Zoonotic Diseases of Mass Destruction (Part II) – Who is regulating who?

Stephen Wiggins Article 1 Comment

Banner image courtesy of Animals Asia

In the ongoing COVID-19 pandemic, the legal trade and illegal wildlife trafficking trade has come under increasing scrutiny (for good reason). A 2019 study concluded that one in every five species is affected by trade of some sort, but that the wildlife trade will expand to “affect up to 3196 additional species – totalling 8775 species at risk of extinction from trade.”

In comparison, an April 2020 article, “Despite COVID-19, using wild species may still be the best way to save them,” Dylis Roe, Chair of the International Union for Conservation of Nature (IUCN) Sustainable Use and Livelihoods Specialist Group (SULi) argues that the legal wildlife trade if “well regulated” remains vital for rural economies/livelihoods. Roe also makes the assertion that:

COVID-19 also highlights the limitations of one particular form of sustainable use – wildlife tourism. Tourism has often been heralded as a panacea for conservation and for local peoples’ livelihoods. Its almost overnight curtailment will certainly wreak havoc on the industry…

Of course, COVID-19 has wreaked havoc on non-consumptive wildlife tourism. It would seem that the COVID-19 pandemic has also affected and curtailed elements of the ‘legal’ wildlife trade, with China closing off the consumption of wildlife for “food” via ‘legal’ mechanisms (“China – Urgent measures regarding wildlife trade regulation,” CITES 5 March 2020). Plus of course, during this global lock-down, United States trophy hunters for example, are no longer able to travel to Africa to ‘sustainably utilise’ wildlife (adding to target species’ attrition) for their hunting pleasure. The consumptive ‘sustainable utilisation’ of wildlife advocated by Roe (and others) as a panacea, is similarly not immune from the very zoonotic risks the wildlife utilisation trade potentially poses to human health [and illicit trade]:

[Update] “What Does A One-Trick-Pony And Australian Crocodile Farming Have In Common? Sustainable-Use Ideology,” Nature Needs More, 13 April 2020

[Update] “The trade in skins for fashion accessories is legal, but experts say viruses do not distinguish between legal and illegal trade” – “Coronavirus: ‘Exotic’ skins in shoe and handbag fashion stores fuel risk of further epidemics, say experts,” The Independent, 13 April 2020

[Update] “A report finds that companies including Chanel, Gucci, and Coach had thousands of imported exotic leather goods seized by U.S. law enforcement from 2003 through 2013 “ – Luxury fashion brands had thousands of exotic leather goods seized by U.S. law enforcement,” National Geographic, 22 May 2020

The IUCN is “a democratic Union that brings together the world’s most influential organisations and top experts in a combined effort to conserve nature and accelerate the transition to sustainable development.” But, we must not forget the pressure that the IUCN is under with regard to its reputation, particularly with regard to its forthright defence of ‘sustainable utilisation’ of wildlife ( “Compatibility of trophy-hunting as a form of sustainable use with IUCN’s objectives,” IWB, 2 October 2019). The World Commission on Environmental Law (WCEL) Ethics Specialist Group (ESG) concluded that the IUCN’s support for trophy hunting (an IUCN ‘sustainable use’ policy) clashed with the IUCN’s objectives and “threaten IUCN’s credibility for providing moral and ethical leadership in conservation policies.”


Is all ‘legal’ wildlife trade well regulated?

However, not all ‘legal’ wildlife trade is ‘well regulated’ in the first place, particularly with regard to the risks of illicit activity encompassed within that wildlife trade and the human health risks posed. For example, in 2016 South Africa’s lion bone trade from captive bred lions (utilised within Traditional Chinese Medicine) became a legally sanctioned, stand-alone commercial trade via the Convention for International Trade in Endangered Species of Wild Fauna and Flora (CITES). But this ‘legal’ trade is known to facilitate illicit wildlife trafficking networks and criminal organisations.

The ‘legal’ lion bone trade also potentially threatens the spread of tuberculosis (TB) through the handling and slaughter process, but also potentially by human consumption (“Lion Cake” – p12 and p112) – in South Africa alone, “two to three people die every hour from TB” (“Tested by HIV and TB, South Africa Confronts New Pandemic” – Science, Vol. 368 Issue 6487, 10 April 2020).

Across the globe, TB infects and kills millions of humans per year (World Health Organisation (WHO), tuberculosis fact sheet) – the WHO lists bovine tuberculosis as one of the seven neglected zoonoses perceived to pose severe threats to public health:

  • A total of 1.5 million people died from TB in 2018. Worldwide, TB is one of the top 10 causes of death and the leading cause from a single infectious agent.
  • In 2018, an estimated 10 million people fell ill with TB worldwide. 5.7 million men, 3.2 million women and 1.1 million children. There were cases in all countries and age groups.

[Update] “Not only are captive lions well-known for harboring bovine tuberculosis, which can be passed to humans, wild lions across Africa are infected with the cat equivalent of HIV (known as feline immunodeficiency virus, or FIV). “I’m not saying it is likely to mutate in lions and jump to humans, but it did in gorillas, and they were free-ranging animals that were likely to be as healthy as possible,” Funston [Panthera] said. “We should be taking more care” –  Coronavirus is a crisis for South Africa’s captive lions, campaigners warn,” Mongabay, 13 April 2020


The Impact of Zoonotic Diseases vs. ‘Sustainable Utilisation’

The United Nations Environment Programme’s (UNEP’s) Strategic Development ‘Sustainable utilisation’ Goals and its endeavours to sustain “rural communities and their livelihoods” through wildlife trading must be weighed against the sheer economic fall-out from zoonotic pandemics, such as the COVID-19 one we are currently witnessing – which is devastating the health, livelihoods and the economic stability of millions of people across the globe. Projected global economic costs for the COVID-19 pandemic may exceed $4.2 trillion USD, far outstripping the sustainment of the “rural livelihoods” that stem from wildlife trading:

Proponents of ‘sustainable use’ worry about the uncertainty of outcomes for ‘wildlife economies’ [stemming from COVID-19]. This is now an irrelevance. Wildlife breeding may be worth $74 billion and involve 14 million people in China alone. One imagines those people would gladly trade that for an alternative source of income. Wildlife economies are the very bloody (quite literally) thing that have caused global economic collapse“ – Ross Harvey, PhD, Independent Economist, School of Economics, University of Cape Town

The UNEP goals (“Medium-term Strategy, 2018 – 2021”) includes “No. 15 – Life on Land” as a Strategic Development Goal (SDG), with the main message being protection through “Promoting policy coherence and strong legal and institutional frameworks to achieve environmental goals in the context of sustainable development.

With regard to the illegal wildlife trafficking that often piggy-backs the ‘sustainable’ ‘legal’ wildlife trade, UNEP relies upon CITES and the International Consortium on Combatting Wildlife Crime (ICCWC)to eradicate this problem.

The recent UNEP response to the open letter (“Live Wild Animal Markets, Human and Animal Health, and Biodiversity Protection,” February 2020) to the World Health Organisation, Office International Epizoologies and United Nations Environment Program states:

“The trade in wild animals from species that are not threatened with extinction, when conducted legally and sustainably (in accordance with national legislation, including provisions of the Convention on International Trade in Endangered Species of Wild Fauna and Flora where appropriate), can positively contribute to the conservation of both species and their habitats, and provides a source of livelihood for many indigenous peoples and communities. However, such trade should be subject to rigorous health regulations and standards, to minimize the risk of emergence of new zoonotic diseases, among others” – but UNEP does not state which body is tasked with ensuring “rigorous health regulations and standards,” but somehow assumes it is taken care of within the originating country of export, and/or county of import.

But the plight of the vicuña illustrates why ‘legal’ ‘sustainable utilisation’ of wildlife to support “indigenous peoples and communities” can be a curse for the utilised species and indigenous peoples, not a blessing:

Speaking from his university office, Bonacic [ecologist Cristian Bonacic, of Pontifical Catholic University of Chile, in Santiago, was at the forefront of developing best practice guidelines for sustainable, ethical use of vicuñas] explains his recent shift away from the notion of sustainable use of wildlife, why a legal trade in vicuña wool has led to more—not less—poaching, and why he thinks a legal trade in rhino horn could be catastrophic for the species” – “Legalizing Rhino Horn Trade Won’t Save Species, Ecologist Argues,” National Geographic, 8 January 2015

Furthermore, UNEP cautions “If the trade allowed by international and national laws is shut down, there is a significant risk of that activity being driven underground, making it extremely difficult to control and regulate, depriving rural communities of their livelihoods…..” – UNEP, 1 April 2020

Much of the trade in live wildlife within Asian and African “wet markets” is already “underground” and virtually uncontrolled and unregulated (due to a lack of national legislation (domestic law) and/or enforcement, and/or disparate, lacklustre policies), hence the problem for wildlife conservation and inherent human health risks.

UNEP’s ‘approach’ was re-emphasised within a Guardian article (“Ban wildlife markets to avert pandemics, says UN biodiversity chief,” The Guardian, 6 April 2020), quoting Elizabeth Maruma Mrema, the acting executive secretary of the UN Convention on Biological Diversity, but perhaps with increasing recognition that a ban on “wet markets” [live wildlife market element] is becoming a necessity to protect global human health:

…..countries should move to prevent future pandemics by banning “wet markets” that sell live and dead animals for human consumption, but cautioned against unintended consequences…….

It would be good to ban the live animal markets as China has done and some countries. But we should also remember you have communities, particularly from low-income rural areas, particularly in Africa, which are dependent on wild animals to sustain the livelihoods of millions of people……..So unless we get alternatives for these communities, there might be a danger of opening up illegal trade in wild animals which currently is already leading us to the brink of extinction for some species.”


Wildlife Encompassed in Traditional Medicine (TM)

As yet here is no recognition by the UNEP of Traditional Medicine (TM) consumption encompassing wildlife derivatives and products.

TM encompasses wildlife derivatives sourced from leopard, lion, rhino, tigerpangolindonkey……. not to mention bear bile ‘farmed’ in Asia (recently touted as an ingredient within a TM ‘remedy’ to COVID-19). An estimated 7,000 – 8,000 tigers are held captive across swathes of Asia – China, Vietnam, Laos and Thailand to supply ingredients for Tiger Bone Wine, Tiger “Glue,” “Cake,” TM ‘potions’ of no proven efficacy, but tigers are still illicitly bred across Asia in defiance of CITES 2007 “ban” (decision 14.69) to curtail any commercial tiger farming:

Parties with intensive operations breeding tigers on a commercial scale shall implement measures to restrict the captive population to a level supportive only to conserving wild tigers; tigers should not be bred for trade in their parts and derivatives

[Update] ““Glue” made from the bones of endangered tigers is being sold to promote health during the pandemic,” Environmental Investigation Agency, 10 April 2020

[Update] “Fears for sun bear after China touts bear bile in coronavirus fight,” The Independent, 13 April 2020

Do any activities in support of TM protect “rural livelihoods,” or just favour pure profiteering regardless of human health risks?

A recent open letter (“Open Letter to the World Health Organisation (WHO),“ 7 April 2020) signed by some 241 groups called not only for the permanent closing of “wet markets” [live wildlife market element], but also the withdrawal of the WHO’s “definition and endorsement of Traditional Medicine [TM]” encompassing wild and captive bred wildlife. The WHO gave endorsement to TM potions (despite an overwhelming lack of efficacy for many) in 2018 (“Increased Threat to Wildlife from Traditional Chinese Medicine,” IWB, 3 October 2018):

“……….WHO said that its Traditional Medicine Strategy “provides guidance to Member States and other stakeholders for regulation and integration, of safe and quality assured traditional and complementary medicine products, practices, and practitioners.”

In China, academics recognise that a ban on wildlife consumption is not enough to protect public health from wildlife-associated diseases. They called on the government to support transitioning the wildlife farming industry away from the production of Traditional Medicine (“Wildlife consumption ban is insufficient,” Wang et al., Science, Vol 367, Issue 6485, 27 March 2020).


A Risk Based Approach to the Wildlife Trade

The open letter (“Open Letter to the World Health Organisation (WHO),“ 7 April 2020) also called for the WHO to:

Recommend to governments that they address the potential risks to human health from the trade in wildlife – including collection from the wild, ranching, farming, transport, and trade through physical or online markets for any purpose – and act to close down or limit such trade in order to mitigate those risks.”

The world needs to reconsider its sustainable utilisation/exploitation of wildlife:

Hunting, farming and the global move of people to cities has led to massive declines in biodiversity and increased the risk of dangerous viruses like Covid-19 spilling over from animals to humans, a major study has concluded” – “Human impact on wildlife to blame for spread of viruses, says study,” The Guardian, 8 April 2020

Academics (Oxford University) within the IUCN SULi, have somehow misconstrued this open letter as a call for a “blanket ban” (“Coronavirus: why a blanket ban on wildlife trade would not be the right response,” The Conversation, 8 April 2020):

More extreme calls from more than 200 organisations include ending the keeping, breeding, domestication and use of all wildlife, which also covers traditional medicine

No, a blanket “ending” was clearly not recommended with regard to “…the wild, ranching, farming, transport, and trade through physical or online markets for any purpose” in the open letter to the WHO, but a complete risk review and human health risk assessment of the wildlife trade that such practices present – in light of the ongoing zoonotic pandemic (COVID-19), a complete risk assessment of all such wildlife trade practices with regard to human health implications does not seem an irrational response.

That ’risk assessment’ includes the handling of species that are captive bred/farmed for TM, with big cats (captive bred hunting specimens and to supply the lion bone trade for example) seemingly susceptible to COVID-19 transmission from humans (“Bronx zoo tiger tests positive for coronavirus,” The Guardian, 6 April 2020). Big cats could potentially act as a reservoir for transmission of COVID-19 back to humans, but the science needed is still to be conclusively established, which would suggest a precautionary risk approach is advisable to “address the potential risks to human health from the trade in wildlife:

“Exploitation of wildlife through hunting and trade facilitates close contact between wildlife and humans, and our findings provide further evidence that exploitation, as well as anthropogenic activities that have caused losses in wildlife habitat quality, have increased opportunities for animal–human interactions and facilitated zoonotic disease transmission” – Johnson, C.K.; Hitchens, P.L.; Pandit, P.S.; Rushmore, J.; Evans, T.S.; Young, C.C.W.; Doyle, M.M., 8 April 2020 – “Global Shifts in mammalian population trends reveal key predictors of virus spillover risk,” The Royal Society Publishing

[Update] “A study published on-line 8 April in Science, for example, reported the virus [COVID-19] can infect cats. Autopsies showed the infection led to “massive” lesions in their nasal passages, trachea, and lungs” – Science, “From mice to monkeys, animals studied for coronavirus answers,“ 17 April 2020, Vol. 368 Issue 6488, p 221 – 222

Shi, J. ; Wen, Z.; Zhong, G.; Yang, H.; Wang, C.; Huang, B.; Liu, R; He, X.; Shuai, L.; Sun, Z.; Zhao, Y.; Liu, P.; Liang, L.; Cui, P.; Wang, J; Zhang, X.; Guan, Y.; Tan, W.; Wu, G.; Chen, H.; Bu, Z., 8 April 2020 – “Susceptibility of ferrets, cats, dogs, and other domesticated animals to SARS–coronavirus 2,“ Science, DOI: 10.1126/science.abb7015


Smart Regulation?

Rather than bans, the IUCN SULi authors have advocated for “Smart Regulation,” by devolving overarching policy to “self-regulation and co-regulation using commercial interests and non-government organisations (NGOs) ……as regulatory surrogates.“ This does not sound dissimilar to the South African Predator Association’s (SAPA’s) – the SAPA is a captive breeders club – suggestion it could self-regulate the captive predator breeding industry (“The “800 skeletons” – “captive produced lion bone trade under the quota system,“ IWB, 27 January 2017 – comments section, Rooi Jan, 13 February 2017).

Regulatory surrogates” require appropriate overarching regulatory policy to enforce, which is lacking in the current COVID-19 pandemic – and even “regulatory surrogates” need to be effectively monitored/regulated, or potentially “Smart Regulation” puts the fox in charge of the hen house doesn’t it?

“Although SAPA claims that no welfare issues exist among their member lion facilities, earlier this year, as an example to the contrary, the owner of a facility in the North West Province (a SAPA member and member of their Council [Jan Steinman]) was charged by the NSPCA with animal cruelty. Inspectors found 27 lions with severe mange, two lion cubs unable to walk due to Meningoencephalitis, obese caracal unable to groom themselves, overcrowded and filthy enclosures, inadequate shelter, lack of water, and parasitic conditions” –  “Public Participation Submission of the Coalition to Stop the Captive Breeding and Keeping of Lions and Other Big Cats for Commercial Purposes,” June 2019

The IUCN is a body of scientists that also provides scientific advice to CITES. When recently asked for comment on the wildlife trade and COVID-19, CITES reportedly responded:

In a growing sign that global organisations are embarrassed by the emergence of zoonotic diseases in traded animals, Cites, the body which regulates the international trade of animals, refused to be drawn into the growing debate about the origins of Covid-19.

In a terse statement it said: “Matters regarding zoonotic diseases are outside of Cites’s mandate and the Secretariat does not have the competence to make comments on the recent news on the possible links between human consumption of wild animals and Covid-19”” – “Human impact on wildlife to blame for spread of viruses, says study,” The Guardian, 8 April 2020

CITES Structure – CITES was drafted as a result of a resolution adopted in 1963 at a meeting of members of the IUCN (The World Conservation Union). The ‘convention’ came into force on 1 July 1975

Therefore, if CITES does not think it has the “competence” to comment on the “possible links between human consumption of wild animals and Covid-19” within the legal wildlife trade, then who does have that regulatory oversight/competence?

TRAFFIC also informs CITES and recently published “Wildlife trade, COVID-19 and zoonotic disease risks: shaping the response,” 6 April 2020. TRAFFIC describes CITES as “the principal instrument for international co-operation in addressing conservation concerns related to wildlife trade….” but no mention of any role for CITES in the human health implications of the very same wildlife trade, but instead states “Many countries also have significant legislative provision for animal health protection, including reduction of risks from zoonotic diseases through trade restrictions, quarantine requirements and health inspection regimes in the marketplace…” but cautions “provisions of such regulations are seldom tailored to the specific dynamics and risks of wild-sourced animal trade” – so CITES just ships the ‘legal’ stuff. Whether CITES’ ‘legal’ wildlife shipments have human health issues is someone else’s regulatory problem it would seem.

With regard to any calls to “shut down wildlife trade,” TRAFFIC states “Many countries do not have the legislative provision to enact such prohibition quickly and there is no doubt that governments would face significant opposition from some of the affected private sector interests and (potentially) consumers” with TRAFFIC suggesting “more specific risk management measures. These might include: targeted prohibitions on trade and consumption of particular species and parts/products of concern; introduction of stronger health inspection and quarantine controls on international borders; closing high risk market locations, such as wildlife meat outlets; or prohibiting co-location in markets of outlets selling different wild and domesticated animals. The main challenge for the design of any such measures is likely to be how strong or weak the evidence base is for risk-based decision-making.”

In terms of an international response and not a country by country approach, TRAFFIC suggests “If there is to be a co-ordinated international response to disease risks of wildlife trade, there may well need to be a new international agreement perhaps to be developed under the auspices of bodies such as the World Health Organization (WHO) and the World Organisation for Animal Health (OiE).”

With CITES, and the IUCN seemingly stepping back from adding their “competence” to the current COVID-19 impact on world health and the wildlife trade, then yes, this leaves the WHO in the hot seat, along with the Office International Epizoologies (OIE) – World Organisation for Animal Health.

World Health Organisation (WHO) and Office International Epizoologies (OIE) – World Organisation for Animal Health

The WHO is yet to formally respond (as far as I am aware) to the first or second open letter addressed to the WHO.

[Update] “Coronavirus: WHO urges China to close ‘dangerous’ wet market as stalls in Wuhan begin to reopen,” The Independent, 13 April 2020:

Yesterday (13 April 2020), Dr Nabarro (WHO Special Envoy and United Nations Secretary – General for Food Security and Nutrition) pleaded on the ‘Today’ programme, BBC Radio 4, with China (and elsewhere) to take the WHO’s and UN’s Food & Agricultural Organisation’s ‘pre-existing advice’ and shut down “wet markets” – at 2:19:17 to 2:21:00 of the ‘Today’ programme recording: 

“Dr Nabarro [WHO Special Envoy and United Nations Secretary-General for Food Security and Nutrition] said while the WHO is not able to tell governments what to do, their advice is to close wet markets…….He replied: “You know how the WHO and other parts of the international system work – we don’t have the capacity to police the world. Instead, what we have to do is offer advice and guidance, and there’s very clear advice from the [UN Food and Agriculture Organisation] and the WHO that said there are real dangers in these kinds of environments, pathogens hopping from animals to humans“”

But this statement by Dr Nabarro has been contradicted in reporting of the Australian PM’s, Scott Morrisons’ impression of the WHO stance – “PM puzzled by unfathomable animal markets,” The Canberra Times, 14 April 2020

[Update] Professor Sir Robert Watson, Chair UN Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) – discussion on ‘Today’  programme (17 April 2020), BBC Radio 4,  of “Wet Markets” [live wildlife market element] and also suggests the WHO wants to close them….UNEP sustainability policy, rural communities important, better regulation/risk management seems to be his suggested approach –  at 52:17 – 57:31 of ‘Today’  programme recording.

Even if the WHO agrees that an all-encompassing rethink of the legal wildlife trade is necessary, it could face implementation problems without further IUCN, CITES, UNEP and global support:

WHO’s total annual budget is about $2.5bn, and contributions from member states have not significantly increased over three decades…..The WHO’s budget is around the equivalent of a large US hospital, which is utterly incommensurate with its global responsibilities

Amanda Glassman, the executive vice-president and senior fellow at the Center for Global Development, said a deeper problem is the WHO’s low budget and relatively toothless structure. Unlike the nuclear watchdog, the International Atomic Energy Agency, it has no redress against governments that do not cooperate” – “Trump scapegoating of WHO obscures its key role in tackling pandemic,” The Guardian, 8 April 2020

For all the responsibility vested in the WHO, it has little power. Unlike international bodies such as the World Trade Organization, the WHO, which is a specialised body of the UN, has no ability to bind or sanction its members” – “The WHO v coronavirus: why it can’t handle the pandemic,“ The Guardian, 10 April 2020

like any international body, it is only as strong as its member states make it” – “Coronavirus: The WHO is not perfect, but it needs everyone’s support,” The Independent, 11 April 2020

The WHO is a specialised body of the United Nations (UN), so the WHO’s stance with regard to the legal wildlife trade would in theory need to remain aligned with the UNEP’s stated wildlife ‘sustainable utilisation’ policy – which seemingly does not allow the WHO much room for manoeuvre unless human health risks override legal wildlife utilisation as “a source of livelihood for many indigenous peoples and communities.” Perhaps such livelihoods could be funded by alternative means in the event of a WHO vs. UNEP policy conflict and human health concerns take precedent?

[Update] There is also the upcoming review of  the Strategic Plan for biodiversity to align later in 2020 – the UN’s Convention on Biological Diversity (CBD) entered into force on 29 December 1993, with three man objectives (Article 1):

The objectives of this Convention, to be pursued in accordance with its relevant provisions, are the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources, including by appropriate access to genetic resources and by appropriate transfer of relevant technologies, taking into account all rights over those resources and to technologies, and by appropriate funding” –  Note: ““Genetic resourcesmeans genetic material of actual or potential value. “Genetic material” means any material of plant, animal, microbial or other origin containing functional units of heredity [biological inheritance].”


In the recent OIE response, it states a need for “Policy/social research to regulate wildlife trading – innovation (cameras, drones etc.), collaboration with social scientists, law enforcement/ behaviour/demographic patterns” but does not specify which regulatory body should do this or when….however, the urgency is palpable.


Wildlife Trade Bans

China has voluntarily taken action to ([Update] temporarily is seems) close its “wet markets” via national legislation and has sought to close off the consumption of wildlife via ‘legal’ mechanisms (“China – Urgent measures regarding wildlife trade regulation,” CITES 5 March 2020).

[Update] “China’s new tax incentives encourage wild animal exports,” The Week, 12 April 2020

However, the ‘measures’ announced by China in the referenced CITES notice is limited to forbidding “..food..” consumption of wildlife (captive, or wild sourced), which does not encompass the incorporation of wildlife and derivatives within Traditional Chinese Medicine (TCM).

The need for a review of all aspects of the wildlife trade needs to be global, with some permanent bans, not temporary and not just China – zoonotic pandemics do not recognise borders, a fact we are now all too aware of. Vietnam’s prime minister has proposed a similar ban to China, but plenty more countries need to realise the risk of harbouring wildlife trading and the potential risks to, and liability for global human health.



Right now, when it comes to zoonotic pandemics of mass destruction and preventing the next ‘big one,’ the human species would seem to be in denial. A co-ordinated global response is absent and an over-arching wildlife trade regulatory vacuum clearly exists (a void any devolved “Smart Regulation” vision is unlikely to fill). But the risks and potential impacts of that vacuum are immense.

The World Health Organisation (WHO) is clearly the current focus for resolving all the issues the current COVID-19 pandemic has raised – but some of the issues the pandemic has raised with regard to the broad spectrum of the global wildlife trade have laid-bear long-standing policy versus reality conflicts of interest.

COVID-19 was not unpredictable or some kind of ‘once in a 1,000 year event’ – the pandemic’s contributory factors were well known. The next zoonotic disease/pandemic is already out there waiting to happen unless there is a global rethink of our interaction with (and destruction of) nature and treatment of wildlife/animals as mere ‘sustainable use’ commodity:

The first thing to understand is that whatever future threats we’re going to face already exist; they are currently circulating in wildlife. Think of it as viral dark matter. A large pool of viruses are circulating and we don’t become familiar with them until we see a spillover event and people getting ill” – Dennis Carroll (PREDICT/Global Virome Project), “The Man Who Saw the Pandemic Coming,” Nautilus, 12 March 2020

Trying to pretend ‘business as usual’ can resume (despite the reality of the potential risk hitting us in the face), rather than an international, co-ordinated risk-based assessment approach, would at best seem the opposite of a long overdue precautionary risk approach to all wildlife trading, land use and industrial meat production. At worst, it’s a naïve gamble that puts the fate of the whole human species at risk. In probably the understatement of all time:

If our preparations and responses are country-centric, we’re in for some serious trouble” – Dennis Carroll, 2020


Further Reading

Another deadly pandemic seems inevitable – but there is a way to avoid it,” The Guardian, 4 July 2023

Be warned: the next deadly pandemic is not inevitable, but all the elements are in place,” The Guardian, 8 February 2023

Covid origin studies say evidence points to Wuhan market,” BBC News, 26 July 2022

WHO Points To Wildlife Farms In Southern China As Likely Source Of Pandemic,” NPR, 15 March 2021

Blood Lions: “A member of the World Health Organization (WHO)’s investigative team says wildlife farms in southern China are the most likely source of the COVID-19 pandemic.

The evidence suggests that the wildlife farms were supplying vendors at the Huanan Seafood Wholesale Market in Wuhan, where an early outbreak of COVID-19 occurred.  China shut down those wildlife farms in February 2020, says Peter Daszak, a disease ecologist with EcoHealth Alliance and a member of the WHO delegation that traveled to China this year. Many of these farms are located in or around a southern province, Yunnan, where virologists found a bat virus that’s genetically 96% similar to SARS-CoV-2, the coronavirus that causes the disease COVID-19. Second, the farms breed animals that are known to carry coronaviruses. “They take exotic animals, like civets, porcupines, pangolins, raccoon dogs and bamboo rats, and they breed them in captivity,” says Daszak. “China closes that pathway down for a reason,” added Daszak. “The reason was, back in February 2020, they believed this was the most likely pathway [for the coronavirus to spread to Wuhan]. And when the WHO report comes out … we believe it’s the most likely pathway too.”

Inaction leaves world playing ‘Russian roulette’ with pandemics, say experts,” The Guardian, 9 March 2021

How our abuse of nature makes pandemics like covid-19 more likely,” New Scientist, 3 March 2021

Two legal challenges expose grave flaws at the heart of global wildlife trading system,” Tracey Keeling, The Canary, Conservation Action Trust, 17 February 2021

Meat-eating creates risk of future pandemic that ‘would make Covid seem a dress rehearsal’, scientists warn,” The Independent, 30 January 2021

Preventing the next pandemic – Zoonotic diseases and how to break the chain of transmission,” UNEP, 6 July 2020

Coronavirus: world treating symptoms, not cause of pandemics, says UN,” the Guardian, 6 July 2020

UN warns of ‘steady stream’ of infectious diseases unless world tackles wildlife exploitation,” The Independent, 6 July 2020

Why the wildlife trade convention failed to prevent Covid-19,” IWB, 27 May 2020

Coronavirus: WHO backs away from ban on live animal markets, prompting warnings over emergence of new diseases,“ The Independent, 10 May 2020

WHO ate all the pangolins? The World Health Organization’s tacit defense of Traditional Chinese Medicine,” USA Spectator, 8 May 2020

‘The vaccine is only half the story’: If a cure is found, the world must be ready for the challenges that follow,“ The Independent, 4 May 2020

Halt destruction of nature or suffer even worse pandemics, say world’s top scientists,” The Guardian, 27 April 2020

Now is the Time to Ban Wildlife Trade,” Wildlife Initiative, 20 April 2020

‘We knew this was coming’: Coronavirus pandemic was preventable, ZSL chief says,” The Independent, 18 April 2020

‘Mixed with prejudice’: calls for ban on ‘wet’ markets misguided, experts argue,” The Guardian, 15 April 2020

China needs to face a full reckoning for its secrecy over coronavirus,” The Independent, 15 April 2020

Explainer: what Donald Trump’s funding cuts to WHO mean for the world,” The Conversation, 15 April 2020

Trump announces WHO funding is suspended and blames organisation for coronavirus deaths,” The Independent, 14 April 2020

‘Great Lockdown’ to rival Great Depression with 3% hit to global economy, says IMF Latest World Economic Outlook describes shock of coronavirus pandemic as ‘like no other’,” The Guardian, 14 April 2020

Nature’s comeback? No, the coronavirus pandemic threatens the world’s wildlife,” The Conversation, 14 April

Coronavirus is a crisis for South Africa’s captive lions, campaigners warn,” Mongabay, 13 April 2020


In China, bear bile farming was promoted in the 1980s as a sustainable way to exploit bears while creating a buffer to protect wild populations from poaching. But after decades of trade, China’s wild bear populations are decreasing while the number of bears caged and tortured are increasing. Research shows farmed bear bile has little effect on reducing poaching and may increase the demand for wild bear bile due to consumer preference.”

What Does A One-Trick-Pony And Australian Crocodile Farming Have In Common? Sustainable-Use Ideology,” Nature Needs More, 13 April 2020

Coronavirus: ‘Exotic’ skins in shoe and handbag fashion stores fuel risk of further epidemics, say experts,” The Independent, 13 April 2020

The Independent calls for tighter restrictions on wildlife trade and markets,” The Independent, 11 April 2020

Surely the link between abusing animals and the world’s health is now clear,” The Guardian, 11 April 2020

As a conservation biologist, I believe this outbreak demonstrates the urgent need to end the global wildlife trade,” The Conversation, 10 April 2020

Bats in the belfry: Time for a rethink on a troubling harvest,” Roving Reporters, 10 April 2020

Bipartisan lawmakers call for global ‘wet markets’ ban amid coronavirus crisis,” The Hill, 9 April 2020

Coronavirus is no surprise – our relationship to wildlife has put us on a course to this for years,” Environmental Investigation Agency, 25 March 2020

Unbelievable: Chinese Gov’t recommends injections containing bear bile to treat coronavirus,” Environmental Investigation Agency, 23 March 2020

Zoonotic Diseases of Mass Destruction,” IWB, 14 March 2020

Addressing corruption in CITES documentation processes,” TRAFFIC, March 2020

David Quammen: How animal diseases spread to humans,” RNZ, 29 February 2020 – Science writer David Quammen is the author of 2012 book, “Spillover: Animal Infections and the Next Human Pandemic

China and Laos wildlife traffickers exploiting coronavirus fears to peddle illegal wildlife,” Environmental Investigation Agency, 7 February 2020

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