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Footrot Vaccine and Red Tape

Updated: Jul 29, 2021

I’ll start with a brief welcome to the WoolProducers blog!

In the 9 months since I’ve been with WoolProducers, it’s become apparent that we do a lot on behalf of Australian wool growers. The problem is that we aren’t great at telling people about it!

We’re hoping that this blog will give readers some valuable insights into the daily work that we undertake on behalf of Australian wool growers. If a blog post triggers your interest, or you’d like to know more, please feel free to reach out to Ed, Jo, myself or any of our board members.

Now, onto the headline! An issue that has been fueling my frustration since commencing with WoolProducers relates to grower access (or lack thereof) to the “custom” footrot vaccine. In response to market need, AWI partnered with the University of Sydney to invest a total $1.5 million, comprising of compulsory grower levies (your money) and government matched funding into the development of the custom footrot vaccine.

The result of this investment was the development of a highly effective and safe vaccine that could be customised based on the specific strain(s) of footrot present on a particular property. Subsequent research undertaken by AWI (which can be read about here) has identified where this product can best be used as part of a vaccination strategy in a footrot control program.

Unfortunately, due to government red tape and the removal of the Emergency Use Permit at the end of 2020, Australian sheep farmers are no longer able to access the safe and highly effective custom footrot vaccine that was developed using wool grower levies.

The market forces that drove the development of the custom vaccine included the removal from the market of the mainstream commercial vaccine due to biosecurity concerns (associated with an ingredient of bovine origin and BSE risk) and the desire to have a vaccine that was provided a higher level of/ longer period of protection.

Footrot in Australia can be classed into 10 different strains (serotypes). The mainstream/commercial vaccine is “multivalent” and targets 9 of the 10 strains, whereas the “custom” vaccine targets just one or two of the strains (identified through on-farm testing). Because the custom vaccine targets just one or two strains, the animals has a more focused immune response, resulting in a higher concentration of (strain specific) antibodies for a longer period of time.

Using the custom vaccine requires grower investment in diagnostics to identify what strains are present on-farm, plus commitment to a strong farm biosecurity plan (including boundary fencing) to ensure that new strains are not introduced. While this sounds somewhat onerous, the custom product is in the most viable tool to combat footrot on some sheep farming operations.

Many will be familiar with the perils associated with Ag and Vet chemical regulations in Australia. While these regulations assist in protecting Australia’s favorable reputation as a supplier of safe food products, protect the environment, animal welfare and the safety of users, there is need for a practical regulatory balance to be re-established.

The costs (internal and external) associated with full registration of a vaccine are in the order of $3-4 million dollars and two to four years to complete. For a product like the custom footrot vaccine, with gross annual sales amounting to just a small fraction of the total registration costs, the sums just don’t add up!

The custom vaccine was offered a “fast-track” to market as a result of the absence of the mainstream / commercial product, due to the biosecurity concerns mentioned earlier. Obviously, a government official at the time appreciated the animal welfare issues and an Emergency Use Permit was put in place for several years. During this time growers and sheep vets were able to gain an appreciation of the effectiveness of the custom vaccine as an integral part of their footrot control program.

The biosecurity concerns associated with the multivalent product have since been addressed with the product returning to market in 2020, a welcome return of a tool to assist growers in managing footrot. However, a consequence of this is the removal of the Emergency Use Permit for the custom vaccine.

The reason for the removal is due to the fact that APVMA “policy” prevents granting Emergency (or Minor Use) Permits when there is a fully registered product available. I’m sorry APVMA- but that’s like putting a selective and broad spectrum herbicide in the same box and calling them “equivalent”, seemingly a policy to uphold the existence of the red tape and protect bureaucrats from having to make and/or justify decisions.

WoolProducers have been working hard over the last 6 months, coordinating efforts of State Farming Organisations and members of the Animal Health Australia Footrot Working Group to lobby government (and the APVMA) for a return of an Emergency Use Permit for the custom vaccine.

Due to the statutory nature of the APVMA, it appears that the Federal Minister for Agriculture has little capacity to intervene. While it is usually easy to “blame Canberra”, it appears that blame for the unnecessary animal suffering that will be endured this spring lies firmly with decision makers in Armidale. This is a shame, as I was of the opinion, that the decentralisation of the APVMA would have brought them closer to stakeholders. I wonder what the Deputy Prime Minister, Barnaby Joyce thinks of the current situation?

In an age of vaccine scarcity, it seems ironic that the government is blocking grower access to a vaccine that:

· Was developed using grower (and government) funds

· Has a proven track record of safety; and

· Can be manufactured domestically.

There is little doubt that recent stock movements and seasonal conditions will see an increase in the incidence of footrot this spring. When you see “hoppy” sheep, just remember the APVMA red tape and $1.5 million of wool grower and government money that could quite easily alleviate a lot of that unnecessary animal suffering if it weren’t for disconnected decision makers within government agencies.

As a final twist of the knife the vaccine that Australian wool grower levies developed is now being used by our friends over in New Zealand. Perhaps we need to look across the Tasman to know what an industry aligned regulatory framework looks like?

Cheers for now,

Adam Dawes

General Manager


WoolProducers Australia contacts: Jo Hall, CEO

02 6110 2067

About WoolProducers’ Australia WoolProducers plays a critical role in working closely with companies and entities funded by woolgrower funds including compulsory levies or fees for service.

Its mission is to develop constructive and profitable outcomes for woolgrowers nationally.

The agency is responsible for appointing a director to each of the Australian Wool Exchange and the Australia Wool Testing Authority, promoting good corporate governance and ensuring that the interests of growers are met.

WoolProducers maintains a working relationship with Australian Wool Innovation as the voice of woolgrower shareholders. It aims to contribute to AWI’s programs for the benefit of growers, promoting responsible use of levy funds and ensuring good corporate governance.


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