Combatting Salmonella in poultry in the Netherlands:

An evaluation of the cooperation between stakeholders

Paper One Health, 01/07/2016 Frank Coenjaerds Elise Bertijn 4258479 Jolien Jacobs Jacqueline van Eck Marloes Berkelaar 3949621 Supervisor: Floor Haalboom

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Index

Introduction 3 Food safety and control of Salmonella in One Health 3 Research Question 5 Overview and method 5

1. What is Salmonella? 7 General information 7 Salmonellosis 8 Health impact 8 Food vehicles 9 Salmonella in eggs 10 Salmonella in poultry 11

2. Who are different stakeholders in the issue of Salmonella in poultry and what are their perspectives, interests and legal role? 13

(International) rules and guidelines 15 Administrative parties 18 (Independent) Research Institutes 19 Structure of the control of Salmonella 19 NVWA 21 RIVM 22 GD 24 GGD 25 Poultry Farmers 25 Veterinarians 26 Slaughterhouses 27 Supermarkets 27 Consumers 28 General practitioners and doctors 29

3. How is the cooperation between these different actors and what can be points of improvement? 29

Analysis of the relation of different supervisory body’s 29 Issues and conflicts in the relation between public and private supervision 31 Policy and measures in the cooperation in the control of zoonosis 32 Cooperation in practice 33 Other European countries and the policy of cooperation in food safety issues 34

4. How are actors and their cooperation of influence on the spread of Salmonella and the occurrence of salmonellosis? 35

Transmission of Salmonella in the production chains 38 Sampling and measures on Salmonella positive farms 39 A structure with weak links 40

Conclusion 42 Recommendations 44

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Introduction On October 11 in 2001 a Salmonella outbreak took place in the joint kitchen of hospital and nursing home Isala clinics in the Netherlands. One of the doctors reported an extremely high rate of diarrhoea cases that day and the GGD was informed. The symptoms had started a few days earlier and were in accordance with a Salmonella infection. The patients tested positive on S. Enteriditis. After investigation by the outbreak management team it turned out that the source of the epidemic of around 150 sick patients (including staff members), was the strawberry bavarois, which was served for lunch on the 7th of October. The bavarois was made of raw chicken eggs1. This is not the only case of Salmonella in chicken products the past few years. Regularly outbreaks take place as a consequence of infected chicken eggs that are used for the preparation of foods containing raw eggs like mayonnaise or tiramisu. In the past decades the same thing that happened with the bavarois in Isala clinics, happened with other deserts in a hospital in New York City, United States (1987), in a nursing home in Venlo, The Netherlands (1990), and in Napels, Italy (1999). More recently the European Food Safety Authority discovered that multiple outbreaks of Salmonella in chicken eggs in different countries in Europe, (Austria, France, Germany and the United Kingdom) were caused by contaminated eggs from Germany. The European Centre for Disease Prevention and Control has therefore sharped their supervision since these incidents in 2014.2 Not only chicken eggs can be a source of Salmonella. Chicken meat is also an important source for these salmonellosis incidents. A report of the European Food Safety Authority from 2014 points out that in that year the amount of Salmonella contaminations in Europe has increased again for the first year in a long time, and that the source of the bacteria was mostly found to be chicken meat3. These incidents show that despite the strict regulation of the European Union and its member states, these kinds of incidents can still occur and form a threat for the public health. Where do these products come from and where in the long chain from chicken farm to consumer can we detect the problem? How do the production chains of chicken eggs and chicken meat differ and how does the control on Salmonella in these chains differ and why?

Food safety and control of Salmonella in One Health Food safety and risk assessment of foodborne diseases like salmonellosis are major themes in One Health research. This topic will be the central theme that will be discussed in this paper, with the focus on poultry. Salmonella occurs sporadically in outbreaks when the victims are linked by the common source, like in the case of the strawberry bavarois in the hospital kitchen. These outbreaks can have a great public health impact and a social and economic impact on a global scale. Because of increased globalisation and internationalization of food production and consumption chains, the need of global food production control and surveillance becomes more and more urgent. In the age of globalization, there is an increasing mobility of people, animals and products. Therefore, food production and distribution takes place on a larger scale. International trade agreements like the Transatlantic Trade and Investment Partnership (TTIP)

1 Bruins, M.J., Fernandes, T.M.A., Ruijs, G.J.H.M., Wolfhagen, M.J.H.M., Rijn-Berkel, van, J.M., Schenk, B.E.

&Duynhoven, van, Y.T.H.P. (2003). Een uitbraak van Slamonella enteritidis in een ziekenhuis en een verpleeghuis en het effect van een protocol voor het verwerpen van feceskweken op de ontdekking ervan, Tijdschrift voor Hygiëne en InfectiePreventie, 5, p.127-131. 2 European Centre for Disease Prevention and Control & European Food Safety Authority (2014) Multi-

country outbreak of Salmonella Enteritidis infections associated with consumption of eggs from Germany. 3 European Centre for Disease Prevention and Control & European Food Safety Authority (2014). The

European Union summary report on trends and sources of zoonosis, zoonotic agents and food-borne outbreaks in 2014.

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support these developments. A downside to these developments can be that it becomes less transparent what kind of products including food products come in to our country. There are people and groups, like Greenpeace, who are worried that the food safety of Europe can no longer be guaranteed because of the favourable terms from TTIP to export food with less strict rules from for example the United States to the European Union. This current social dynamic and international political debate makes the subject of food safety, regulation and hygiene extremely relevant today. National governments and international organizations like the Food and Agriculture Organization, the World Health Organization and the Organization for Animal Health are with many other stakeholders involved in this issue. They developed the Hazard Analysis Critical Control Points to identify hazards and control them. The primary goal of this risk assessment is the health of humans, but the implementation of this model has been broadened in a One Health approach to include animal health and environmental issues as well.4 The theoretical concept of the One Health approach is not unambiguous. There are different definitions of the concept in different sources. The major characteristic of the field of One Health research is that it tries to offer benefit for health issues in general by integration of different disciplines. It must be taken into account that One Health issues are situated in a context of a planet that is threatened by overwhelming demands of populations of people and livestock and that the ecological sustainability is also an important element. Therefore the following general definition will be used in this paper:

One Health can be defined as any added value in terms of health of humans and animals, financial savings or environmental services achievable by the cooperation of human and veterinary medicine when compared to the two medicines working separately5. In this definition the word cooperation is an important statement, because a lot of different actors are involved in the food production chain who have a certain responsibility for one small piece of the chain. This makes it extremely difficult to control a foodborne disease like salmonellosis along this whole chicken egg or meat production chain. Investigation of an outbreak contains tracing and categorizing each stage of the production process in the chain, like animal feed, primary production, animal transport, slaughter, storage and cooking. After this risk assessment a human-case control study is usually the next step. Expert opinion is also an important source of information. Other important factors in food risk assessment concerning Salmonella are ecological elements, economic incentives to poultry farmers, competition among poultry producers, antibiotic-use in poultry, consumer expectations and fossil fuel prices, etcetera. This requires a lot of communication between scientists and scholars from a variety of fields and between the different stakeholders themselves. Ideally a One Health approach to the assessment of food risks like Salmonella needs to operate across multiple levels, sectors and stakeholders. Because this risk assessment will be of great influence on the trade on the food market, strong international leadership is required to meet this ideal6.

4 Zinsstag, J., Schelling, E., Waltner-Toews, D, Whittaker, M. & Tanner, M. (2015). One Health: The Theory and

Practice of Integrated Health Approaches. Oxfordshire: CAB International. 5 Zinsstag, J., Schelling, E., Waltner-Toews, D, Whittaker, M. & Tanner, M. (2015). One Health: The Theory and

Practice of Integrated Health Approaches. Oxfordshire: CAB International. 6 Zinsstag, J., Schelling, E., Waltner-Toews, D, Whittaker, M. & Tanner, M. (2015). One Health: The Theory and

Practice of Integrated Health Approaches. Oxfordshire: CAB International.

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Research Question In the control of food safety and also in specifically the control of Salmonella in poultry there are thus many different parties involved. These are either just stakeholders with certain interests or they can actually influence the policy around food safety and participate in the decision-making or implementation around it. These different actors might have different interests, but also different protocols, rules and instruments for enforcement of these rules. Therefore, the collaboration between the different actors in taking action on a subject as food safety is an interesting aspect to investigate. The case of Salmonella in poultry will be used as an example to investigate this cooperation. The expectation in this light is that there will be certain conflicts in the collaboration between all the different actors. There could be conflicts of interest, like financial versus health interests, but there could also be conflicts in the communication between the actors. These conflicts and the way of collaboration between stakeholders in general have an important influence on the control of the disease and spread of the disease. We expect to find in this research certain flaws and best practices in the way stakeholders are involved in the whole process of detecting of and dealing with Salmonella in poultry that can be used to formulate some recommendations for optimization of the collaboration of different actors in the control of Salmonella in poultry in the future. From this interest and relevancy of the above described issue, the research question this paper addresses is:

How is the control of Salmonella in poultry organized in the Netherlands and what are consequences of this for Salmonella in poultry from a One Health perspective? This research question is divided in different sub questions:

· What is Salmonella? · Who are different stakeholders in the issue of Salmonella in poultry and what are their

perspectives, interests and legal role? · How is the cooperation between these different actors and what can be points of

improvement? · How are actors and their cooperation of influence on the spread of Salmonella and the

occurrence of salmonellosis?

Overview and method The research question will be answered step by step, by answering the abovementioned sub-questions. First we will give some general information about the Salmonella bacterium and its journey through the whole production chain from chicken to egg or meat on the plate of the consumer. We will use insights from both the veterinary science and the biomedical discipline. Next there will be a policy analysis to describe al the stakeholders involved and the momenta of interventions to control the Salmonella. Than we will evaluate the actual cooperation between these parties and in the end we will integrate all these insights into the concluding final sub question, and we will describe the influence of this collaboration on the journey of the Salmonella bacteria. Data was collected using all kinds of different documents scientific as well as non-scientific. The amount of scientific literature about the specific research subject of cooperation in the control of Salmonella in poultry is somewhat limited, because it was simply not available. About the microbiological aspect of Salmonella there is a lot of research, but on the administrative aspect of control of Salmonella on the contrary, there is a gab that we are hoping to contribute to with this research. As an alternative we used semi-scientific literature, for example a lot of reports of governmental and private institutions and articles from websites and newspapers. In addition, we have also spoken to core stakeholders regarding to our theme. These interviews offer a view on the sector in general and the practical consequences of the

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current cooperation in the control of Salmonella in poultry. Table 1 offers an overview of the respondents.

Respondent Position Organization

1 Veterinary expert in the field of poultry Utrecht University

2 Veterinarian specialized in chicken meat NVWA

3 Veterinarian specialized in chicken eggs NVWA

4 Microbiological expert RIVM

Table 1

Although these interviews offer a lot of inside information, we realise that our respondents do not guarantee a representative image of the whole sector and that we should be careful in the adoption of this data. After answering the different sub questions, the research question will be answered in a concluding chapter. Regarding the conclusions there will be some policy recommendations made in the final chapter.

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1. What is Salmonella? Considering the large disease outbreaks Salmonella can cause it is a known and feared pathogen. But what is Salmonella exactly and how does it cause disease? These questions will be answered in this chapter concerning Salmonella.

General information Salmonella is an important cause of foodborne illness worldwide.7 It is a bacterium belonging to the family Enterobacteriaceae. They are gram-negative rods which can be up to 3 µm in length. There are two species of Salmonella: S. enterica and S. bongori. These species are both divided in several subspecies. S. enterica is divided in six subspecies which are referred to by a roman numeral and a name (I, S. enterica subsp. enterica; II, S. enterica subsp. salamae; IIIa, S. enterica subsp.arizonae; IIIb, S. enterica subsp. diarizonae; IV, S. enterica subsp. houtenae; and VI, S. enterica subsp.indica). The subspecies are further qualified by the serotype. Serotyping is based on the immunological identification of surface antigens on pathogens. Immunological techniques such as fluorescent antibody staining can be used for identifying bacterial pathogens and determining their serotype. The genus Salmonella contains more than 2600 serotypes which occur worldwide. These serotypes can be divided into three groups based upon their host range: broad-host-range, host-adapted and host-restricted. Host-restricted serotypes are associated with just one particular host species. For example S. enterica subsp. enterica serotypes Typhi, Paratyphi A, Paratyphi C and Sendai can only cause disease in humans. This restriction in host range is associated with changes in the virulence plasmid pSV, accumulation of pseudogenes, and chromosome rearrangements. Other serotypes are adapted to a particular host, but have retained the ability to cause disease in alternative hosts. Host-restricted and host-adapted serotypes cause systemic infection in their natural hosts, but no gastroenteritis. Broad-range serotypes such as S. enterica subsp. enterica ser. Enteritidis and S. enterica subsp. enterica ser. Typhimurium can infect a wide range of animals, including humans. These Salmonella types will be referred to as S. Enteritidis and S. Typhimurium in the subsequent sections. Although capable of causing systemic disease in certain animals, broad-host-range serotypes usually induce a self-limiting gastroenteritis in infected hosts. The broad-host-range Salmonella pathogens typically cause gastroenteritis in humans.8 9 10 The majority of human Salmonella pathogens belong to S. enterica subspecies I (S. enterica subsp. enterica). Only about 50 serotypes of this subspecies are isolated as both animal and human pathogens.11

7 Kirk, M.D., Pires, S.M., Black, R.E., Caipo, M., Crump, J.A., Devleesschauwer, B., … Angulo F.J. (2015).

World Health Organization Estimates of the Global and Regional Disease Burden of 22 Foodborne Bacterial, Protozoal, and Viral Diseases, 2010: A Data Synthesis. Plos Medicine, 12(12). 8 Silva, C., Calva, E., & Maloy, S. (2014). One Health and Food-Borne Disease: Salmonella Transmission between Humans, Animals, and Plants. Microbiology Spectrum, 2(1). 9 Van de Giessen, A.W., Ament, A.J.H.A., & Notermans, S.H.W. (1994). Intervention strategies for Salmonella enteritidis in poultry flocks: a basic approach. International Journal of Food Microbiology, 21(1-2), 145-154. 10 Quin, P.J., Markey, B.K., Leonard, F.C., FitzPatrick, E.S., Fanning, S. Hartigan, P.J. (2011). Veterinary

micriobiology and microbial disease. The Atrium, Southern Gate, Chichester, West Sussex, UK: Wiley-Blackwell 11 Silva, C., Calva, E., & Maloy, S. (2014). One Health and Food-Borne Disease: Salmonella Transmission

between Humans, Animals, and Plants. Microbiology Spectrum, 2(1).

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Most human salmonellosis cases are foodborne, often derived indirectly from animal or human faecal contamination. Direct or indirect animal contact in homes, veterinary clinics, zoological gardens, farm environments, or other public and private settings can also be a source of salmonellosis. Infection through the mucosae of the upper respiratory tract and conjunctiva is possible as well.12

There are reservoirs of Salmonella in humans, animals, plants and the environment. Humans and animals can be asymptomatic carriers of Salmonella. It can also grow in plants and survive in protozoa, soil and water. Excretion of Salmonella in faeces is the main source of environmental contamination. Reducing human Salmonella infections will require a reduction of Salmonella in animals and a limitation of transmission from the environment. Therefore, a one health approach is needed.13

Salmonellosis Human Salmonellosis can be divided into four disease patterns: enteric fever, gastroenteritis, bacteraemia and other complications of nontyphoidal salmonellosis, and the chronic carrier state. There are two types of enteric fever: typhoid fever caused by S. enterica subsp. enterica ser. Typhi and paratyphoid fever with milder symptoms and a lower mortality rate caused by S. enterica subsp. enterica ser. Paratyphi A, B, and C. Both serotypes are solely human pathogens. Infection typically occurs due to ingestion of food or water contaminated with human waste. Nontyphoidal salmonellosis is caused by at least 150 different serotypes, Typhimurium and Enteritidis being the most common ones. It results in a gastroenteritis which main symptom is acute diarrhoea14. Infection occurs via ingestion of food or water contaminated with animal waste15. Young children or infants, elderly, pregnant women and people with compromised immune systems because of disease or pharmacologic therapy are at higher risk of foodborne illness like salmonellosis. Each of these groups is immune suppressed. Collectively they are called the YOPI’s (Young, Old, Pregnant, Immune deficient).16 About 8% of the untreated cases of salmonellosis result in bacteraemia, a serious condition in which bacteria pass the intestinal barrier and end up in the bloodstream. Bacteraemia and other complications should be treated with antibiotics. In certain cases, a chronic carrier state can develop. Salmonellosis can be spread by chronic carriers who can infect many people, especially when working in the food industry. Factors contributing to the carrier state are not yet fully understood.17

Health impact The World Health Organisation examined the impact of various pathogens on human health worldwide and found that various serotypes from S. enterica were responsible for the greatest food-borne disease burden. S. enterica from contaminated food accounts for an estimated 6,43

12 Silva, C., Calva, E., & Maloy, S. (2014). One Health and Food-Borne Disease: Salmonella Transmission

between Humans, Animals, and Plants. Microbiology Spectrum, 2(1). 13 Silva, C., Calva, E., & Maloy, S. (2014). One Health and Food-Borne Disease: Salmonella Transmission

between Humans, Animals, and Plants. Microbiology Spectrum, 2(1). 14 Aranda-Michel, J., & Giannella, R.A. (1999). Acute diarrhea: a practical review. The American Journal of

Medicine, 106(6), 670-676. 15 Pui, C.F., Wong, W.C., Chai, L.C., Tunung, R., Jeyaletchumi, P., Noor Hidayah, M.S., … Son, R. (2011).

Review Article Salmonella: A Foodborne Pathogen. International Food Research, 18, 465-473. 16 Kendall, P., Medeiros, L.C., Hillers, V., Chen, G., & Dimascola, S. (2003). Food handling behaviors of special

importance for pregnant women, infants and young children, the elderly, and immune-compromised people. Journal of the American Dietetic Association, 103(12), 1646-1649. 17 Pui, C.F., Wong, W.C., Chai, L.C., Tunung, R., Jeyaletchumi, P., Noor Hidayah, M.S., … Son, R. (2011).

Review Article Salmonella: A Foodborne Pathogen. International Food Research, 18, 465-473.

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million Disability Adjusted Life Years (DALYs) around the world.18 This illustrates the enormous impact of food-borne salmonellosis. In the Netherlands Salmonella is also one of the food-borne pathogens that cause the highest disease burden on a population level. It is responsible for 1270 DALYs per year.19 New Zealand did the same analysis on foodborne disease burden following the approach of the Netherlands. Salmonellosis in New Zealand accounts for an estimated 186 DALYs per year.20 This is significantly lower than in the Netherlands. Of course both countries have different numbers of inhabitants and thus the amount of DALYs is not directly comparable. Nevertheless, these numbers give a good illustration of the scale of the negative effects of Salmonellosis.

Food vehicles Salmonella can occur in common foods like poultry, beef, pork, eggs, milk, fruits, vegetable, spices, nuts, etcetera.21 In the European Union, eggs and egg products were the most frequently identified food vehicles for Salmonella in 2014. This was also the case in previous years. Salmonella from eggs and egg products accounted for 44.0% of the reported Salmonella strong-evidence outbreaks. Broiler meat caused 3.6% of the strong-evidence outbreaks. Strong evidence outbreaks are outbreaks from which the source has been determined with certainty. Figure 1 shows the distribution of the most common food vehicles for Salmonella in strong-evidence Salmonella outbreaks in 2014.22

18 Kirk, M.D., Pires, S.M., Black, R.E., Caipo, M., Crump, J.A., Devleesschauwer, B., … Angulo F.J. (2015).

World Health Organization Estimates of the Global and Regional Disease Burden of 22 Foodborne Bacterial, Protozoal, and Viral Diseases, 2010: A Data Synthesis. Plos Medicine, 12(12). 19 Havelaar, A., Haagsma, J.A., Mangen, M.J., Kemmeren, J.M., Verhoef, L.P., Vijgen, S.M., … Van Pelt, W.

(2012). Disease burden of foodborne pathogens in the Netherlands, 2009. International Journal of Food Microbiology, 156(3), 231-238. 20 Lake, R.J., Cressey, P.J., Campbell, D.M., & Oakley, E. (2010). Risk Ranking for Foodborne Microbial

Hazards in New Zealand: Burden of Disease Estimates. Risk Analysis, 30(5), 743-752. 21 Silva, C., Calva, E., & Maloy, S. (2014). One Health and Food-Borne Disease: Salmonella Transmission

between Humans, Animals, and Plants. Microbiology Spectrum, 2(1), 22 European Food Safety Authority (2015). U summary report on zoonoses, zoonotic agents and food-borne

outbreaks 2014. European Food Safety Authority Journal, 13(12), 4329-4520.

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Figure 1, Distribution of food vehicles in strong-evidence outbreaks caused by Salmonella in the EU, 201423

Salmonella in eggs S. Typhimurium and S. Enteritidis are the two most commonly identified causative serotypes in contaminated eggs and eggshells. They have the ability to colonise the reproductive organs of hens. Eggs can be contaminated with Salmonella in a direct or an indirect way. Direct contamination occurs during the development of an egg in the reproductive tract of hens. Indirect contamination occurs after the egg has been laid. Salmonella contaminating the outside of the egg can penetrate through the shell membrane.24 Storing these contaminated eggs at inadequate temperatures (above 8ºC) and insufficient heating of the eggs prior to consumption may then lead to salmonellosis. Approximately 0,15% off eggs in the Netherlands are contaminated with Salmonella.25 26 So the incidence of Salmonella in eggs is quite low.

The production of eggs involves a large production chain. (figure 2). It starts with the breeding company, which produces parent stock from pure line grand parent stock. The products are day old chicks which will constitute the breeding flock (parent stock) and are sold and transported to rearing farms. The rearing farms deliver young breeders to layer breeder farms which produce hatching eggs. These eggs are transported to the hatchery and are put in a brooder, where they hatch. The day old chicks are subsequently transported to another rearing farm, which rears the chicks to young pullets. These young pullets then go to a layer farm, where the production of eggs takes place. The eggs can go to a packing station or directly to the egg processing industry. From the packing station the eggs can be distributed to retail like supermarkets or to

23 European Food Safety Authority (2015). U summary report on zoonoses, zoonotic agents and food-borne

outbreaks 2014. European Food Safety Authority Journal, 13(12), 4329-4520. 24 Whiley, H., & Ross, K. (2015). Salmonella and eggs: from production to plate. International Journal of

Environmental Research and Public Health, 12(3), 2543-2556. 25 RIVM (2014). Report 2014-0076 Staat van zoonosen 2013. Retrieved June 12th, 2016, from

http://www.rivm.nl/dsresource?objectid=rivmp:266580&type=org&disposition=inline 26 Lublin, A., & Sela, S. (2008). The Impact of Temperature During the Storage of Table Eggs on the Viability

of Salmonella enterica Serovars Enteritidis and Virchow in the Eggs. Poultry Science, 87(11), 2208-2214.

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food service. Food service includes for example restaurants, catering and institutions.27 In the egg processing industry eggs are broken whereby the shell is separated from the contents. Whole eggs or eggs yolks and egg whites are produced which are sold both in liquid and in powder form. Besides these standard products, special substances may be obtained from eggs such as lysozyme. The products are pasteurized before delivery to the food industry.28

Figure 2, Egg production chain29

Salmonella in poultry The poultry production chain (figure 3) differs from the egg production chain, although some components are the same. The first step takes place in the breeding company, where breeding of parent stock and hatching occur. The day old chicks are transported to rearing farms. When they are older they are transported to broiler breeder farms. These broiler breeder farms produce hatching eggs. The eggs are hatched in the hatchery, followed by transport of day old chicks to

27 Van Horne, P.L.M. (2007). Production and consumption of poultry meat and eggs in the European Union. 28 Agricultural Economics Research Institute (2003). Report 2.03.03 The future of the Dutch egg processing

industry. Retrieved June 12th, 2016, from https://core.ac.uk/download/files/153/6654764.pdf 29 Van Horne, P.L.M. (2007). Production and consumption of poultry meat and eggs in the European Union.

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the broiler farm where they reach their final weight before slaughter. This is slightly different from the egg production chain, where the day old chicks go to a rearing farm and lastly to a laying farm. In contrast to broiler chicks, pullets do reach adulthood. The broilers are slaughtered in slaughterhouses and further processed in processing plants for use in the food industry, food service or retail. The different parts of the production chain are independent companies in the Netherlands. The farmers themselves are owners of the eggs and birds and sell them to the next company in the production chain. In other words, there is no umbrella organisation.30

Figure 3, Poultry production chain31

30 Van Horne, P.L.M. (2007). Production and consumption of poultry meat and eggs in the European

Union. 31 Van Horne, P.L.M. (2007). Production and consumption of poultry meat and eggs in the European Union.

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2. Who are different stakeholders in the issue of Salmonella in poultry and what are their perspectives, interests and legal role? This chapter is constructed following systematically the chain we have found concerning the transmission of Salmonella. First we will discuss the different stakeholders and subsequently the different parties that are involved. Overarching are the European Guidelines that are imposed by the United Nations and the WHO. Those are leading guidelines with regard to the law and regulations in the Netherlands overlaid by the Dutch Government relating to Zoonotic - Salmonella control. The chain starts with the NVWA, which monitors farmers and other business owners in the production chain who must take samples on their farms periodically. At a certain percentage of the farms and slaughterhouses the NVWA takes samples as well. Because of the strict laws and regulations an occasional occurrence of Salmonella should be detected in an early stage in the chain. It should be registered by a poultry flock, prior to the distribution of the flock or the distribution of its eggs for sales in retail businesses such as supermarkets or in the food service industry. The NVWA is the institute that monitors the Veterinary Sector and is under control of the Ministry of Economic Affairs. The NVWA cooperates with the RIVM, which is the organization that covers the humane sector. The RIVM is under control of the Ministry of Public Health. If a sample that is taken and tested by the NVWA is positive the RIVM will test it a second time. The other way around the RIVM reports to the NVWA humane cases of illnesses that might be caused by a product of an animal. Diseases that can be transmitted from animals or animal products to humans are called zoonotic diseases. The NVWA collaborates with the GD, which is concerned with animal health. The GD monitors the farmers. Concerning the humane sector the instance that monitors the humane health is the GGD. The GGD is in contact with general practitioners and the RIVM. Besides these stakeholders in the sector there are several other interested parties in the chain. Starting with the business owner and the veterinarian. Further in the chain you can see the slaughterhouses, supermarkets and the consumers. Finally at the end of the chain are the general practitioners, who become involved when a consumer gets infected and becomes ill.

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Figure 4

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Figure 5

(International) rules and guidelines

Dutch companies that produce food, for example eggs, have to comply certain rules and guidelines. Those rules and guidelines are a combination of guidelines made and instructed by the European Union and those of the Netherlands itself. The European legislation is composed of the European Guidelines. Zoonotic diseases and thereby the health of animals are described in the legislation of Community. In the legislation of Community, a specific legislation is described that relates to Veterinary Public Health.32 Based on scientific advice the European Commission revised the legislation and composed the White Paper on Food Safety in which it covers regulations and directives concerning the Veterinary Public Health to confine the incidence of zoonotic diseases, like salmonellosis. In the General Food Law, the guidelines to which food that is produced or distributed in the European Union has to comply, are registered. The General Food Law contains the rules concerning packaging, added substances and traceability. The European Food Safety Authority (EFSA) is responsible for the compliance of these rules. The EFSA also advises the European Committee

32 The European Parliament and the Council 12.12.2003OJ L 325, European Commission. (2016, May 31). Food borne diseases (zoonoses). Retrieved June 28th, 2016, from http://ec.europa.eu/food/safety/biosafety/food_borne_diseases/index_en.htm

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about food safety risks and animal health.33 The EFSA is an independent organisation. It operates mostly in response to the requests for scientific advice from the European Commission, Parliament and European Union Member states. It monitors and analyses data on biological hazards, chemical contaminants, food consumption and emerging risks.34

All members of the European Union are obligatory to announce a yearly report about the zoonotic diseases in their country.35 The European Union prepares a summary on the trends and sources of zoonotic agents in animals, food and humans in the European Union. This report is composed by the Zoonosis Unit of the EFSA, in collaboration with the European Centre for Disease Prevention and Control (ECDC).36

The ECDC is an agency of the European Union and is directed to enforce the defences of Europe against infectious diseases. It pools the expertises of Europe’s experts to assemble the health knowledge of Europe and to develop authorized scientific opinions relating to emerging infectious diseases.37

The European guidelines are based on the Codex Alimentarius, which is an organization of the United Nations that coordinates international rules and norms for safe and fair production and trade of provision and food. The Codex Alimentarius is partner of the World Health Organization (WHO) and the Food and Agriculture Organization of the United Nations.38

The values of the WHO are integrated by making the European Guidelines. According to the WHO, successful prevention of Salmonella consists of monitoring at three different levels in the production chain. Firstly, measures should be taken with regard to the food-producing animal, which is called pre-harvest control. The Salmonella status of a farm can be determined by bacteriological or immunological methods. The results of bacteriological methods give an indication of the actual infection status of an animal and all serotypes can be detected. On the other hand, immunological methods are easier and faster to perform, but they identify only previous exposure to Salmonella. Therefore it is recommended to use both immunological and bacteriological methods. In addition, good management and hygiene routines can minimise the spreading of Salmonella on a farm. Raising broilers of different ages and different previous farms in separate groups, which has been applied for years, is very effective. Besides, introduction of Salmonella through wild animals, visitors, manure or machinery should be prevented. Secondly, proper hygiene regulation need to be taken during slaughter and processing of the meat. After this so called harvest control is post-harvest control the last step. Post-harvest control consists of providing information to the food industry and consumers about hygiene and preparation.39 The European guidelines and rules are the foundation of the activities of all the parties in the Netherlands that we will describe below and thus are a very important factor of influence on the conducted policy on Salmonella in the Netherlands. In the Netherlands two laws are relating to food safety, the Food and Drugs Act and the Animal Act. The Nederlandse Controle Autoriteit

33 Rijksoverheid. Voedselveiligheid in Europa. Retrieved June 15th, 2016, from https://www.rijksoverheid.nl/onderwerpen/voeding/inhoud/voedselveiligheid-in-europa 34 European Food Safety Authority. How we work. Retrieved June 15th, 2016 from http://www.efsa.europa.eu/en/about/howwework 35 European parliament 2003. Richtlijn 2003/99 van het Europees parlement en de raad. Hoofdstuk V: artikel 9. Retrieved june 15th, 2016 from http://eur-lex.europa.eu/legal-content/NL/TXT/PDF/?uri=CELEX:32003L0099&rid=1 36 European Food Safety Authority. How we work. Retrieved June 15th, 2016 from

http://www.efsa.europa.eu/en/about/howwework 37 European Centre for Disease Prevention and Control. About us. Retrieved June 15th, 2016 from

http://ecdc.europa.eu/en/aboutus/Pages/aboutus.aspx 38 Ministerie van Economische Zaken. Codex Alimentarius. Retrieved June 15th, 2016 from

https://www.codexalimentarius.nl 39 Plym Forshell, L., & Wierup, M. (2006). Salmonella contamination: a significant challenge to the global marketing of animal food products. Scientific and Technical Review of the Office International des Epizooties, 25(2), 541-554.

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Eieren (NCAE) is part of the Centraal Orgaan voor Kwaliteitsaangelegenheden in de Zuivel (COKZ) which is a private institution supervised by the Ministry of Economic affairs (EZ) and performs public assignments in commission of public authorities. The NCAE has control of the dairy industry and poultry industry, including the egg industry. Since 2012 the NCAE supervises the egg and poultry sector and monitors the eggs of these companies to test if they act in accordance with the Food and Safety Act and the Animal Act. The Food and Safety Act is in line with the European Union regulations concerning hygiene, including the following laws: Verordening EG nr. 178/2002 - general hygiene regulations Verordening EG nr. 882/2004 - control regulations Verordening EG nr. 852/2004 - groceries regulations Verordening EG nr. 853/2004 - specific regulations relating to products of animals Verordening EG nr. 854/2004 - specific regulations of official controls The Animal Act relates to the marketing regulations relating to animal products, including the following laws: Besluit dierlijke producten - Decision making Animal Products Regeling dierlijke producten - Regulation Animal Products Verordening EG nr. 1234/2007 - Specific regulations agricultural products Verordening EG nr. 589/2008 - marketing standards eggs Verordening EG nr. 543/2008 - marketing standards poultry40

Besides those Acts the businesses in the poultry and egg sector also have to act in accordance with the Hazard Analysis Critical Control Points (HACCP-system). This is an internationally recognized system for reducing the food safety risks. This system requires that companies that work with food must have a food safety plan that describes the hygiene and safety risks. These rules can be based on for example the shipping and transport of the food, the packaging of the food, the storage of the food or the machines that are used by the production of the food.41 One of these rules is that if a company discovers a harmful substance in their product they are obliged to report this to the Nederlandse Voedsel- en Warenautoriteit (NVWA). The NVWA is an institution under surveillance of the ministry of EZ and plays an important role in reporting and monitoring the Veterinary Sector. We will subsequently describe the context of the NVWA more extensively. Surveillance on the compliance of the rules set by the HACCP-system is the responsibility of the NVWA. The NVWA approves certain quality systems that have the purpose to improve self-regulation among the companies in the poultry and egg sector. One example is the Bureau de Wit Keurmerk Voedselveiligheid. This is an independent national operating organisation that counsels on food-, water- and air safety as well as on vermin control. A label of endorsement of the Bureau de Wit Keurmerk indicates that the organization meets with the standards that are demanded by the laws and guidelines according to food safety and hygiene.42 Businesses who score ‘green’ on this label are being considered to receive less inspection by the NVWA.

40 (Nederlands Controle Autoriteit Eieren. (2013) Over NCAE. Retrieved June 20th, 2016, from

http://www.ncae.nl/pages/over-ncae.aspx 41 Rijksoverheid. Voedselveiligheid in Europa. Retrieved June 20th, 2016, from

https://www.rijksoverheid.nl/onderwerpen/voeding/inhoud/voedselveiligheid-in-europa 42 Bureau de Wit. Over Bureau de Wit. Retrieved June 20th, 2016, from https://www.bureaudewit.nl

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Administrative parties The stakeholder that implements the (inter)national rules and guidelines set by the European Union and by EFSA, is the Dutch government. The ministry of EZ is among other things responsible for the agriculture in the Netherlands. In the item food safety the ministry of Health Welfare and sports (VWS) is responsible for the part where people get sick, but the ministry of EZ has the responsibility for the (safe) production of food and the resources and material involved.43 44

The government has the following priorities with regard to nutrition: the consumer should have the ability to choose for sufficiently healthy, safe and sustainable food and drinks. Therefore the government has to ensure that manufactures produce safe foods in a hygienic way. The food production should not come at the expense of the environment or animal welfare. The government promotes a sustainable food production and the reduction of unnecessary waste of food.45

You could say that the ministry of VWS is more concerned with human health and the ministry of EZ with the animal health in the prior process. However, there are more interests at stake. The ministry of EZ represents also the interests of the (food) market and wants a healthy market as well as a(n international) financial beneficial market. This tension in interests has lead to many discussions about which ministry in the Netherlands has the final say in food safety issues. Faber, member of the parliament of the Christen Unie stated in 2015 that the NVWA in her opinion had to fall under the ministry of VWS, because their only interest should be the people’s health. She thought that the everlasting dilemma of health versus economic interests was not good for the people’s trust in the NVWA and in food safety.46

A rapport composed by Marcel van Silfhout elucidates the regulation of control of the veterinary sector by the NVWA and ministry of EZ and its disbalance with the public health sector. It states that the collaboration between the ministry of Public Health and Veterinary Sector - ministry of EZ is not close. This results in gaps and in a higher occurrence of Salmonella incidences.47

The actual inspection and supervision in the agriculture business is not under control of the ministry of EA, but is delegated to the NVWA. Both the ministries of EA and of HWS have regular meetings with the NVWA. The ministry of EA is also the formal client of different investigations in the field of food safety; this concerns the DLO, RIKILT at the Central Veterinary Institute.48

43 Rijksoverheid., Voedselveiligheid in Europa. Retrieved June 20th, 2016, from https://www.rijksoverheid.nl/onderwerpen/voeding/inhoud/voedselveiligheid-in-europa 44 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers (NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 45 Rijksoverheid., Voeding. Retrieved June 21th, 2016, from https://www.rijksoverheid.nl/onderwerpen/voeding 46 Scharenborg M., (01-04-2015) NVWA hoort niet bij Economische Zaken. Retrieved June 21th, 2016 from http://www.pigbusiness.nl/nieuws/3200/nvwa-hoort-niet-bij-economische-zaken 47 Van Silfhout M., (September 2013) Uitgebeend – De strijd om de voedselveiligheid. Retrieved June 21th, 2016, from http://www.maatschappijenveiligheid.nl/wordpress/wp-content/uploads/2013/10/voorpublicatie-onderzoek-voedselveiligheid-Marcel-van-Silfhout.pdf 48 Boer, de A., Doornbos, H. & Wesselink, T. (2014) Berenschot, Evaluatie Wettelijke Onderzoekstaken Voedselveiligheid.

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(Independent) Research Institutes The ministry of EA contracted the Wageningen University and Research Centre for investigation in the field of food safety. The Central Veterinary Institute (CVI), performer of Stichting Dienst Landbouwkundig Onderzoek (DLO), cooperates with the government, but also with the business world to improve health for animals and humans by prevention and control of animal diseases. The CVI also is notified when there is an outbreak risk from the veterinary sector and advises the NVWA. The CVI works closely together with the GD (pp RIVM). The CVI has several research projects, and an important one to mention is RIKILT, which does independent research on the topic of food safety and quality. The tasks of RIKILT include for a large part advising the ministries of EA and HWS, examining law on behalf of the ministry of EA and the NVWA and advise in case of outbreaks.49

Structure of the control of Salmonella In the following figures (6 and 7) you can see that in the control of zoonotic diseases the main parties involved are the ministry of VWS and EZ, the NVWA, the RIVM, the GGD and the GD. These stakeholders will be explained below. In the last part of this chapter there will be other parties described who don’t have a formal role in the control of Salmonella in poultry, but who do have a big interest at stake and a different perspective on the issue.

Figure 650

49 Wageningen UR. Taken. Retrieved June 24th, 2016, from http://www.wageningenur.nl/nl/Expertises-

Dienstverlening/Onderzoeksinstituten/RIKILT/Over-RIKILT/Taken.htm 50 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg.

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Figure 751

To detect an infection with Salmonella as soon as possible, control samples are taken at different times in different links of the production chain of eggs and poultry. The minimum amount of samples that must be taken at certain points in the production chain is laid down in European legislation. The sector is responsible for the sampling. Therefore the farmers have to take the samples. They are trusted that they take these samples in the correct way according to the protocol. The samples are tested in certified laboratories. The certification of the laboratories is provided by the NVWA. The NVWA monitors the poultry sector and checks if the farmers take their samples on time. The RIVM monitors the laboratories and advises the NVWA about their quality.52

The compulsory sampling will be discussed below: Both the egg production chain and the poultry production chain start with the breeding flock. The chickens which constitute the breeding flock start on a rearing farm. There they are sampled at 1 day of age, four weeks of age and two weeks before they are transported to breeder farms. Adult breeding flocks in the breeder farms have to be sampled every two weeks during the laying period.53 Three kinds of samples need to be taken: fresh fecal samples, overshoes and naturally

51 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers (NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 52 Respondent 4 53 European Parliament 2003. Verordening 2160/2003, Retrieved from http://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:32003R2160&qid=1466857710847&from=EN

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mixed feces, for example from a manure belt.54 If the samples are tested positive for S. Typhimurium or S. Enteritidis, the entire flock, including day old chicks, has to be slaughtered or destroyed. These two serovars are most often associated with human disease. Besides, S. Typhimurium is the most frequent transmitted serotype from mother hen to descendants. Non-incubated eggs from a Salmonella positive breeding flock have to be destroyed or can be used for consumption if they have undergone a treatment which guarantees the elimination of Salmonella. Incubated eggs of a Salmonella positive breeding flock have to be destroyed or have to be treated. The hatching eggs produced by breeder farms are transported to hatcheries. The product of these hatcheries are day old chicks. In the egg production chain, these day old chicks are transported to rearing farms. They have to be sampled at one day of age and two weeks before transport to a layer farm. The pullets at a layer farm have to be sampled every 15 weeks. Eggs from a Salmonella positive laying flock shall only be used for consumption if they have undergone a treatment which guarantees the elimination of Salmonella.55 It is forbidden to deliver these eggs to packing stations to prevent them from ending up in the retail untreated and available for direct consumption.56 In the poultry production chain, the day old chicks are transported from the hatchery to the broiler farm. Sampling takes place just before the broilers leave the farm for slaughter.57

NVWA The Nederlandse Voedsel- en Warenautoriteit, (NVWA), is responsible for the control of food safety and thereby monitors several societal values like safe food and products, the health of plants and animals, the wellbeing of animals and nature.58 It consists out of seven different compartments: five different sections, a board of managers and an agency of risk judgement and the programing of research. The general inspector has the leadership of the whole organization. The rules, guidelines and laws obliged by the European Union and the Government of the Netherlands, as described above, are to be strictly observed by all the different parties. The main aim of the NVWA is to monitor whether those rules are being executed and to take measures when there are factors that are not correct. Turning to Salmonella, the NVWA tests all different kinds of products on a yearly basis to determine whether they meet the requirements set by the law. The NVWA monitors the hygiene of the companies as well. Thereby it is taken into account whether the company has well written records of their production system and if they work via the HACCP protocol.59

Apart from this, the NVWA checks if the farmers meet the monitor commitments. The NVWA itself performs the official monitoring in relation to Salmonella. Before 2015 a veterinarian

54 European Parliament (2010). Verordening 200/2010, Retrieved June 24th, 2016, from http://eur-

lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010R0200&qid=1466857799374&from=EN 55 European Parliament 2003. Verordening 2160/2003, Retrieved June 24th, 2016, from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003R2160&qid=1466857710847&from=EN 56 Respondent 2 57 European Parliament 2003. Verordening 2160/2003, Retrieved June 24th, 2016, from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003R2160&qid=1466857710847&from=EN 58 Nederlandse Voedsel en Warenautoriteit Ministerie van Economische Zaken. Jaarverslag 2015. Retrieved June 24th, 2016, from https://www.nvwa.nl/onderwerpen/hoe-nvwa-werkt/dossier/jaarverslag-2015 59 Respondent 2

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performed those monitoring tasks related to Salmonella for laying hens businesses. The European Commission has enforced the NVWA to do the monitoring since 2015.60

The European Law enforces that all laying farms take samples every 15 weeks. In the Netherlands the layer hens are vaccinated against Salmonella. Nevertheless, the samples are taken in the obliged periods. These samples will be tested in labs that are acknowledged by the NVWA. If a sample is Salmonella positive it has to be reported to the Nationaal Vergiftigingen Informatie Centrum (NVIC), which was a department of the ‘Rijksinstituut Volksgezondheid en Milieu’ (RIVM), since 2011 it is part of University Medical Centre Utrecht (UMC Utrecht). The NVIC itself will take and test samples and test them of the primary laying farm. If this sample is positive as well, the farmer can either accept this fact and the measures that need to be taken or the farmer can decide to test another sample. The costs of the extra trial will be for the farmer himself. By this you can see the intercorporation between the NVWA and the RIVM. The other way around is possible as well. The RIVM or the Gemeentelijke Gezondheidsdienst (GGD) are able to ask the NVWA to perform source research when animals are supposed to be related to illnesses amongst humans. The NVWA decides whether they will perform research based on an estimation of risk and possibility to take samples of the source.61

RIVM Besides the NVWA, the ‘Rijksinstituut Volksgezondheid en Milieu’ (RIVM) is another important stakeholder in the control of Salmonella. Where the NVWA is concerned with the animal health and food safety, the RIVM is concerned with the human side and the human disease.62 The RIVM is concerned with scientific research for the use of government policy and the enforcement of rules for public health and environment. The RIVM is an agency of the Ministry of Health, Welfare and Sports (VWS). The Law on the RIVM describes the actual tasks on the outline and the way of acting of the RIVM, as well as the supervision and control on scientific research of the RIVM. The institute has several main commissioning parties, one of them is aforementioned, the VWS, others are the ministries of Infrastructure and Environment (I&M) and Economic Affairs (EZ). International institutions like the European Union, United Nations and the World Health Organisation are principals as well. The commissioning parties create a position for the RIVM in a way that the RIVM is able to work independently on its given tasks. A continuous availability and expertise of the RIVM are essential criteria for the commissioning parties63 64. Turning to Salmonella, it is the job of the RIVM to register when there is an epidemic or infectious disease in humans. Salmonella is a zoonotic disease, which the RIVM needs to monitor. The RIVM needs to be able to recognize when there are infections caused by Salmonella and to localize what the source is of the infection. To be able to do this, the RIVM started to work together with the medical and veterinary state inspections. There are constantly samples taken in a regular time period of the animal products like poultry and products of the egg industry. In this way the RIVM

60 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 61 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 62 Respondent 2 63 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 64 Rijksoverheid., (18 April 2014) Doorlichtingsrapport RIVM Status Definitief.

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manages to monitor Salmonella in those industries.65 These rules containing the monitoring of Salmonella are obliged by the European Union.

Figure 866

As you can see in the triangle the control of infectious diseases including zoonotic diseases can be seen as two interconnected parties that work together: the infectious factors and the microbes. At the bottom you can see what the primary institutes are at the different sources, infectious or microbes. At the left you can see the GGD and at the right you’ll see the microbiological laboratories. At the top you can see the RIVM. This demonstrates that the RIVM actually regulates the infectious repression. The ‘Centrum Infectieziekten bestrijding’ (CIb) of the RIVM controls and coordinates when there is a potential threat or outbreak of an infectious disease and informs the Minister of Public Health.67 68

65 Van Zon H., Tachtig jaar R.I.V.M., Rijksinstituut voor Volksgezondheid en Milieuhygiene - Assen: Van

Gorcum. - III, ISBN 90-232-2574-0 geb. 66 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 67 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 68 Rijksinstituut voor Volksgezondheid en Milieu Ministerie van Volksgezondheid Welzijn en Sport. (9th of

February 2006) LCI-richtlijn Salmonellose. Retrieved June 25th, 2016, from http://www.rivm.nl/Documenten_en_publicaties/Professioneel_Praktisch/Richtlijnen/Infectieziekten/LCI_richtlijnen/LCI_richtlijn_Salmonellose

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Landelijke Coordinatie Infectieziekten (LCI) is an institute of the RIVM that coordinates infectious diseases, including zoonotic diseases in the Netherlands. It provides directives for primary professionals like doctors and other employees that work for the GGD and are concerned with infectious diseases. It plays an important role when there is an outbreak, however it provides general and primary information as well. The LCI guidelines are all to be found on the Internet. For Salmonella it explains what the disease is, how you can get affected by it and it explains how you can easily prevent getting an infection caused by Salmonella. Concerning salmonellosis caused by chicken eggs, it tells you never to eat a raw eggs and to always boil them well.69

The EU Zoonosis Directive obliges all member states to confer yearly and to make up surveys on the occurrence of zoonotic diseases. Because oof this the RIVM developed a surveillance program to prevent zoonotic infections and bacteria in poultry and farm animals on the whole. This program is developed in commission of the Voedsel en Waren Autoriteit / Keuringsdienst van Waren (VWA/KvW). Nowadays it is called the NVWA. The program started in 1997. The occurrence of Salmonella in laying hens has decreased significantly in the period from 1999 to 2002. A conceivable explanation for this decrease can be allocated to the control measures the poultry industry has taken.70

GD The Dutch organization for animal healthcare is called the GD. The GD aims to improve animal health in sake of the animal, the farmer and society. It performs over 4 million laboratory tests per year and owns one of the largest veterinary laboratories in the world for this purpose. The GD employs laboratory staff, veterinarians, scientists, information specialists and market employees. They carry out animal health monitoring, do practical research and develop programs for disease prevention and control.71 It is noteworthy that on the website of the GD there is a special page for Salmonella in cows and in the cow industry with a plan to act up against this illness and on the website there is not such information about Salmonella in poultry or eggs72. At the same time, the GD plays an important role in the detection and control of Salmonella in for example chicken eggs in the early stage. The farmer is obligated to report to the veterinarian, the NVWA and the GD when he notices that a zoonotic disease emerges in his (poultry) farm.73 The NVWA, RIVM and the GD are closely working together in sharing information and the exchange of expert knowledge.74 This coaction differs for each region and is formally described in the Protocol

69 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 70 Bouwknegt M., Dam-Deisz W.D.C., Wannet, W.J.B., van Pelt, Visser G., van de Giessen A.W., (January

1998-December 2002). Surveillance of zoonotic bacteria in farm animals in the Netherlands. RIVM report 330050001/2004. 71 Gezondheidsdienst voor Dieren (GD). Over GD. Samenwerken aan diergezondheid. Retrieved June 26th,

2016, from http://www.gddiergezondheid.nl/de-gd/over-de-gd 72 Gezondheidsdienst voor Dieren (GD). Salmonella-aanpak. Retrieved June 26th, 2016, from

http://www.gddiergezondheid.nl/producten%20en%20diensten/producten/rundvee/salmonella-aanpak 73 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg, 13, figuur 2. 74 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg.

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Regionale Samenwerking Zoönosen en Voedselinfecties.75 The core task of the GD is the monitoring of the health of the Dutch livestock. This is being done by consultations of the livestock farms. It is noteworthy that the GD is a private organization and that the testing of samples from farms takes place on a commercial base. The GD also hands out certifications to the farms that follow a voluntary program to improve and prove the health of their farm. In the cases of zoonosis that are dangerous and have a high risk of spreading the GD has a responsibility for prevention and control. That’s why they take samples of livestock to check on for example salmonellosis.76

GGD The Gemeentelijke Gezondheidsdienst (GGD) is an institution of the government and belongs to the ministry of VWS. It has a public health care authority. Several tasks the GGD has to fulfil are to survey groups that carry a higher risk on certain diseases or getting infected by infections, building campaigns of vaccinations and the coordination of outbreaks, like Salmonella. Doctors are obliged by the Act of Public Health (the Wet Publieke Gezondheid (WPG)) to register several infectious diseases to the GGD and one of these diseases is salmonellosis. The GGD will take measures to control the infectious disease in consideration with the patient, doctor and institution. The measures are prescribed in the ‘LCI-richtlijnen’, which are made by the LCI, an institution of the RIVM (as mentioned above). The GGD needs to report the infection to the ‘Centrum voor Infectiebestrijding’ (CIb), in an instructed time period. If the infection contains a zoonotic or food related infection, the GGD has to report this to the NVWA.77 78

The occurrence of infectious diseases is relatively frequent. As already discussed above, it is obliged to inform the government about epidemics, and to take measures if needed. The RIVM has to report when national threats occur. Because of the great importance of the good detecting the ‘signaleringsoverleg’ was established on January 1st 1999. The ‘signaleringsoverleg’ is a consultation in which the different parties inform each other. It is held on a regular basis. The main aim is to generate trustworthy signals concerning infectious diseases and to record this with all parties that are involved.

Beyond these formal stakeholders who actually are actively involved in the decision making process there are a lot more actors who do have an important interest in this matter and try to influence the policy through other (informal) ways. We will discuss those following the chain shown in figure 5.

Poultry Farmers Poultry farmers in the Netherlands are not required to vaccinate their chickens against Salmonella. For laying hens and breeding flocks vaccines are available against S. Enteritidis and S. Typhimurium (both zoonotic).79 When a laying farm has ever had a case of Salmonella, it is

75 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 76 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 77 Jacobs, P., van Kessel R., Langelaar M., Stenvers O., Wulf M., van den Kerkhof (RIVM) J.H.T.C., Stenvers

(NVWA) O.F.J., (2014). Vademecum Zoönosen Een praktische gids over de melding, signalering en bestrijding van zoonosen in de humane en veterinaire gezondheidszorg. 78 GGD. Algemene Brochure GGD Nederlands. Retrieved June 27th, 2016, from

http://www.ggd.amsterdam.nl/ggd/ 79 GD. Vaccinatiemogelijkheden binnen de wettelijke kaders voor leghennen. Retrieved June 27th, 2016,

from

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obligatory to vaccinate from that moment on. The ‘Gezondheidsdienst voor Dieren’ (GD) advises poultry farmers to vaccinate their animals, in addition to adequate hygiene management.80 Every year, poultry farmers have the possibility to apply for grants from the Netherlands Enterprise Agency (RVO) for purchase of vaccines against Salmonella. They can make this request via their supplier of the vaccinated animals through an authorisation form. The grant amounts to 14 cents per vaccinated animal. With this arrangement, the European Union wants to diminish the number of Salmonella contaminations.81 It seems a bit contradictory that poultry farmers have to pay for the vaccinations in the first place, because they also have to pay animal health tax to the ‘Animal health fund’ (Diergezondheidfonds). The Animal health fund is part of the ministry of Economic Affairs and it is used to prevent and control infectious diseases, including disease caused by S. Arizonae, S. gallinarum and S. Pullorum.82 However, these Salmonella types are not zoonotic, which means that the vaccinations cannot be compared with the preventive measures that are financed by the Animal health fund. For poultry farmers it is advantageous to prevent Salmonella, because if Salmonella is present, the farmer faces the risk that the flock has to be culled. This will have economic consequences for the farmer. When Salmonella is identified in samples, it has to be directly reported to the NVWA. From that moment on, it is forbidden to transport the animals. After verification of the presence of Salmonella, the animals are slaughtered. The farmer has to pay for the removal and slaughter of the animals. In case of laying hens, the eggs may only be transported to the egg processing industry for heating.83

The interests of the poultry farmers are represented by NEPLUVI (Nederlandse Pluimveeverwerkende Industrie). On their website, they present a positive image of salmonellosis caused by poultry. They claim that Salmonella in poultry is not a big threat to public health and that it only in a few cases leads to infection. Besides, they emphasize that Salmonella in other products that are not heated before consumption, poses a much greater risk. Lastly, they indicate that a downward trend can be observed in salmonellosis cases in Europe over the last years. However, they do acknowledge that the consumption of eggs and egg products still lead to most food related human Salmonella infections.84 The positive message of NEPLUVI shows that the poultry processing industry has a clear interest in the general public having a positive view on Salmonella in poultry. If the public starts to think that poultry is too unsafe to eat, the sales numbers will decline, which is economically unfavourable for the poultry industry.

Veterinarians All veterinarians and (veterinary) research institutes are obliged to notify the Netherlands Food and Consumer Product Safety Authority (NVWA) when they have indications of salmonellosis. The

http://www.gddiergezondheid.nl/~/media/Files/Vaccinatieschemas%20Pluimvee/Vaccinatiekaart%20leghennen.ashx 80 GD. Salmonella. Retrieved June 27th, 2016, from

http://www.gddiergezondheid.nl/diergezondheid/dierziekten/salmonella-bij-de-kip-algemene-informatie 81 Veearts.nl. Subsidie voor aankoop vaccins tegen Salmonella. (29 October, 2015). Retrieved June 27th, 2016,

by http://www.veearts.nl/2015/subsidie-voor-aankoop-vaccins-tegen-salmonella/ 82 Rijksdienst voor voor ondernemend Nederland. Diergezondheidsfonds. Retrieved June 27th, 2016, by

http://www.rvo.nl/onderwerpen/agrarisch-ondernemen/dieren/dierziektepreventie/diergezondheidsfonds 83 Nederlandse Voedsel- en Warenautoriteit Ministerie van Economische Zaken. Pluimvee. Retrieved June

27th, 2016, by https://www.nvwa.nl/onderwerpen/dieren-dierlijke-producten/dossier/pluimvee/monstername-zoonotische-salmonella/aanpak-afhandeling-zoonotische-salmonella-bij-pluimvee-2016 84 NEPLUVI. Salmonella besmetting door pluimveevlees veel minder dan door chocolade. (2015). Retrieved

June 27th, 2016,by http://www.nepluvi.nl/page/530/salmonella-besmetting-door-pluimveevlees-veel-minder-dan-door-chocolade.html

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‘Koninklijke Nederlandse Maatschappij voor Diergeneeskunde’ urges veterinarians to do this consequently in order to gain insight in the occurrence of Salmonella (KNMvD).85

In practice, not all of these cases are reported.86 A possible explanation is that veterinarians are afraid to damage the relationship with the farmers. Not only with the concerned farmer, but also with other farmers when the news spreads. Factors of interest are underlying reasons. If a case is reported, the NVWA would start a research to confirm the Salmonella case. If the sample turns out to be positive the chickens either needs to be slaughtered or the chickens (eggs) could only be used for industrial processing. This has a major economic impact. The veterinarian is mainly concerned with animal health and less concerned with the economic factors of the production of meat or eggs, which are of more importance to the farmer.

Slaughterhouses Slaughterhouses would like to see that poultry farmers take more measures to prevent Salmonella infection, according to René Welpelo from slaughterhouse Plukon. The financial consequences of the presence of Salmonella in broiler chickens can be up to tons of euros. Depending on the type of Salmonella the meat has to undergo a special preparation before distribution to the consumers.87 The Slaughterhouses are being looked after by ‘the Centrale Organisatie voor de Vleessector (COV). Which is an organisation that looks after the interests of employers in the Dutch national and international meat sector.

Supermarkets Supermarkets (represented by the ‘Centraal Bureau Levensmiddelenhandel’) are responsible for the safety of the food they sell. If retailers have indications of the presence of Salmonella in eggs, they are responsible for withdrawal from the market. They are also required to inform consumers and to notify the authorities. If products with Salmonella are already sold, retailers have to organise the recall of these products. Supermarkets have an interest in a proper handling of the case, because it is important not to lose the trust of their customers. Fewer customers will of course lead to financial consequences for supermarkets. Retailers are dependent on their suppliers to learn about potential health risks, according to Leon Mol from Ahold.88 He claims that it is impossible for retailers to be an expert with regard to all products in their assortment. In guaranteeing food safety, retailers have to take account of food trends. For example, when eating raw food is a trend, it becomes more important that supermarkets sell pathogen free food. Recently it became a growing tendency to feed pets with raw flesh89. This results also in a higher risk for pet owners to get infected. Retailers need to think about how to deal with trends like these. Supermarkets can benefit from having strict food safety measures by using it as a marketing strategy. Besides, if all retailers would decide to sell only completely Salmonella free eggs and chicken, this would be a considerable turning point. The poultry sector would then be forced to take measures against Salmonella contamination. For example, in 2005, supermarkets stopped selling eggs of caged chickens in anticipation of a law forbidding ‘leg batterijen’.90

85 KNMvD. Salmonella meldingsplichting. (17th of November, 2015). Retrieved June 27th, 2016, by

https://www.knmvd.nl/actueel/nieuws/item/10866269/Salmonella-meldingsplichtig 86 Veearts. Verwarring over meldingsplicht salmonellose. (17th of Febryary, 2014). Retrieved June 25th, 2016,

by http://www.veearts.nl/2014/verwarring-over-meldplicht-salmonellose/ 87 Ellenkamp R., Zieverink I., Salmonella de keten uit. (18th of May, 2016). Retrieved June 25th, 2016, by

https://www.pluimveeweb.nl/artikelen/2016/05/salmonella/ 88 Mat J., (28th of July 2000). Wees gewaarschuwd voor de kip. NRC Webpagina’s. 89 Nu.nl. (25th of September 2015). Gezondheidsrisco’s door trend om huisdier rauw voedsel te geven.

Retrieved June 25th, 2016, by http://www.nu.nl/gezondheid/4132662/gezondheidsrisicos-trend-huisdier-rauw-voedsel-geven.html 90 CBL. Duurzaamheid. Eieren. Retrieved June 25th, 2016, by

http://www.cbl.nl/activiteiten/duurzaamheid/eieren/

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Noteworthy is the fact that this only applies to the eggs for consumption, in all products sold by supermarkets in which eggs are processed, caged chicken eggs are being used apart from biological products that only use biological eggs.

Consumers The largest party that has an interest in the Salmonella problem is that of consumers. For them, it is important to be able to trust the safety of the food which is sold in the supermarkets. The ‘Consumentenbond’ has a long history of fighting against the sale of Salmonella containing chicken in supermarkets. However, the ‘Consumentenbond’ also emphasizes that part of the responsibility of safe food lies with the consumer itself. According to the ‘Consumentenbond’, it is essential to preserve, prepare and consume the food products in an appropriate and hygienic manner. The refrigerator should have a temperature of about 4 °C. It is important to sufficiently heat eggs and chicken and to prevent cross-contamination through cutting boards or knives.91 Especially for young children, pregnant women, sick people and elderly it is recommended not to eat raw eggs.92 Not only the ‘Consumentenbond’ provides consumers with these advices, the ‘Voedingscentrum’ and the National Institute for Public Health and the Environment (RIVM) do the same.93 94 Since a few years ago a warning is placed on the packaging of chicken, which says: “Beware: Do not give harmful bacteria a chance to survive. Make sure that these bacteria do not end up in your food via transmission through the package, your hands or kitchen utensils. Cook this meat thoroughly to eliminate these bacteria.” Research by the RIVM has shown that 84% of the consumers sometimes reads this warning label and that 81% finds it helpful. 95 The Consumentenbond did not agree with the content of the warning. According to them, this warning is too soft and the first sentence should be ‘This product contains pathogenic bacteria’. At first it was intended to use this sentence, but in consultation with the meat industry it was decided to change it into the current used definition.96 The ‘Nederlandse Organisatie van Pluimveehouders’ (NEPLUVI) was afraid of declining sales as a result of the warning and therefore they wanted a milder description.97 The ‘Voedingscentrum’, which is funded by the authorities, agreed. The independent ‘Consumentenbond’ kept insisting on a harsher definition, but with no success. Lastly, consumers play a role in the detection of a food safety problem, such as Salmonella, by consulting a general practitioner or by complaining to the retailer, manufacturer, ‘Consumentenbond’ or NVWA.

91 Consumentenbond. Stel de temperatuur van je koelkast in. Retrieved June 26th, 2016, by

http://www.consumentenbond.nl/koelkast/temperatuur-koelkast/ 92 Dom G., van Dooren C., Consumentenbond en Voedingscentrum. (2014). Gezondheidsgids 4. Eten &

weten. Den Haag. 93 Voedingscentrum. Salmonella. Retrieved June 26th, 2016, by

https://www.voedingscentrum.nl/encyclopedie/salmonella.aspx 94 Rijksinstituut voor Volksgezondheid en Milieu Ministerie van Volksgezondheid Welzijn en Sport.

Salmonellose. Retrieved June 26th, 2016, by http://www.rivm.nl/Onderwerpen/S/Salmonellose 95 Voedingscentrum. Consument wordt graag op etiket gewaarschuwd over risico’s kip. (15th of October

2015). Retrieved June 26th, 2016, by https://www.voedingscentrum.nl/nl/nieuws/consument-wordt-graag-op-etiket-gewaarschuwd-over-risico-s-kip.aspx 96 Refdag. Ruzie over waarschuwingssticker op kippenvlees. Brussel eist hardere aanpak salmonella. (2nd of

August 2001). Retrieved June 26th, 2016, by http://www.refdag.nl/oud/econ/010802econ01.html 97 Agf. (7th of May 2015).Met voedselveiligheid valt niet te schipperen. Retrieved June 26th, 2016, by

http://www.agf.nl/artikel/125317/Met-voedselveiligheid-valt-niet-te-schipperen

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General practitioners and doctors The general practitioners and doctors in nursing homes and hospitals are the first to determine (an outbreak of) salmonellosis. When they suspect salmonellosis, they can collect defecation samples in which Salmonella, if present, can be determined. If salmonellosis is defined in two or more people with a possible connection, they have to notify the GGD and the NVWA.98

3. How is the cooperation between these different actors and what can be points of improvement? In this chapter the subquestion about cooperation between the different actors will be answered. The previous section described the different stakeholders, their interests and their formal position in the control of Salmonella in poultry. This chapter analyses the cooperation in practice at a higher level and identifies difficulties in this cooperation. Firstly this will be done from a scientific perspective and secondly from a more interpretative perspective with the use of interviews from the different actors involved.

Analysis of the relation of different supervisory body’s As described in the previous section, the government plays an important role in the supervision of Salmonella in poultry. However, in the food sector the role of the government is different and weaker than in other domestic public services. The government has no direct influence as a financier or owner. It only exerts control through external supervision on safety and quality. The actors that create and maintain the rules and guidelines on behalf of food safety are private companies as well and there is an ongoing development in the direction of more self-regulation by companies and farmers. The NVWA has a decreasing capacity of inspectors and personnel and also wants to build on a relationship based on trust with the companies and farmers. Therefore, the NVWA aims for more cooperation with the sector by for example the proposal of agreements with the companies. In this way there is scope for self-regulation and a private party other than the NVWA can do the primary control. This is called horizontal supervision. Recent scandals such as the horsemeat affair have somewhat changed this vision, and have showed the importance of a supervisory authority like the NVWA.99 Another downside of this private supervision is that different varieties of supervision are intertwined. This leads to double work and lack of transparency. Private control systems are also susceptible for different interpretations of the legal national rules. There are different forms of cooperation between public and private supervision in the food sector. The most important ones are the following:

1. Consultation and coordination between government and sector. (For example ‘Regulier Overleg Warenwet’.) 2. Sharing and interconnecting of information. (For example Risk Plaza: a database with information about risks and measures.) 3. Private support of public regulation. (For example by making rules concrete in hygiene codes.)

98 Rijksinstituut voor Volksgezondheid en Milieu Ministerie van Volksgezondheid Welzijn en Sport.(9th of

February 2006) LCI-richtlijn Salmonellose. Retrieved June 26th, 2016, http://www.rivm.nl/Documenten_en_publicaties/Professioneel_Praktisch/Richtlijnen/Infectieziekten/LCI_richtlijnen/LCI_richtlijn_Salmonellose 99 Nierop, van L. (2015, dec. 9). Waarom moet de toezichthouder dat allemaal handhaven? NRC.

Geraadpleegd via: http://www.nrc.nl/next/2015/12/09/waarom-moet-de-toezichthouder-dat-allemaal-handha-1566070

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4. Public recognition and support of private standards and monitoring forms. (For example by acceptance of self-control systems.) 5. Agreements between government organizations and businesses or the sector. 6. Private 'supervision' on public organizations. (For example with an advisory commission, the hygiene codes and the HACCP.)100

100 Waarden, van F. & Havinga, T. (2013). Vertrouwen in Toezicht op Voedselveiligheid. De Staat van Toezicht.

Amsterdam: Amsterdam University Press.

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Issues and conflicts in the relation between public and private supervision There are several important difficulties in the above-mentioned cooperation. Firstly, the relationship between public and private surveillance is a challenge. This is because of the described tension between self-regulation, legitimacy and transparency. Six (2010) has investigated the position of trust (and self-regulation) in the relationship between the enforcement party and the companies. He argues that trust inevitably fits in supervisory relationships because the government depends on the farms and companies to achieve policy goals. Furthermore, inspections cannot fully monitor the companies or predict with certainty what these companies will do. Six points out the confusion in the debate on trust and supervision by two different political motivations that are linked to each other: the idea that trust between government, citizens and businesses is vital for a well-functioning society and also the pursuit of a smaller government and more space for entrepreneurs (and less protection of the weak). The latter is, according to Six, wrongly linked to trust because it is assumed that control and trust cannot coexist in a relationship. He therefore concludes that control based on sound confidence, supplemented with trust- reinforcing control, can lead to social gains.101

The second difficulty is the capacity of the public supervision. The NVWA struggles with a low number of inspectors and a lack of capacity to supervise the whole sector. The integration of trust in the supervision style that Six (2010) describes, can solve part of this problem. Self-control can be the interpretation of this. That requires close cooperation between NVWA and supervised parties to set certain standards and criteria in combination with trust in the sector. This is already applied in the Salmonella sampling by the farmers themselves. Another problem is constituted by the limitations due to regulations of the European Union. The guidelines of EU law have to be implemented into the Dutch law and thus be maintained by the supervisory bodies. This can be an issue if the guidelines are vague or on the other hand too strict concerning the Dutch situation. One last issue is the questionable desired level of food safety. We all agree that the consumer himself has a certain responsibility regarding the food he buys and eats. However, the consumer cannot control or simply know what has happened to the eggs and meat in the whole production chain before these products end up in the supermarket. So how far do we go with the rules and enforcement of restrictions in food safety?102

These tensions find their origin also in a bigger issue, that is the confrontation between the design - made from the perspective of the public regulator - and the existing institutions of the private supervising body’s and the sector as such. The supervised companies for example sometimes stuck to a for them acceptable amount of checks and private regulators are able to thwart the desired implementation of the rules by public authorities.103

The Consumentenbond expresses for example a lot of anger towards the sector that determines which different labels they can use on their products to influence and deceive consumers.104

Not only the issue of this confrontation is important, another relevant point is the transparency and clarity of the legislation of food safety. Nowhere is clearly reflected what legislation applies, not at sector level and not at the level of the chain. It also happens that legislation has not yet entered into force or does not apply to all links in the chain.

101 Six, F.E. (2010). Vertrouwen in Toezicht. Tijdschrift voor Toezicht, 6-26 102 Waarden, van F. & Havinga, T. (2013). Vertrouwen in Toezicht op Voedselveiligheid. De Staat van Toezicht.

Amsterdam: Amsterdam University Press.) 103 Voort, van der H. (2013). Naar een drie-eenheid van co-regulering: over spanningen tussen drie

toezichtregimes. Nootdorp: Sandedruk. 104 Berends, R. (2016, mrt. 10) ‘Duurzame logo’s en keurmerken zijn een ‘noodzakelijk kwaad’. Geraadpleegd

via: http://www.foodlog.nl/artikel/de-noodzakelijke-rommel-in-keurmerkenland/

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Even if the relevant legislation is known, it is difficult to assess whether the legislation is correctly entered in the private system. The reason is that laws often include global target requirements (open standards), while private systems describe concrete requirements (closed standards). Unlike the situation with control by governmental organizations it is relatively clear in private systems, who is checked by who and how often that happens. But in the private systems the problem is that it is often unclear how and which exact legal requirements are incorporated in the systems. Also the factor trust is an important one in the agreements between different supervisory bodies. Communication and corporation between government and sector are crucial.105

Policy and measures in the cooperation in the control of zoonosis The past years there have been many zoonotic outbreaks in general. Not only for Salmonella this is a tricky issue to control but also in broader sense. That is why there are a couple initiatives from policy makers to improve the coordination between the different stakeholders on the subject of zoonosis. These developments also have consequences for the cooperation in the control of Salmonella especially in the case of outbreaks. One example of that is the Emzoo project. This project ‘Emerging Zoonosis’ started in 2007. The initiative lay with the NVWA and financial support came from the former Ministry of Agriculture, Nature and Food Quality (LNV) (now Economic Affairs). Several institutions are involved in the project including the RIVM, the health service for animals (GD), the Central Veterinary Institute (CVI) and the Veterinary Faculty of Utrecht University (UU). In a report of the RIVM is described that the ultimate goal of Emzoo was to develop a blueprint for an effective early warning- and signalling microbial threats that are relevant to both public health and animal health, including Salmonella.106

Then there are some other formal forms of cooperation that are important in case of a Salmonella outbreak. In case of a complex incident, an outbreak management team of professionals advises the administrative board of policy makers of the two ministries and these eventually translate political decisions into the practical guidelines for the local implementation.107 The municipalities and the union for municipalities in the Netherlands (VNG) are also evolved in this decision making process and carry this policy through. But not only in the case of outbreaks collaboration is required. The occurrence of infectious diseases is relatively frequent. It is obliged to inform the government about those epidemics, and to take measures if needed. The RIVM has to report when national threats occur. Because of the great importance of a good detection the ‘signaleringsoverleg’ was established at January 1st, 1999. The ‘signaleringsoverleg’ is a consultation in which the different parties inform each other. The main aim is to generate trustworthy signals concerning infectious diseases and to record this with all parties that are involved. The ‘signaleringsoverleg’ takes place weekly and its report goes to the IGZ and VWS, as well as to other parties (GGD, LCI, CVI). The human-veterinary ‘signaleringsoverleg’ consists of the GDD, NVWA and RIVM and is focused on zoonotic diseases. Those meetings are held every two or three weeks. It discusses all kinds of zoonotic diseases, including S. Enteridis or S. Typhymurium.

105 Voedselveiligheid, ketens en toezicht op controle, N. Bondt S.D.C. Deneux I. van Dijke, O. de JongA. SmeltG. Splinter S.O. Tromp J.J. de Vlieger, LEI, Den Haag, januari 2006 106 Vliet, van E., Kooij, van der J., Smout, J.E., Bijl, N. & Schetters, S.T.T. (2011). Risico’s van opkomende zoönosen voor de Nederlandse maatschappij: adviesrapport Vereniging Leefmilieu 107 One Health, RIVM, NVWA. (2014) Vademecum Zoönosen: Een praktische gids voer de melding, signalering en bestrijding van zoönosen in de humane en veterinaire gezondheidszorg.

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Cooperation in practice To find out what kind of experiences professionals have with these different forms of cooperation we have spoken to four different professionals from the sector: one veterinary expert in the field of poultry, two veterinarians working at the NVWA and one microbiological specialist from the RIVM. (For an overview, see table 1 in the introduction.) In each interview the above-mentioned ‘signaleringsoverleg’ came up. According to the respondents this is a valuable cooperation in which information is exchanged, but also different actors advise each other through a panel of specialists. Respondent 1 calls this unique for the Netherlands, because in other countries this form of consultation is less institutionalized. The Q-fever outbreak has helped to establish this form of collaboration. The collaboration is smooth. The ‘signalseringsoverleg’ meets regularly and there is often room for feedback. Respondent 2 from the NVWA also calls it a good collaboration. She says there are structural agreements between the ‘veterinarian field and the human field’: if one of both detects something important that will be deliberated. Despite the fact that this form functions very well, the different actors don’t always understand each other. They have different opinions about the control of risk factors. Respondent 1 says this has to do with different interests and sometimes with ethical questions: what do we find more important? The interest of the animal and its economic value or the interest of the human health? Besides this cooperation, the NVWA has contact with the poultry sector through the organization NEPLUVI, which represents the sector. Respondent 2 describes that she has contact with NEPLUVI for the farmers and industry of poultry meat. But regarding Salmonella in a later stadium of the production chain, when it is already in the meat or in the eggs, she has nothing to do with it anymore. Then the department of Consumer and Safety from the NVWA is responsible. They have contact with the Centraal Bureau Levensmiddelen (CBL) with represents the supermarkets and retailers. The NVWA organizes meetings with the different divisions to integrate information if there is for example a Salmonella case. According to the other respondent from NVWA, respondent 3, the contact with colleagues from other divisions from the NVWA is easy and you always know where you have to be if you need consultation. She is not included in the cooperation with the RIVM, but does have contact with the NCAE and the GD about contaminated eggs, when these are detected. AVINED is another representative of the sector where she has contact with. She calls the relationship with the sector a tough one, because the farmers never like to be controlled, and the control has become even stricter than it used to be. This reflects in the relationship between the government (and NVWA) and NEPLUVI, who have different interests. At the same time the sector is important, because they have to carry out the monitoring in the end, according to respondent 1. Respondent 3 from the NVWA pictures the NVWA as a governmental organization and they ‘just have to enforce the law’. What the background is from these European and national rules and guidelines she does not know, they just implement and enforce. The RIVM advises the NVWA in the control of the labs who investigate the potentially contaminated Salmonella samples. Also the RIVM does second opinions on positive samples if the NVWA needs them. According to our respondent from the RIVM, respondent 4, this does not happen regularly. The NVWA has the biggest role in the detection of Salmonella, the RIVM has a more supporting role. The RIVM does have a role in the control of Salmonella, according to respondent 4 they have contact with the GD, the CVI, the NVWA and university’s in the research on a zoonosis like salmonellosis. The RIVM is obligated to report data to the European Union, for the EFSA (European Food Safety) report. From the interviews a big point was that all different parties and actors have different ways of coordination in the control of Salmonella. However, their focus is still more on their little piece of the chain. The respondents talk a lot about their own specific tasks and mention multiple times ‘that is not my expertise, I don’t know how they do that, what happens after or where it comes

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from’. This is noteworthy because of the emphasis that the literature describes on chain responsibility. In the next paragraph we look at other European countries for best practices regarding this issue.

Other European countries and the policy of cooperation in food safety issues It has been observed that the implementation and funding of supervision and control of food safety is strongly influenced by the historical developments and the administrative culture. That explains the large differences between different European countries despite the fact that they must comply with the same European regulations. The European framework offers space for that. This makes the formulation of good practices for the Netherlands a difficult exercise, but there are lessons to be learned from the policies and cooperation in other European countries. Belgium is ahead of all EU Member States when it comes to the translation of EC Regulation 882/2004 into national policy. An important feature in the Belgian policy is the importance of chain liability. It works in Belgium, because they have established one new institute (FAVV) that addresses the sector on the centralized responsibility for food safety and the financing of different products considering the whole chain and not just its own responsibilities. In the Netherlands this offers perspective for the ambitions of the NVWA regarding division of responsibilities between public and private parties and transparency. Maintain different prices for control of food safety as in England would not fit in a country like the Netherlands where companies are treated equally. However, it is a recommendation to provide unpaid advice and guidance to the companies in the implementation of the rules to be able to meet the requirements. The decentralized implementation of control of food safety, as in Germany, contributes to a smaller distance between the companies and the inspectors. This is according to administrators not harmful for the independence of the inspectors. The tariff structure is worth further study since it takes into account the size of companies and locally it is still relatively simple. In the Netherlands on the contrary, it is sought to reduce the amount of tariffs in favour of transparency and simplicity. The question is whether the issue about transparency should be sought in the amount of prices and if the German decentralized policy would work in the Netherlands. In Denmark self-control through auto control systems as the obligatory Smiley system takes an important place in the policy on food safety. This works well there, entrepreneurs who meet the requirements can thus distinguish themselves in public from the non-compliers.108 Overall the collaboration in the control of Salmonella in the Netherlands is structured well and the professionals have good experiences with the cooperation. But with the freedom of self-regulation of the companies and farmers, there is also a bigger responsibility for these stakeholders. In order for this control to work, all the actors involved have to feel and act responsible for the safety of the eggs and meat, not only for their own part of the chain, but for the whole chain in general to prevent negative consequences for the quality of the control. That is also the consequence of the structural division between veterinary and human health. It is a logic assumption that this division will always be an issue and that is not necessarily a problem. It is important that the interests of both sectors are being represented and that is exactly what happens in the cooperation of these disciplines. The NVWA plays a big role in this, and their position is a dubious one, because they supervise the sector they represent at the same time. Besides these points, the practical cooperation between the stakeholders seems positive.

108 Wubben, E.F.M. & Hubeek, F.B. (2006) Europese 'good practices' voor de VWA, De implementatie van EG-

verordening 882/2004 in België, het Verenigd Koninkrijk, Duitsland en Denemarken, Wageningen U.R.

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4. How are actors and their cooperation of influence on the spread of Salmonella and the occurrence of salmonellosis? In the previous sub question we have discussed the cooperation between different actors concerning the poultry industry and Salmonella transmission. In this chapter we will elaborate on how these actors and their cooperation are of influence on the transmission of Salmonella and the occurrence of salmonellosis. To create a clear overview, we made a scheme shown in figure 9 for the production of eggs and in figure 10 for the production of broiler meat. These schemes show how Salmonella can be transmitted and eventually infect consumers and how the different actors are connected to each other and to the production chain. The black arrows show communication between actors. The green arrows show the flow of products to the various links in the production chain. The red arrows illustrate the transmission of Salmonella. The actors are shown in three different colours to clarify which actors form the production chain (green), which actors are involved in the detection of Salmonella (yellow) and which actors have a regulating or advising function (purple).

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Figure 9

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Figure 10

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Transmission of Salmonella in the production chains

In several points in the production chain of eggs and poultry, contamination with Salmonella can occur. The contamination with and transmission of Salmonella is illustrated in the schemes by the red arrows. Transmission routes of Salmonella within the production chain can be divided in two categories: Dependent transmission and independent transmission. Dependent transmission is also called vertical transmission. It is a result of Salmonella contamination in a previous component of the production chain.109 Vertical transmission of Salmonella from breeder flocks to their progeny is an example of a route of infection. Salmonella can easily enter the contents of the hatching eggs, where it is protected against disinfection treatments of the outside of the eggs before and during hatching. In the Netherlands, the contamination of the breeder stock is reduced to a minimal level due to a successful Salmonella control programme. Therefore, the contribution of infected breeder flocks to infections in laying flocks or broiler flocks is small.110 The second route of infection, independent transmission, is a result of contamination from the environment and is therefore determined by the hygienic conditions of the company.111 Flocks can be infected from environmental sources during the rearing period. The consequence of these two routes of infection is that a certain percentage of laying flocks will be infected at the start of the laying period. After the rearing period the flocks are transported to layer farms. An improperly cleaned and disinfected poultry house, which is contaminated with Salmonella, may lead to infection of the flock that is subsequently introduced into the house. Flocks can also become infected from other sources present on the farm. If a multiple-age system for laying flocks is used on the farm, Salmonella can be easily transmitted from already infected flocks to new flocks because of a lack of hygienic precautions. Salmonella infected rodents, birds or insects are temporarily driven out by the cleaning and disinfection procedures, but can transmit Salmonella into the poultry house after the introduction of a new flock. Laying flocks may become infected by other environmental factors outside the farm as well. Visitors and improperly cleaned and disinfected materials like lorries and cages can transmit Salmonella from external sources like another contaminated farm or a slaughterhouse to the farm. Vermin can transmit Salmonella over larger distances. Lastly, feed contaminated with Salmonella can also introduce an infection112. Laying flocks infected with S. Enteritidis or S. Typhimurium can produce eggs contaminated with these types of Salmonella that are dangerous for consumers.113 The eggs can be distributed to the egg processing industry or to packing stations. In the egg processing industry, the egg products are pasteurized preventing further transmission of Salmonella. From the egg packing station, the contaminated eggs can be distributed to retail or to food service.114 If these eggs are heated insufficiently prior to consumption they can cause salmonellosis in the consumer.

109 Nauta, M.J., Van de Giessen, A.W., & Henken, A.M. (2000). A model for evaluating intervention strategies to control salmonella in the poultry meat production chain. Epidemiology and Infection, 24(3), 365-373. 110 Van de Giessen, A.W., Ament, A.J.H.A., & Notermans, S.H.W. (1994). Intervention strategies for Salmonella enteritidis in poultry flocks: a basic approach. International Journal of Food Microbiology, 21(1-2), 145-154. 111 Nauta, M.J., Van de Giessen, A.W., & Henken, A.M. (2000). A model for evaluating intervention strategies to control salmonella in the poultry meat production chain. Epidemiology and Infection, 24(3), 365-373. 112 Nauta, M.J., Van de Giessen, A.W., & Henken, A.M. (2000). A model for evaluating intervention strategies to control salmonella in the poultry meat production chain. Epidemiology and Infection, 24(3), 365-373. 113 Whiley, H., & Ross, K. (2015). Salmonella and eggs: from production to plate. International Journal of Environmental Research and Public Health, 12(3), 2543-2556. 114 Agricultural Economics Research Institute (2003). Report 2.03.03 The future of the Dutch egg processing industry. Retrieved June 28th, 2016, from https://core.ac.uk/download/files/153/6654764.pdf

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Infected broilers serve as reservoirs of Salmonella. It is present in their intestines and it is secreted with their feces. The main cause of salmonellosis as a result of consuming poultry, is therefore contamination of meat with fecal material of infected animals.115

Sampling and measures on Salmonella positive farms

The presence of Salmonella can be detected at several stages of the production process. Although infections with S. Enteritidis and S. Typhimurium in poultry are usually subclinical, sometimes these are noticed and diagnosed by the veterinarian. Both the veterinarian and the farmer can report this to the GD, which monitors animal health in the sector and can report to the NVWA. However, an infection of the flock with S. Enteritidis or S. Typhimurium usually goes unnoticed. To detect an infection with Salmonella as soon as possible, control samples are taken at different times in different links of the production chain of eggs and poultry. The minimum amount of samples that must be taken at certain points in the production chain is laid down in European legislation. The sector is responsible for the sampling. Therefore, the farmers have to take the samples. They are trusted that they take these samples in the correct way according to the protocol. The samples are tested in certified laboratories. The certification of the laboratories is provided by the NVWA. The NVWA monitors the poultry sector and checks if the farmers take their samples on time and take the compulsory measures when samples turn out positive. The RIVM monitors the laboratories and advises the NVWA about their quality.116 Although the sector is primarily responsible for the sampling, the NVWA takes samples from a certain percentage of the farms under the guise of at random control.9 The exact compulsory sampling moments in the production process for farmers and measures that must be taken in case of a positive sample are described in the following paragraphs. Both the egg production chain and the poultry production chain start with the breeding flock. The chickens, which constitute the breeding flock, start on a rearing farm. There they are sampled at 1 day of age, four weeks of age and two weeks before they are transported to breeder farms. Adult breeding flocks in the breeder farms have to be sampled every two weeks during the laying period.117 Three kinds of samples need to be taken: fresh fecal samples, overshoes and naturally mixed feces, for example from a manure belt.118 If the samples are tested positive for S. Typhimurium or S. Enteritidis, the entire flock, including day old chicks, has to be slaughtered or destroyed. S. Typhimurium is the most frequent transmitted serovar from mother hen to descendants. Non-incubated eggs from a Salmonella positive breeding flock have to be destroyed or can be used for consumption if they have undergone a treatment which guarantees the elimination of Salmonella. Incubated eggs of a Salmonella positive breeding flock have to be destroyed or have to be treated. The hatching eggs produced by breeder farms are transported to hatcheries. The product of these hatcheries are day old chicks. In the egg production chain, these day old chicks are transported to rearing farms. They have to be sampled at one day of age and two weeks of age before transport to a layer farm. The pullets at a layer farm have to be sampled every 15 weeks. Eggs from a Salmonella positive laying flock shall only be used for consumption if they have undergone a treatment which guarantees the elimination of Salmonella.119 It is forbidden to

115 Cosby, D.E., Cox, N.A., Harrison, M.A. Wilson, J.L. Buhr, R.J., & Fedorka-Cray, P.J. (2015). Salmonella and

antimicrobial resistance in broilers: A review. The Journal of Applied Poultry Research, 24(3), 408-426. 116 Respondent 4 117 European Parliament 2003. Verordening 2160/2003, Retrieved june 18, 2016, from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003R2160&qid=1466857710847&from=EN 118 European Parliament (2010). Verordening 200/2010, Retrieved june 18, 2016, from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010R0200&qid=1466857799374&from=EN 119 European Parliament 2003. Verordening 2160/2003, Retrieved, june 18, 2016 from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003R2160&qid=1466857710847&from=EN

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deliver these eggs to packing stations to prevent them from ending up in the retail untreated and available for direct consumption.120 In the poultry production chain, the day old chicks are transported from the hatchery to the broiler farm. Sampling takes place by the farmer just before the broilers leave the farm for slaughter.121 At the slaughterhouses samples are taken on a regular basis as well. If a sample is tested positive, the entire day production has to be withdrawn from the market. Usually the meat has already been sold when the results of the sample test come back. The NVWA obliges the slaughterhouse in that case to make a General Food Law report (GFL report). The GFL report contains the type and the amount of product that is produced and to which companies it is sold. These companies have to be informed about the contamination of the meat with Salmonella and have to withdraw the products from the market. The NVWA checks if this withdrawal of the products actually takes place.122

A structure with weak links

Because of the well-organized monitoring sampling system of Salmonella in the poultry production chains of meat and eggs, Salmonella is intercepted at different points in the chain preventing it to end up on the consumer's plate. However, not all Salmonella is intercepted and some may still cause contamination of the food. But Salmonella contaminated food does not necessarily have to be a problem. Education of the consumer about the correct storage temperatures and heating of food can prevent salmonellosis. Temperatures below 8 degrees celcius inhibit the multiplication of Salmonella. Properly cooking of the meat and the eggs kills the Salmonella bacteria making the food safe to eat. The consumers also have to be informed about the risks of cross-contamination in the kitchen.123 124 The Consumentenbond, the RIVM and the Voedingscentrum are concerned with consumer education. However, this information will not reach all consumers and not all consumers will follow the advices. Cross-contamination is not only a risk in the consumer’s kitchen. In all food industries and foodservices cross-contamination with Salmonella can occur. This is especially dangerous if Salmonella or other pathogenic bacteria aren’t expected to be present in those particular types of foods. A clear example of the dangers of cross-contamination in the food industry is the large Salmonella outbreak caused by contaminated salmon in 2012 in the Netherlands.125 Despite all the controls and the education of the consumer it can still happen that a person or a group of people gets foodborne salmonellosis. An infected patient with salmonellosis may go to a general practitioner (GP). However, not all people with symptoms caused by salmonellosis will visit their GP. This makes it hard to determine the exact number of people getting salmonellosis. The GP can send a feces sample of the patient to a microbiological laboratory for culturing and serotyping of the causative bacterium, in this case S. Enteritidis or S. Typhimurium. If a GP notices a sudden raise in salmonellosis cases and suspects an outbreak a report can be made to the GGD. The GGD will inform the RIVM. In the ‘signaleringsoverleg’ the GGD and RIVM will report the potential salmonellosis outbreak informing the NVWA as well. The other way around, the NVWA will report any positive samples from farms in the production chain. If a compulsory sample from a farm is tested positive, the NVWA will take notice via the registration of positive samples in the database from Avined. The microbiological laboratory that tests the samples puts the results in

120 Respondent 2 121 European Parliament 2003. Verordening 2160/2003, Retrieved june 18, 2016, from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003R2160&qid=1466857710847&from=EN 122 Respondent 2 123 Lublin, A., & Sela, S. (2008). The Impact of Temperature During the Storage of Table Eggs on the Viability of Salmonella enterica Serovars Enteritidis and Virchow in the Eggs. Poultry Science, 87(11), 2208-2214. 124 European Parliament (2010). Verordening 200/2010, Retrieved june 18, 2016, from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010R0200&qid=1466857799374&from=EN 125 Onderzoeksraad voor veiligheid (2012). Salmonella in gerookte zalm

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the database that is also accessible for the NVWA. In case of a positive sample, the NVWA receives automatically a notification. In the scheme it is clearly visible that there are two organizational structures: the veterinary side and human side. There seems to be a good communication between the different organizations of both sides and between the different divisions within organizations. This contributes to a well-organized control system that reduces Salmonella transmission in the food production chains. Every organization has their own task and responsibility. These tasks are further divided over the staff working in divisions. This causes fragmentation of the responsibility in the control of Salmonella. In our interviews the respondents often replied on certain questions with the words: ‘I don’t know, that is not my responsibility. This is someone else’s task.’ This fragmentation has an influence on Salmonella transmission. If all subsequent tasks in the Salmonella control are executed properly and communication between divisions and organisations is well like it is in the current situation, no problems occur. However, the farmers are not monitored on how they take their samples. It is considered their own responsibility. A farmer could decide to not take this responsibility and choose for his own economic interest by sending in samples that were taken incorrectly. The ad random sampling of the NVWA at a certain percentage of farms is not enough to monitor the farmers on their sampling. The test results will come out negative and the people checking the test results will assume that the previous step in the Salmonella control, the sampling, was executed properly and will not presume that there still could be Salmonella present in the products. These contaminated products of the farmer will move further along the production chain out of his responsibility. This way, Salmonella can end up in the food of the consumer without anyone carrying the responsibility for it. The trust put in the integrity of the farmers is therefore potentially a weak link in the Salmonella control, especially in combination with the fragmentation of the responsibility.

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Conclusion The monitoring of Salmonella in the production process of poultry products in the Netherlands is organized in accordance with European legislation. The NVWA has the task to monitor all the segments of the production process. The RIVM monitors only the foodborne salmonellosis in consumers. Therefore, the NVWA and the RIVM are the main stakeholders in the control of Salmonella. They are both public authorities. The NVWA is part of the Ministry of Economic Affairs (EZ) and the RIVM is part of the Ministry of Health, Welfare and Sports (VWS). Both the NVWA and RIVM are obliged to inform the ministries when there are cases or outbreaks of (infectious) diseases and zoonotic diseases, such as Salmonella. The NVWA has a monitoring and regulatory function with regard to the whole sector. It supervises whether the different parties that form the sector act in accordance with the guidelines. The aim of the NVWA is to achieve the highest possible level of food safety. Monitoring by taking samples at regular time points is an important way of controlling the occurrence of Salmonella. The GD is an organisation that cooperates with the NVWA. The GD is a private institution and its aim is to improve animal health in sake of the animal, the farmer and society. It carries out animal health monitoring, conducts practical research and develops programs for disease prevention and control. The farmer is obliged to report to the veterinarian, the NVWA and the GD when a zoonotic disease emerges in his (poultry) farm. The RIVM has a supervising (noticing outbreaks), monitoring and regulatory function concerning infectious diseases. In the case of Salmonella its main function is to register potential outbreaks and signals of reduced food safety. Its regulatory function involves among other things the formation of LCI guidelines. The RIVM cooperates with an organisation called the GGD. The GGD is an institution of the government and belongs to the Ministry of VWS. It has a public health care authority and is responsible for the coordination of outbreaks of (infectious) diseases, such as salmonellosis. Doctors are obliged by the Act of Public Health to report certain infectious diseases to the GGD and one of these diseases is salmonellosis. The GGD has to inform the CIb, a department of the RIVM. If the infection is zoonotic or food related, such as an infection with Salmonella, the GGD has to report this to the NVWA as well. The NWVA has the authority to decide whether they think it is critical enough to investigate the case and whether it is possible to conduct research on the potential source.

As described before, many actors with different roles and sometimes even actors with double roles are involved. The parties have different interests and one finding is that the veterinary (and economic) sector and the human sector (public health) are still very separate. Striking is that there are different attempts (for example, by ‘signaleringsoverleg’ and collaboration structures,) to bring for example the NVWA and RIVM closer together. However, precisely in these consultations it becomes clear that the two sectors do not always speak the same language and that they do not always understand each other, although cooperation on a daily basis is working smoothly. Another issue is that the NVWA itself has an odd role. They act in behalf of the ministry of EZ, thus in favour of the sector, but they also have to supervise this sector. This can be problematic for the trustworthiness and credibility of the institution. At the practical level of the professional, the interviews show that the employees of the various organizations know how their activities fit into the big picture, despite the complicated organizational structures in the field of control of Salmonella. They are aware of their part in the chain, they know exactly which tasks are assigned to them and they are totally okay with that. At the same time, they oversee only that little piece and do not feel responsible for the bigger picture of the entire chain. This is remarkable, because the overview of the whole chain turned out to be very important according to literature, scientists and managers. Having this overview is

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supply chain responsibility because Salmonella is an issue that, as described in chapter one, runs through the whole production chain of poultry.

In conclusion, the Salmonella control system, in which all organizations have a particular task, is very well organised in the Netherlands. These tasks, however, cannot be entirely separated from each other. Therefore the organizations involved in the control of Salmonella in poultry need each other to fulfil their tasks. The cooperation between the involved organizations is of influence on the transmission of Salmonella in the production chains. As pointed out in chapter four, there are two organizational structures: the veterinary side and the human side. These two sides have to communicate and cooperate with each other to intercept and locate the source of outbreaks of zoonotic diseases like Salmonella on time. This communication and cooperation seems to be functioning quite well. The systematic sampling and testing for Salmonella in all links of the production chain is an effective method for the detection and interception of Salmonella in the production process. However, not all Salmonella is intercepted and some bacteria may still cause contamination of the food. The trust put in the integrity of the farmers may be a weak link in the Salmonella control. Farmers may choose for their own economic interest and take samples in an incorrect way. As described in chapter four, we thus do not know for sure if these samples are trustworthy. The NVWA is an important actor in this: they use these samples for administrative control and assume that these samples are correct. The only ‘guarantee’ is that the NVWA itself sometimes takes random samples in the sector, but that is far from enough to guarantee that the samples of the farmers are correct. Therefore Salmonella contaminated products may still end up in the food unnoticed. Because not all consumers and food services properly store and prepare their poultry products, cases of salmonellosis may occur.

In our introduction we defined One Health as follows: Any added value in terms of health of humans and animals, financial savings or environmental services achievable by the cooperation of human and veterinary medicine when compared to the two medicines working separately. This applies to the Salmonella issue in poultry in which cooperation between the veterinary and human organizations is of great importance to keep Salmonella under control and to guarantee food safety. Lack of communication would make the control of Salmonella much more difficult, since Salmonella transmission occurs from poultry products to consumers, who belong to the human domain. The source of human cases of foodborne salmonellosis due to poultry products must be sought in the production chains that are part of the responsibility of the veterinary sector. Therefore, the Salmonella issue asks for a One Health approach. This is well understood by both the veterinary and the human organizations who cooperate with each other rather smoothly in the current situation. The control is fragmented and divided, but these different links do cooperate very well and therefore the system functions as it should. Due to this definition there doesn’t seem to be a problem with the detection and control of Salmonella in the Netherlands. But, the weakest link in the chain is an issue of a more political character. Because every single link in the chain relies on the samples that are taken by the farmers in the sector and these samples are potentially not always reliable, there still can occur Salmonella in the production chain. The farmers do no longer feel responsible as soon as their sample is accepted and from that moment no one is responsible for that potentially wrongly taken sample, because everyone assumes that the system is watertight. That is an One Health issue, because it is about the chain responsibility in the whole production of chicken meat and eggs. One step further, this implies that apparently One Health is not only about the cooperation between disciplines (according to our definition). That part is functioning quite fine. It is important as a One Health researcher not to focus too much on this One Health aspect, because

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the ‘veterinary domain’ usually is interpreted as veterinary doctors, without including the farmers. The main focus of the One Health approach of Salmonella in poultry should therefore be on collaboration through the whole production chain instead of on cooperation between the two disciplines.

Recommendations First of the trust put in the farmers is an important point to be aware of. As a society we have to decide if we want to do something with this finding and if we want to do something about this weak link. This is a political and subjective consideration, with two extremes: On the one hand it is a good thing that farmers are given the trust and responsibility to supervise and control their own sector. The self-regulating system shows faith in the sector and the awareness of this responsibility is enough to secure this link. On the other hand we might want to change this weak link and therefore change the sampling system. For example to transfer the process of sampling more to the whole chain by giving a mandate to professional veterinarians or let the NVWA do the whole sampling process in all the companies. In any way, there should be at least taken notice of this relatively weak link and there has to exist some form of chain responsibility in order to prevent the transfer of Salmonella in an early stage into the production chain.