing evaluation should be available.

2. In addition to raw quantitative data on this resource base, the functions of the various categories of personnel in the Veterinary Services should be described in detail. This is necessary for analysis and estimation of the appropriateness of the application of qualified skills to the tasks undertaken by the Veterinary Services and may be relevant, for example, to the roles of veterinarians and veterinary para-professionals in field services. In this case, the evaluation should provide assurances that disease monitoring is being conducted by a sufficient number of qualified, experienced field veterinarians who are directly involved in farm visits; there should not be an over-reliance on veterinary para-professionals for this task.

3. Analysis of these data can be used to estimate the potential of the Veterinary Services to have reliable knowledge of the state of animal health in the country and to support an optimal level of animal disease control programmes. A large population of private veterinarians would not provide the Veterinary Services with an effective epizootiological information base without legislative (e.g. compulsory reporting of notifiable diseases) and administrative (e.g. official animal health surveillance and reporting systems) mechanisms in place.

4. These data should be assessed in close conjunction with the other information described in this chapter. For example, a large field staff (veterinarians and veterinary para-professionals) need fixed, mobile and budgetary resources for animal health activities in the livestock farming territory of the country. If deficiencies are evident, there would be reason to challenge the validity of epizootiological information.

Article 3.2.6.



Evaluation criteria for material resources

1. Financial

Actual yearly budgetary information regarding the Veterinary Services should be available and should include the details set out in the model questionnaire outlined in Article 3.2.14. Information is required on conditions of service for veterinary staff (including salaries and incentives), and should provide a comparison with the private sector and perhaps with other professionals. Information should also be available on non-government sources of revenue available to veterinarians in their official responsibilities.

2. Administrative

a. Accommodation

The Veterinary Services should be accommodated in premises suitable for efficient performance of their functions. The component parts of the Veterinary Services should be located as closely as possible to each other at the central level, and in the regions where they are represented, in order to facilitate efficient internal communication and function.

b. Communications

The Veterinary Services should be able to demonstrate that they have reliable access to effective communications systems, especially for animal health surveillance and control programmes. Inadequate communications systems within the field services components of these programmes or between outlying offices and headquarters, or between the Veterinary Services and other relevant administrative and professional services, signify an inherent weakness in these programmes. Adequate communications systems between laboratories and between field and laboratory components of the Veterinary Services should also be demonstrated.

Examples of types of communications which should be routinely available on an adequate country-wide basis are national postal, freight and telephone networks. Rapid courier services, facsimile and electronic data interchange systems (e.g. e-mail and Internet services) are examples of useful communication services which, if available, can supplement or replace the others. A means for rapid international communication should be available to the Veterinary Authority, to permit reporting of changes in national disease status consistent with OIE recommendations and to allow bilateral contact on urgent matters with counterpart Veterinary Authorities in trading-partner countries.

c. Transport systems

The availability of sufficient reliable transport facilities is essential for the performance of many functions of Veterinary Services. This applies particularly to the field services components of animal health activities (e.g. emergency response visits). Otherwise, the Veterinary Services cannot assure counterpart services in other countries that they are in control of the animal health situation within the country.

Appropriate means of transport are also vital for the satisfactory receipt of samples to be tested at veterinary laboratories, for inspection of imports and exports, and for the performance of animals and animal product inspection in outlying production or processing establishments.

3. Technical

Details available on laboratories should include resources data, programmes under way as well as those recently completed and review reports on the role or functions of the laboratory. Information as described in the model questionnaire should be used in the evaluation of laboratory services.

a. Cold chain for laboratory samples and veterinary medicines

Adequate refrigeration and freezing systems should be available and should be used throughout the country to provide suitable low temperature protection for laboratory samples in transit or awaiting analysis, as well as veterinary medical products (e.g. vaccines) when these are required for use in animal disease control programmes. If these assurances cannot be given, it may be valid to discount many types of test results, as well as the effectiveness of certain disease control programmes and the export inspection system in the country undergoing evaluation.

b. Diagnostic laboratories

Analysis of the laboratory service component of Veterinary Services, which would include official governmental laboratories and other laboratories accredited by the Veterinary Services for specified purposes, is an essential element of the evaluation process. The quality of the veterinary diagnostic laboratories of a country underpins the whole control and certification processes of the zoosanitary/sanitary status of exported animals and animal products, and therefore these laboratories should be subject to rigid quality assurance procedures and should use international quality assurance programmes (wherever available) for standardising test methodologies and testing proficiency. An example is the use of International Standard Sera for standardising reagents.

This emphasis is valid whether one relates it to the actual testing performed on individual export consignments or to the more broad and ongoing testing regimes which are used to determine the animal health and veterinary public health profiles of the country and to support its disease control programmes. For the purposes of evaluation, veterinary diagnostic laboratories include those which are concerned with either animal health or veterinary public health activities. The Veterinary Services must approve and designate these laboratories for such purposes and have them audited regularly.

c. Research

The scope of animal disease and veterinary public health problems in the country concerned, the stages reached in the controls which address those problems and their relative importance can be measured to some degree by analysis of information on government priorities and programmes for research in animal health. This information should be accessible for evaluation purposes.

Article 3.2.7.



Legislation and fFunctional capabilities and legislative support

1. Animal health and veterinary public health

The Veterinary Authority should be able to demonstrate that it has the capacity, supported by appropriate legislation, to exercise control over all animal health matters. These controls should include, where appropriate, compulsory notification of prescribed animal diseases, inspection, movement controls through systems which provide adequate traceability, registration of facilities, quarantine of infected premises/areas, testing, treatment, destruction of infected animals or contaminated materials, controls over the use of veterinary medicines, etc. The scope of the legislative controls should include domestic animals and their reproductive material, animal products, wildlife as it relates to the transmission of diseases to humans and domestic animals, and other products subject to veterinary inspection. Arrangements should exist for co-operation with the Veterinary Authorities of the neighbouring countries for the control of animal diseases in border areas and for establishing linkages to recognise and regulate transboundary activities. Information on the veterinary public health legislation covering the production of products of animal origin for national consumption may be also considered in the evaluation.

2. Export/import inspection

The Veterinary Authority should have appropriate legislation and adequate capabilities to prescribe the methods for control and to exercise systematic control over the import and export processes of animals and animal products in so far as this control relates to sanitary and zoosanitary matters. The evaluation should also involve the consideration of administrative instructions to ensure the enforcement of importing country requirements during the pre-export period.

In the context of production for export of foodstuffs of animal origin, the Veterinary Authority should demonstrate that comprehensive legislative provisions are available for the oversight by the relevant authorities of the hygienic process and to support official inspection systems of these commodities which function to standards consistent with or equivalent to relevant Codex Alimentarius and OIE standards.

Control systems should be in place which permit the exporting Veterinary Authority to approve export premises. The Veterinary Services should also be able to conduct testing and treatment as well as to exercise controls over the movement, handling and storage of exports and to make inspections at any stage of the export process. The product scope of this export legislation should include, inter alia, animals and animal products (including animal semen, ova and embryos), and animal feedstuffs.

The Veterinary Authority should be able to demonstrate that they have adequate capabilities and legislative support for zoosanitary control of imports and transit of animals, animal products and other materials which may introduce animal diseases. This could be necessary to support claims by the Veterinary Services that the animal health status of the country is suitably stable, and that cross-contamination of exports from imports of unknown or less favourable zoosanitary status is unlikely. The same considerations should apply in respect of veterinary control of public health. The Veterinary Services should be able to demonstrate that there is no conflict of interest when certifying veterinarians are performing official duties.

Legislation should also provide the right to deny and/or withdraw official certification. Penalty provisions applying to malpractice on the part of certifying officials should be included.

The Veterinary Services should demonstrate that they are capable of providing accurate and valid certification for exports of animals and animal products, based on Chapters 5.1. and 5.2. of the Terrestrial Code. They should have appropriately organised procedures which ensure that sanitary/animal health certificates are issued by efficient and secure methods. The documentation control system should be able to correlate reliably the certification details with the relevant export consignments and with any inspections to which the consignments were subjected.

Security in the export certification process, including electronic documentation transfer, is important. A system of independent compliance review is desirable, to safeguard against fraud in certification by officials and by private individuals or corporations. The certifying veterinarian should have no conflict of interest in the commercial aspects of the animals or animal product being certified and be independent from the commercial parties.

Article 3.2.8.



Animal health controls

1. Animal health status

An updated assessment of the present animal disease status of a country is an important and necessary procedure. For this undertaking, studies of the OIE publications such as World Animal Health, the Bulletin and Disease Information must be fundamental reference points. The evaluation should consider the recent history of the compliance of the country with its obligations regarding international notification of animal diseases. In the case of an OIE Member, failure to provide the necessary animal health reports consistent with OIE requirements will detract from the overall outcome of the evaluation of the country.

An exporting country should be able to provide further, detailed elaboration of any elements of its animal disease status as reported to the OIE. This additional information will have particular importance in the case of animal diseases which are foreign to or strictly controlled in the importing country or region. The ability of the Veterinary Services to substantiate elements of their animal disease status reports with surveillance data, results of monitoring programmes and details of disease history is highly relevant to the evaluation. In the case of evaluation of the Veterinary Services of an exporting country for international trade purposes, an importing country should be able to demonstrate the reasonableness of its request and expectations in this process.

2. Animal health control

Details of current animal disease control programmes should be considered in the evaluation. These programmes would include epidemiological surveillance, official government-administered or officially-endorsed, industry-administered control or eradication programmes for specific diseases or disease complexes, and animal disease emergency preparedness. Details should include enabling legislation, programme plans for epidemiological surveillance and animal disease emergency responses, quarantine arrangements for infected and exposed animals or herds, compensation provisions for animal owners affected by disease control measures, training programmes, physical and other barriers between the free country or zone and those infected, incidence and prevalence data, resource commitments, interim results and programme review reports.

3. National animal disease reporting systems

The presence of a functional animal disease reporting system which covers all agricultural regions of the country and all veterinary administrative control areas should be demonstrated.

An acceptable variation would be the application of this principle to specific zones of the country. In this case also, the animal disease reporting system should cover each of these zones. Other factors should come to bear on this situation, e.g. the ability to satisfy trading partners that sound animal health controls exist to prevent the introduction of disease or export products from regions of lesser veterinary control.

Article 3.2.9.



Veterinary public health controls

1. Food hygiene

The Veterinary Authority should be able to demonstrate effective responsibility for the veterinary public health programmes relating to the production and processing of animal products. If the Veterinary Authority does not exercise responsibility over these programmes, the evaluation should include a comprehensive review of the role and relationship of the organisations (national, state/provincial, and municipal) which are involved. In such a case, the evaluation should consider whether the Veterinary Authority can provide guarantees of responsibility for an effective control of the sanitary status of animal products throughout the slaughter, processing, transport and storage periods.

2. Zoonoses

Within the structure of Veterinary Services, there should be appropriately qualified personnel whose responsibilities include the monitoring and control of zoonotic diseases and, where appropriate, liaison with medical authorities.

3. Chemical residue testing programmes

Adequacy of controls over chemical residues in exported animals, animal products and feedstuffs should be demonstrated. Statistically-based surveillance and monitoring programmes for environmental and other chemical contaminants in animals, in animal-derived foodstuffs and in animal feedstuffs should be favourably noted. These programmes should be coordinated nationwide. Correlated results should be freely available on request to existing and prospective trading partner countries. Analytical methods and result reporting should be consistent with internationally recognised standards. If official responsibility for these programmes does not rest with the Veterinary Services, there should be appropriate provision to ensure that the results of such programmes are made available to the Veterinary Services for assessment. This process should be consistent with the standards set by the Codex Alimentarius Commission or with alternative requirements set by the importing country where the latter are scientifically justified.

4. Veterinary medicines

It should be acknowledged that primary control over veterinary medicinal products may not rest with the Veterinary Authority in some countries, owing to differences between governments in the division of legislative responsibilities. However, for the purpose of evaluation, the Veterinary Authority should be able to demonstrate the existence of effective controls (including nationwide consistency of application) over the manufacture, importation, export, registration, supply, sale and use of veterinary medicines, biologicals and diagnostic reagents, whatever their origin. The control of veterinary medicines has direct relevance to the areas of animal health and public health.

In the animal health sphere, this has particular application to biological products. Inadequate controls on the registration and use of biological products leave the Veterinary Services open to challenge over the quality of animal disease control programmes and over safeguards against animal disease introduction in imported veterinary biological products.

It is valid, for evaluation purposes, to seek assurances of effective government controls over veterinary medicines in so far as these relate to the public health risks associated with residues of these chemicals in animals and animal-derived foodstuffs. This process should be consistent with the standards set by the Codex Alimentarius Commission or with alternative requirements set by the importing country where the latter are scientifically justified.

5. Integration between animal health controls and veterinary public health

The existence of any organised programme which incorporates a structured system of information feedback from inspection in establishments producing products of animal origin, in particular meat or dairy products, and applies this in animal health control should be favourably noted. Such programmes should be integrated within a national disease surveillance scheme.

Veterinary Services which direct a significant element of their animal health programmes specifically towards minimising microbial and chemical contamination of animal-derived products in the human food chain should receive favourable recognition in the evaluation. There should be evident linkage between these programmes and the official control of veterinary medicines and relevant agricultural chemicals.

Article 3.2.10.



Performance assessment and audit programmes

1. Strategic plans

The objectives and priorities of the Veterinary Services can be well evaluated if there is a published official strategic plan which is regularly updated. Understanding of functional activities is enhanced if an operational plan is maintained within the context of the strategic plan. The strategic and operational plans, if these exist, should be included in the evaluation.

Veterinary Services which use strategic and operational plans may be better able to demonstrate effective management than countries without such plans.

2. Performance assessment

If a strategic plan is used, it is desirable to have a process which allows the organisation to assess its own performance against its objectives. Performance indicators and the outcomes of any review to measure achievements against pre-determined performance indicators should be available for evaluation. The results should be considered in the evaluation process.

3. Compliance

Matters which can compromise compliance and adversely affect a favourable evaluation include instances of inaccurate or misleading official certification, evidence of fraud, corruption, or interference by higher political levels in international veterinary certification, and lack of resources and poor infrastructure.

It is desirable that the Veterinary Services contain (or have a formal linkage with) an independent internal unit/section/commission the function of which is to critically scrutinise their operations. The aim of this unit should be to ensure consistent and high integrity in the work of the individual officials in the Veterinary Services and of the corporate body itself. The existence of such a body can be important to the establishment of international confidence in the Veterinary Services.

An important feature when demonstrating the integrity of the Veterinary Services is their ability to take corrective action when miscertification, fraud or corruption has occurred.

A supplementary or an alternative process for setting performance standards and application of monitoring and audit is the implementation of formal quality systems to some or all activities for which the Veterinary Services are responsible. Formal accreditation to international quality system standards should be utilised if recognition in the evaluation process is to be sought.

4. Veterinary Services administration

a. Annual reports

Official government annual reports should be published, which provide information on the organisation and structure, budget, activities and contemporary performance of the Veterinary Services. Current and retrospective copies of such reports should be available to counterpart Services in other countries, especially trade partners.

b. Reports of government review bodies

The reports of any periodic or ad hoc government reviews of Veterinary Services or of particular functions or roles of the Veterinary Services should be considered in the evaluation process. Details of action taken as a consequence of the review should also be accessible.

c. Reports of special committees of enquiry or independent review bodies

Recent reports on the Veterinary Services or elements of their role or function, and details of any subsequent implementation of recommendations contained in these reports should be available. The Veterinary Services concerned should recognise that the provision of such information need not be detrimental to the evaluation outcome; in fact, it may demonstrate evidence of an effective audit and response programme. The supplying of such information can reinforce a commitment to transparency.

d. In-service training and development programme for staff

In order to maintain a progressive approach to meeting the needs and challenges of the changing domestic and international role of Veterinary Services, the national administration should have in place an organised programme which provides appropriate training across a range of subjects for relevant staff. This programme should include participation in scientific meetings of animal health organisations. Such a programme should be used in assessing the effectiveness of the Services.

e. Publications



Veterinary Services can augment their reputation by demonstrating that their staff publish scientific articles in refereed veterinary journals or other publications.

f. Formal linkages with sources of independent scientific expertise

Details of formal consultation or advisory mechanisms in place and operating between the Veterinary Services and local and international universities, scientific institutions or recognised veterinary organisations should be taken into consideration. These could serve to enhance the international recognition of the Veterinary Services.

g. Trade performance history

In the evaluation of the Veterinary Services of a country, it is pertinent to examine the recent history of their performance and integrity in trade dealings with other countries. Sources of such historical data may include Customs Services.

Article 3.2.11.



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