Subcommittee on Food Safety Committee on May 27th, 2009

[The Chair, Conservative, Larry Miller]

Thank you, Mr. Williams.

We actually had the lights flashing, but Mr. McKeown, you'd like to comment on the same question by Mr. Allen, so go ahead.

[Dr. David McKeown]

Thank you, Mr. Chair. I'll try to be brief.

I've certainly seen examples in which local public health officials were prepared to take action when the CFIA was not. I think if the system is working well together, then we should be on the same page. We should be using the same kinds of triggers in order to make those important decisions. I can't say in the listeriosis outbreak whether earlier decisions would have made a difference in terms of the health outcomes, but clearly, under some circumstances, it might. That's why it's important.

[The Chair, Conservative, Larry Miller]

Thank you very much.

I apologize to our witnesses, but we have three votes in the House tonight. Seeing that we have a little further to go than normally, we'll have to end now.

Thank you very much, all of you, for being here. I think you answered a lot of questions, so thanks for participating in our study.

I know you're scheduled to be here till 6 o'clock, but the votes are scheduled for 6:45 p.m. and I know there's no way we're going to be back here in time to resume before our next witnesses are here. So thanks again for being here.

[Dr. David Williams]

Okay, thank you very much.

[The Chair, Conservative, Larry Miller]

The meeting is suspended until after the votes.

[The Chair, Conservative, Larry Miller]

Okay, for the sake of time we'll move into our next session.

We have witnesses here from Bioniche Food Safety, Mr. Culbert; from the Canadian Agricultural Safety Association, Mr. Hacault and Mr. Anderson; from the American Meat Institute, Mr. Jim Hodges.

We'll start with Mr. Culbert, for 10 minutes or less, please.

[Rick Culbert, President, Bioniche Food Safety]

Mr. Chair, members of the subcommittee, on behalf of Bioniche Life Sciences, I want to thank you for the opportunity to speak to you about food safety in Canada.

As you know, Bioniche Life Sciences is an innovative biopharmaceutical company based in Belleville, Ontario. Our mandate is to act on innovation and to improve quality of life. We’re publicly traded and invest heavily in research and development. We currently employ about 200 people around the world in highly skilled scientific and research-based jobs, with the majority of these being in Belleville, Ontario, and Montreal, Quebec.

An important part of this subcommittee’s mandate is seeking recommendations to reduce the risk of future food-borne illnesses. Today, I want to tell you about a breakthrough in reducing the risk of Escherichia coli or E. coli, the O157 strain in particular, which is a food-borne pathogen and public health issue.

Highly publicized outbreaks such as Walkerton in 2000 and up to and including last year, where we had an outbreak in North Bay as well as one in the Niagara region, are tragedies caused by E. coli O157 that can shake the confidence of Canadians in the safety of their food.

There are many strains of E. coli that are harmless, but the O157 strain is one that releases toxins that cause severe illness, permanent illness, or even death. Like listeria, unfortunately, it is young children and the elderly who are often most at risk. The Government of Canada can take pride in the fact that it supported research and development that led to the world’s first licensed vaccine against E. coli O157, named Econiche. This unique innovation, which has positive implications for Canada’s agricultural sector, national food supply, health care system, and overall consumer confidence, speaks to the calibre of this country’s scientific research community.

Econiche is designed to reduce the risk of E. coli O157 contamination of food and water, and it received full licensing approval from the Canadian Food Inspection Agency in October 2008, only a few months ago. The vaccine is given to cattle and is the first of its kind in the world to combat E. coli O157 at the source. By “source”, I mean beef and dairy cattle, the natural hosts of these bacteria.

This deadly strain of E. coli lives within the intestines of cattle without causing any ill effects to them. Studies have shown the vaccine significantly reduces E. coli colonization in cattle by as much as 98%. This reduction in the amount of E. coli O157 shed by cattle helps to reduce the risk of it being present in ground beef or via groundwater or spread to children who pet animals during farm tours, or via produce, as was the case with the huge spinach recall in 2006.

Adoption of this vaccine will position Canada as a global leader in food safety, preserve consumer confidence in Canadian agriculture products, and bolster public health. It will provide much-needed assistance to the agricultural sector, particularly the beef industry, by offering an additional stamp of safety and acting as a premium on Canadian agriculture products, potentially increasing foreign demand for our beef and produce.

Given the many of benefits that will result from inoculating beef and dairy cows with this vaccine, one might assume cattlemen would move quickly to vaccinate their cattle; however, it is not that simple. The challenge with adoption of this on-farm intervention is that individual cattlemen receive no immediate or direct benefits for spending the money to vaccinate their animals against E. coli O157. As this bacteria does not make cattle sick, there is no incentive for cattlemen to vaccinate them. We believe that if governments provide the initial funding to encourage adoption, the long-term benefit to the overall cattle industry will become apparent. We must recognize that E. coli O157 is more than only a beef issue; it poses a risk to humans through other foods, water, and direct contact.

Organizations such as the Canadian Association of Bovine Veterinarian, the Canadian Association of Fairs and Exhibits, and the Beef Value Chain Roundtable have all issued statements supportive of approved licensed on-farm interventions to reduce the public health risk of food-borne pathogens such as E. coli O157.

During these subcommittee hearings, we have heard about the shared responsibility between industry and government in regard to food safety. We have heard that government’s role is to deliver resources and establish policies necessary to keep our food supply safe. We have heard that in Canada a greater cost for food safety is paid for by producers compared with other countries where a greater proportion of public dollars is used for food safety.

In Canada, we have successfully used vaccines for decades to address serious public health issues. Safe, effective vaccines are a proven technology to reduce the risk of infectious disease. The concept of vaccinating cattle to proactively reduce a serious public health risk is a perfect fit for the “one world, one health” concept widely advocated by health experts. The challenge, however, is that such innovations may require the cost to be incurred by one party, yet the benefits to be realized by another. Ultimately, as you know, food safety is about protecting Canadians, which is the purpose of the government's food and consumer safety plan. All of society benefits from the use of technology to reduce the risk of infection and illness.

The subcommittee is looking for suggestions to strengthen the food safety system and reduce the risk of future food-borne illnesses; therefore, I will put forth three recommendations on behalf of Bioniche for your consideration.

Number one, our key recommendation is the funding of a program, or pilot projects, designed to ensure the removal of E. coli 0157 from the Canadian food chain. This was previously recommended by the House of Commons Standing Committee on Finance in the pre-budget report of 2008. We feel confident that Canadian taxpayers would prefer having the fiscal responsibility involved in funding the prevention of food-borne illness than in funding the long-term consequences of an outbreak. Food-borne illness in Canada costs approximately $10 billion each year.

A series of pilot projects, funded through a program such as AgriFlexibility, would enhance the position of the cattle industry and beef value chain by encouraging primary producers to incorporate technologies, such as Econiche, that add value for other members of the supply chain as well as the end consumer.

There are four such potential shovel-ready value chain pilot projects, with Bioniche acting as a partner.

In Ontario there's a group involving the Ontario Corn Fed Beef organization and also the Ontario Veterinary School and the Ontario Ministry of Agriculture, Food and Rural Affairs.

In Quebec, there's a project waiting with Viandes Sélectionnées des Cantons; and l'Association des médecins vétérinaires praticiens du Québec; and le ministère de l'Agriculture, des Pêcheries et de l'Alimentation du Québec.

In Prince Edward Island, there's another group with the Atlantic Veterinary College, as well as the public health office.

And also in Alberta, there is the Canadian Cattlemen’s Association, Alberta Agriculture and Rural Development, and the newly created Alberta Livestock and Meat Agency.

Our second recommendation is to implement policy changes that support development of novel approaches to food-borne pathogens. When a company such as Bioniche researches, manufactures, and commercializes a new vaccine to prevent illness in people, the vaccine is typically reviewed by the Public Health Agency of Canada’s National Advisory Council on Immunization. The advisory council will make a recommendation about its use in Canada. This recommendation will determine if health care dollars can be used for the purchase of the vaccine, and the cost of immunization. However, innovative products like Econiche—given to cattle to prevent illness in people—fall outside of the council’s current mandate and therefore are not considered for public health funding.

Our final recommendation is that enteric pathogen surveillance systems, such as the C-EnterNet, should be fully funded. This is an initiative facilitated by the Public Health Agency of Canada, and also funded by Agriculture and Agri-Food Canada, designed to support activities that reduce the burden of gastrointestinal illness.

To summarize, our first priority is the funding of pilot programs that encourage adoption of on-farm food safety technologies. Our next recommendations relate to policy changes and support of public health initiatives to monitor enteric diseases in the environment.

In conclusion, I will say that all of us are in the consumer confidence business. From farm to fork, each link of the value chain has an obligation to do everything it can in the production of safe food. Government and industry are partners in the development of a shared vision going forward to reduce the risk of food-borne illness. We believe that Canada’s commitment to be a leader is built on a foundation where innovation is encouraged, commercialization nurtured, and the adoption of novel approaches to food safety supported.

Thank you.

[The Chair, Conservative, Larry Miller]

Thank you very much.

Now we move to Mr. Hodges from the American Meat Institute, for 10 minutes or less, please.

[James Hodges, Executive Vice-President, American Meat Institute]

Good afternoon, Mr. Chairman and members of Parliament. Thank you for allowing me the opportunity to appear before this subcommittee.

My name is Jim Hodges and I'm the executive vice-president of the American Meat Institute. I previously held the position of president of the American Meat Institute Foundation, which is the scientific research and educational arm of AMI. The institute has provided services to the meat and poultry industry for more than 100 years. AMI's 200 members include some of the most well-known meat and poultry food manufacturers in the United States and Canada.

Food safety is the institute's number one priority. We share a commitment with the Canadian Meat Council and other organizations to share best practices and new technology to improve food safety for the good of the industry.

A common refrain heard in Washington, Ottawa, and other venues is that our food safety regulatory system is broken. Although some criticism may be warranted, a closer look at our meat and poultry food safety systems, at least from the U.S. perspective, might yield a different conclusion.

Illnesses associated with meat and poultry consumption have declined. Nearly one billion meals are consumed each day in the United States without incident. But most individuals still believe that the food safety system can be improved. I would like to discuss with you today some of the improvements that the meat and poultry industry has made and the important role government oversight plays in ensuring food safety.

First, the U.S. meat and poultry industry supports a strong federal oversight system. The approximately 8,000 employees of the U.S. Department of Agriculture's Food Safety and Inspection Service inspect approximately 6,300 domestic meat and poultry operations. An additional 2,000 federal employees provide supervision and support services at a total cost of more than $1 billion annually.

Federal law requires a foreign country's inspection system to be equivalent to the system in the United States. Thirty-three foreign countries, including Canada, are currently approved to ship to the U.S. Canada is our largest trading partner, which requires our import systems to be as effective and efficient as possible.

Most importantly, a food safety system, in order to be effective, must be preventive. More than a decade ago, the USDA and the industry embraced a major shift in the approach to food safety programs by adopting principles of prevention that are embodied in the hazard analysis and critical control point programs, or HACCP. Mandatory HACCP provides a framework for identifying potential hazards and implementing measures to control those potential hazards during the production process.

USDA ensures that processes are scientifically validated and working properly. During the course of a year, USDA conducts more than 80,000 microbiological tests to verify that production processes in federally inspected establishments are under control. FSIS conducts these verification tests in addition to the several million microbiological tests the industry does each year.

Both Canada and the U.S. have strong federal meat and poultry inspection systems, but it is important to recognize that only industry can produce safe food. Although food processors and handlers can, and must, minimize risk, there can be no absolute certainty that all food products are free of all risk. Notwithstanding that caveat, progress is being made every day.

Specifically, U.S. government data show a decline in pathogen prevalence on meat and poultry products. Since 2000, the industry has reduced the prevalence of E. coli 0157:H7 in ground beef by more than 45% to less than one-half of one per cent incidence rate. The prevalence of listeria monocytogenes in ready-to-eat products has been reduced by 74% to less than 0.4% incidence rate.

We've seen similar improvements in the incidence of food-borne illness. Since 2000, illnesses caused by E. coli 0157 are down 40%, and listeriosis is down by 10%, with much of the improvement occurring before 2000. That's reflected in the data.

Science and scientific facts should be the foundation of establishing a food safety system that has public health protection as its goal. Government has the responsibility to set food safety standards that provide an appropriate level of public health protection. Industry has a responsibility to produce safe food that meets or exceeds government food safety standards. Caution should be exercised, however, that the government food safety regulations not stifle innovation and continuous improvement by being overly prescriptive in defining how food safety goals should be met.

Let me conclude with some suggestions on what will improve food safety.

One, with respect to government inspection programs, the focus must be on systems designed and implemented to protect public health. Inspection activities that do not have a direct impact on public health waste scarce resources and divert attention from issues of public health importance.

Two, continual improvement of preventative process control systems is needed. Mandatory HACCP and sanitation programs that focus on prevention versus detection are critical, and the rigour of the control systems should be proportional to the public health risk.

Three, government agencies must be fully funded to help assure the safety of domestically produced and imported food products.

Four, resources should be allocated based on the public health risk posed by a particular food and the control measures that are used during the manufacturing and distribution processes to control such risk.

Five, objective and achievable food safety standards that are scientifically determined to measure whether food is safe and non-injurious to public health are needed. Food safety standards must be based on quantifiable, measurable criteria and must have a direct impact on public health.

Six, domestic food safety standards must be compatible with internationally recognized standards, such as Codex Alimentarius, to protect the health of consumers, ensure fair trade practices, and promote the coordination of food standards development by the international community.

Seven, efforts should be focused on conducting a thorough analysis to identify how and why a food-borne disease outbreak occurred. Each government agency should be required to report detailed information that will assist food handlers in preventing future occurrences.

Eight, rigorous government inspection and testing is needed to verify that consumer-ready products are safe. Test results should be performed under accepted sampling and analytical protocol.

Finally, establishment of a public-private partnership to design and implement a comprehensive research program to develop more advanced risk mitigation and intervention strategies is needed.

Thank you for the opportunity to testify before the subcommittee today. I'll be happy to answer questions that you may have.

[The Chair, Conservative, Larry Miller]

Thank you.

Now we move to Mr. Anderson or Mr. Hacault. You have 10 minutes, more or less.

[Marcel Hacault, Executive Director, Canadian Agricultural Safety Association (CASA)]

I'm going to start with a few comments in French.

Mr. Chairman, I want to thank you for the opportunity to make a presentation to the subcommittee. My name is Marcel Hacault, the Executive Director of the Canadian Agricultural Safety Association. I was somewhat surprised when I was asked to make a presentation before this subcommittee, but after hearing the presentation by Rick and James, I think the purpose is to examine the issue of food safety from a more comprehensive standpoint. That's why we are making this presentation today.

It is our basic assertion that a safe farm produces safe food, and that farmers must be provided with the tools to do so.

It is the vision CASA, the Canadian Agricultural Safety Association, to have a Canada where no one is hurt farming, and our mission is to make the agricultural sector a safe place to live and work by helping farmers see and manage the risk in their workplace. Although a majority of our funding is from Agriculture and Agri-Food Canada, it's our partners and our safety leads in all the provinces that allow us to change behaviours and to work with farmers to improve the safety on their farms for their families and for their workers.

Dean.

[Dean Anderson, President and Chief Executive Officer, Farm Safety Association, and Vice-Chair, Canadian Agricultural Safety Association]

Thanks, Marcel.

I'm going to take over the rest of the role.

The point we want to make today is that safe farms produce safe food. We want to raise the awareness of the committee that it's not only the general public that's impacted by food safety, but we also must not forget that it's the safety of the farmers, their families, and the workers who produce the food. It's our assertion that safe farms produce safe foods and that farmers must be provided the tools to do so.

Although each province has different levels of health and safety enforcement and compliance, there are many efforts under way to support food safety and the safety of those who produce it.

Many of the producers have strict biosecurity protocols that control disease transmission risks on their farm. These same protocols protect workers in their operations. Many food safety quality programs, such as HACCP, which was mentioned here before, have components that both protect the safety of the workers and minimize the risk of residues and contamination in food. This applies as easily to pesticides as it does to medication. For the administration of livestock medication, needle injection and injection safety procedures include correct dosage administration, minimizing direct exposure to drugs, and preventing needle stick. So it's easy to see how one component is making sure that we don't have improper application of medication to animals, but then we also have proper procedures in place ensuring that employees don't get improper sticks.

In the national safety culture, wherever it's directed, if safety is not part of the culture, we end up with injuries and incidents across the country. A farm safety plan is not specific to food safety or human safety. It's done to plan for safety, and the end result is that we have a safer culture. We don't do it for the food; we do it to protect human health. The result is that food is also protected. By promoting safe handling of animals to protect workers, the end result of the proper handling of these animals also promotes better meat quality.

To promote a safety matrix where food is a component is our goal.

When we think of Canadian food safety, we don't think it can be in isolation of workplace safety. We think the quality of the environment it's produced in, if you account for producer safety, will automatically improve food safety. If the workers are protected from biologicals and zoonotics, the food system will also be protected. We need a good strategy for food safety that is inclusive. We cannot keep our food safe separately from the overall safety of the producers. If we have a safe Canada, where families can be safe and keep safety in mind, all of that is inclusive.

In the 95-page “Growing Forward” policy document, multiple references are made to food safety, the protection of the environment, and animal care. Human health is only mentioned once. The protection of the farmers and their families—the underpinning of the whole production system—does not come across as being a priority. Although most farmers believe that farm safety is very important to their personal and economic well-being and the future of their business, and most believe they act safely, only 15% have some type of safety plan. It's our goal to close that gap. Working together with those farmers to identify the risks and reduce them and ultimately to make farms safer will go a long way toward ensuring that Canada's food supply is also safe.

We strongly believe that safe farms produce safe food.

Thank you for the opportunity to speak. We welcome any questions.

[The Chair, Conservative, Larry Miller]

Thank you very much for staying under the time limit. I appreciate that.

Mr. Easter, for seven minutes.

[Wayne Easter, Liberal, Malpeque, PE]

Thank you, Chair

Thank you for coming before the committee.

Mr. Culbert, I'll start with you. I would disagree with you on the project that's been funded under the AgriFlexibility program. One of the problems we have in the farm sector is on food safety issues; costs often get passed down to the farmers. There's not enough money in Agriculture and Agri-Food Canada to deal with the problems we already have, so I wouldn't want to shortchange those programs even further, but I do believe the government overall should have responsibility for maybe doing a pilot project on the initiatives that you're talking about.

I guess my question would be along the line of this. What would a pilot project cost the government? How long would it take to do, from your perspective?

I do know there are agricultural organizations in Canada that are interested in doing pilot projects.

[Rick Culbert]

Yes.

[Wayne Easter, Liberal, Malpeque, PE]

The problem, as is often the case, is funding.

I have one other question to you while you're at it. You may have mentioned this, but I didn't catch it because I was a little late getting here. What would the cost per animal be for a vaccine? Do you know?

[Rick Culbert]

Thank you for those questions.

The answer to the last question is that the vaccine retails at the farm level for about $3 a dose and animals would require a minimum of two doses, a sensitizing dose and a booster dose, similar to all other vaccines. For subsequent years, in the case of a resident cow herd, you would give the cow an annual booster each year thereafter, the same as other vaccines.

In reference to the pilot projects, of course they would vary depending on their scale, but for the most part, what's being contemplated and what people would like some support to do tends to be a two- or three-year project where you would vaccinate large groups, entire farms of animals, compare over a period of time, and measure how much of a reduction in the shedding of O157 we see into the environment around that farm.

On those trials, again, if you involve a veterinary school in measuring it and maybe even the public health surveillance unit, the C-EnterNet that's in place, the other component that people are interested in building in is some of the brand-specific things. There are a couple of brands. I mentioned Ontario corn-fed beef and another one in Quebec. There's one in the Maritimes as well. I think Atlantic beef is the name. They are interested in knowing, over a period of time, if you add an on-farm food safety component to your whole value proposition, what does that do for your brand over time?

So there are three different elements that can be looked at in these pilot projects. The scale in terms of dollars would probably vary from about $1 million to $3 million over a period of years, again depending on the scale of the project. In essence, $10 million would fund all four of the current pilot projects that are being discussed and looked at right now.

[Wayne Easter, Liberal, Malpeque, PE]

Thank you.

To the American Meat Institute, I think you have some good recommendations here that we'll have a closer look at. In our system in Canada, one of the things a number of us are concerned about is that there are some proposals to go to just one inspection system, the highest standard in the country nationally. We believe--or I certainly do believe--that food is safe that goes through the smaller abattoirs in the provinces that are under provincial regulations and where smaller producers and local consumers get their products.

What is happening in the States? Is there a divergence between the state level and the federal level? Can you give us an explanation of how that system operates?

[James Hodges]

There are two systems employed in the United States: a federal inspection system as well as the individual state systems. The individual state systems must be equivalent to the federal system. I think about 27 states out of the 50 states have state inspection systems. If they don't have state inspection systems for whatever reason, whether it be state finances or other reasons, all the plants in those states are federally inspected.

Whether the inspection process is done by the federal government or by the state government is really not the issue. The standards are virtually the same in both state and federal systems. It was only a couple of years ago that the statutes were revised again to basically make the state standards equivalent to the federal standards.

[Wayne Easter, Liberal, Malpeque, PE]

Thank you.

[The Chair, Conservative, Larry Miller]

Mr. Bellavance, seven minutes.

[André Bellavance, Bloc, Richmond—Arthabaska, QC]

Mr. Culbert, I wanted to mention to you that the Viandes Sélectionnées des Cantons corporation is located in my riding. So I have a real interest in the pilot projects you refer to. Can you give us a little more detail on those pilot projects?

You said that you'll be introducing those pilot projects in Quebec in cooperation with VSC, the veterinarians and the Department of Agriculture. You will also be doing that in other provinces. Have you already identified certain farms where you'll be providing the livestock vaccine? Have you any more analyses to conduct to determine the effects of the vaccine or are they already complete? Is the vaccine available?

I'd like to have some explanation on what the pilot project is exactly.

[Rick Culbert]

Yes, and thank you for those questions.

In reference to the farms being identified, the principal group would be all the members of that one brand, and you did a much more eloquent job of saying the name, Viandes sélectionnées des Cantons. They have quite an exclusive membership. That entire group consists of farms that are willing to participate in an evaluation right now. Other groups we have spoken to are more in the dairy sector, such as Valacta and some of their membership as well.

So yes, there are some farms that have stepped forward and expressed a willingness to participate in a project now.

In terms of our other analysis needed on the vaccine, the vaccine is fully licensed. The majority of the licensing work that is done falls into two categories: safety and efficacy. The safety has been demonstrated already in commercial farmed animals, so there are no questions about the safety of the product. The efficacy has been established in experimental laboratory challenges, if you will, where cattle are administered large doses of this particular strain of E. coli and it is shown that they don't shed it if they were vaccinated, compared to unvaccinated animals. What hasn't been shown—and the industry is quite interested in this—is when we use it on a large scale out in the farming community, again, how well or how much or how effective is it at suppressing that strain of E. coli from even being on the farm in the groundwater, in the manure samples, or on the hides of the animals from that farm. So that's the type of data they're looking at.

The third part, as I had spoken to Mr. Easter about, was the whole marketing benefit of that. There isn't a really strong message here for consumers that this beef was vaccinated. That's not a consumer message, but it's a very strong message to other members of the value chain: when you go to retail your animals for slaughter or your dairy animals for dairy beef, that they've had an intervention such as vaccine done to reduce the risk of your processing plant becoming contaminated; you're not letting that strain of E. coli come through the door. So that's part of the other element of research: what that does for you if you're trying to market and brand your beef, either in Canada or elsewhere around the world, to help grow that market.

[André Bellavance, Bloc, Richmond—Arthabaska, QC]

How long will the pilot project last? Ultimately, will the analysis you do following this experiment be decisive for your industry, that is to say whether or not it's worth the trouble to market the vaccine? Has the decision already been made? I understand the stages you're going through and what you're going to check by conducting these pilot projects, but I want to know whether it will be decisive for you with regard to future action. That's especially what I'd like to understand.

[Rick Culbert]

The pilot projects that are being proposed are a minimum of two years and perhaps as long as three years, the reason being that when you start to suppress the amount of shedding of E. coli 0157, the more you suppress it over the longer period of time, the greater benefit you see. So they're designed to measure that.

The analysis that would come out of this would definitely give the industry greater insight. When we spoke with the Canadian Cattlemen's Association as an entirety, that was really their question. Even though the product is fully licensed and ready to go, they want to understand better what the impact is of using this. How effective is it in the large-scale field use that's suppressing it and cleaning up the environment and reducing the risk through beef and other food-borne carriers of this strain of vaccine?

I think what the whole industry needs to see before adopting this, again, is what that total value is. Right now they know the vaccine has a cost and they know that if they don't do it at the farm right now there's no penalty. I don't mean to sound callous, and there may still be some food-borne illness, but it didn't specifically get traced back to them. Yet if a large group starts to incorporate vaccination and prevention and they see that the brand they're associated with, such as VSC, grows in consumer acceptance and grows in market demand, now they can see this is a worthwhile thing to do.

I don't know if that helps answer your question, but I think that's part of the market outcome that many sectors of the industry are looking for.