13 May Submission on Campylobacter performance target limits.

Transcription

1 Auckland Regional Public Health Service Cornwall Complex Floor 2, Building 15 Greenlane Clinical Centre Private Bag Symonds Street Auckland 1150 New Zealand Telephone: Facsimile: May 2015 Submission on Campylobacter performance target limits. 1. Thank you for the opportunity for the Auckland Regional Public Health Service (ARPHS) to provide a submission on the Review of the Poultry NMD Programme s Campylobacter performance target (CPT) limit(s). 2. The following submission represents the views of the Auckland Regional Public Health Service and does not necessarily reflect the views of the three District Health Boards it serves. Please refer to Appendix 1 for more information on ARPHS. 3. ARPHS understands that all submissions will be available under the Official Information Act 1982, except if grounds set out under the Act apply. The primary contact point for this submission is: Jane Dudley Policy Analyst: Systems Intelligence and Planning Auckland Regional Public Health Service Private Bag Symonds Street Auckland ext jane.dudley@adhb.govt.nz Yours sincerely, pp Jane McEntee General Manager Auckland Regional Public Health Service Dr Richard Hoskins Medical Officer of Health Auckland Regional Public Health Service

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3 Introduction 1. Thank you for the opportunity to submit on this issue. Auckland Regional Public Health Service (ARPHS) has an interest in measures to assist in the reduction of the burden of disease from Campylobacter infection. 2. While rates of Campylobacter infection have reduced substantially with improved poultry processing, the incidence of Campylobacter infection in the Auckland region remains high. We support measures to further reduce the rates of infection from Campylobacter. Background 3. Food borne communicable disease forms a large share of the disease burden in Auckland and generates a substantial proportion of ARPHS communicable disease activities. 4. Campylobacter cases currently form the majority of ARPHS notifications of food borne illnesses. While most cases of Campylobacter infection recover completely, a small minority develop severe complications including Guillain-Barré syndrome. 5. In the 2012/2013 financial year, ARPHS investigated 225 enteric outbreaks in Auckland involving 1695 cases, and managed a total of 3,393 enteric disease notifications. ARPHS notifications of the following food borne illnesses in the 2012/2013 year: Campylobacteriosis = 1,658 Cholera = 8 Cronobacter species = 1 Cryptosporidiosis = 192 Gastroenteritis / foodborne intoxication = 72 Gastroenteritis - unknown cause = 149 Giardiasis = 552 Listeriosis = 7 Listeriosis - perinatal = 3 Paratyphoid fever = 15 Salmonellosis = 328 Shigellosis = 95 Typhoid fever = 48 VTEC/STEC infection = 110 Yersiniosis = Cost benefit analysis has shown that the costs of treating food borne disease are high. These include both human suffering and loss of life, as well as financial costs, which include both direct medical and treatment costs, and indirect costs (such as lost work days due to sickness). A 2000 study estimated these costs to be $55.1

4 million per year 1. A 2009 study found that 4.52 million work days were lost to acute gastrointestinal illness (AGI) in New Zealand in one year 2. Food borne illnesses and Māori 7. Research has indicated that Māori have a higher rate of some food borne illnesses than non-māori. A 2009 New Zealand study found that the rate of gastroenteritis is higher for Māori (11.0%) than for non-māori (8.0%) 3. Measures to reduce food borne illnesses are a contributing factor to helping to improve health inequalities. ARPHS response: general principles 8. We are supportive of the positive reductions in the numbers of Campylobacter cases as a result of improved practises. We would, however, like to see the current rates of Campylobacter infection further reduced. Contaminated chicken is still one of the major sources of transmission of Campylobacter infection. 9. We strongly support higher rates of control to reduce the burden of disease associated with Campylobacter. We would also like data on levels of poultry infection to be available for public health surveillance (primarily through the Institute of Environmental Science and Research, ESR) in order to improve public health responses. Option 1: Maintain status quo for the limits. 10. We are opposed to the status quo option on the basis that it does not promote further improvement of infection rates. Non-complying premises are currently not sufficiently incentivised to make improvements to their practises. Option 2: Require tighter enumeration and / or detection limits 11. We support the introduction of tighter enumeration and detection limits to reduce the rates of contamination and incidence of disease. We support this on the basis that tightening the enumeration limits may encourage industry to develop strategies that will promote improvements. 12. ARPHS supports Ministry for Primary Industries (MPI) taking a proactive role in working with industry to meet their target goal besides testing flock. We also seek clarification on whether this would also include environmental sampling. 1 Scott. W.G., Scott. H.M., Lake. R.J., Baker. M.G. (2000). Economic Cost to New Zealand of Food Borne Disease. The New Zealand Medical Journal. 113(1113). 281: Lake. R., Adlam. B., Perera. S. (2009). Acute Gastrointestinal Illness (AGI) Study: Final Study Report. ESR. Accessed from: 3 Lake. R., Adlam. B., Perera. S. (2009). Acute Gastrointestinal Illness (AGI) Study: Final Study Report. ESR. Accessed from:

5 Access to data 13. ARPHS supports having data on poultry infection and contamination being available for microbiological and statistical public health surveillance. This is primarily undertaken by ESR. Option 3: Require poor performers to take additional measures 14. While ARPHS advocates for improvements from all suppliers, ARPHS supports a risk-based approach that requires poor performers to take additional measures. Option 4: Require additional measures for start-up premises. 15. We support this measure as a means of reducing overall rates of infection from Campylobacter. 16. We support consistent food safety and personal hygiene control measures at a national level that will minimise the bacterial load. Conclusion 17. Thank you for the opportunity to submit on the Review of the Poultry NMD Programme s Campylobacter performance target (CPT) limit(s). We support the overall aim of the review as a means to further reduce campylobacter infection in the community. We support moves to reduce the rates of infection. We welcome feedback from MPI on this issue.

6 Appendix 1 - Auckland Regional Public Health Service Auckland Regional Public Health Service (ARPHS) provides public health services for the three district health boards (DHBs) in the Auckland region (Auckland, Counties Manukau and Waitemata District Health Boards). ARPHS has a statutory obligation under the New Zealand Public Health and Disability Act 2000 to improve, promote and protect the health of people and communities in the Auckland region. The Medical Officer of Health has an enforcement and regulatory role under the Health Act 1956 and other legislative designations to protect the health of the community. ARPHS primary role is to improve population health. It actively seeks to influence any initiatives or proposals that may affect population health in the Auckland region to maximise their positive impact and minimise possible negative effects on population health. The Auckland region faces a number of public health challenges through changing demographics, increasingly diverse communities, increasing incidence of lifestyle-related health conditions such as obesity and type 2 diabetes, infrastructure requirements, the balancing of transport needs, and the reconciliation of urban design and urban intensification issues.

7 Appendix 2 - ARPHS role and the relationship between food safety and public health Food Safety Pursuant to the Health Act 1956, ARPHS investigates infectious diseases that are notifiable to the Medical Officer of Health (Schedule 1) and take steps to mitigate risk to the wider population. This can involve contact tracing, provision of advice to individuals and institutions and liaison with the Ministry for Primary Industries (MPI) when the source of infection may be related to food and food hygiene practices. ARPHS does not currently investigate food complaints or conduct food premises investigation work under contract to MPI but nevertheless retains a professional interest in how such work is conducted to prevent future disease outbreaks ARPHS may visit food premises to determine whether food workers have food borne illness and in an advisory capacity to institutions and Government premises in response to a disease investigation. ARPHS also has a role to exclude food handlers diagnosed with a notifiable infectious disease and food handlers who are identified as close contacts of a person with a notifiable infectious disease from work under the Food Safety Regulations (2002). This is to prevent the risk and spread of contamination onto the food chain. ARPHS also provides health promotion advice to aid in the reduction of non-notifiable non communicable diseases (such as obesity and diabetes). Cost benefit analysis has shown that the costs of treating food borne disease are particularly high. A 2000 study estimated these costs to be $55.1 million per year 4. Food borne communicable disease forms a large share of the disease burden in Auckland and generates a substantial proportion of ARPHS communicable disease activities. In the 2014 financial year, ARPHS investigated 191 enteric outbreaks in Auckland involving 3468 cases, and managed a total of 3437 enteric disease notifications. ARPHS also receives notifications regarding non communicable diseases resulting from food contamination. Sources of chemical contamination of food can include: Lead poisoning and other heavy metal contamination resulting from heavy metals contamination of food. Toxicity resulting from heavy metals contamination and other chemical contamination of food (i.e. excessive sulphur dioxide in meat as a preservative). Pesticide contamination of food. Non-communicable diseases can also be associated with malnutrition (which includes inappropriate diet). Some of the most common include: Obesity (27% of New Zealand s population are currently obese 5 ); Type 2 diabetes; and Cancer (approximately 30% of cancers are associated with poor diet/malnutrition 6 including bowel cancer, breast cancer, mouth cancer and stomach cancer). 4 Scott. W.G., Scott. H.M., Lake. R.J., Baker. M.G. (2000). Economic Cost to New Zealand of Food Borne Disease. The New Zealand Medical Journal. 113(1113). 281: Organization of the United Nations. (2013). The State of Food and Agriculture Food and Agriculture. Pg. 78. Accessed from: 6 Key. J.T., Shatzkin.A., Willet. W.C., Allen.N.A, Spencer. E.A., Travis.R.C. (2004). Diet, Nutrition and the Prevention of Cancer. Public Health Nutrition. 7 (1A) Accessed from:

8 Early childhood education services ARPHS carries out Early Childcare Education Centres (ECECs) health and safety checks on behalf of the Ministry of Education, as the Director General of Health s nominated officers. ECECs may present a number of risks to children s health and safety. For example, they can become settings for disease transmission, and exposure to environmental hazards. ARPHS also delivers Kahuku, a health promotion professional development training programme for licensed early childhood education staff in the greater Auckland region. Kahuku aims to improve the health and wellbeing of children 0-5 years by providing supporting tools to strengthen environments and build the capacity of early childhood services. The trainings are based on the Waikato District Health Board s Keeping Families and Communities Well programme and designed in partnership with education representatives and providers. Kahuku began implementation June 2014 and currently has two training modules, Preventing Communicable Childhood Illness and Kai Culture.