EUROPEAN UNION The European Union IPA 2013 programme for Kosovo KOSOVO TECHNICAL ASSISTANCE FOR THE ANIMAL HEALTH DEPARTMENT OF THE KVFA AND THE FOOD AND VETERINARY LABORATORY (KOSOVO) REF: EuropeAid/133795/DH/SER/XK Deliverable 1.1 Assessment of the structure and functions of the Directorate for Animal Health and Welfare October 2015 DRAFT Consortium Agrotec SpA / IZSVe / NIRAS 1 / 12
This document has been produced with the financial assistance of the European Union The contents of this publication are the sole responsibility of the author / contractor / implementing partner and are in no way be taken to reflect the views of the European Union. Consortium Agrotec SpA / IZSVe / NIRAS 2 / 12
Introduction The role of the KAHL project is to assess the structures and functions of the Directorate of Animal Health and Welfare (DAHW) and make recommendations for improvements. This may also include some recommendations for other Directorates that are responsible for complementary functions such as the Inspectorate who will carry out the routine field activities and the Administration who would provide support in legislation and budgeting. Organisational Structure of KFVA The Kosovo Food and Veterinary Authority (KFVA) is currently situated within the Office of the Prime Minister, although it has in the past been part of the Ministry Of Agriculture, Forests and Rural Development (MAFRD). KFVA has set out its policy and objectives in terms of functions and responsibilities as defined by the Law on Food and Regulation No. 03/2010 on the Organisation of the Food and Veterinary Agency. KFVA is divided into five directorates: Public Health Animal Health and Welfare Laboratory and Food Inspectorate Administration The Inspectorate Directorate presently has operating regional offices in Pristina, Peja, Ferizaj and Prizen and is in the process of establishing regional offices in Gjakova, Giljan and Mitrovice. Each regional office has a Veterinary Inspector for Animal Health, Inspector for Phytosanitary and a Sanitary (Public Health) Inspector. Responsibilities of the DAHW The DAHW has responsibility for: Formulation of national livestock policies, including animal welfare. Regulations governing animal production, processing and marketing activities including Identification and Registration (I&R) of livestock. Regulations covering the activities of private veterinarians and para veterinarians. Ensuring the health of the national herds (disease surveillance, animal movement, quarantine, quality control of drugs and vaccines, emergency planning, disease reporting to OIE and EU) Inspection and control of livestock products for food safety purposes. Import and export certification. Accreditation and monitoring of private suppliers of services and animal health services. These responsibilities are presently divided between 4 main sectors of the DAHW, with provision for a sector on Animal Feeds. The current sectors are Animal Health, Identification and Registration of livestock units and livestock (I&R) Consortium Agrotec SpA / IZSVe / NIRAS 3 / 12
Animal Welfare Veterinary Medicinal Products. Each sector has a Chief of Sector (CoS) and then positions for 2 or more officers within each sector. Presently the total number of officers employed within the DAHW is 13, with 5 vacant positions (a total of 18 posts). Fig D1.1.1 shows an organogram of the structure and staffing of the DAHW. Two of the current sectors have a Chief of Sector and no officers. Veterinary Law and Administrative Instructions KVFA has the authority to prepare administrative instructions / bye laws, but is limited by number of veterinary personnel with an interest and skills in writing administrative instructions at central level and the absence of a legal officer. Functional Responsibilities of DAHW Staff The functional responsibilities of staff are not clearly defined by the Directorate itself. They are outlined in the job descriptions found in the Administrative Order for the Food and Veterinary Agency. These job descriptions are very general and do not identify all main tasks according to job position and do not include outputs. Consortium Agrotec SpA / IZSVe / NIRAS 4 / 12
Fig D1.1.1: Organogram of the Present Organisational Structure and staffing for the Directorate of Animal Health and Welfare Consortium Agrotec SpA / IZSVe / NIRAS 5 / 12
Functions and Responsibilities of Each Sector of DAHW. The DAHW lacks a document or policy paper which explains the functions and responsibilities of each sector with intended outputs. For a clear analysis of the structure of each sector, the sector responsibilities need to be defined along with expected outputs. The following is a description of the functions and responsibilities of each sector as described by their staff. 1 Director of DAHW The Director of DAHW has responsibility for the overall supervision of and planning for the Directorate. The Director is responsible for the production of annual work plans and annual reports. 2 Animal Health Sector 2.1 Animal Health Sector Staffing Within the DAHW, the animal health sector is the largest sector with the following seven (7) posts of which 6 are currently filled and one vacant: Position Qualification of person in position Chief of Sector DVM Animal Health Officer DVM Contingency Planning Officer DVM Epidemiologist Medical degree ( Doctor ) Data base operators x2 Economist and customs Feed Officer Vacant 2.2 Main Responsibilities and Outputs for Animal Health Sector. The main responsibilities and outputs for the animal health sector that are needed to comply with EU legislation are shown in the table below: Each area of responsibility is examined more fully below with a subjective assessment of outputs based on information in the National Annual Plan for 2015 for Control of Animal Diseases, Work Plan 2015 for DAHW and Annual Report 2014 for DAHW Consortium Agrotec SpA / IZSVe / NIRAS 6 / 12
Main Responsibilities and Outputs for Animal Health Sector SECTOR RESPONSIBILITY OUTPUT Animal Health Disease Control Programme - National Plan - Evidence of results Biosecurity - National Plan - Results International Trade for Live - SOPs Animals - Licenses issued Contingency Planning - Operational Contingency Plans - Simulation exercises Licensing of Private - Up dated data base Veterinarians Disease control poultry, bees - National Plan and fish - Reports of results (Under epidemiology) Disease surveillance and reporting system - National implemented system - Reports on disease status Risk analysis and assessment - Risk Reports Outbreak Investigation - Outbreak Investigation Reports Analysis and interpretation of - Special reports data Study design, monitoring and analysis - Economic Analysis of Disease Control Programme Liaise with Public health - Co-ordinated strategy Consortium Agrotec SpA / IZSVe / NIRAS 7 / 12
2.3 Disease Control Programmes Presently the DAHW is involved in 12 active disease control programmes. The programmes are implemented by private veterinarians issued with government contracts and monitored by Veterinary Inspectorate within the Inspectorate Directorate. It would appear that some of the disease control programmes being implemented have been chosen with inadequate scientific evaluation of their efficacy or efficiency. Disease Control Programmes Being Implemented Disease Control programme Common Good Private Good Brucellosis (SR) +++ ++ Brucellosis (LR) ++ + Tuberculosis (LR) ++ - Mastitis (LR) - ++ Clostridia (LR, SR) - ++ Anthrax ++ + Rabies in dogs +++ + Echinococcus ++ - Classical Swine Fever ++ ++ Salmonella Poultry +++ - Trichinella +++ - Rabies in Foxes ++ - Crimean Congo Haemorrhagic Fever ++ - SR Small Ruminants (sheep and goats) LR Large Ruminants (cattle) The Animal Health sector is presently unable to carry out any economic analysis to show the cost benefit analysis of each of the above disease control programmes. A cost benefit analysis is some of the vital information needed for formulating policies, strategies and budgets for the DAHW. 2.4 Primary and Active Disease Surveillance The monitoring of the disease control programmes rely on active and primary disease surveillance which involves data collection and blood and tissue samples being sent from the field to the KFVA laboratory in Pristina for analysis. The quality and quantity of the data coming to the data entry staff relies on data received at regional level being passed on to central level on a monthly basis. The data collected at regional level relies on farmers, private veterinarians working on contract basis for DAHW and veterinary inspectors. The collection of data is largely unsupervised and without the implementation of standard operating procedures (SOPs) for data collection. The quality of the data is therefore uncertain and not checked at either regional or central level. Also the number of reports received by KFVA for notifiable diseases is low, suggesting the present disease surveillance system is limited. The active disease surveillance programs vary in their efficacy. Post-vaccination monitoring of brucellosis vaccination is reasonable but other such as bovine tuberculosis testing suffer severe technical issues. Consortium Agrotec SpA / IZSVe / NIRAS 8 / 12
2.5 Biosecurity The veterinary inspectors under the Inspectorate Directorate and municipality inspectors are responsible for inspecting markets, slaughter houses and farms. Neither group of inspectors are under the direct line of command of the AHW Directorate and rely on personal relationships. Presently veterinary inspectors and municipality veterinarians do not carry out inspections in markets, slaughter houses or enforce legislation for animal movement, animal identification, animal welfare and animal health. 2.6 International Trade for Live Animals Import and export licenses are issued by either the Head of AHW Directorate or the Chief of Animal Health Sector. 2.7 Contingency Planning The SSTE Animal Disease and JSTE Animal Disease KAHL project are presently working with the Contingency Officer to develop contingency plans for generic diseases. 2.8 Licensing of Veterinarians Presently no one has responsibility for this process and none of the private or government veterinarians are licensed as individuals. Veterinary clinics are licensed according to Administrative Instruction 22/2005. 2.9 Disease Control for Poultry, Bees and Fish Within the National Annual Plan for Control of Animal Diseases, 2015 Newcastle Disease, Avian Influenza and Salmonella in poultry are included in diseases to be monitored and controlled. Whilst active surveillance of salmonellosis in poultry is included in the annual work plan, implementation is not clear. Viral, bacterial and parasitic diseases of fish are to be monitored by passive surveillance of fish farms, rivers and lakes. Also infectious parasitic diseases of bees are to be monitored by passive surveillance. However presently there is no post within the AH sector for an officer to be employed to undertake these duties. 2.10 Epidemiology The overall role of the epidemiologist is to collate all data regarding active or passive disease surveillance within Kosovo, neighbouring countries and disease status of countries exporting live animals and animal products to Kosovo. With such data an epidemiologist can map out the epidemiological situation for any disease, especially zoonotic diseases which can spread through the human population and carry out a risk analysis on diseases that have an economic negative impact on the livestock industry. Presently this position within the AH sector is filled by a human doctor, who has no formal qualifications in epidemiology and supported by two data entry officers who have limited data Consortium Agrotec SpA / IZSVe / NIRAS 9 / 12
analysis skills. The work of the SSTE Disease Control with the data entry staff has shown a very clear need for basic training to increase skills in Excel and Access in data handling. There is no economic analysis undertaken to assist in the decision making processes for formulating policies and strategies for the control of animal diseases. Overall the quality of the data received is not verified, the data analysis conducted by the AH sector is very limited and no economic analysis is undertaken. This is a major deficiency that needs to be addressed in order to improve the overall quality of work for the Directorate. 3 Identification and Registration Sector This sector is responsible for keeping and updating the national farm register, identification and registration of animals and animal movement. The sector consists of a Chief of Sector, one officer responsible for distribution of materials, monitoring animal movements, identification and registration and two data entry officers one responsible for cattle and the other responsible for sheep, goats and pigs. Up until 2012 the sector also had I&R inspectors, but their positions have been removed and their responsibilities transferred to the Veterinary Inspectors in the Inspectorate. 4 Animal Welfare Sector This sector has a Chief of Sector only, although the organogram of DAHW allows for two more posts below the Chief of Sector. Following discussions with the Chief of the sector, it seems that the importance of Animal Welfare is not fully recognised within the DAHW, within the Inspectorate Directorate, by farmers and the public in general. 5 Veterinary Medicinal Sector This sector has a chief of sector only, although the Organogram for the DAHW allows for 2 more posts to be filled. One post for Registration of Veterinary Medicinal Products and one post for Distribution of Veterinary Medicinal Products. Presently the registration, supervision and pharmacovigilance are the responsibility of the Kosovo Medicines Agency (KMA) set up within the Ministry of Health. The KMA has responsibility for defining veterinary medicinal products, which has yet to be undertaken and it may be more appropriate that the Food and Veterinary Agency has responsibility for all procedures involved in registration, supervision and pharmacovigilance of veterinary medicinal products in Kosovo. 6 Animal Feed Sector This sector is pending and will consist of a Chief of the sector and one officer. The main responsibilities and outputs of the sector are shown in the following table Consortium Agrotec SpA / IZSVe / NIRAS 10 / 12
Sector Responsibility Output Animal Feeds Licensing of Animal Feed Accurate up dated data base Licensing of Animal Feed Traders Licensing of Animal Feed Companies Licensing of producers selling animal feeds Inspection of animal feeds Regulations Accurate up dated data base Accurate up dated data base Accurate up dated data base SOPS Regulations harmonized with EU Legislation 7 Veterinary Inspectors The government employed veterinary inspectors in the regions report to the Director of Inspectorate and not the DAHW. Therefore only some of their main tasks involve disease control/reporting, I&R and implementing programmes e.g. vaccination, mastitis control, TB testing for the DAHW. Nonetheless, this work is vital to the application of disease control and welfare regulations in the field. Their direct line of reporting is to the Head of Veterinary Inspectorate within the Inspection Directorate and not under the direct control of the DAHW. There is an additional issue of some animal health and welfare responsibilities being undertaken by inspectors employed by municipalities. Gap Analysis The gap analysis shown on the following page identifies the main weaknesses in the outputs from the DAHW. The main identified weakness for the disease control programme is the lack of a qualified epidemiologist to design and implement disease surveillance programmes, check quality of data and provide good data analysis. The weaknesses in the other areas of responsibility are due to lack of enforcement of legislation and lack of knowledge and skills, which can be corrected through training and working with the SSTEs from the project. Conclusion and Recommendations Once the number of disease control programmes have been rationalised at central level there should be sufficient staff presently employed and vacant positions to allow the DAHW to fulfil its role in implementation of the veterinary legislation. The setting up of an epidemiology sector, headed up by an epidemiologist should provide the basis for an improved disease surveillance and reporting system. Consortium Agrotec SpA / IZSVe / NIRAS 11 / 12
Gap Analysis for Outputs of DAHW SECTOR RESPONSIBILITY OUTPUT Animal Health Disease Control Programme - Lack of cost/benefit analysis - Poor monitoring - Poor data collection and analysis - Lack of implementation of some programs Biosecurity - No enforcement of legislation International Trade for Live - No SOPs Animals Contingency Planning - Lack of expertise Licensing of Private - Not undertaken Veterinarians Disease control poultry, bees and fish - No position exists Epidemiology Disease surveillance and reporting system - No qualified epidemiologist - No livestock economist Data Entry Checking data quality/entry - Poor data handling I&R - National Farm Register - I&R - Animal Movement - No enforcement of Legislation Animal Welfare - Policy and Regulations - No enforcement of - Enforcement legislation Veterinary Medicinal Products - Licensing - Monitoring sales - Regulations for use/withdrawal - Undertaken by KMA - Incomplete data collected - No enforcement Animal Feeds Licensing and inspection - Non operational Veterinary - Not undertaken Inspectors Private Veterinarians - Enforcement of legislation - Monitoring disease control programmes Implementation of disease control programmes - Vet. Inspectors report directly to Inspectorate Directorate - Poorly monitored by Veterinary Inspectors Consortium Agrotec SpA / IZSVe / NIRAS 12 / 12