The BMA fully supports moves to set up the ECDC and sees it as an essential step towards improving disease surveillance and the ability to take prompt and effective action in Europe. Increased mobility of the population, emergence of new diseases and the threat of bioterrorism means that the risks from disease are not diminishing. However, the strength of the Centre should be its role in the monitoring and control of more common but less topical disease such as Legionnaires disease and tuberculosis (not just multi-drug resistant).
Cooperation and commitment from each country is required for this initiative to be effective. It is important that all diseases, where indicated (communicable and non-communicable), are reported by all countries to the ECDC. This will ensure that a repeat of the SARS outbreak, where countries failed to report to the World Health Organisation (WHO), does not occur. The usefulness of the Centre will be heightened as more countries join the community. The Centre should not simply be attached to an existing disease control centre in a given country, but should be at a new and separate site. There should also be links to the centre for disease control in Atlanta, USA.
The ECDC should be set up in consultation with the WHO European Regional Office who have a wealth of experience. The Centre should build on the work of existing surveillance systems in each country. For example, the UK already has a good public health system in place. There should be no duplication of efforts of surveillance already carried out within countries and by WHO, and there should be no added layer of bureaucracy. Furthermore, there is need for flexibility with regard to regulations and directives, so that they can be updated as evidence accumulates.
page 16, article 4 We are concerned that some countries may not already have systems in place, and requirements by the ECDC may be beyond what can currently be provided. The requirements of ECDC should not place an unnecessary burden on the countries involved and support should be provided where appropriate in order to attain harmonisation of surveillance methods. For example, some Member States, especially those newly joined, may not have enough public health officers, including epidemiologists, to second for defined periods of time to the Centre. Therefore, the regulations should define the maximum length of time and number of personnel that can be seconded from each country at any given time.
page 21, article 14 It may not be sufficient to have just three members of the management board to represent patient non-governmental organisations, professional bodies and academia. Alternatives should therefore come from different bodies rather than be deputies from the members’ organisation.
page 27, article 22, paragraph 3(d) Any voluntary contributions from Member States must be unhypothecated to prevent any "buying" of priority which is not scientifically and epidemiologically justified
page 43 Task 1 seems to infer that the Centre will have first refusal of the best staff regardless of priorities set within the Member State for its own purposes. This needs careful monitoring and may require modifying.
In summary, the BMA welcomes this proposal as a valuable tool in monitoring the spread of disease in Europe.
