Consultation on the implementation of EU Directive 2003/99/EC – the Zoonoses (Monitoring) Regulations 2006.
Response from Lyme Disease Action
Registered charity 1100448
Registered company 4839410
Registered in England.
With reference to the covering
letter accompanying this consultation:
Lyme Disease Action is in broad agreement with Defra taking the needed additional powers to ensure that the Zoonosis Directive is fully implemented in all parts of the UK.
However, we as a charity are concerned about some potential
omissions which could in our understanding mean that implementation fell short of what the Directive requires.
We shall confine these comments solely to those that concern this charity, that is, that not enough detailed monitoring of the tick-borne diseases as they interface with humans
is being undertaken. We feel that the current provision still could be improved upon and that this does have the possibility of increasing human health by enhancing the prevention of tick-borne diseases. (Here we are not just referring to what we perceive as a need for increased awareness of the
possibility of catching Lyme borreliosis through transmission pathways already known about.)
The phenomenon of quite large numbers of patients presenting with a hard to diagnose syndrome of symptoms is perhaps relatively recent in our society. Suddenly, within the last two or three
decades the numbers of these patients has increased. Many of these patients have a syndrome that clinically resembles Lyme borreliosis. The Health Protection Agency website itself refers to this phenomenon when it acknowledges confusion between Lyme borreliosis and a condition known as
‘chronic fatigue.’ We are aware that the medical authorities feel that many of this population of patients do not have a disease related to infection in any way. Our charity is also aware, that some of the ‘medical mystery patients’ can, after all, respond to antibiotic
treatment of a similar type that would be used to treat Lyme borreliosis. We have increasing numbers of case reports of this. Therefore, we have asked ourselves two questions (1) relates to test accuracy which is outside the remit of this consultation and (2) whether there could be other unknown
factors, disease reservoirs, species or transmission pathways for tick-borne disease/diseases such as other borrelioses that might be Lyme-like in their presentation. Human health is after all paramount and such questions need to be asked.
Were this to be so, it would warrant
investigation, indeed the legislation (Annex 1/B) would require that in a suspicious epidemiological situation, that borreliosis and agents thereof be adequately monitored. We find we have a potential human resource that might be helpful in any investigation, insofar as human patients remember the
circumstances of tick bite more frequently if they are asked about it. We certainly have anecdotal information of bites occurring in unexpected ways and places. Anecdotes are individual experiences, and by their very nature, may not occur in great numbers. People do not notice what they have not
been led to believe is of any significance and this itself could lead to under-reporting of unusual tick-bite circumstances. Numbers of reports therefore may or may not relate to the relevance of tick-bite observations.
More detailed monitoring and use of human observation may lead to new
factors, disease reservoirs, species or transmission pathways being found. We wonder does the word ‘monitoring’ mean that Defra and its agencies only concern themselves with Borrelia species known to occur in a relatively widespread way in the UK, i.e. Borrelia burgdorferi sensu stricto,
Borrelia afzelii, Borrelia garinii, and Borrelia valaisiana? If so, this would seem to require more thought, because the spirit of the legislation would seem to be more anticipatory than that, and charges national agencies to attempt ‘horizon scanning’ for dangers to public health.
It is also worth mentioning that little known tick-bite co-infections might also be part of the picture of ill health if a person has the misfortune to contract tick-borne disease. Some of these are not listed in the annex and that might be an omission.
We would appreciate being
placed upon your list of consultees in any further correspondence upon this matter.
On behalf of
Lyme Disease Action