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Rev. sci. tech. Off. int. Epiz., 1993,12 (4), 1135-1146 Risk assessment on the importation of milk and milk products (excluding cheese) from countries not free from foot and mouth disease N.H. HENG and D.W. WILSON * Summary: The authors discuss the risk assessment conducted by the Australian Quarantine and Inspection Service (AQIS) on the importation of milk and milk products (excluding cheese) from countries not free from foot and mouth disease (FMD). This assessment was undertaken in response to requests from countries wishing to export dairy products for sale on the Australian market. AQIS conducted a public consultation on the proposal, in line with Australian Government policy on transparency and accountability in the quarantine decision-making process. The authors examine the procedures involved in the investigation of the likely presence of FMD virus in milk of vaccinated and non-vaccinated cows, and of the heat treatment parameters effective in the inactivation of the virus. The data provide a useful aid in the assessment of the risk factors associated with the importation of milk and milk products, and in the development of quarantine conditions for importation. KEYWORDS: Foot and mouth disease virus - Heat treatment - Milk - Milk products - Public consultation - Risk assessment - Risk factors. BACKGROUND Foot and mouth disease (FMD) is of significant quarantine concern to Australia, as this is a major exotic disease which has t h e p o t e n t i a l to d e v a s t a t e t h e A u s t r a l i a n livestock industry. The disease has not occurred in Australia since 1872. Current Australian quarantine legislation permits the importation of dairy products other than cheese and lactose only from countries considered to be officially free from FMD. T h e s e countries include C a n a d a , D e n m a r k , Finland, J a p a n , New Z e a l a n d , Norway, the Republic of Ireland, Sweden, the United Kingdom and the United States of America. In response to requests to export dairy products to the Australian market from the governments of several countries which are not considered to b e free from F M D , the Australian Government decided to review the relevant quarantine conditions. The Australian Quarantine and Inspection Service (AQIS) conducted a risk assessment on the importation of dairy products (excluding cheese) from countries not free from F M D . * The Australian Quarantine and Inspection Service, G.P.O. Box 858, Canberra, A C T 2601, Australia. 1136 A literature search was conducted on the epidemiology of the disease in vaccinated and non-vaccinated herds, particularly in relation to virus secretion in milk. As the role of milk and milk products in the spread of the disease is well established, information on the heat inactivation of F M D virus (FMDV) was sought, in order to establish conditions for the safe importation of dairy products. Although F M D V was the main object of the risk assessment, other important viruses and b a c t e r i a excreted in the milk of cows - including bovine virus d i a r r h o e a virus ( B V D V ) , enzootic bovine leukosis virus (EBLV), Mycobacterium tuberculosis (TB), Listeria spp. and Brucella abortus - were also considered in the assessment. While a review of the scientific literature revealed that F M D V is not inactivated in the conventional pasteurisation of milk, other viruses and bacteria were found to be of negligible significance, as heat treatment in pasteurisation regimes has been shown to be effective in the inactivation of B V D V (2), EBLV (13), TB (3), Listeria spp. (9, 26) and B. abortus (21). A Q I S prepared and circulated the risk assessment discussion paper - for evaluation and c o m m e n t - to the Australian States, industry, scientific organisations and all interested parties, including the governments of the countries seeking market access in Australia for their milk and milk products. T h e public consultative process is in conformity with Australian Government policy on transparency and accountability in the quarantine decision-making procedure. Relevant comments from respondents to the risk assessment process were incorporated in a position paper which was circulated, together with draft protocols for possible importation, for a further round of consultation. ASSESSMENT OF DISEASE RISK T h e four principal factors influencing the disease risk are as follows: - zone/country factors (i.e. diseases p r e s e n t in the animal p o p u l a t i o n of the exporting zone/country) - commodity factors (i.e. diseases present in the animal or product) - risk reduction factors (i.e. methods of reducing risk by product treatment) - probability of domestic exposure (i.e. risk of pathogens from the imported product reaching susceptible animal populations in the importing country). The first three of these factors are discussed below. FOOT AND MOUTH DISEASE CARRIER STATUS AND VIRUS EXCRETION The F M D carrier status of cattle represents a major problem for disease control in situations where the disease is enzootic or where a vaccination policy is adopted. Studies have shown that both vaccinated and non-vaccinated cattle are likely to become carriers after exposure to F M D V infection. T h e virus was isolated from recovered, non-immunised cattle for several months after clinical infection (32,18). Vaccinated cattle exposed to the virus became carriers without showing clinical signs of the disease (32, 3 0 , 1 0 , 1 8 , 31,19). Virus multiplication occurred primarily in the oropharyngeal 1137 mucosae (10). Observations conducted by Hedger (19) in a group of vaccinated cattle exposed to severe n a t u r a l field challenge with FMDV, revealed that 8 5 % b e c a m e carriers without showing clinical symptoms. Virus-negative animals in the group were found to possess very high antibody titres, and it was suggested that vaccinated animals may possess sufficient immunity to resist clinical disease, as well as being carriers of infection. Partly-immunised cattle may exhibit clinical signs which could be overlooked in field conditions, as the symptoms may not be as severe as those seen in susceptible animals (27). Several workers were unable to detect viraemia in immunised cattle exposed to FMDV infection (31,19, 27). McVicar and Sutmoller (27) also reported the absence of viraemia in partly-immunised cattle which exhibited clinical signs after challenge with the virus. Doubts were expressed over the possible excretion of F M D V in the milk of vaccinated cows, as L e e u w et al. (23) w e r e u n a b l e to isolate F M D V from the milk of experimentally-infected, vaccinated cows. There is a high probability that the virus may be absent from milk in a well-immunised herd in which no outbreak of the disease has been reported for some years. Some workers have also r e p o r t e d that spread of virus did not occur from carrier animals to susceptible in-contact animals (32,10,19). However, Hedger (18) reported evidence of transmission of the virus from a carrier animal to another animal within a herd in the field. Studies by Sellers et al. (29) on airborne dispersal of F M D V revealed that vaccinated and non-vaccinated cattle excreted virus in two phases - between 30 min and 22 h, and 2 and 7 days after exposure. T h e authors suggested that the first phase probably resulted from the mechanical shedding of the virus from the respiratory tract and the coat of animals, or from the clothing of p e o p l e exposed in the experiment; shedding in the second phase was thought to result from the multiplication of the virus in the respiratory tract. Virus excretion was not detected after the first day in animals which had been vaccinated more than once. This finding suggested that higher immunity levels resulted in reduced or zero virus production. However, studies were not conducted on the infectivity of the virus for susceptible animals. Donaldson and Kitching (17) found that cattle vaccinated three weeks before challenge with F M D V did not transmit virus to susceptible in-contact animals. In cattle vaccinated two weeks before challenge, transmission of the virus to susceptible in-contact animals occurred but the infection was subclinical. Transmission and s u b s e q u e n t clinical disease occurred in susceptible in-contact animals which had b e e n exposed to cattle challenged four or seven days after vaccination. T h e above findings p e r t a i n i n g to the spread of F M D V from carrier animals to susceptible in-contact animals support the conclusion by Anderson et al. (1) that in a well-immunised herd where reintroduction of the virus is prevented through livestock movement controls and other animal health measures, F M D V is unlikely to persist for a lengthy period in the population and, therefore, that elimination of the virus from the herd can be achieved. FOOT AND MOUTH DISEASE VIRUS EXCRETION IN MILK L i t e r a t u r e r e p o r t s confirm the i m p o r t a n t role of milk in the s p r e a d of F M D V . Dawson (16) m a d e references to early l i t e r a t u r e in which l a b o r a t o r y e x p e r i m e n t s supported r e p o r t s on the role of milk in the s p r e a d of F M D . D a w s o n p r e s e n t e d 1138 evidence on the involvement of milk and milk movement in the natural spread of the disease during the 1967-1968 outbreak in the U n i t e d Kingdom. Studies by Burrows et al. (12) and Blackwell et al. (8) confirmed that F M D V replicated in the mammary gland. T h e fact that F M D V is excreted in milk before the onset of clinical disease in infected cattle is of major epidemiological significance in the control of the disease. Burrows (11) had demonstrated virus excretion before the onset of clinical symptoms in experimental studies. Hedger and Dawson (20) demonstrated high titres of infective virus in milk, at least 33 h before the detection of clinical disease. It is important to note that Leeuw et al. (23) were unable to demonstrate F M D V in milk from vaccinated cows infected by the intranasal route. Milk samples obtained from cows exposed to the virus between two and nine months after their last vaccination were found to be negative for F M D V when inoculated onto cell cultures, fed to susceptible pigs and calves or injected intramuscularly and/or intradermolingually into susceptible steers. The absence of viraemia in immunised cattle exposed to F M D V infection and in partly-immunised cattle which had exhibited clinical signs after challenge with the virus, support the findings of Leeuw et al. CATEGORISATION OF COUNTRIES As scientific evidence supports the contention that the probability of F M D V being present in milk from well-vaccinated herds would be low, the feasibility of importing milk products from countries with well-protected herds was assessed. Accordingly, countries were categorised according to disease status, disease control programmes and the ability to implement such programmes effectively. AQIS categorised potential exporting countries as follows: Category 1: F M D vaccination is prohibited, and no outbreaks of the disease have been reported in the past twelve months. Category 2: Compulsory official control p r o g r a m m e s are i m p l e m e n t e d and no outbreaks of F M D have been reported in the past two years. The veterinary authorities in these countries have d e m o n s t r a t e d the ability to implement disease control programmes effectively and could b e relied upon to diagnose and notify any disease occurrence rapidly. Category 3: F M D outbreaks continue to occur, or the disease status is unclear. These countries have difficulty in the effective implementation of disease control programmes and in the early detection, diagnosis and notification of the disease. Draft quarantine conditions were then developed to facilitate the safe importation of milk products from these countries, subject to a full public consultation. FOOT AND MOUTH DISEASE VIRUS SURVIVAL IN MILK AND MILK PRODUCTS T h e investigation of F M D V inactivation in milk has b e e n conducted largely on samples o b t a i n e d from susceptible cows inoculated by the i n t r a m a m m a r y and 1139 intravenous routes, although Blackwell et al. (7) reported similar results for susceptible cows infected by oral exposure. Several workers h a v e shown that c u r r e n t t e m p e r a t u r e / t i m e regimes used for pasteurisation (either 60-65.5°C for at least 30 min, or high-temperature, short-time [HTST] treatment at 71-72°C for at least 15 sec) are inadequate to inactivate F M D V reliably in milk. Earlier work, such as that by Sellers (28), used relatively insensitive cell-culture techniques for residual virus detection, and added virus to milk instead of using milk from infected animals (Table I). Hyde et al. (22) and Leeuw et al. (25) demonstrated that virus in milk from infected cows survived longer than virus added to milk from healthy cows, due to the protection afforded by cells, proteins and fat in the milk. These authors also showed that susceptible cattle provided a more sensitive means for the detection of residual viral activity than cell cultures. TABLE I Results of inactivation Temperature of foot and mouth disease virus (28) Time taken to inactivate FMDV to a survival of 0.00001% at pH 6.7 56°C 63°C 72°C 80°C 85°C pH (at 4°C) 2 4 5.5 5.8 11 12 13 (FMDV) 6 1 17 <5 <5 at pH 7.6 min min sec sec sec 30 2 55 <5 <5 min min sec sec sec Time taken for inactivation 1 2 30 18 2 2.5 2.5 min min min h h min min Note: traces of virus were detected after the times recorded Hyde et al. (22) infected susceptible cows by the intravenous and i n t r a m a m m a r y routes. Infected milk samples, heated at 72°C and 80°C for 15-17 sec, were found to be positive for F M D V by cell-culture techniques. Milk treated at the above temperatures and times and then heated at 65°C for 64.5 min to reduce the volume by 5 0 % tested negative for F M D V in cell cultures. However, susceptible steers inoculated with the evaporated milk samples developed clinical disease (Table II). 1140 TABLE II Results of inactivation Sample of foot and mouth disease virus (FMDV) in milk (22) Treatment Milk obtained 24 h post-inoculation 80°C Milk pasteurised at 72°C and 80°C for 15-17 sec 72°C for 15-17 sec for 15-17 Virus survival sec 65°C for 64.5 min (evaporated to 50% of original volume) Detected in cell cultures Detected in cell cultures Not detected in cell cultures Detected in cattle inoculation tests Similar results (Table III) were obtained by Blackwell and Hyde (6), who found that F M D V survived pasteurisation at 72°C for 15 sec in skimmed milk, cream and pelleted cellular components. F M D V survived in whole milk heated at 72°C for 5 min and 85°C for 15 sec, skimmed milk heated at 72°C for 2 min and 85°C for 15 sec, and in cream TABLE III Results of heat treatment on components of milk from cows infected with foot and mouth disease virus (FMDV) (6) Cattle inoculation Sample Heat treatment for FMDV Whole milk 72°C for 5 min 85°C for 15 sec Skimmed milk 72°C for 2 min 85°C for 15 sec Cream 93°C for 15 sec Pelleted cellular debris 72°C for 15 sec Whole milk (heated at 72°C for 5 min) 65°C for 1 h maximum (evaporated to 50% of original volume) Skimmed milk (heated at 72°C for 15 sec) as above Skimmed milk (heated at 72°C for 30 sec) as above + positive - negative 1141 heated at 93°C for 15 sec. F M D V survived in whole milk which was heated at 72°C for 5 min and then evaporated. The virus survived in skimmed milk after this was heated at 72°C for 15 sec, but not when it was heated at 72°C for 30 sec and then evaporated. Most of the h e a t e d samples were found to b e negative for F M D V by cell-culture assay but were positive in cattle inoculation tests. These findings reinforced the report by Hyde et al. (22) that inoculation into susceptible cattle was a more sensitive method for the detection of residual virus. The results support the findings of Hyde et al. (22) that conventional pasteurisation is insufficient to inactivate F M D V in milk and milk components. Blackwell (4) showed that pasteurisation of cream at 93°C for 16 sec, followed by processing to butter and storage for up to 45 days at 4°C at a p H which fell from 5.9 to 5.4, did not completely inactivate the virus. F M D V was detected in cattle inoculation tests. Leeuw et al. (25) also found that cell-culture assay was less sensitive t h a n cattle inoculation in the detection of residual virus. Using cell-culture assay, F M D V was not detected in skimmed milk heated at 72°C for 30 sec. However, the same sample heated at 80°C for 30 sec was found to be positive for virus when inoculated into cattle. Cunliffe and Blackwell (14) found that F M D V survived in casein p r e p a r e d from skimmed milk pasteurised at 72°C for 15 sec. Casein had been maintained at p H 4.5-4.7 for 2-3 h during processing. F M D V was d e t e c t e d by the i n t r a d e r m o l i n g u a l and intramuscular inoculation of cattle. F M D V was not detected by either cell-culture assay or cattle inoculation in whey constituents manufactured from virus-positive milk (5). The effectiveness of ultra-high temperature ( U H T ) processes in virus inactivation was examined by Cunliffe et al. (15), who found that heating milk at 138°C for 2-3 sec did not inactivate the virus completely, while heating at 148°C for 2-3 sec was effective (Table IV). Intradermolingual and intramuscular inoculation of susceptible steers was conducted to detect residual virus in the treated milk samples. Walker et al. (33) confirmed that heating infected milk at 148°C for 2.5 sec could effectively inactivate F M D V and also d e m o n s t r a t e d that m o r e than 20 min w e r e required to inactivate virus at 100°C. The data presented by Walker et al. were obtained from a collaborative project c o n d u c t e d at the Plum Island A n i m a l Disease C e n t r e (PIADC) in the United States of America and the Central Veterinary Institute (CVI) in the N e t h e r l a n d s . D a t a on the e x p e r i m e n t s c o n d u c t e d at the CVI have also b e e n reported separately by L e e u w and Van B e k k u m (24). Milk was o b t a i n e d from susceptible cows infected by the intramammary and intravenous routes. T h e CVI used whole and skimmed milk, whereas the P I A D C used only whole milk. However, no differences w e r e d e t e c t e d in the t h e r m a l inactivation of F M D V in either whole or skimmed milk. All assays for infectivity following heat t r e a t m e n t were conducted in susceptible cattle which were inoculated by the intradermolingual and intramuscular routes. The results are presented in Table V. DISCUSSION The literature review confirms that conventional pasteurisation of milk and milk products is inadequate for the reliable inactivation of FMDV. 1142 TABLE IV Results of ultra-high temperature treatments on milk from cows infected with foot and mouth disease virus (FMDV) (15) Time Cattle inoculation for FMDV 102°C 2-3 sec + 123°C 2-3 sec + 130°C 2-3 sec + 138°C 2-3 sec + 148°C 2-3 sec - Temperature + positive - negative TABLE V Results of inactivation of foot and mouth disease virus in milk heated at various temperatures and times (33) Time 80°C 30 sec + 85°C 30 sec + 90°C 3 min + 100°C 9 min + 100°C 27 min - 110°C 30 sec + 3 min 120°C 30 sec - 130°C 10 sec + 135°C 17 sec - 138°C 2.5 sec + 138°C 5 sec - 148°C 3 sec — 110°C + Results of virus assay in susceptible cattle Temperature positive - negative Most of the work reported was conducted in milk obtained from susceptible cows infected by intravenous and intramammary inoculation of the virus, although reports were also made on milk from cows infected by contact exposure ( 7 ) . Reports on virus excretion in milk ( 1 6 , 1 9 ) in the 1967-1968 outbreak in the United Kingdom pertained to susceptible cattle. Leeuw et al. (23) failed to detect F M D V in milk from vaccinated cows up to 19 days after intranasal challenge, although virus was detected in oropharyngeal fluids during 1143 this period. F M D V was not detected when the milk samples were inoculated into cell cultures, fed to pigs and calves, or injected intramuscularly and/or intradermolingually into susceptible steers. T h e contention of Leeuw et al. (23) is that infected, vaccinated cattle are unlikely to excrete virus in milk and that, even if excretion did occur, the concentration of virus would not approach that recorded for susceptible cows infected via the intramammary route. These authors further suggested that standard commercial heat treatments, coupled with the activity of neutralising antibodies in pooled milk, should be a d e q u a t e to inactivate the virus. R e p o r t s by some workers that viraemia could not be detected in either well-immunised or partly-immunised cattle exposed to FMDV, and the suggestion made by Anderson et al. (1) that total disease eradication in a well-immunised herd is possible, would support this argument. The above a r g u m e n t provides a sound basis for the d e v e l o p m e n t of q u a r a n t i n e conditions to facilitate the safe importation of milk and milk products from Category 2 countries. In the case of Category 3 countries, there is a high risk of F M D V contamination in milk and milk products. As commercial pasteurisation procedures have b e e n shown to be inadequate to inactivate the virus, only milk products which have been subject to commercial sterilisation treatments in cans or retort pouches (or the equivalent) would be considered to present an acceptable risk. * ÉVALUATION DES RISQUES LIÉS À L'IMPORTATION DE LAIT ET DE PRODUITS LAITIERS (À L'EXCEPTION DES FROMAGES) EN PROVENANCE DE PAYS NON INDEMNES DE FIÈVRE APHTEUSE. - N.H. Heng et D.W. Wilson. Résumé : Les auteurs étudient la méthode utilisée par les Services australiens de quarantaine et d'inspection (Australian Quarantine and Inspection Service : AQIS) pour évaluer les risques liés à l'importation de lait et de produits laitiers (à l'exclusion des fromages) en provenance de pays non indemnes de fièvre aphteuse. Cette évaluation a été entreprise pour répondre aux demandes de pays désireux d'exporter des produits laitiers en Australie. L'AQIS a effectué une enquête publique en la matière, conformément à la réglementation australienne sur la transparence et la responsabilité dans le processus de prise de décision relatif à la quarantaine. Les auteurs examinent les procédures appliquées à la recherche du virus de la fièvre aphteuse dans le lait de vaches vaccinées et non vaccinées, ainsi qu'à l'étude des paramètres de traitement thermique efficaces pour l'inactivation du virus. Les données ainsi obtenues constituent une aide précieuse pour l'évaluation des facteurs de risques liés à l'importation de lait et de produits laitiers, ainsi que pour l'élaboration d'une réglementation de la quarantaine applicable aux marchandises importées. MOTS-CLÉS : Enquête publique - Evaluation des risques - Facteurs de risques - Lait - Produits laitiers - Traitement thermique - Virus de la fièvre aphteuse. * * * 1144 EVALUACIÓN DE RIESGOS POR IMPORTACIÓN DE LECHE Y DE PRODUCTOS LECHEROS (EXCEPTO QUESOS) PROVENIENTES D E PAÍSES NO LIBRES DE FIEBRE AFTOSA. - N.H. Heng y D.W. Wilson. Resumen: Los autores estudian el método utilizado por el Servicio australiano de cuarentena e inspección (Australian Quarantine and Inspection Service: AQIS) para evaluar los riesgos derivados de la importación de leche y productos lecheros (excepto quesos) provenientes de países no libres de fiebre aftosa. Este método fue establecido en respuesta a los pedidos de países deseosos de exportar sus productos lecheros a Australia. El AQIS llevó a cabo una encuesta pública al respecto, conforme a la reglamentación australiana que se refiere a la transparencia y la responsabilidad en el proceso de tomar decisiones sobre cuarentenas. Los autores examinan los procedimientos que se aplican en la investigación del virus de la fiebre aftosa en la leche de vacas vacunadas y no vacunadas y los que se aplican en el estudio de los parámetros de tratamiento térmico eficaces para la inactivación del virus. Los datos así obtenidos son de gran ayuda para la evaluación de los factores de riesgo en la importación de leche y de productos lecheros, así como también para la elaboración de una reglamentación de la cuarentena aplicable a las mercaderías importadas. PALABRAS CLAVE: Encuesta pública - Evaluación de riesgos - Factores de riesgo - Leche - Productos lecheros - Tratamiento térmico - Virus de la fiebre aftosa. * * * REFERENCES 1. ANDERSON E.C., D O U G H T Y W . J . & ANDERSON J . (1974). - The effect of repeated vaccination in an enzootic foot-and-mouth disease area on the incidence of virus carrier cattle. J. Hyg., Camb., 73, 229-235. 2. ANDREWES C , PEREIRA H . G . & WILDY P. (1978). - Bovine virus diarrhoea. 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