Background to the VTEC/E. coli O157 Action Plan
In 2001 the joint Scottish Executive/Food Standards Agency (Scotland) Task Force on E. coli O157 produced its report including 104 recommendations to reduce the incidence and severity of verotoxin-producing Escherichia coli (VTEC) infections in Scotland. In 2001, there were 235 reported E. coli O157 cases in Scotland, and despite the Task Force's recommendations the number has remained largely unchanged, with 234 cases in 2012. Since 2001 incidence rates of E. coli O157 infection have remained consistently higher in Scotland than in other UK countries.
The absence of a decline in cases may indicate that the Task Force's recommendations were:
- not implemented, or;
- implemented but ineffective, or;
- implemented and effective, but without them the number of cases would have risen, or;
- implemented and effective, but the number of cases represents an irreducible minimum.
Annual reviews of compliance with Task Force recommendations were conducted by the Scottish Government from 2002 onwards, with additional extensive reviews by Health Protection Scotland (HPS) in 2007, and by Price Waterhouse Cooper (PwC) in 2008. These reviews were hampered by having no power to require responses from those people or agencies to whom recommendations had been made: indeed HPS and PwC concluded that 44 of the recommendations could not be evaluated, mainly because their ownership was unspecified, or the agencies concerned no longer existed. PwC therefore recommended that the Scottish Government convene a VTEC/E. coli O157 Action Group.
In late 2010 the Scottish Government invited those agencies deemed most relevant to the task to nominate members to the Action Group, which is chaired by Dr Edward Coyle, Director of Public Health, NHS Fife. The agencies were those the Scottish Government had agreed with HPS were the most qualified to advise on current controls, and on measuring compliance with, and effectiveness of, both new and existing control measures. The agencies nominated their representatives of choice to the Action Group, whose members are listed in the appendices.
The Action Group's full Terms of Reference are in the appendices, but were in essence to produce a VTEC/E. coli O157 Action Plan describing the current epidemiology and management of VTEC in Scotland and to make practical recommendations for actions to reduce the risk of infection to humans. The Action Plan should address ways to measure the implementation of its recommendations, and to evaluate their effectiveness when implemented.
The approach taken by the Action Group was to devise a logical framework to underpin a systematic and consistent consideration of risks and viable control measures related to VTEC infection.
The Action Plan therefore addresses the steps in the pathways of transmission of VTEC infection from source (colonised animal) to receptor (human case). It makes recommendations directed at specific agencies to reduce the risks at each step, and to verify where possible, whether the recommendations have been carried out, and if so, if they have been effective. Where recommendations already exist, including those from previous reports and reviews, they are addressed in the paragraphs dealing with the current position (of control measures, measures of compliance, and evaluation), but are not restated. The Action Group felt that to recommend that agencies do what they have already been recommended to do would be repetitive and unhelpful. Recommendations are therefore for new actions, and are addressed to agencies according to their specific responsibilities, or their capacity, for implementation and evaluation.
The Action Plan is intended for the action of those agencies to whom recommendations are directed, and to other interested bodies or individuals for information. It is also intended to aid Scottish Government to co-ordinate responses by the relevant agencies in Scotland, with the overall aim of minimising risk of infection to the Scottish population.
While the recommendations of the Action Plan relate to VTEC, some of the preventative strategies - for example those on reducing contamination of land for growing food crops, or of private water supplies - have the additional benefit of reducing risk from other pathogens or hazards as well, especially those of animal origin.
The Action Plan is necessarily a sizeable and detailed document. While the Action Group has tried to keep repetition to a minimum, it is inevitable that some stakeholders will wish to concentrate on chapters pertinent to their specific responsibilities. Each chapter has therefore been written so that it can be read as a free standing item, and so some definitions and issues - for example untreated water - appear in more than one chapter.
The number of recommendations for each step in the pathway is not a reflection of deficiencies in the control measures that already exist. Public water supplies, for example are extremely safe and current control measures are highly effective, but the consequences of any fault with a public mains supply are potentially very serious, and so the Action Group believes it should seize every opportunity to improve what is already an excellent regime. Similarly there are steps, such as the exposure of the public to contaminated environments, which undoubtedly pose a risk, but where opportunities for control - other than risk communication and scrupulous personal hygiene - are limited.
As the Action Group was commissioned to produce the Action Plan on behalf of the Scottish Government, the agencies represented on the group therefore endorse the Action Plan and the implementation of its recommendations. The Action Plan has been presented to Scottish Ministers as the culmination of this phase of the Action Group's work, and Ministers have been asked to respond to the Action Plan and its recommendations. The Action Group recognises the obvious implications for the resources that need to be committed to implement the Action Plan, and call upon Scottish Ministers, and the agencies to which the recommendations are directed, to ensure that the required resources are provided.
For brevity the plan provides only selected references. Generally accepted facts and well known research and legislation are not referenced, but relevant documents and papers are included in a bibliography within this document, and a fuller list of relevant references is provided online.
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