The Bella Moss Foundation has voiced serious concerns about new regulations from the Environmental Agency that are causing uncertainty and concern within the veterinary profession as well as to pet owners’ groups and charities.
The regulations, which concern the classification and disposal of hazardous waste, came into effect in July 2005 but have yet to be enforced fully because of a lack of clarity on how they should be interpreted.
The new regulations say that animals dying as a result of serious infectious diseases (such as MRSA) must be classified as H9 waste in the same way as tissue from surgical procedures and bodily fluids, and must be disposed of only through licensed facilities. The vast majority of pet crematoria, which up until now were permitted to cremate such animals, will now no longer be able to do the work because their equipment cannot guarantee complete destruction of every part of an infectious organism. The regulations, however, do not make the same stipulation for human remains.
The Bella Moss Foundation agrees with the opinion of the BSAVA, which has been involved in discussions with the Environment Agency on the issue, that there are likely to be serious consequences for veterinary practices if the regulations are enforced, not the least of which will be the fact that vet practices will be considered to have ‘produced’ the waste and thus be just as responsible for its disposal as the facility that actually takes on the job. In the case of an animal dying from a serious infection at its home and without direct veterinary attention, the responsibility for appropriate disposal will be borne by the owner.
Some estimates put the cost of approved disposal in the region of £6 per kilo of body weight, which will add an unbearable financial burden to practices already having to decide between improving their procedures and keeping their prices competitive, and will also encourage some pet owners to default on cremation costs.
In addition, pet charities, which often have to deal with terminally ill, ownerless animals will have to bear a huge cost as result of the new regulations if they go to the trouble of identifying infectious conditions in the animals they rescue.
Mark Dosher, Secretary of The Bella Moss Foundation, said, “No one is arguing that the Environmental Agency should ignore safety, but we have seen the way the regulations are phrased, and The Foundation shares the BSAVA’s concerns that there is a serious inconsistency in the way human and animal remains are treated. Apart from this, and because of the likelihood that there will be a prohibitive rise in the cost of cremation, we believe that the regulations will lead to a reluctance on the part of vets to clearly identify bacterial strains occurring in companion animal which will, in turn, lead to greater use of the broad-spectrum antibiotics that are blamed for MRSA and other resistant bacteria in the first place.”
Jill Moss, President of The Bella Moss Foundation, added that vets seem to face a higher occupational risk of carrying MRSA, and that failure to accurately identify resistant bacterial strains will increase their frequency and thus the risk to vets, animals and pet owners.
However, there are also aspects of the regulations that are just not clear; in particular is the fact that they seem to say that the body of a pet euthanised whilst suffering from a serious infection will not have to be considered hazardous waste in the same way as an animal that dies before it is euthanised.
“This is not just a technical issue for pet owners.” Said Moss. “It’s as much an emotional one. We believe that pet owners will be horrified to have their pet, often a much-loved family member, designated as ‘waste’: no one would want their brother or parent to be classed as that, and the regulations allow people who have died from MRSA and other serious infection to be cremated normally. We believe that pets should be treated in the same way, and not just for sentimental reasons. If a human body can be cremated without being designated ‘waste’ and without creating a significant health risk, whatever the cause of death, then we think the same should apply to pets.”
Cremation of pets through approved facilities will also mean that owners will not receive ashes. “The issue of closure, of having the last remains of a cremation, is incredibly important to pet owners,” continued Moss, “and the Environment Agency needs to understand that there is more to this than a simplistic risk-assessment.”
Moss says that no one would want the Environment Agency to ignore reasonable risk, but agrees with the BSAVA that the risk has been overstated because of a lack of proper analysis. “The Environmental Agency seems to be saying that any risk to humans needs to be prevented, but they only take this view with animals. We believe that this is based on a political assessment more than anything else because there would be no support for treating human remains in the same way.”
Dosher agreed. “The assessment of risk is not simply about trying to work out if something bad could possibly happen, but much more about the likelihood that it will. We believe that the Environment Agency has turned an enormously unlikely possibility into a practical probability without any logic or sensible analysis. Moreover, it makes no sense at all to designate as waste an animal that died from MRSA but not one that would have died from it but was euthanised first.”
At present, the new regulations remain in place but un-enforced while discussions between the Environment Agency and the BSAVA continue. For charities and pet owners, however, the uncertainty only adds to what is an already stressful and expensive process.
The Bella Moss Foundation is a charitable company concerned with improving the care and treatment of companion animals suffering from serious infections. Its websites can be found at www.thebellamossfoundation.com and www.pets-mrsa.com.