Guidance

Response to the identification of a resistant bacterial isolate of potential high risk to human or animal health: Contingency plan

Updated 22 March 2023

1. Contingency Planning: Current Policy

The Veterinary Medicines Directorate (VMD) has responsibility for advice and implementation of policy on antimicrobial resistance (AMR). Policy interventions on AMR aim to mitigate or limit a number of key risks including:

• The emergence of a significant animal health risk and associated animal welfare problems and/or implications for food security
• The emergence of a significant public health risk arising from resistant organisms and/or resistance genes that could spread to humans (including transmission via food and/or the environment)

The policy options and responses currently in place include:

• Surveillance of bacterial resistance. This includes both targeted and scanning surveillance
• Access to premises and animals for sampling to confirm disease or the presence of a resistant organism. Although this is currently voluntary, it is possible to use zoonoses legislation to obtain samples. However, the risks and benefits of invoking these powers need to be considered (for example, potential negative impact of future cooperation). There are currently limited resources for investigation of individual incidents
• Advisory visits by the Animal and Plant Health Agency (APHA), Agri-Food and Biosciences Institute (AFBI) and Scotland’s Rural College (SRUC) experts. These may have a good impact at premises level but a limited wider effect
• Communication and raising awareness
• Medicines legislation. Involves setting out restrictions on prescribing practices

Additional policy tools, currently unavailable because the legal powers are not yet in place, could include:

• Movement restrictions on livestock (and in theory, companion animals)
• Restrictions on the disposal of farm wastes such as manure and bedding
• Slaughter of livestock (if appropriate to the disease situation)
• Further restrictions on the prescription and supply of antimicrobials

Implementation of the first three additional policy tools would achieve tighter control of the situation on affected premises. The risk of dissemination of the resistant organism (from that premises) could be greatly reduced. However, without a significantly larger bacterial resistance surveillance programme than currently exists, there is significant potential for that farm to be only one of many where animals carry such an organism.

Applying rigorous controls only at the premises where the organism had been first identified could be considered unfair and discriminatory. In addition, the measures would have little impact on the overall epidemiological situation if the organism is already present on other premises. Such measures would be appropriate if a particularly dangerous combination of species of micro-organism and/or type of resistance is identified and believed not to be widespread. In these exceptional circumstances, such control measures might significantly reduce the impact on public and animal health.

2. Overview and Scope of Contingency Plan

The purpose of this contingency plan is to outline the actions to be taken and identify the organisations responsible for such actions when a resistant bacterial isolate or resistance gene considered to be high risk is detected from an animal or group of animals, feed, or food of animal origin. It covers the responsibilities of the relevant Government animal health departments/agencies (Defra, VMD, APHA, and equivalents in the Welsh, Scottish and Northern Irish Governments). Where other organisations may be involved, their specific role and responsibilities, including any relevant actions they may undertake, are outside the scope of this document.

Potentially high-risk isolates from animals may be detected by scanning surveillance activities carried out by APHA/AFBI/SRUC or as part of ongoing AMR surveillance and monitoring. This document intends to give a broad overview of the investigation of, and response to, resistant bacterial isolates of concern; it does not deal with specific diseases. It intends to cover both zoonotic and non-zoonotic bacteria. This is a living document and as such can be updated as required but any revisions are to be agreed by the relevant organisations involved.

This contingency plan supports and is complementary to the Guidelines for the Investigation of Zoonotic Disease in England and Wales available on the UK Health Security Agency (UKHSA) website, which should be consulted and applied in parallel.

3. Contingency Process

The contingency process has been broken down into four sections: alert, risk assessment, risk management and risk communication. Actions from each section may take place simultaneously and may be revisited or be ongoing. In particular, the process of risk communication should be considered to be continuous.

This is a UK-wide plan; the lead animal health laboratory and policy team will be decided by the location of the detected bacterial isolate under consideration.

3.1 Alert

Procedure following initial identification of bacterial isolate:

• The laboratory will alert the appropriate policy lead within 24 hours
• A completed ResAlert form should be sent to the VMD from the laboratory within 3 working days of the ResAlert notification, providing as much information as possible. The VMD will circulate the completed form to all on the circulation list. Each representative will review the information and will reply to the VMD within 24 hours, detailing which option for follow up is most appropriate based on the potential risk. The options are as follows:
  • Full teleconference with all representatives from all departments (for example, for isolates that are likely to pose a high risk).
  • Small teleconference with key representatives (for example, if it is primarily an animal health issue requiring only animal health input).
  • No further action, but further information on the case is to be circulated to all when available.
• Based on the response to the ResAlert, the initial case conference call (or other appropriate response) for relevant parties is to be organised by VMD. The conference call should take place within 5 working days of receiving notification of the ResAlert, unless it is deemed an imminent risk, in which case it should be held within 24 hours. The full conference call should aim to include representation from the organisations listed in Section 4. Additional DARC members are to be invited dependent on their expertise relevant to the identified isolate.

3.2 Risk Assessment

If a teleconference is held, any relevant initial information on the source of the isolate, relevant AMR genes and/or mechanisms of resistance should be discussed. An initial assessment of potential risk to human health (for example, through direct contact, environmental exposure, food borne exposure) and to animal health (for example, through direct contact, fomites, environmental exposure, and animal movements) should be made. Data collection should be ongoing during this time to continue informing the risk assessment process.

3.3 Points for consideration during Risk Assessment

• Agree, as early as possible, the policy lead and agencies responsible for further investigation/actions based on the level of risk to public and/or animal health and geographic location. The need for a Ministerial briefing is determined by the level of risk the isolate represents
• Determine what powers, if any, are available for control. This is dependent on the organism isolated. Salmonella cases can be subject to statutory powers under zoonoses control, but currently there is no legislation that provides for the control of non-notifiable disease. Government can provide advice and request voluntary restrictions for example, on movement
• Decide if/what additional epidemiological/microbiological/molecular investigation should be undertaken to inform the risk assessment and agree on logistics, including: ownership of further investigation, mechanism/powers to collect further samples (if required), information to be collected, instructions for staff, the type and number of samples to be taken, and by whom, which laboratories are to be involved
• Consider and flag any funding issues, for example, farm visits for a Salmonella isolate of concern may fall under the Defra Salmonella programme umbrella in some circumstances. For other organisms, a funding source for follow up control and investigation procedures would need to be determined
• Determine if any further or increased level of surveillance is needed, and at what level for example, on site, on linked premises, or on a wider local or national basis. Consider investigation of linked premises and personnel (as needed and as funding allows)
• Determine whether a multi-agency incident needs to be declared, to facilitate further public health investigation through established channels such as local public health teams
• Agree on any additional liaison with relevant public health risk surveillance groups, including cross-governmental bodies
• Agree on whether the case should be taken to any advisory committees/groups– thus ensuring the Chief Veterinary Officers /Chief Medical Officers are kept informed
• Agree whether other agencies/bodies need to be notified and which representatives should be included in follow up case conferences (for example, the attending private veterinary surgeon (PVS), local public health team/Consultant in Communicable Disease Control officer, food safety team, local authority representative, relevant environmental health officer, British Veterinary Association representative(s), livestock industry bodies, etc.)
• Determine whether any international agencies/bodies need to be notified
• Agree on future case conference follow up schedule once initial activity is completed. Further case conferences should consider any developments in the initial case, the results of follow up epidemiological investigation, the outcome of actions agreed in previous conferences, and (where appropriate) ministerial direction and media activity. Timing will depend on the potential level of risk and the speed at which significant new information is likely to become available

3.4 Risk Management – Short term

Primary epidemiological investigation is to be undertaken by the relevant animal health laboratory to identify the source and spread of the isolate. Other aims of the primary risk management process include:

• The laboratory is to determine how widespread the organism(s) is on farm (in animals and in the environment)
• The laboratory is to collect other relevant information, for example, investigate previous/current antibiotic use on the farm, information of recent animal movements on/off holding, possible vectors, potential sources including human sources, etc
• The laboratory is to provide advice to owner/farmer (and PVS as required) regarding containment and elimination of organism, for example isolation of affected animals, cleansing and disinfection
• The laboratory/appropriate policy lead is to initiate official controls (if applicable)
• The laboratory/appropriate policy lead is to initiate other actions required to contain the organism, for example, voluntary restrictions on source (and other) premises
• The laboratory/appropriate policy lead is to alert local/national laboratories to ensure relevant samples are screened appropriately
• The relevant local public health organisation is to initiate dissemination of public health advice by (local) Public Health Authority, as required

3.5 Risk Management – Medium/Long Term

• Continued case follow-up/surveillance by the agreed lead laboratory/appropriate policy lead. Follow up to the index case should be based on the findings of the initial epidemiological investigation and the outcome of risk assessment and mitigation discussions between all involved Government agencies/departments.
• Wider risk assessment and/or surveillance by the appropriate policy lead in consultation with the laboratory lead, if deemed necessary, based on the risk to UK animal and human health posed by the bacterial strain concerned.

3.6 Risk Communication

• The initial case conference should consider any immediate communication needed across Government, including alerting senior officials and Ministers
• Media interest should be considered, and a media management strategy should be agreed upon accordingly. Departmental press teams should be involved at an early stage if significant media interest is likely
• The laboratory is to ensure the animal keeper and PVS are kept informed, (and prepared in advance for any media coverage). The animal keeper should be kept engaged and compliant in the risk investigation and follow up activity
• Where an isolate represents a public health risk, the laboratory and relevant public health body, in collaboration with the appropriate policy lead, should liaise on communication to the animal keeper and other in-contact or at-risk humans, to ensure co-ordinated messaging and approach
• Dissemination of information and liaison with relevant livestock industry bodies and to the wider veterinary profession should be considered
• Agreed actions should be communicated to relevant Government committees and groups, Government Departments, Ministers, and other interested organisations as appropriate
• The relevant public health body is to lead on any agreed alert/dissemination of information to hospitals and GP surgeries in the locality of the incident of the risk, so appropriate screening of patients can be initiated as required

4. Organisations and representatives to be invited to initial case conference call.

Organisation	Abbreviation
Veterinary Medicines Directorate	VMD
Agri-Food and Biosciences Institute (Northern Ireland)	AFBI
Animal and Plant Health Agency	APHA
Department for the Environment, Food and Rural Affairs	Defra
Department of Agriculture, Environment and Rural Affairs Northern Ireland	DAERA
Department of Health &Social Care	DHSC
Environment Agency	EA
Food Standards Agency	FSA
Food Standards Agency Northern Ireland	FSA NI
Food Standards Scotland	FSS
ARHAI Scotland/Public Health Scotland	ARHAI/PHS
Public Health Agency – Northern Ireland	PHA NI
Public Health Wales	PHW
Scottish Government	SG
Scotland’s Rural College	SRUC
UK Health Security Agency	UKHSA
Welsh Government	WG