Diagnosis and control of fish disease in Greece is an official responsibility of the Ministry of Agriculture (Veterinary Division) under Ministerial Decision 393733 of 22 August 1986. This control extends to the importation of all live animals (including fish) and also involves edible and non-edible animal products such as hides, wool, etc. There is a “country list” which prohibits the import of certain animals and animal products from specified countries, but there are no specific bans on fish or fish product importation at the present time.
If a fish-farmer wishes to import fish, he must first ask for written permission from the regional veterinary service. If this is given, any import must be then accompanied by a health certificate. This latter requirement was the result of the Ministerial Decision from 1st January 1987 which applied to all live animals. The certificates concerned apply to live fish and fish eggs (model certificate 19 - Appendix 1) and specify that the stock concerned is under regular veterinary control and has been free from specified diseases, namely VHS, IPN, IHN and Myxosomiasis. No stipulation is made as to the type of testing required, the frequency of testing and numbers of individuals tested. Such certificates are valid for 10 days only from the date of signing.
A health certificate, signed by an official veterinarian, is also required for the import of aquarium fish (model certificate 20 - Appendix 1) and specifies that on examination, the fish showed no signs of infectious disease.
No specific controls are demanded at the moment for the import of shellfish, but a health certificate is again required stating that the shellfish show no signs of disease.
The Ministry of Forestry is officially in charge of wild river fish problems but liaises closely with the Ministry of Agriculture (Veterinary Division) should there be any suspected disease in the stocks.
Certificates and imported stocks are checked at borders inland or at ports of entry by officials of the Veterinary Division of the Ministry of Agriculture as well as by Customs Authorities.
No controls of movement of live fish and eggs exist within Greece.
Suggested legislative requirements to control disease spread in fish and shellfish both within Greece and through importation of fish and shellfish
Proper legislative control of disease spread within Greece is at present impossible because of the lack of suitable testing facilities at approved Government centres. As suggested in the section on diagnostic services, such centres could be developed at existing facilities within Greece, geographically placed to give good cover of the existing centres of aquaculture. An assessment of the presence and location of those diseases considered to be important in controlling imports should first be made and possible eradication decided on once the extent of these diseases is known and the practical possibilities of such eradication can be determined in terms of degree of spread and financial cost of control. The methods used for such screening should be those generally in use within the EEC for such purposes (see “Certification” later).
However, as a basic step in preventing further importation of the serious infectious diseases of fish and shellfish, it is suggested that a Diseases of Fishes Act be established in Greece.
It is suggested that as a model for such legislative measures, aspects of animal and fish disease control legislation in the UK (similar to that in many other countries) be used. It was not possible during the course of the present project to examine all the detail of current Greek legislation and it should be possible to parallel some of the current animal regulations and extend them to areas of fish and shellfish disease control. It would however be probably more manageable to develop a completely separate Diseases of Fish and Shellfish Act.
The Animal Health Act (1981) Chapter 22 comprises the basic health control regulations for animal species in the UK. Specific fish disease control was established by the Diseases of Fish Act (1937) updated and amended by the Diseases of Fish Act (1983).1 The basic layout of such health control is embodied in the Animal Health Act (1981). The Act is divided into a number of parts and sections, but the important points in the legislation are as follows:
1 These documents have been sent to the authorities in Greece, together with a copy of this report. Copies of the UK Health Certifications Forms pertaining to imports of fish and fish eggs, and the Canadian Fish Health Protection Regulations (1984) have also been included (see Appendix 2).
Photocopies are on file in the Fisheries Branch Library, FAO, Rome.
Powers are given to the Minister to make orders for the control of animal disease.
These powers may be extended to local authorities to allow efficient localized control of disease.
Expenditure is made possible from parliamentary sources for the eradication of specific diseases and may allow for a slaughter and compensation policy. This latter policy has never been extended to fish so far.
Powers of entry are given to Ministry inspectors for testing and sampling in connection with suspected notifiable diseases.
Certain diseases are made notifiable i.e. suspicion of any of these diseases must be reported to the Ministry by the fish-farmer, river-board (for wild fish) or any other person so that investigations may be undertaken. Failure to do so constitutes an offence under the Act.
Details of offences and penalties under the Act are provided.
Powers are given to supply veterinary services for the purpose of animal health control.
Cleansing and disinfection procedures may be specified.
Movement controls into and out of “infected areas” may be specified. Details of notification of such infected areas are also specified.
Part I, Section 10, of the Act is particularly important and controls importation of animals. Detail requirements are given in the Diseases of Fish Acts but Section 10 gives wide control of animal products in that “the Ministers may by orders make such provision as they think fit for the purpose of preventing the introduction or spreading of disease … through the importation of:
Subsection 4c) of this section specifies fish, reptiles, crustaceans and other cold-blooded creatures.
Export to EEC member states and certification requirements and quarantine station requirements for such exports are specified.
Part 2 of the Act is concerned with specific diseases and gives details of the above applied to those specific diseases. Section 26 also involves zoonoses, though as yet, particular controls involving fish in this respect have not been necessary.
Part 3 of the Act is involved with welfare and export of animals.
Schedule 1 of the Animal Health Act is concerned with veterinary therapeutic substances and is discussed under the heading of “medicines” in this report.
The above Animal Health Act (1981) thus provides a basis for disease control in animals. The specific legislation applied to fish was first established in the Diseases of Fish Act (1937) which was produced in an attempt to control the spread of furunculosis in the UK. Actions taken under the Act are carried out by officials of the Minister for fish farm enterprises whereas disease in wild fish also involves the Fisheries Boards. Such a differentiation will also need to be taken into account of in Greece where the Ministry of Forestry has particular responsibilities in connection with wild freshwater fish. The arrangement of sections is clearly set out in the Act:
Section 1 - restricts the importation of live fish and eggs. It bans the import of live salmonids and only allows the import of eggs of fish and of other live freshwater fish species by a licensed person. It also specifies that prescribed disinfection procedures are to be undertaken, allows seizure of stocks if an offence is suspected and has a sub-section allowing possible importation for the purposes of immediate exportation under exceptional circumstances. It should be noted that the terms of this act specifically mention freshwater fish and salmonids, there being no marine fish farming at the time of publication of the Act.
Section 2 - concerns infected areas and may regulate transport of live fish, eggs and feed out of such infected areas. Disposal of dead or dying fish is also included.
Section 3 - specifies the powers and duties of fishery boards, particularly involving the reporting of wild fish mortalities and the removal of carcases as necessary.
Section 4 - concerns the serving of notices if there are “reasonable grounds for suspicion that waters of any fish farm are infected waters”. Under this Act, a 16 day movement restriction order from the infected area could then be placed on live fish, eggs and feed. Such movement orders could be reapplied as necessary until the area was determined as being free from the notifiable disease. Under this section there was also a statutory duty to report the suspicion of a notifiable disease.
Section 5 - placed a duty on the Minister to examine suspect cases of fish disease on demand.
Section 6 - allows a justice of the peace, if suspicious that an offence has taken place under the act to authorise entry and seizure of infected stocks. Inspectors under the Act are also given powers of entry and procurement of samples and payment of the market value is allowed of the samples taken if found negative on testing.
Section 7 is concerned with the serving of notices.
Section 8 deals with penalties for offences under the act.
Section 9 gives the Minister power to make regulations.
Section 10 consists of a series of legal definitions.
Section 11 applies to variations in Scotland, where a different legal system is in force, and
Sections 12 and 13 deal with the costs of such actions and powers to extend the act to other diseases.
The above act was thus the basic fish disease legislation until modifications were introduced in the recent 1983 Diseases of Fish Act, which superceded the 1937 Act. The principal amendments were as follows:
Section 1 is concerned with extending the legislation to other fish species and also allows for the revocation of orders (it was previously impossible to remove a disease from the notifiable list once it had been added).
Section 2 varies the definition of a designated area to specifically include marine waters and may prohibit the taking into as well as out of an infected area, live fish, feed and eggs. The possibility of control of movement within such an area is also covered.
Sections 2 (A & B) include directions on the proper disposal of dead and dying fish.
Section 3 is a substitution of section 4 of the 1937 Act and prevents the movements of live fish, eggs and feed both into and out of infected farms and specifically changes the movement restriction period to 30 days, with a possibility of extending this period to 60 days. This extended period from the previous 16-day period was provided in order to allow for the time-consuming techniques necessary for proper viral examination and BKD screening. Suspicion of infection must again be notified and offences are specified under the Act.
Section 4A is similar to section 4 but applies to marine waters.
Section 6 is concerned with shellfish diseases and expands the powers of the Sea Fisheries (Shellfish) Act 1967 (which allows the prevention of deposition of shellfish) by also allowing the prevention of taking of shellfish from infected waters in an attempt to control the spread of disease.
Section 7 gives major powers to require information of fish farmers in order to control movements and follow up disease spread more rapidly. Registration of fish farms is compulsory, details may be asked for as considered necessary and may involve physical details of the farm, and supplies of eggs and feed; and record-keeping is stipulated for a three-year period (see appendix 4A for further details).
Section 8 involves offences if records are not kept or if documents are falsified.
Section 9 ensures the nondisclosure of such information to other individuals, and
Section 10 is concerned with financing the Act.
Thus a Diseases of Fish Act should control importation of fish and fish eggs and should prevent movements into and out of infected areas. There should be an obligation to notify suspicion of the presence of certain “notifiable” diseases and penalties for offences under the Act must be stipulated. Powers of entry must be given to inspectors under the Act and there must be a necessity to follow guidelines on disposal of carcases, disinfection, etc. Registration by farms and the keeping of records is essential if outbreaks of disease are to be rapidly traced and further spread prevented and there must be a financial capability to pay for actions under the Act supplied by central government.
Such legislation requires the preparation of standard forms and certificates and those in use in England and Wales at the moment are included in the UK Ministry of Agriculture, Fisheries and Food “Notes on procedure and use of forms” pertaining to “Imports of fish and fish eggs subject to health certification” (and consists of DOF 10, 7, 1, 5, 2, 3, 4 and 6).
These forms describe the procedures to be carried out to allow an import and describe in some detail the sampling and test requirements as well as disinfection procedures required for health certification. Attempts at standardization of such tests are being made internationally at present but the English regulations are generally in use. Comparison should be made with the Canadian regulations which do show some variation in terms of diseases covered and specific tests used.
The most important diseases which should be covered in these regulations and which are at present also stipulated in current Greek import forms are:
Viral Haemorrhagic Septicaemia of Salmonids
Infectious Pancreatic Necrosis of Salmonids
Infectious Haematopoietic Necrosis of Salmonids
Myxosomiasis of Salmonids (Whirling Disease)
Spring Viraemia of Carp
Infectious Dropsy of Carp, at present covered in Greek regulations is a rather poorly-defined entity and should perhaps be removed from the list.
In addition, control is often extended to Bacterial Kidney Disease of Salmonids (Renebacterium salmoninarum infection). Furunculosis of Salmonids (Aeromonas salmonicida infection) and possibly Enteric Redmouth infection of Salmonids (Yersinia ruckeri infection).
Control of Shellfish Disease
The importation of exotic species and even native species of shellfish has caused major economic disaster in a number of European countries and had a devastating effect on established extensive shellfish culture. Exotic agents, such as Bonamia and Marteilia, have been introduced which, though having a minor effect on their natural host, have virtually wiped out new native hosts which were important commercially exploited species such as Ostrea edulis.
Attempts at control have been made by requiring certification before import of live shellfish for farming purposes but such attempts have not been successful. It is strongly recommended that import of all live shellfish for culture purposes, whether an exotic or native species, be banned. Furthermore, as at present in UK regulations, there should be control of the laying-down and taking of shellfish and registration of shellfish farms.
It may be that the industry will require new sources of genetic material for the improvement of shellfish and fish stocks in aquaculture. Should this be undertaken, then importation should be carefully controlled, using eggs from certified sources for fish as in the suggested fish disease regulations. Importation of exotic species should be considered very carefully - the main dangers lie in the importation of exotic disease agents which may not be apparent in the imported novel species as they are present in small numbers and not having any serious effects on the host. These may then have a serious effect on native species when eventual exposure takes place. The other danger lies in exotic species escaping and displacing a native species which may have significant ecological and financial implications.
If it is decided that shellfish imports or exotic fish imports are necessary, the quarantine stations should be established for such importations. Strict disinfection should be undertaken, including that of the water supply to and from the station and continuous monitoring and sampling of populations should be undertaken during growth of the imported species. No material should be released for culture purposes until a number of generations of the species have been produced in quarantine and during this period, cohabitation experiments with detailed testing should be carried out with as many native species as possible. The quarantine station should be established as far away as possible from any aquaculture developments and where possible, away from similar native species. Control of such stations should be in the hands of the Veterinary Division of the Ministry of Agriculture as an extension of their disease control role.
It should be noted that any proposed new legislation which may interfere with imports from another member-state of the EEC requires notification to the EEC for approval.