Wednesday, November 30, 2011

Email exchange with Dr. Gary Marty


From: Ivan Doumenc [ivan.doumenc@gmail.com]
Sent: October 31, 2011 12:51 PM
To: Marty, Gary D AGRI:EX
Subject: Open letter to Dr. Gary Marty, Fish Pathologist, BC Ministry of Agriculture & Lands

Dr. Gary Marty
Fish Pathologist
Animal Health Centre
BC Ministry of Agriculture & Lands

Gary.Marty@gov.bc.ca<mailto:Gary.Marty@gov.bc.ca>

CC: the public

October 31, 2011

Dear Dr. Marty,

I am a member of the general public living in Vancouver. Over the past couple years I have become increasingly involved in the conservation of wild salmon. But who I am is not very relevant.

On August 31, 2011, while you were on the witness stand at the Cohen Commission, you made a rather stunning comment: “CFIA [the Canadian Food Inspection Agency] actually discourages us to test for international foreign animal diseases. They prefer that they be called.”

Let me provide some context.

You were being cross-examined by Mr. Spiegelman, counsel for Canada, and the topic was a report that Dr. Alexandra Morton wrote to CFIA inquiring about some possible cases of infectious salmon anemia (ISA) that she had found in the Commission's disclosure database.

Those suspected cases of ISA, it appears, turned out to be false alarms since CFIA responded to Dr. Morton’s query on May 16, 2011 by stating that “All cases were evaluated as NO RISK for ISA”.

But then, Mr. Spiegelman asked you some follow-up questions about how you – as a fish pathologist for the Province of B.C. – dealt with the risk of ISA, and what was your level of confidence that B.C. was protected from that disease.

And you stated:

“Throughout the audit program, we test between 600 and 800 fish every year, since 2003, with a highly sensitive and specific PCR test, and those have been all negative. And so that gives me a great deal of confidence that we don't have ISAV in British Columbia.

So in several of these cases, it's not routine, when you have that level of confidence, it's not routine to always test for it when it's not known to occur, especially when you always have this active audit program going on. In fact, CFIA actually discourages us to test for international foreign animal diseases. They prefer that they be called.

So the fish health, because there weren't requirements from CFIA before January, we sort of have a grandfather-type system.”

Your comments, I take it, were intended to convey the reassuring message that the risk of ISA in British Columbia was so low that CFIA considered systematic testing to be somewhat redundant and unnecessary.

What a difference six weeks can make! Today, obviously, your comments convey a very different message – that the regulatory agencies in charge of protecting us against animal disease pandemics were at sleep at the wheel, sloppy, complacent, dismissive, negligent, or worse.

I have four specific questions for you and would appreciate a detailed and prompt response on your part, given that time is of the essence in this matter.

1. Does CFIA actually discourage veterinarians with the B.C. Ministry of Agriculture from conducting tests on foreign animal diseases such as ISA? Is a phone call really the preferred means of communication that this agency encourages, rather than rigorous and formal laboratory tests? How did/does that policy on the part of CFIA specifically impact your work as a veterinarian?

2.  When you said that “when you have that level of confidence, it's not routine to always test for [ISA] when it's not known to occur”, did you mean to say that you did not test potential cases of ISA systematically, or did you mean to say that you did perform those tests systematically in spite of CFIA encouraging you not to do that?

3. I assume that your “level of confidence” has been significantly downgraded by recent developments and that you now consider the disease situation in B.C. to be anything but “routine”. (Unless you would want to take the position that the two separate ISA tests performed by the OIE laboratory in Prince Edward Island are both faulty – in which case I will definitely want to hear your comments about that as well.) How do you intend to change/upgrade your own protocols and procedures to respond to the unfolding ISA crisis, now that you are no longer in “high confidence” territory?

4. Your comment “So the fish health, because there weren't requirements from CFIA before January, we sort of have a grandfather-type system” is unclear to me. I would appreciate if could elaborate on that.

Please provide any relevant documentation and/or explanations to support your answers.

In case you would want to dismiss my questions as being yet another overreaction from an uninformed member of the public, I would like to conclude by quoting from a letter by Dale Kelley, executive director of the Alaska Trollers Association, which was published in the Vancouver Sun this morning.

Her comments, I hope, will help convey to you the extreme level of urgency that the outside world places in this matter, as well as the potential dire consequences that inaction on the part of government – which you as a lead scientist represent – could involve:

“As the representative of Alaska fishermen who rely exclusively on the health of wild fish, I am appalled by the near-silence of the Canadian agencies responsible to protect them. I've reserved comment in hopes that they would send some signal to the public, and West Coast fishermen in particular, that Canada is proactively engaged with a "fish first" attitude.

On Friday Oct. 21 - more than a week after ISA was detected in B.C. salmon - Canadian officials issued a press release devoid of any sense of urgency. They announced they will run more tests, wait several weeks for results, and only then, if additional testing reveals ISA, stakeholders will be convened to, "identify and take appropriate next steps." Really?!”


Yours very truly,

Ivan Doumenc

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On Mon, Oct 31, 2011 at 3:23 PM, Marty, Gary D AGRI:EX <Gary.Marty@gov.bc.ca> wrote:

Dear Ivan,

   I am leaving for a 2-week holiday tomorrow, so I will not have time to provide a detailed answer.  I remain confident that our farm salmon do not have ISAV.  I await the results from CFIA's investigationn before I can comment on ISAV in wild salmon.  As for concerns in Alaska, the press release the state government released last week put things in perspective very well:

http://www.alaska-native-news.com/article/State_News/State_News/ADFG_Monitoring_Reported_Evidence_of_Disease_Exposure_in_BC_Sockeye_Salmon/23540

Sincerely,

Gary Marty

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From: Ivan Doumenc [mailto:ivan.doumenc@gmail.com]
Sent: Monday, November 21, 2011 9:06 AM

To: Marty, Gary D AGRI:EX

Cc: Alexandra Morton
Subject: Re: Open letter to Dr. Gary Marty, Fish Pathologist, BC Ministry of Agriculture & Lands

Dear Dr. Marty,

I hope that you had a pleasant vacation.

I am wondering if you have found the time yet to provide detailed answers to my questions below. The results of the CFIA investigation are now in, although for my part I fail to see how those results are relevant to the specific questions I was asking you. So I trust that there is nothing preventing you from responding now.

Yours truly,

Ivan Doumenc

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On Mon, Nov 21, 2011 at 9:18 AM, Marty, Gary D AGRI:EX <Gary.Marty@gov.bc.ca> wrote:

Dear Ivan,

I am back from vacation.  Regarding questions about reporting of disease to CFIA, I recommend contacting CFIA directly.  The CFIA investigation is still ongoing, so it remains too soon to publicly comment on their results.  However, I can say that the results so far are consistent with my expectations.  When I see PCR positive results for a disease not known to be in BC, in a species not known to be susceptible to the disease, and the fish had no clinical signs (or “classis lesions”) lesions of the disease, I suspect that the PCR results are false positives until proven otherwise.  For more details, please see my response to Tyee Bridge at:

http://salmon-nation-and-the-dfo.blogspot.com/2011_11_01_archive.html

Sincerely,

Gary


Gary D. Marty, Fish Pathologist
Animal Health Centre
Ministry of Agriculture
1767 Angus Campbell Rd.
Abbotsford, BC, V3G 2M3
604-556-3123

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From: Ivan Doumenc [mailto:ivan.doumenc@gmail.com]
Sent: Monday, November 21, 2011 9:57 AM

To: Marty, Gary D AGRI:EX
Cc: Alexandra Morton
Subject: Re: Open letter to Dr. Gary Marty, Fish Pathologist, BC Ministry of Agriculture & Lands

Thank you for your prompt reply.

Yes, I have read your responses to Tyee Bridge’s questions, which were on a related yet different topic.

My specific questions were referring to some comments that you personally made on public record at the Cohen Commission. As such, my questions were addressed to you. The CFIA would not be in any position to comment on what you have said.

For reference, I am pasting here the specific comments which you made at the Commission on August 31 and which I am referring to:

 “Throughout the audit program, we test between 600 and 800 fish every year, since 2003, with a highly sensitive and specific PCR test, and those have been all negative. And so that gives me a great deal of confidence that we don't have ISAV in British Columbia.

So in several of these cases, it's not routine, when you have that level of confidence, it's not routine to always test for it when it's not known to occur, especially when you always have this active audit program going on. In fact, CFIA actually discourages us to test for international foreign animal diseases. They prefer that they be called.

So the fish health, because there weren't requirements from CFIA before January, we sort of have a grandfather-type system.”

And my questions to you in relation to your comments at the Commission were the following:

1. Does CFIA actually discourage veterinarians with the B.C. Ministry of Agriculture from conducting tests on foreign animal diseases such as ISA? Is a phone call really the preferred means of communication that this agency encourages, rather than rigorous and formal laboratory tests? How did/does that policy on the part of CFIA specifically impact your work as a veterinarian?

2.  When you said that “when you have that level of confidence, it's not routine to always test for [ISA] when it's not known to occur”, did you mean to say that you did not test potential cases of ISA systematically, or did you mean to say that you did perform those tests systematically in spite of CFIA encouraging you not to do that?

3. I assume that your “level of confidence” has been significantly downgraded by recent developments and that you now consider the disease situation in B.C. to be anything but “routine”. (Unless you would want to take the position that the two separate ISA tests performed by the OIE laboratory in Prince Edward Island are both faulty – in which case I will definitely want to hear your comments about that as well.) How do you intend to change/upgrade your own protocols and procedures to respond to the unfolding ISA crisis, now that you are no longer in “high confidence” territory?

4. Your comment “So the fish health, because there weren't requirements from CFIA before January, we sort of have a grandfather-type system” is unclear to me. I would appreciate if could elaborate on that.

Your responses to Tyee Bridge did not address questions 1, 2, and 4 at all, and they only addressed question 3 indirectly. As such  I am still looking forward to reading your detailed responses to my questions at your earliest convenience.

Yours truly,

Ivan Doumenc

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On Mon, Nov 21, 2011 at 11:46 AM, Marty, Gary D AGRI:EX <Gary.Marty@gov.bc.ca> wrote:

Dear Ivan,

I have several other fish cases that require my attention before I can provide you with the requested detailed response.  In the meantime, consider investigating the difference between the 17 October 2011 SFU press release, “...Infectious Salmon Anaemia (ISA) has for the first time been officially reported after being found in the Pacific on B.C.’s central coast” and the OIE manual definition of a confirmed case (i.e., PCR test results alone are not sufficient evidence for confirmation of ISA):

Source: OIE CHAPTER 2.3.5. INFECTIOUS SALMON ANAEMIA (Cohen Exhibit #1676)

7.2. Definition of confirmed case

The following criteria in i) should be met for confirmation of ISA. The criteria given in ii) and iii) should be met for

the confirmation of ISAV infection.

i) Mortality, clinical signs and pathological changes consistent with ISA (Section 4.2), and detection of ISAV

in tissue preparations by means of specific antibodies against ISAV (IFAT on tissue imprints [Section

4.3.1.1.2] or fixed sections as described in Section 4.3.1.1.3) in addition to either:

a) isolation and identification of ISAV in cell culture from at least one sample from any fish on the farm,

as described in Section 4.3.1.2.1

or

b) detection of ISAV by RT-PCR by the methods described in Section 4.3.1.2.3;

ii) Isolation and identification of ISAV in cell culture from at least two independent samples (targeted or

routine) from any fish on the farm tested on separate occasions as described in Section 4.3.1.2.1;

iii) Isolation and identification of ISAV in cell culture from at least one sample from any fish on the farm with

corroborating evidence of ISAV in tissue preparations using either RT-PCR (Section 4.3.1.2.3) or IFAT

(Sections 4.3.1.1.2 and 4.3.1.1.3).



Sincerely,



Gary


Gary D. Marty, Fish Pathologist
Animal Health Centre
Ministry of Agriculture
1767 Angus Campbell Rd.
Abbotsford, BC, V3G 2M3
604-556-3123

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From: Ivan Doumenc [mailto:ivan.doumenc@gmail.com]
Sent: Monday, November 21, 2011 1:40 PM

To: Marty, Gary D AGRI:EX

Cc: Alexandra Morton
Subject: Re: Open letter to Dr. Gary Marty, Fish Pathologist, BC Ministry of Agriculture & Lands

Dear Dr. Marty,

I am confused.

I greatly appreciate your answers, but you keep referring me back to the issue of whether or not the presence of ISAv has been confirmed in British Columbia.

While this critical issue obviously informs our ongoing conversation, this does not constitute my questions.

My questions to you are really procedural in nature. In your testimony before the Cohen Commission, you indicated that CFIA has discouraged you to test for international foreign animal diseases such as ISAv in the past, preferring that you give them a phone call instead.

This question of process is critical in assessing the level of protection which has been afforded to BC in regards to ISAv over the past few years. And in this matter, it is actually quite irrelevant whether or not ISAv was confirmed in BC.

Said otherwise, I would have asked you the same questions regarding your comments at the Commission, even if no laboratory had found any ISAv positives. Obviously, the fact that two labs did find positives of ISAv (or false positives, as you and CFIA have stated) has made this question all the more urgent.

But by responding to my questions about the processes in place between you and CFIA by stating that there are no cases of ISAv in BC, you are missing the point of my questions.

I apologize for insisting. But my questions do stand. Please read them again, and hopefully it will appear to you that, indeed, you have not responded to them yet.

Also, you mention that you must attend to other work. While I fully understand and accept that, please note that my request was initially sent to you on October 31, about three weeks ago.  I would appreciate if at one point you did find time in your busy schedule to respond to my questions. Perhaps if you could provide me with an ETA, it would help?

Yours very truly,

Ivan Doumenc

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On Mon, Nov 21, 2011 at 4:14 PM, Kitching, Paul AGRI:EX <Paul.Kitching@gov.bc.ca> wrote:

Dear Ivan

Dr Marty has asked me to respond to your e mail to allow him to catch up on his current work load. I will reply to each of your questions – see below

1.
CFIA is responsible for the diagnosis of all federally reportable diseases, such as notifiable avian influenza and foot and mouth disease. This year certain fish diseases such as ISA were added to the list of federally reportable diseases. Our laboratory has until recently been responsible for the fish health program (until the transfer to DFO last year). This surveillance program required and entitled us to look for any pathogen, including ISA. CFIA did not have any authority to stop us looking. Now that ISA is a federally reportable disease, we are obliged to inform CFIA of any suspect cases, but at no time have they indicated that they do not want us to maintain our testing.

2.    
This statement refers to how we handle routine samples submitted directly by the fish farm veterinarians.  Some veterinarians request a PCR test for ISAV in nearly every submission to us; their goal is to establish a record that they are free from ISAV.  In contrast, other veterinarians will test only when they see clinical signs and mortality patterns consistent with ISA (this has not yet happened in BC), or when required before fish transfer.  Because our comprehensive auditing program gives a high degree of confidence that BC farm salmon are free from ISAV, the decision to ask or not ask for ISAV PCR is based on sound scientific principals and, therefore, both choices constitute “best practices” in veterinary medicine.  We do not test every fish for every disease as it would be too expensive and totally unnecessary. The point of doing the initial histopathology screening is to narrow the number of specific laboratory tests required. In the same way your doctor makes a physical examination before requesting additional laboratory tests

3.    
If you look at the notes associated with the test results from the PEI laboratory you will see that they indicate that additional tests are required for a positive ISA diagnosis. To my knowledge no additional tests have confirmed the presence of ISA. It also says “the presence of ISAV sequences in the tissue samples does not imply that the subject fish had ISA.”

It is essential to sequence the PCR product to ensure that it is actually ISAV sequence or is not a cross contaminant in the laboratory or from elsewhere. This was not done. The PEI laboratory is the only laboratory that has been consistently able to find ISAV like sequences in pacific salmon. I and the OIE need more convincing evidence that ISAV is in BC, although we will continue to look for it in samples when we consider it appropriate. If it is here, causing mortality in fish, it will not be difficult to find.

4.    
The point here is that because we have been carrying out ISA testing for so long, CFIA have no objection to us continuing the testing, provided we inform them of any suspicious results.

I hope this is helpful

Paul Kitching

Director Plant and Animal Health, Provincial Chief Veterinary Officer

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From: Ivan Doumenc [mailto:ivan.doumenc@gmail.com]
Sent: Tuesday, November 22, 2011 12:36 PM
To: Kitching, Paul AGRI:EX
Cc: Marty, Gary D AGRI:EX; Alexandra Morton
Subject: Re: FW: Open letter to Dr. Gary Marty, Fish Pathologist, BC Ministry of Agriculture & Lands

Dear Dr. Kitching,

Thank you very much for your kind response. I greatly appreciate that you would accept to fill in for Dr. Marty as he catches up with his work.

Let me ask you my follow-up questions in the order of my initial questions:

1.

You wrote: “at no time have [CFIA] indicated that they do not want us to maintain our testing.”

This statement appears to contradict the statement made by Dr. Marty at the Cohen Commission when he said: “CFIA actually discourages us to test for international foreign animal diseases. They prefer that they be called.”

The word “discourage” has a very specific meaning in the English language. According to the Free Online Dictionary:

dis•cour•age
1. To deprive of confidence, hope, or spirit.
2. To hamper by discouraging; deter.
3. To try to prevent by expressing disapproval or raising objections.

And so, if we accept Dr. Marty’s testimony at face value, it appears that CFIA did attempt to hamper, deter, or prevent him from conducting tests on ISAv and other foreign diseases.

Now I understand that appearances may sometimes be deceiving and so, I wanted Dr. Marty to perhaps clarify and qualify the statement he made on public record. And I would understand that it may be difficult for you to make such clarifications on his behalf, since you did not make those statements yourself.

Also, your response does not address the specific comment made by Dr. Marty at the Commission that CFIA would rather “prefer that they be called” instead of having Dr. Marty’s team conduct formal laboratory tests for ISAv.

Those are very striking comments which members of the public such as myself cannot take lightly. Your response in that regard remains too general to address Dr. Marty’s comments. Which is why I was – and still am – specifically asking Dr. Marty to elaborate on them.

2.

You wrote: ‘We do not test every fish for every disease as it would be too expensive and totally unnecessary. The point of doing the initial histopathology screening is to narrow the number of specific laboratory tests required.”

Again, this appears to contradict a statement made by Dr. Marty on CBC Radio on October 18, when he said in reference to ISAv: “every one of our fish that we sample is also tested with a highly specific PCR test, and those tests have consistently and 100% been negative, so there is no virus there.” I have also heard Dr. Marty refer on several occasions that all 4,700 fish included in the Province’s  Fish Health Auditing and Surveillance Program had indeed been tested for ISAv using a highly specific and sensitive PCR test.

So I am confused. Did your laboratory ISAv -test all the fish that you routinely sampled, or not? That is why I was hoping that Dr. Marty could clarify this confusion for me. As it stands, your response makes things even more difficult for me to understand, since it sends the conflicting message that you did not perform those systematic tests, contrary to what Dr. Marty stated.

I have two additional follow-up questions to my initial second question which for its part remains unaddressed:

2 (a)

I understand that PCR tests look only at highly specific portions of the virus, meaning that if the wrong test is used, specific strains of ISA can be missed, or that if only a specific type of ISA is tested (such as the North American strain) other types (such as the European strain) can be missed altogether.

And so I was planning to ask Dr. Marty what exact type of PCR did he use on those 4,700 fish. Was it a PCR test specifically looking for ISAv? And if so, was it for the European strain, or the North American strain? If you are able to respond to this on Dr. Marty’s behalf I would be very grateful, otherwise I will have to address this back to him.

2 (b)

In his initial response to me (Nov. 21), Dr. Marty referred to the 48 salmon that Dr. Morton and Dr. Routledge have sent to he PEI lab for testing, and we wrote: “the fish had no clinical signs (or “classic lesions”) lesions of the disease”. This is consistent with a statement that Dr. Marty also made to the Journal of American Veterinary Medical Association on November 16 that “none of the [48 sockeye salmon smolts] had signs consistent with the disease”.

I was wondering how Dr. Marty would know that. Was he able to inspect/diagnose the 48 fish that were sampled by Dr. Morton? If not, how did he determine that those fish had no “classic lesions” associated with ISAv?

3.

Should I conclude from your response here that your agency has taken no steps / made no plans to change your processes and protocols after ISAv (albeit a false positive, as CFIA has stated) was reported by Dr. Kibenge’s OIE laboratory last month?

You also wrote that “we will continue to look for [ISAv] in samples when we consider it appropriate. If it is here, causing mortality in fish, it will not be difficult to find.” Does this mean that you have found it appropriate to increase the number of fish samples for 2011? Or that you have found it appropriate not to increase your sampling activity?

4.    

Thank you for your response, this clarifies that point for me.


Thank you again for your interest in this matter.

Yours truly,
Ivan Doumenc

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On Tue, Nov 22, 2011 at 1:07 PM, Kitching, Paul AGRI:EX <Paul.Kitching@gov.bc.ca> wrote:

Dear Ivan,

Thankyou for your email. I regret that you are still confused, even though Dr Marty and myself have done our best to answer your questions. I see no value in continuing this exchange.

Regards

Paul Kitching



2 comments:

  1. Ivan, thanks for posting. It is interesting that you posted something that makes you look like a complete idiot.

    Again, thanks. Good for a chuckle.

    Ken Hunter

    ReplyDelete
  2. I was expecting some kind of revelation here, but I can't figure out what you (Ivan) were trying to say either.

    ReplyDelete