Subject: Submission on the MAF
import risk analysis - Babesia gibsoni

The New Zealand Kennel Club represents over 8,000 dog owners and breeders throughout New Zealand who will be drastically affected if the Recommended Sanitary Measures as outlined in the MAF import risk analysis were to proceed.

We recognise the need for New Zealand to take every measure possible to protect against any import risk and will support those measures should they be shown to be necessary. However we must also be mindful of the needs of our members and to ensure that any measures that are put into place are fair and equitable to them.

To this end the NZKC have taken this issue very seriously and working with NZKC member Dr. Paul Mason we submitted the following.

Submission
That the proposed sanitary measures are not proceeded with at this time.

The main points of our submission are:

  • That there have been insufficient cases of B. gibsoni reported in Australia to prove that the disease is endemic to that country.
  • That there is doubt about the likelihood that H. longicornis is an effective transmitter of the disease, on the basis of the Japanese research. As this is shown as the major pathway in Figure 1 we consider that there is enough doubt that further research needs to be undertaken.
  • The fact that other carriers may be introduced is no reason to impose such a drastic regime at this time.
  • The evidence does not support the view that the risk estimate for B. gibsoni is non-negligible
  • If following all other submissions it is still decided to proceed with a management regime then the NZKC and other interested parties be invited to discuss the exact details of such a regime. This would be done with a view to adopting a regime that has as little impact as possible on our members.

In summary the NZKC does not believe that on the current evidence the strong measures being proposed can be substantiated.

Martin Hewitt
For NZKC Executive Council


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