Avian influenza outbreak exercise: evaluation
Report setting out lessons identified following Exercise Hazel, a test of Scotland’s plans for controlling an avian influenza (bird flu) outbreak.
3. Lessons identified
3.1 General
As a matter of course in the event of an outbreak, our Disease Policy Unit (DPU) is convened. The DPU is primarily formed from the staff within the Disease Control Branch supplemented by additional staff dependent on the scale and scope of the outbreak. The lead role in response to such an outbreak will be taken by the Disease Strategy Group (DSG). The Chief Veterinary Officer (CVO) and the Head of the DPU in consultation with the Director, will initiate the Disease Strategy Group (DSG) which includes representatives from key areas within Scottish Government, local authorities and representatives from other key organisations depending on the circumstances. The DSG will take the lead role providing instructions to the DPU. The DPU and DSG will work collaboratively with colleagues in APHA and the Rural Payments and Inspection Division (RPID).
During an outbreak, APHA would take control of an infected premises and control all movements, ensuring that everyone is signed onto and off the site, and that they are given a full site briefing before entry. The need for APHA to gain early access to premises where AI is suspected is paramount from a disease containment perspective. Historically, APHA found that access to suspected Infected Premises (IP) in general had not always been easy, and this could cause delays in managing an outbreak.
From the onset of the exercise, the producer emphasised that it was essential to their business that their hatchery continued to operate with as much normality as possible given that it was such a vital area within their organisation. This included birds being moved to rearing premises, and from a welfare perspective, ensuring feed and other essentials were able to come onto the premises under the required licencing.
3.2 Cross Border
It was noted there is also the possibility that areas out with Scotland (cross border) could be affected given that this producer, as with many others, has specialised premises in different parts of Great Britain. This would impact on the production of the required licences given the need to comply with the specific legislation in each country.
3.3 Hatchery
The company gave a presentation outlining their production timetable in great detail. The company's first priority in the hatchery was to continue production and continue bird welfare and to ensure the flow of eggs from the hatchery and onwards to rearing premises.
They also advised that the hatchery manager could trace the source of each egg brought into the hatchery, all of which are fumigated on initial entry and again on a daily basis whilst held in a temperature-controlled store. The producer advised that during an AI outbreak, they would do everything possible to allow movement of chicks from the hatchery. They emphasised the importance of receiving movement licences promptly to allow movement of chicks out of the hatchery as quickly as possible is critical for the business.
Any restrictions on the hatchery would cause disruption within the business. The process and benefits of pre-designating a hatchery and activation of that designation was explained. Premises in disease control zones may only send hatching eggs to a designated hatchery under a movement licence. Premises in disease control zones may only receive day-old chicks where the movement is licensed and they originate
from a designated hatchery. It would be useful if hatchery staff were made aware in peace time what information would be required and what restrictions would be applied.
3.4 Lesson Identified 1
Government to outline to industry what information would be required to allow a hatchery to operate while other parts of the business were under restrictions, what restrictions would be applied in a hatchery in the event of an AI outbreak and what steps need to be undertaken in order that a hatchery may become designated.
It was noted that it would be beneficial for APHA to gain access to the hatchery quickly during an outbreak. It was also suggested that an annual contingency visit to a hatchery would allow field epidemiology investigators to acquire an understanding of the operation within a hatchery during peace time. This would in turn, enable APHA staff to understand the problems that could arise during an outbreak. It would also provide the opportunity to speed up decision making and work towards a common understanding of the licencing system, and how it works, with the overall aim of devising a slicker process. This should include single points of contact between both APHA and the producer, and ultimately result in clear roles and responsibilities.
3.5 Lesson Identified 2
APHA to arrange annual contingency planning visits to a hatchery by field epidemiology investigators to allow better understanding of operations. This should facilitate the development of a smooth process and define clear roles and responsibilities between APHA and Producers.
3.6 Record Keeping and Good Practices
One important area discussed was the need for producers to have up to date, accurate and robust record keeping process in place. This information is important for APHA in supporting any veterinary investigation into suspect or confirmed notifiable disease. Therefore during peacetime it is important that checklists and daily tasks are completed fully and to the required standard. In the event that it was found that this was not the case then this could have a significant impact during an outbreak, cause costly delays and mean that revisits may need to take place.
3.7 Lesson Identified 3
Government and APHA to work with producers to impress upon them the importance of prompt and accurate record routine record keeping.
3.8 Licences
Discussion took place around the process for applying and issuing of general and specific movement licences. Industry representatives emphasised again, as was emphasised similarly around the need for licences covering the movement of hatching eggs and day-old chicks to/from hatcheries, which many movements were time critical and delays in processing licences would have an impact on the business.
The company required a clear understanding of what kind of template licences were available and the conditions that may be applied to ensure that issues arising during the course of an outbreak could be pre-empted and contingencies put it place to mitigate against any potential delays or impacts. There was general consensus for the need to have a smooth licensing protocol with clear roles and responsibilities for each organisation, the Scottish Government, APHA and the producer.
Clear routes of communication were needed between those requesting movement licences, particularly where the business affected included an infected premises, and the application process from initial application to approval so that industry knew where the conduit for information lay. The Forward Operating Base (FOB) was managed by APHA and they and the producer/IP should work together to identify clear points of contact. The producer advised that historically the company manager had been the main point of contact. A clear system should be put in place to include cover for rest periods and staff rotation, so that information continues to flow effectively.
3.9 Lesson Identified 4
A detailed protocol with clear roles and responsibilities for each organisation namely, the Scottish Government, APHA and the producer should be identified. This should include identifying key points of contact taking staff rotation and rest periods into account. This should be used during an outbreak to update the producer on timings for receipt of licences.
It was recommended that risk assessments based on HPAI H5N1 should be recommissioned and reviewed to ensure licences are up to date and any gaps are identified. Any accompanying template licences should also be reviewed/produced, so that a library of 'off the shelf licences' is maintained and developed further.
3.10 Lesson Identified 5
We, the other GB policy administrations and APHA work together to develop and improve template Veterinary Risk Assessments to facilitate the production of an 'off the shelf library of risk assessments and their corresponding template movement licences' which would be suitable for all administrations once adapted to meet specific legislative requirements.
3.11 Cleansing and Disinfection and the Storage and Movement of Litter
A detailed discussion took place on the management, movement and safe disposal of manure and litter from premises under area based movement restrictions, and from infected premises which was key to allowing secondary cleansing and disinfection to take place. The roles and responsibilities between APHA or the Scottish Environment Protection Agency (SEPA) during this process was explained but there was consensus for the need for SEPA and APHA to work together to produce guidance to provide clarity to industry on the controls/conditions applied to the movement and safe disposal of manure and litter off site.
3.12 Lesson Identified 6
APHA and SEPA should work together to produce guidance on the safe movement and disposal of licensed litter and manure off sites in infected zones.
The value of identifying in advance of any outbreak, potential areas onsite and off-site (where no poultry were kept) for storage of litter and manure, as well as having the capacity to potentially hold dirty wash water prior to final disposal was raised. It was acknowledged that any sites identified as part of the development of contingency plans would still be dependent on the advice and recommendations given by APHA or SEPA at the time of an outbreak. All parties recognised the need for early engagement on this matter.
3.13 Lesson Identified 7
Through early engagement with APHA and SEPA, individual producers should identify potential location on and off site where used litter, manure and wastewater could be stored for long periods as part of their own contingency planning for disease outbreaks.
Once disinfected, used litter and manure on an infected premises must be covered to prevent the ingress of rodents, stored either inside a building or in a field for a period of 42 days.
Alternatively, the manure and bedding or litter could be transported under licence to a previously identified site where arrangements for receipt of contaminated material has already been agreed. It was also recognised that there were specific waste plants that have agreed to take contaminated material. Industry representatives requested a clear guidance from experts regarding areas suitable for the litter to be moved to and suitable methods of transportation.
3.14 Lesson Identified 8
Scottish Government, SEPA and APHA to collaborate on the production of guidance that could be used to assist in the identification of areas suitable for the litter to be moved for storage so as to prevent leakage. To facilitate this, suitable methods of transportation also needed to be identified.
Primary Cleansing and Disinfection (C&D) was carried out by APHA using government approved disinfectants. The process was then repeated seven days later. Secondary C & D was the responsibility of the company on the IP. It was during that time that manure and bedding or litter were removed to a previously identified area on site and securely coved for a period of 42 days to prevent the ingress of rodents.
SEPA advised that during peacetime, wastewater went onto land. Guidance available deemed the type of wastewater used in the secondary cleansing and disinfection process as hazardous. The only place known to take such material for treatment prior to disposal was Seafield in Edinburgh. Clearer guidance was required from SEPA detailing when wash water could be spread onto land and what treatment was required with infected wash water to allow this to take place.
Several suggestions about alternative methods as part of the cleansing and disinfection process were discussed:
- heating – It was noted that heat treatment in sheds had been approved in the USA so could this be considered as an approved option as part of the cleansing and disinfection process – this option could reduce wastewater?
- dry cleaning - perhaps an option before disinfection? Disinfection and then cleansing would remove organic material. It was noted that the Poultry Health Working Group (PHWG) run by the National Farmers Union Scotland (NFUS) were funding this work, which was discussed at the Cleansing and Disinfection event held in Stoneleigh in 2018.
- UV heat treatment of wastewater whilst in storage.
3.15 Lesson Identified 9
Clear guidance was required from SEPA detailing at what point wash water could be safely spread onto land and what treatment would allow this.
3.16 Lesson Identified 10
SG and APHA to consider the viability of alternative methods as part of the cleansing and disinfection process i.e.: heat treatment, dry cleaning and UV treatment.
3.17 Antivirals
It was noted that Health Protection Scotland (HPS) continues to work collaboratively with both APHA and local NHS boards in Scotland regarding risk assessments for human health. A proportion of antiviral stock was pre-distributed to each NHS board where each local Chief Pharmaceutical Officer (CPO) authorised its use.
APHA will issue antivirals to their own staff. One issue that arose during the discussion was how and to whom antivirals should be disseminated should APHA's stock become limited.
3.18 Lesson Identified 11
Occupational Health advisers in APHA to identify the basis for allocating antivirals.
It was noted that when contractors were brought onto the site by APHA, it would be the responsibility of that contractor's employers Occupational Health (OH) provider rather than APHA to ensure that antivirals were available to contracted in staff
The producer/infected premises would be responsible for dealing with all of their own staff, including those living on site and those brought onto the site as contractors. Their local NHS board should be contacted to obtain antivirals. It was also noted that it was the responsibility of companies to provide adequate occupational health information, guidance/preventative vaccination etc. to their employees, rather than reliance on government or the NHS.
3.19 Lesson Identified 12
Scottish Government to remind industry of their requirement to have a system in place with their local NHS board regarding accessing antivirals for their staff.
3.20 Personal Protective Equipment (PPE)
As was the position with antivirals above, it was noted in the exercise that it would be the responsibility of the relevant employers to ensure their staff had the required PPE when dealing with an AI outbreak.
3.21 Biosecurity
APHA would look at engaging with producers who had a history of substandard biosecurity practices. APHA also have frameworks with all 32 Local Authorities and Local Authorities regularly engaged with companies regarding good biosecurity practices on premises.
The industry representatives at this exercise noted that they had a detailed biosecurity protocol, which included vehicles, foot dips, designated footwear, as well as inside/outside hand sanitisers. Good biosecurity practice should include treatments of wheels/wheel arches on vehicles, as well as the practicality of disinfecting building roofs (where wild birds may perch) which needed to be carefully measured against health and safety risks.
It was also noted that birds may need to be housed as an adjunct to other biosecurity measures, and whilst this did not severely affect companies that were meat producers, it had a significant impact on egg producers, as housing affected the ability to market eggs as free range after a certain period of time.
3.22 Lesson Identified 13
APHA to look at the engaging with any producers where they have been made aware of substandard biosecurity practices.
Contact
Email: Animal.Health@gov.scot
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