Proposed Import Requirements for Animals Listed in Schedule III Susceptible to Epizootic Ulcerative Syndrome (EUS)

Policy Statement

In order to be consistent with the World Trade Organization Rules under the Sanitary and Phytosanitary Agreement (SPS Agreement indicates), countries are required to ensure that import controls imposed on trade partners are not more restrictive than those required for domestic disease control purposes.

Based on a scientific evaluation of Epizootic Ulcerative Syndrome (EUS), the Canadian Food Inspection Agency (CFIA) will not be applying domestic disease control measures on the movement of seventy five (75) aquatic animal species that are currently listed in Schedule III of the Health of Animals Regulations as susceptible only to EUS. As a result and to ensure that Canadian policy is consistent with international standards and obligations, the CFIA will also remove the import controls associated with the importation of these same aquatic animal species.

Policy Objective

The objective of this policy is to provide the scientific rationale for and implications of the removal of import and domestic controls of the seventy five (75) aquatic animal's species listed in Schedule III of the Health of Animals Regulations that are listed as susceptible to only EUS.

Principles

The WTO SPS Agreement indicates that any measures applied to trade partners should not be more restrictive than those a Member Country applies to control of a disease domestically.

Canada as a signatory to this agreement is removing import control measures for all aquatic animals susceptible to EUS listed in Schedule III of the Health of Animals Regulations.

Rationale

EUS is listed in Schedule VII as an Immediately Notifiable Disease and, at the time of promulgation of the regulatory amendments in December 2010, was considered an exotic disease to Canada. Subsequently, EUS has been positively identified in wild fish in Ontario in 2010.

Epizootic Ulcerative Syndrome has been evaluated against the criteria for listing diseases outlined in the Aquatic Animal Health Code (herein, the Code) of the World Organization for Animal Health (OIE). Based on this evaluation, the CFIA has demonstrated that the current scientific evidence does not support the listing of EUS in the Code nor as a disease requiring domestic movement control to prevent spread of this disease within Canada.

Based on the evaluation of the science, the agent, Aphanomyces invadans, the purported cause of EUS:

1. is an opportunistic water mould found globally;
2. does not cause disease unless there is an inciting cause;
3. is a disease agent whose occurrence is dependent on environmental factors;
4. is a disease that can be managed/controlled in culture situations using environmental and other production manipulation methods.
5. is caused by an agent that cannot be detected using usual surveillance methods as there is no reliable, robust and repeatable test method, that can be used on clinically healthy animals. Only when clinical lesions are visible on finfish can a diagnosis be made. Surveillance in healthy populations of fish cannot be conducted and this is required to establish freedom from EUS.

Given that the CFIA cannot accurately conduct surveillance required to establish the geographic parameters of this disease in Canada or put into place effective disease control measures to prevent spread of EUS or declare zone freedom from EUS, the CFIA will not be implementing import or movement restrictions for domestic disease control purposes for this disease at this time. Canada has proposed that Epizootic Ulcerative Syndrome be removed from the World Animal Health Organization (OIE) Aquatic Animal Health Code list of aquatic animal diseases of finfish; however at this time this disease continues to remain listed by the OIE. The science will continue to be evaluated and changes to this approach adapted as required.

Implications for Trade

The removal of import requirements, including export certification by the country of origin, will have a positive benefit for Canadian importers as well as Canada's trade partners. Canada's exports will be protected because EUS will remain in Schedule VII of the Health of Animals Regulations and be reported by laboratories. Canada will be able to use these reports to attest to Canada health status for EUS. Any disease specific requirements can be met through disease identification at the premises or compartment level if requested by an importing country.

Removal of import requirements for this disease will mean that ninety (90) finfish listed in Schedule III will no longer require import permits and zoosanitary certification from the country of origin to enter Canada. Of the ninety finfish, seventy five (75) species (Table 1) that are susceptible to EUS alone will no longer be subject to any disease response or control activities within Canada, or import permit and zoosanitary export certification requirements prior to entry into Canada.

The species listed as susceptible to EUS are imported live for the ornamental trade, food service and retail use, aquaculture and display in public zoo and aquaria. Given that the vast majority of the species susceptible to EUS and listed in Schedule III of the Health of Animals Regulations (75 of 90 species) are listed as susceptible to only EUS, the removal of import controls will mean a reduction in export certification requirements and overall costs for importers.

In 2012 there were approximately seven hundred and fifty (750) import transactions of the 75 EUS susceptible species worth $2.25M dollars. Each shipment must be accompanied by an import permit, which can be multi entry, and a zoosanitary export certificate which is issued on a shipment by shipment basis. The direct decrease in cost of permits is anticipated to be significant (approximately ~50 to 85K) and export certification costs which are higher will be removed. As such this will have a positive net benefit in cost reduction for importers and number of certification inspection activities conducted by exporting countries.

For exports, certification for aquatic animals is conducted by the CFIA only when requested by the importing country. If Canadian exporters wish to export to countries with requirements for EUS, the CFIA will be required to certify the health status at the premises level. The CFIA has the Aquatic Animal Health Compartmentalization Program which can include country specific export requirements. Alternatively, the CFIA can certify on a shipment by shipment basis by following the recommendations of the OIE Manual of Diagnostic Tests for surveillance for disease freedom.

EUS will remain on Canada's Immediately Notifiable disease list (Schedule VII) as long as it is listed by the World Animal Health Organization (OIE). This maintains Canada's ability to:

1. re-impose import controls if deemed necessary,
2. respond to detections of the agent if required,
3. continue to meet Canada's international requirements for export if required by the importing country through premises-specific certification activities.

Implications on the Aquatic Resource Base

Implications for both the cultured and wild finfish resources are considered minimal at this time. Aphanomyces invadans is an opportunistic pathogen and requires water quality conditions that affect the integrity of the epidermal/dermal layer of the aquatic animal in order to invade and cause disease.

The CFIA suspects that Aphanomyces invadans is likely widespread in the natural waters of Canada. It has been found in finfish in many States in the US, including California, Oregon, Washington, Alaska, Louisiana, North Carolina, Connecticut, and Florida.

In 2012, EUS was detected in wild catfish in Hamilton Harbour, ON. This is the only reported finding of EUS and the significance is considered limited as sick fish were apparent for a short time with no subsequent reports in this species in Lake Ontario. EUS has never been detected in Canadian aquaculture premises.

The USA has not reported any significant impacts of EUS in their wild or cultured finfish populations.

Table 1. Aquatic Species Susceptible to EUS

Taxonomic Name of Species Susceptible to EUS	Common name
Acanthopagrus australis	surf bream
Acanthopagrus berda	goldsilk seabream
Alosa sapidissima	American shad
Ambassis agassizii	agassiz's olive glassfish
Ameiurus melas	black bullhead
Amniataba percoides	barred grunter
Anabas testudineus	climbing perch
Archosargus probatocephalus	sheepshead
Aseraggodes macleayanus	narrowbanded sole
Bairdiella chrysoura	silver perch
Barbonymus gonionotus	java barab; silver barb
Barbus paludinosus	straightfin barb
Barbus poechii	dashtail barb
Barbus thamalakanensis	thamalakane barb
Barbus unitaeniatus	slender barb
Brevoortia tyrannus	Atlantic menhaden
Brycinus lateralis	stripped robber
Channa striata	striped snakehead
Cirrhinus mrigala	mrigal carp
Clarias batrachus	Philippine catfish
Clarias gariepinus	North African catfish
Clarias ngamensis	blunt-toothed African catfish
Colisa lalia	dwarf gourami
Fundulus heteroclitus	mummichog
Fundulus majalis	striped killifish
Gibelion catla	catla
Glossamia aprion	mouth almighty
Glossogobius giuris	tank goby
Hepsetus odoe	kafue pike
Hydrocynus vittatus	tiger fish
Kurtus gulliveri	nurseryfish
Labeo cylindricus	redeye labeo
Labeo lunatus	upper zambezi labeo
Labeo rohita	rohu labeo
Leiopotherapon unicolor	spangled perch
Lutjanus argentimaculatus	mangrove red snapper
Marcusenius macrolepidotus	bulldog
Melanotaenia splendida	eastern rainbow fish
Micralestes acutidens	sharptooth tetra
Monopterus albus	Asian swamp eel
Mugil cephalus	flathead grey mullet
Mugil curema	white mullet
Nematalosa erebi	Australian river gizzard shad
Oreochromis andersonii	three spotted tilapia
Oreochromis macrochir	longfin tilapia
Oreochromis niloticus	Nile tilapia
Osphronemus gouramy	giant gourami
Oxyeleotris lineolata	sleepy cod
Oxyeleotris marmorata	marble goby
Petrocephalus catostoma	churchill
Platycephalus fuscus	dusky flathead
Pogonias cromis	black drum
Puntius sophore	pool barb
Rhodeus ocellatus	rosy bitterling
Sargochromis codringtonii	green happy
Sargochromis giardi	pink happy
Scardinius erythrophthalmus	rudd
Scatophagus argus	spotted scat
Schilbe intermedius	silver catfish
Schilbe mystus	African butter catfish
Scleropages jardini	Australian bonytongue
Scortum barcoo	barcoo grunter
Selenotoca multifasciata	spotbanded scat
Serranochromis angusticeps	thinface cichlid
Serranochromis carlottae	rainbow happy
Serranochromis robustus	yellow-belly bream
Sillago ciliata	sand sillago
Strongylura krefftii	long tom
Tilapia rendalli	redbreast tilapia
Tilapia sparrmanii	banded tilapia
Toxotes chatareus	spotted archerfish
Toxotes lorentzi	primitive archerfish
Trichogaster pectoralis	snakeskin gourami
Trichogaster trichopterus	three spot gourami
Tridentiger obscurus	dusky tripletooth goby

Table 2. Aquatic Species Susceptible to EUS and other Reportable or Immediately Notifiable Diseases

Taxonomic Name	Common name
Bidyanus bidyanus	silver perch
Carassius auratus	goldfish
Carassius carassius	crucian carp
Cyprinus carpio koi	Koi carp
Cyprinus carpio	Common carp
Ictalurus punctatus	Channel catfish
Lates calcarifer	barramundi
Lepomis macrochirus	Bluegill
Micropterus salmoides	largemouth black bass
Oncorhynchus mykiss	Rainbow trout
Plecoglossus altivelis	ayu sweetfish
Rutilus rutilus	Roach
Silurus glanis	Wels catfish