VTEC/E. coli O157 Action Plan for Scotland, 2013-2017

An Action Plan setting out recommendations to tackle the transmission of VTEC/E. coli O157 infection.


VI. SUMMARY TABLE OF RECOMMENDATIONS

SECTION VII - STEP-SPECIFIC CONTROL MEASURES, MONITORING AND EVALUATION Key Agencies
Step 1 - Controlling the excretion of contaminated faeces from colonised animals
There are no recommendations in this chapter.
Step 2 - Controlling animal colonisation from contaminated animal faeces via food, water, the environment or directly
2.1 SG and QMS, in consultation with FSAS, should work with livestock hauliers, markets, and slaughterhouses to develop criteria for adequate cleansing and disinfection facilities for vehicles used to transport livestock - which could be included in the QMS standards - and feed back to the VTEC/E. coli O157 Action Group. SG, QMS, FSAS
Step 3 - Controlling contamination of the environment from contaminated animal faeces
3.1 HSE should work with SG, HPS and SRC to arrange training sessions for agencies that have enforcement responsibility for animal visitor attractions. HSE, SG, HPS, SRC
3.2 SG and LAs, in liaison with HSE, should consider measures to ensure that animal visitor attractions make their activities known to LAs. SG, LAs, HSE
3.3 SG should liaise with agricultural educational establishments, SEPA, NFUS and other stakeholders (e.g. QMS) relevant to farming and rural communities, to ensure that watercourses and the environment are protected by correct application of relevant guidance e.g. the PEPFAA code, Safe Sludge Matrix. SG, SEPA, NFUS, QMS
3.4 SG should review current land access codes and provide guidance to minimise contamination of environments used for food crops by the public or by animals. SG
3.5 SG, in liaison with LA representatives, should establish national systems to monitor compliance with issuing and implementation of SG guidance on clearing pasture before/after recreational events involving animals that are registered with an LA (e.g. galas, agricultural shows). SG, LAs
3.6 SG, in liaison with SEPA and DPMAG, should undertake a snapshot survey of compliance with the PEPFAA Code, Safe Sludge Matrix and other relevant guidance on protection of watercourses and the environment. SG, SEPA, DPMAG
3.7 SG should then take action based on the findings of the survey of compliance with the PEPFAA Code and other relevant guidance on protection of watercourses and the environment (see Recommendation 3.6 above) and feed back to the VTEC/E. coli O157 Action Group. SG
Step 4 - Controlling the contamination of untreated water from contaminated animal faeces or the environment
4.1 SW should develop a catchment management policy to include the scope and frequency of inspections and mechanisms for feeding information from inspections into WSP. SW
4.2 SG should review current land access codes and provide proportionate guidance to minimise contamination of watercourses or the environment wherever possible, by the public or animals. SG
4.3 DWQR to monitor progress on the catchment management policy regarding scope and frequency of inspections and mechanisms for feeding information from inspections into WSP (see Recommendation 4.1 above) and feed back to the VTEC/E. coli O157 Action Group. DWQR
4.4 DWQR to assess the effectiveness of the catchment management policy regarding scope and frequency of inspections and mechanisms for feeding information from inspections into WSP (see Recommendation 4.1 above). DWQR
Step 5 - Controlling the contamination of treated water from contaminated animal faeces, untreated water or the environment
- Public Water Supplies:
5.1 SW should revise its Disinfection Policy to define a consistent national policy for:

(a) Flow proportional and residual disinfection control;
(b) Criteria for auto-shutdown of Water Treatment Works (WTW) on disinfection issues;
(c) Secondary disinfection;
(d) The requirement for duty and standby disinfection equipment.
SW
5.2 SW should compile an inventory of its existing disinfection systems to give clarity on its assets; and should ensure that its Disinfection Policy is then applied to all assets. SW
5.3 SW should ensure that all disinfection systems have the appropriate duty and standby disinfection equipment installed. SW
5.4 SW should ensure that chlorine levels at storage points in distribution systems are site specific and evidence based, to ensure satisfactory microbiological quality of supplies whilst minimising taste and odour impacts to consumers. SW
5.5 SW should carry out species identification where there are repeat failures of the total coliforms and E. coli standards from drinking water samples as per Recommendation 7.13 of the 2001 E. coli O157 Task Force Report, and should ensure that criteria for species identification are set out in the appropriate SW quality management system. SW
5.6 SW should inform public and environmental health professionals of the scope and limitations on typing of
E. coli positive water samples, and of the implications of this for operational decisions.
SW
5.7 SW should consider producing formal guidance for its staff on the assessment of performance of processes used for colour and turbidity removal to ensure consistency of approach across the country. SW
- Private Water Supplies:
5.8 SG, the DWQR, SoCOEHS and REHIS should determine local authorities' training needs for their statutory duties relating to PWS, and should develop and deliver training as appropriate. SG, DWQR, SoCOEHS, REHIS
5.9 DWQR, in liaison with SERL and LAs, should issue guidelines to LAs and to laboratories analysing PWS samples, on the forwarding of E. coli isolates to SERL for typing. DWQR, SERL, LAs
5.10 SG, in partnership with LAs, DWQR, and public health professionals should develop a strategy to further promote the benefits of the risk assessment and risk management approach for PWS and the PWS grants scheme to deliver real and lasting improvements to PWS and consequential health benefits. This strategy should include:

(a) Methods for improving awareness of the potential health risks from PWS to owners and users and their visitors, and the need for correct installation, operation and maintenance of treatment systems.
(b) SG updating section 11 of the PWS Technical Manual (Waterborne Hazard Response for PWS) to include more information on dealing with waterborne incidents; and increase the range and detail on treatment options for small supplies following consultation with LAs, REHIS, DWQR and HPS.
(c) SG, in liaison with DWQR, should review the 'Information Guide' for owners and users of PWS in line with recommendations from recent research by Aberdeen University.
SG, LAs, DWQR, REHIS
5.11 SG should consider the following recommendations from an Incident Management Team Report, which propose that SG should:

(a)"Create a compulsory registration scheme for properties supplied by a PWS, to aid rapid investigation and provision of advice subsequent to a case of E. coli O157 infection" (this should also include non-O157 VTEC).
(b) "Require landlords of properties served by a PWS, to inform their tenant(s) of this in their lease, and to advise tenants on the implications for health".
SG
5.12 DWQR should confirm that all laboratories contracted to analyse PWS samples have the appropriate accreditation and that DWQR has reminded all LAs about the accreditation requirements. DWQR
5.13 SG should liaise with LAs, REHIS and SoCOEHS, and consult with DWQR, to consider methods of improving:

(a)Compliance by owners/users of PWS serving public or commercial activities, with legislation requiring them to display notices informing the public that a PWS is in use.
(b) The extent to which PWS owners/users are complying with the advice from LA risk assessments and sampling, on how to improve/protect their supplies.
SG, LAs, REHIS, SoCOEHS, DWQR
5.14 DWQR should identify methods to monitor any of the additional control measures recommended above, if it transpires that compliance would not be measurable by existing monitoring systems. DWQR
5.15 DWQR, on SG's behalf, should monitor the effectiveness of the grants scheme in terms of water quality improvements. DWQR
5.16 SG Drinking Water Quality Division should feed back to the VTEC/E. coli O157 Action Group on the research project they will be managing on the impact of maintenance and different raw water quality parameters on the effectiveness of UV disinfection of PWs. SG, DWQD
Step 6 - Controlling the contamination of untreated food from contaminated animal faeces or the environment
6.1 FSAS and SG should support EU proposals to permit the use of lactic acid to reduce microbiological surface contamination on bovine carcases to complement good hygienic practice and HACCP based controls, and feed back to the VTEC/E. coli O157 Action Group. FSAS, SG
6.2 FSAS should continue to support initiatives which promote best practice for controlling microbiological risks including VTEC contamination across all areas of the fresh produce sector. FSAS
6.3 SG should review current land access codes and provide guidance to minimise contamination of areas used for food crops or irrigation water by the public or by animals. SG
6.4 FSAS, SEPA and SG should ensure guidance on the safe use of manures and recycled organic wastes in vegetable and fruit production is subject to ongoing review. FSAS, SEPA, SG
6.5 FSAS and SG should support the EC as it develops proposals for controls to reduce the food safety risks associated with VTEC contamination of sprouted seeds intended to be consumed raw/untreated, and feed back to the VTEC/E. coli O157 Action Group. FSAS, SG
6.6 FSAS should feed back to the VTEC/E. coli O157 Action Group the results of its review of official control microbiological sampling undertaken in approved meat establishments for verifying compliance with Food Hygiene Regulations. FSAS
6.7 FSAS should feed back to the VTEC/E. coli O157 Action Group the outcome of its data gathering exercise on compliance monitoring of Scottish vegetable and fruit producers to confirm that appropriate measures are in place to protect produce from VTEC contamination. FSAS
6.8 NFUS should consider liaising with the fresh produce sector to identify any areas where NFUS believes that industry assurance schemes may not be complied with, and feed back to the VTEC/E. coli O157 Action Group. NFUS
Step 7 - Controlling the contamination of treated food from contaminated animal faeces, untreated food, or the environment
7.1 FSAS should ensure that LAs receive appropriate training on FSA UK cross-contamination guidance and that guidance is disseminated to all relevant industry sectors in Scotland. FSAS
7.2 FSAS should ensure that effective cross-contamination control is prioritised in LA enforcement of retail and catering businesses handling raw/untreated and RTE food (i.e. handling both potentially contaminated foods, and foods not subject to subsequent treatment); and that implementation of cross-contamination controls is subject to ongoing review through the LA audit programme. FSAS
7.3 FSAS and LAs should ensure that, where possible, catering specifications for schools, care homes and hospitals take into account the principles of the cross-contamination guidance. FSAS, LAs
7.4 FSAS and REHIS should ensure that the principles of the cross-contamination guidance are embedded in training materials and guidance for food businesses in Scotland. FSAS, REHIS
7.5 SG should liaise with REHIS and SoCOEHS to ensure that LAs continue to disseminate the new Industry Code of Practice 'Preventing or controlling ill health from animal contact at visitor attractions' to all relevant businesses in Scotland. SG, REHIS, SoCOEHS, LAs
7.6 FSAS should feed back to the VTEC/E. coli O157 Action Group the outcome of its evaluation of the impact of the cross-contamination guidance in Scotland. FSAS
Step 8 - Controlling the infection of humans from contaminated treated drinking water or untreated water
8.1 SG should produce guidance warning against the drinking of untreated environmental water (e.g. from burns or rivers) by individuals undertaking commercial, educational or other outdoor activities. SG
8.2 SG should request Health Boards to ensure that IMT reports documenting outbreaks of VTEC infection due to contaminated drinking water should include not only an estimate of the speed with which control measures were applied, but also an estimate of their effectiveness. SG
Step 9 - Controlling the infection of humans from the environment or from contaminated animal faeces
9.1 The Communications Strategy Group (CSG) to be convened by SG (see Section VIII) should undertake a snapshot survey of compliance with the provision and application of health education materials and guidance on reducing VTEC risk via personal hygiene. CSG
9.2 The Communications Strategy Group should then take action based on the findings of the survey of compliance with the provision and application of education and guidance on personal hygiene (see Recommendation 9.1 above) and feed back to the VTEC/E. coli O157 Action Group. CSG
9.3 The Communications Strategy Group should undertake a snapshot survey of the effectiveness of health education materials and guidance on reducing VTEC risk via personal hygiene. CSG
9.4 The Communications Strategy Group should then take action based on the findings of the survey of the effectiveness of education and guidance on personal hygiene (see Recommendation 9.3 above) and feed back to the VTEC/E. coli O157 Action Group. CSG
Step 10 - Controlling the infection of humans from contaminated untreated or treated food
10.1 FSAS and LAs should review the display of point of sale information for unpasteurised cheeses sold loose in Scotland (including those served in restaurants) to ensure consumers are able to make an informed choice. FSAS, LAs
Step 11 - Controlling the excretion of contaminated human faeces
11.1 SG should commission a group to produce clinical guidance for clinicians, especially GPs, providing advice on the early diagnosis and management of suspected VTEC infection. This group should identify methods for monitoring compliance with its guidance, and for evaluating its effectiveness. SG
11.2 SERL, in consultation with diagnostic laboratory representatives, HPS and other relevant stakeholders, should compile a report on current thinking about the best methods to optimise rapid microbiological confirmation of non-O157 VTEC infection, and feed back to the VTEC/E. coli O157 Action Group. SERL, HPS
Step 12 - Controlling the infection of humans from contaminated human faeces via food, water, the environment or directly
12.1 SG should investigate the options for collecting and publishing any existing local data on compliance with current control measures to prevent human infections from contaminated human faeces via food, water the environment or directly, using a national format; or, if that is insufficient, conducting occasional surveys of compliance e.g. by front line NHS staff, HPTs or LAs, or via special studies of confirmed cases e.g. of nurseries, care homes, etc. SG
12.2 SG should investigate the options for evaluating effectiveness to prevent human infections from contaminated human faeces via food, water the environment or directly, using either (a) any existing local data that could be collected and published using a national format; or (b) occasional surveys e.g. of front line NHS staff, HPTs or LAs, or special studies of confirmed cases, nurseries, care homes etc. SG
SECTION VIII - PROPOSALS FOR RISK COMMUNICATION AND HEALTH EDUCATION
C1 SG should convene a Communications Strategy Group to develop and support the implementation of a comprehensive communication strategy for VTEC involving all the key agencies, and feed back to the VTEC/E. coli O157 Action Group. SG
C2 SG with NFUS should ensure VTEC risks are covered in communication with landowners and the public on access to and recreational use of pasture/intensively grazed land. SG, NFUS
C3 SG should develop information and resources for the public about VTEC risks, which may also help to reduce risk from other zoonoses; this should include: advice on supervision of children; the importance of hand washing after contact with animal and rural environments, and before eating, drinking or preparing food; and what constitutes effective handwashing (including advice against relying on anti-bacterial hand gels
or wipes).
SG
C4 FSAS and LAs should continue to highlight the risks associated with undercooked minced meat products, and promote advice on safe cooking. FSAS, LAs
C5 FSAS should ensure that consumers and caterers continue to be reminded of the potential risks associated with vegetables and fruit that are not supplied as RTE, and how these products should be prepared prior to consumption. FSAS
C6 FSAS should continue to ensure that the practices that lead to effective cross contamination control are promoted in food hygiene communication activities, including annual Food Safety Week initiatives. FSAS
C7 FSAS, in partnership with other stakeholders such as REHIS, should ensure that hand hygiene is prioritised in strategies for improving health education for food handlers in catering and domestic kitchens. FSAS
C8 SG should liaise with REHIS and SoCOEHS to ensure that LAs and HPTs continue to provide information and guidance on preventing contamination of food by human faeces in both private households and commercial premises. SG, REHIS, SoCOEHS, LAs, HPTs
C9 SG, LAs and REHIS, with input from DWQR and HPS, should develop educational materials to promote risk awareness and management for all PWS owners or users. SG, LAs, REHIS, DWQR, HPS
C10 SG should ensure that their resources for PWS owners and users include advice on early reporting of diarrhoeal illness (as this is the best way to promote early identification of contaminated supplies); prompt issuing and implementation of boil water notices; and guidance on risk communication for Health Protection Teams and LAs. SG
C11 SG should consider integrating advice on PWS into generic resources such as the SG leaflet 'Shedding Light on E. coli O157'. SG
C12 SG, SEPA and other key stakeholders, through DPMAG, should continue to work in partnership with the farming and forestry sectors in order to maximise the protection of sources of drinking water, and minimise the risk to human health. SG, SEPA, DPMAG
C13 SG, in liaison with HPS and FSAS should consider options for raising awareness of the importance of hand hygiene, both generic and targeted at specific settings such as childcare. SG, HPS, FSAS
C14 SG should consider specific measures to help young children apply hand hygiene. SG
C15 SG should provide advice for frontline NHS and LA staff on achieving early diagnosis of infectious diarrhoea; on the need for low thresholds for suspecting and testing for VTEC, especially in acute onset bloody diarrhoea; on the issues for cases with non-O157 strains, who may initially have been told they were negative, based on local laboratory results; and on the need to forward locally negative stools from clinically suspicious cases, to the Scottish E. coli O157/VTEC Reference Laboratory. SG
C16 SG should advise frontline NHS and LA staff to provide cases, families and health/social care staff with advice on hygiene and preventing secondary spread, as soon as infectious diarrhoea is suspected (whether VTEC or other aetiology), without waiting for laboratory confirmation. SG
SECTION IX - PROPOSALS FOR RESEARCH AND SURVEILLANCE
RS1 SG, in liaison with other relevant agencies, should regularly monitor developments in research efforts to identify practical and efficacious measures for controlling the excretion of VTEC from animals and feed back annually to the VTEC/E. coli O157 Action Group on any potentially useful control strategies. SG
RS2 SG should review available information on proportionate controls to reduce environmental contamination. SG
RS3 SG should then consider resourcing, and where appropriate requiring, relevant agencies or groups to implement any proportionate controls identified by their review on reducing environmental contamination (see Recommendation RS2 above). SG
RS4 SG should feed back to the VTEC/E. coli O157 Action Group their review of proportionate control measures for reducing environmental contamination, and their conclusions on which (if any) agencies or groups should be resourced and/or required to implement them; and should ensure that simple national monitoring systems are established for each new control measure resulting from this review. SG
RS5 FSAS should consider funding research to improve understanding of the potential VTEC risks associated with unwashed and unpeeled fruit and vegetables on retail sale and the food safety implications of internalisation of VTEC by plants. FSAS
RS6 HPS should consider research to investigate the contribution to VTEC infection in Scotland, of emerging food risks, including fresh produce and sprouted seeds. HPS
RS7 FSAS and LAs should ensure that surveillance of VTEC in foods is intelligence led and targeted to evaluating the effectiveness of controls applied to the production of foods which are a known VTEC risk. FSAS, LAs
RS8 FSAS and LAs should ensure that food surveillance programmes include microbiological sampling at food premises producing 'at risk' RTE foods, to evaluate the effectiveness of cross contamination controls undertaken at butchers and catering businesses. FSAS, LAs
RS9 FSAS - with input from SERL - should consider a review of laboratory provision in Scotland for the testing of E. coli and non-O157 VTEC strains in foodstuffs. FSAS, SERL
RS10 SG should commission research into ages of responsibility in children, and should report progress on this to the VTEC Action Group. SG
RS11 HPS should consider a case control study to ascertain whether the aetiological fraction has changed since its previous study in 2001. HPS
RS12 SG should consider commissioning a retrospective study to identify at what stage confirmed cases of E. coli O157 and non‑O157 VTEC infection were suspected, and whether this was at an early enough stage to allow appropriate public health management. SG
RS13 SG should consider commissioning a retrospective study to ascertain the dose and duration of excretion in cases who had been suspected and diagnosed early and treated appropriately (cases) compared to cases who had not (controls), and identify differences (if any) between E. coli O157 and non‑O157 VTEC strains. SG
RS14 SG should investigate the options for conducting occasional surveys of compliance with exclusion and other infection control guidance e.g. by front line NHS staff, HPTs or LAs, or via special studies of confirmed cases e.g. of nurseries, care homes, etc. SG
RS15 HPS should consider options for research on pre-symptomatic exclusion, for instance whether it is possible to identify any differences in the risk of transmission from infected but asymptomatic individuals, depending on whether or not:

(a)They subsequently develop symptoms.
(b) The period of asymptomatic excretion occurred before their onset of symptoms, or after their own symptoms resolved (in those who become symptomatic at some point).
(c) Infection was due to E. coli O157 or non-O157 VTEC strains.
HPS
RS16 SG should investigate options for sentinel or other surveillance of E. coli O157 and non‑O157 VTEC in ruminants, to improve understanding of the strains circulating in ruminants, and to compare ruminant strains with those occurring in human cases. SG
RS17 SG, SERL, HPS and other relevant agencies should consider how molecular epidemiology (including the use of Next Generation Sequencing) may improve understanding of relationships between E. coli O157 and non‑O157 VTEC strains from ruminants, humans, water, the environment and the foodchain. SG, SERL, HPS

Contact

Email: Jeanna.Sandilands@gov.scot 

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