Even though most cattle are slaughtered at commercial slaughterhouses, so-called on-farm emergency slaughter (OFES) offers a possibility for slaughter on-farm when otherwise healthy animals suffer an accident preventing transportation. In the European Union (EU), OFES is regulated by Regulation (EC) No. 853/2004. A legal analysis showed that although this regulation applies directly and should be uniformly interpreted across EU Member States, ambiguous and unprecise terms - especially ‘accident’ - may lead to national differences. A survey among Danish official veterinarians revealed unclear rules and inconsistent interpretations. Answers from competent national authorities in 10 EU Member States showed major differences in definitions, eligible conditions, time limits, and procedural requirements for OFES. EU guidelines are recommended to ensure clarity and consistency.
This paper focuses on temperature data collected by public authorities as part of animal welfare inspections of long-distance transport of pigs in the EU and evaluates the quality of these data in terms of monitoring animal welfare. It is a legal requirement that transporters collect temperature data and that temperature recordings are made available to the public authority upon request. Using the extensive transport of weaner pigs from Denmark to other EU member states as a case, the aim of this paper was to map and review the quality of records collected in this way by public authorities for the purpose of informing about animal welfare during transport. Our analysis involved a spot sample of data containing 180 returned logs representing 124 journeys from selected weeks in 2023. Data analysis revealed a highly heterogeneous material constituting text files in multiple designs. Variables considered critical to understanding the content of the file and interpreting the consequences in terms of animal welfare were identified. For the vast majority of the returned logs, only a limited number of these variables were present. The diversity was evident in terms of, for example, the number of sensors providing the data per vehicle (one to six sensors), highly heterogeneous sampling intervals, lack of information on outdoor temperatures, and lack of multiple data types. Factors such as lack of knowledge about sensor placement (horizontal and vertical), lack of knowledge about the behavior of the pigs during data collection, and missing data are discussed as potential limitations for the quality of returned temperature logs in order to monitor animal welfare. In conclusion, the heterogeneity of the material and the lack of knowledge about sensor placement and pig behavior during data collection constitute significant limitations for the interpretation of the returned temperature logs in terms of animal welfare. In parallel with a future development of standardized digital solutions creating a more efficient, transparent, and enforceable system, further validation studies are needed to identify minimum requirements for how temperature data and associated metadata should be systematically collected in order to be able to assess animal welfare during long-distance transport of pigs.
The EFSA Panel on Animal Health and Welfare (AHAW) was asked to deliver a scientific opinion on the use of Diathermic Syncope® (DTS) for stunning cattle. A dossier was provided by the applicant as the basis for an assessment of the extent to which the method is able to provide a level of animal welfare at least equivalent to that ensured by the currently allowed methods for stunning cattle. This scientific opinion followed the EFSA Guidance (2018) on the assessment criteria for applications for new or modified stunning methods regarding animal protection at time of killing. Under Council Regulation (EC) No 1099/2009, approval of novel stunning methods requires demonstration of (1) the absence of pain, distress or suffering until the onset of unconsciousness and (2) that the animal remains unconscious until death. An ad hoc Working Group (WG) by EFSA performed the assessment as follows: (1) check of provided data against the criteria laid down in the EFSA Guidance; (2) extensive literature search; (3) data extraction and quantitative assessment; (4) exercise based on non-formal expert elicitation and qualitative assessment. Although the data and studies provided in the dossier only partially fulfilled the necessary criteria, they were sufficient to proceed with the animal welfare risk assessment. According to the data and the use of DTS parameterised by the applicant (delivering 160-200 kJ of energy and an incident power of 16-20 kW for 10 s), DTS does not ensure a level of welfare at least equivalent to one or more of the currently allowed methods listed in Annex I of Council Regulation (EC) No 1099/2009.
This Scientific Opinion assesses the welfare of turkeys of all ages (Meleagris gallopavo gallopavo) on farm in relation to the type and condition of the litter, type and availability of enrichment (including covered veranda and outdoor range), space allowance, concentrations of ammonia and carbon dioxide, effective environmental temperature, group size, nest conditions, lighting conditions and hatchery conditions, by using 19 welfare consequences and associated animal-based measures (ABMs) for their assessment. In addition, the risks posed by the practices of flock thinning and removal of hens, mutilations (i.e. beak trimming, desnooding and toe trimming), artificial insemination (including semen collection) and feed restriction are assessed, with the latter two practices only in turkey breeders. The welfare consequences of breeding is assessed. Recommendations to prevent and/or mitigate relevant welfare consequences in fattening and breeder turkeys include increasing space allowance compared to the currently provided space, avoiding feed and water deprivation of newly-hatched poults for more than 48 h, and providing enrichment such as elevated platforms, straw-bales and a covered veranda. It is recommended to maintain dry litter conditions, i.e. below a threshold of 35%-40% humidity. Beak trimming, desnooding and toe trimming as well as the associated welfare consequences can be avoided if the recommended housing and management practices are implemented, e.g. increasing space allowance and providing suitable enrichment. It is recommended to discontinue flock thinning and avoid quantitative feed restriction, the latter currently practised in breeder toms. Also, it is recommended to place more emphasis on leg health and less on weight gain in genetic selection. The selected ABMs to monitor relevant welfare consequences at the slaughterhouse are total mortality, plumage damage, carcass condemnation, wounds, breast blisters and footpad dermatitis.
Abstract The European Commission requested the assessment of the capacity of the surveillance provisions of the World Organization for Animal Health (WOAH) to detect bovine spongiform encephalopathy (BSE) cases (C‐, H‐ and L‐type) in the European Union (EU) and to propose if any current EU surveillance provisions should be kept. The WOAH provisions stipulate that BSE surveillance should target animals on the BSE clinical spectrum and require the implementation of standardised clinical protocols for selecting animals for testing. Based on expert judgement of retrospective clinical data, between 5% and 49% of the 55 BSE cases detected in the EU & UK since 2015 would have been selected for testing by the WOAH surveillance. Assuming the current EU surveillance, a back‐calculation model predicted a very low number of BSE cases detected for the period 2025–2029: 0.0196 for C‐BSE, 10.94 for H‐BSE and 9.13 for L‐BSE. As no classical BSE (C‐BSE) cases are expected, the application of the WOAH provisions would primarily impact the detection of atypical BSE (H‐BSE and L‐BSE), with an estimated detection over the next 5 years of between zero and five H‐BSE cases and between zero and four L‐BSE cases. Supplementing the WOAH provisions with systematic testing of fallen stock (with or without emergency slaughter) with increased age threshold of 60 or 72 months would achieve a detection capability close to current EU levels. This approach would enable the documentation of the effectiveness of BSE control measures, provide scientific assurance that the decline in C‐BSE is sustained and allow atypical BSE trends to be monitored reliably while maintaining the sensitivity required to detect any re‐emergence of C‐BSE. Finally, this would contribute to risk mitigation by triggering immediate statutory control measures when cases are detected. Modifications of EU surveillance requirements should consider any potential adjustments to other available BSE control measures.
EFSA assessed the risk of introducing viral haemorrhagic septicaemia virus (VHSV), infectious haematopoietic necrosis virus (IHNV) and highly polymorphic region-deleted infectious salmon anaemia virus (HPR-deleted ISAV) into free areas through movement of fertilised eggs and gametes. No evidence of true vertical transmission of these viruses was found. However, viral contamination of the surface of fertilised eggs and gametes cannot be ruled out. Assuming full compliance with the recommendations in the new draft 4.Z chapter of the Aquatic Animal Health Code of the World Organisation for Animal Health, including individual testing of broodfish at stripping, the median probability of introduction following importation of fertilised eggs was 0.36% for VHSV and IHNV, and 0.4% for HPR-deleted ISAV. The median probabilities were reduced to 0.02% and 0.01%, respectively, if fertilised eggs were disinfected twice (as green and as eyed eggs) at origin. Additional disinfection upon arrival in the importing establishment reduced the median probability to 0.02% for all viruses with one disinfection at the origin, and to virtually zero when two disinfections were applied at the origin. The assessment also evaluated probability of introduction when only population testing before stripping is applied. Two disinfections at the origin plus one at destination also resulted in virtually zero probability of introduction. For gametes, individual testing of broodfish at stripping, along with the other risk mitigation measures recommended in the new chapter resulted in a probability of introduction ranging from 0% to 0.3%. Implementation of the measures included in the new draft 4.Z chapter is recommended to prevent the introduction of VHSV, IHNV and HPR-deleted ISAV when moving gametes and fertilised eggs from non-free to free areas. In addition, it is recommended that fertilised eggs are disinfected twice before being traded and, to further reduce the risk, also disinfected at the establishment receiving the imported materials.
This opinion assesses the risk of avian influenza H5N1 B3.13 genotype virus infection in EU dairy cattle. Introduction of the virus into EU dairy cattle, poultry or wild birds via trade or migratory birds from the US is assessed as highly unlikely. The potential impact in case of introduction is estimated as high for most Member States. Measures assessed as most effective to prevent introduction of the virus are avoiding importation of cattle and poultry from infected countries, and cleaning and disinfection of milking equipment. Measures assessed as most effective to prevent spread of the virus in the EU are milking hygiene, banning movement of cattle in infected areas, avoiding the exchange of workers, vehicles and equipment, and implementing biosecurity measures before entering farms. Regarding adaptation of current highly pathogenic avian influenza (HPAI) surveillance, a proportional, risk-based preparedness strategy is recommended, including (i) awareness raising to strengthen passive and syndromic surveillance, (ii) targeted investigations of suspicions/outbreaks after confirmed exposure of cattle to HPAI, (iii) using sensitive diagnostics on multiple sample types and (iv) regional active surveillance (bulk milk reverse transcription quantitative polymerase chain reaction (RT-qPCR)) following first detections in cattle. In case the virus is identified in wild birds or poultry, surveillance of dairy farms in the affected area should be considered. The contamination of bulk milk is considered very likely, if EU dairy herds become infected, as cows may not show clear clinical signs and may shed the virus before changes in milk become apparent. If EU bulk milk or colostrum are contaminated with the virus, food-borne exposure of consumers to viable virus would be highest for raw drinking milk, raw colostrum and raw milk cream. To date, however, no confirmed cases of food-borne human infection with H5N1 B3.13 genotype virus have been reported.
This Technical Report was prepared in response to a mandate from the European Commission under Article 31 of Regulation (EC) No 178/2002. The request focused on updating the literature review from the 2001 report “The Welfare of Animals Kept for Fur Production” (SCAHAW, 2001), specifically addressing Section 4 (general aspects of carnivore biology—mink, foxes, and raccoon dog) and Section 5 (general aspects of rodent biology—chinchilla). Using information obtained from a review of literature, a call for evidence from stakeholders, field visits and consideration by experts in an EFSA working group, this report reviews the most up to date information on the species’ biology, production cycles, most common husbandry systems, including field-tested systems, and farming practices used for the commercial fur production of the following species: i) American mink ( Neogale vison or Neovison vison , previously classified as Mustela vison ), ii) Red fox ( Vulpes vulpes , and also known as 'silver fox'), iii) Arctic fox ( Vulpes lagopus , previously classified as Alopex lagopus and also known as 'blue fox'), iv) Raccoon dog ( Nyctereutes procyonoides , also known as ‘finnraccoon’), and v) Chinchilla ( Chinchilla lanigera ).
Housing in metabolic cages for quantitative collection of urine and feces is necessary for nitrogen (N) metabolism studies but may have negative consequences for rat welfare. We hypothesized that providing shelters in metabolic cages would affect the rats’ behavior and reduce the precision of measuring N metabolism. Forty-eight growing male Sprague–Dawley rats were housed in metabolic cages for 9 d, constituting 4 d of adaptation and 5 d for quantitative measurement of feed intake and urine and feces excretion. Using a 2-factorial approach, half of the rats were fed a soybean meal diet, and the other half were fed a diet based on green protein (GP). Half of the rats in each dietary group were provided a ball-shaped shelter in their metabolic cage, and the other half had no shelter (n = 12 per treatment). Video recordings of rat location (cage floor, feed tube, or shelter) were performed on days −3 (adaptation period), 1, and 4 (collection period). Dry matter (DM) and nitrogen (N) digestibility were determined based on DM and N intake and fecal excretion. N metabolism was calculated based on additional measurements of urinary N excretion. The rats used the shelter primarily during the daytime and spent less time in the feed tube during the day than during the night (P = 0.0002). For rats without shelter, there was no difference between day and night in their presence in the feed tube (P = 0.94). The shelters did not interfere with measurements of feed intake, fecal DM, N excretion, or any of the derived N-metabolism-associated responses. There was also no significant effect on the variation associated with the estimated values, and no differences in contamination were detected visually or by rinsing the shelters. We conclude that using ball-shaped shelters to enrich metabolic cages is not a major risk of biocontamination and may improve the rats’ welfare.
Based on experiences from stakeholders, this paper describes and discusses Danish emergency procedures when animal transport vehicles overturn, from a One Welfare perspective. Twenty qualitative interviews were conducted with selected stakeholders involved in emergency responses and their co-ordination. Results from interviews were extracted and are presented as a description of the Danish emergency management procedures in situations where pig transport vehicles overturn in a traffic accident. The description is followed by a discussion of six identified themes related to animal welfare and One Welfare in such situations: (1) Standard operating procedures; (2) Balancing animal welfare and work safety; (3) Roles, education and experience; (4) Communication, time and access to animals; (5) Debriefing; and (6) Killing of animals. Overall, the analyses of the interviews showed that the emergency response at an overturned pig transport vehicle involves different professional groups, requires technical knowledge regarding animal transport vehicles as well as knowledge of the species involved and how to handle the animals. The results are discussed from a One Welfare perspective, suggesting that these emergency responses include an inherent societal prioritisation dilemma involving the balancing of, for example, training, preparation and debriefing of different professional groups. Further research is needed to address ethical considerations, share best practices, and enhance emergency protocols.
Horses of different ages may have to be killed on-farm for purposes other than slaughter (where slaughter is defined as killing for human consumption) either individually (i.e. on-farm killing of unproductive, injured or terminally ill animals) or on a large-scale (i.e. depopulation for disease control purposes and other situations, such as environmental contamination, disaster management, etc.). The purpose of this opinion is to assess the hazards and welfare consequences associated with the on-farm killing of horses. The killing procedure is divided into Phase 1 (pre-killing), which includes the processes (i) handling and moving the animals to the killing place and (ii) restraint of the animals before application of the killing method; and Phase 2 (stunning and/or killing), which includes stunning and killing of the animals (for methods that require one step for stunning and another for subsequent killing) or killing only (for methods that simultaneously stun and kill the animals). Three stunning and/or killing methods for Phase 2 for horses were identified: (i) penetrative captive bolt followed by killing, (ii) firearms with free projectiles and (iii) lethal injection. Welfare consequences that horses may experience during each process (e.g. handling stress, restriction of movement and injuries during restraint) were identified and potential hazards are listed for all phases, along with preventive and corrective measures. Animal-based measures (ABMs) to assess all identified welfare consequences were proposed. During the application of the stunning and/or killing methods, horses will experience pain and fear if they are ineffectively stunned/killed or if they recover consciousness. A flowchart including ABMs for the assessment of consciousness and death to monitor stunning and killing effectiveness is provided. Additionally, specific practices deemed unacceptable on welfare grounds are listed.
Abstract This Scientific Opinion provides an assessment of beef cattle welfare focusing on risks related to flooring, water access, nutrition and feeding, high environmental temperatures, lack of environmental enrichment, lack of outdoor access, minimum space allowance and mixing practices. In addition, risks related to pasture and feedlots, weaning of suckler calves, mutilations (castration, disbudding, dehorning and tail docking), and to breeding practices (hypermuscularity, dystocia and caesarean sections, polledness, maternal ability and temperament) are assessed. Decision‐making criteria for the euthanasia of cull cows are also addressed. A selection of animal‐based measures (ABMs) suitable for collection at slaughterhouses is proposed to monitor on‐farm welfare of fattening cattle. Recommendations to improve the welfare of housed fattening cattle include increasing space allowance and feeding more roughage in relation to current practice, and promoting the use of well‐managed bedded solid floors. Provision of enrichment such as brushes and roughage and an outdoor loafing area for housed cattle are recommended. Cattle kept outdoors should have access to a dry lying area and sufficient shade. Water should be provided ad libitum via large open water surfaces, and the use of nipple drinkers should be avoided. Mixing of unfamiliar cattle should be avoided and groups should be kept stable. Mutilations should be abstained from, but if carried out, a combination of analgesia and anaesthesia should be applied regardless of the calf's age. Early weaning of suckler calves should be avoided (< 6 months). Homozygous double‐muscled animals should be excluded from breeding. Selected ABMs for collection at slaughterhouses to monitor some of the highly relevant welfare consequences experienced by fattening cattle on farm are body condition, carcass fat levels, carcass condemnation, lung lesions and skin lesions. Key data gaps identified are thresholds for dietary fibre, ABM thresholds for fitness for transport and potential long‐term effects of mutilations on pain sensitisation.
This Scientific Opinion (SO) addresses a mandate from the EC regarding welfare of the following animals when farmed for their fur: (i) American mink (Neogale vison or Neovison vison), (ii) Red fox (Vulpes vulpes, also known as 'silver fox'), (iii) Arctic fox (Vulpes lagopus, also known as 'blue fox'), (iv) Raccoon dog (Nyctereutes procyonoides, also known as 'Finnraccoon') and (v) Chinchilla (Chinchilla lanigera). The request was to identify the most relevant welfare consequences (WCs) for each species and to determine whether these could be prevented or substantially mitigated in the current husbandry systems. 'Current system' refers strictly to the cage systems and cage dimensions as described in the EFSA Technical report produced under this mandate, as there was no or very limited information available on animals kept in alternative farming systems. Using information obtained from a review of literature, consultations with stakeholders and consideration by EFSA experts, the SO addresses for each species these WCs along with their underlying hazards and potential preventive or mitigating measures. In all species, Restriction of movement, Inability to perform exploratory or foraging behaviour, and Sensorial under- and overstimulation were selected as the most relevant WCs, sharing common hazards linked to current cage size and barrenness. Species-specific WCs include: soft tissue lesions and integument damage (mink), and handling stress (mink and foxes); locomotory disorders (Arctic fox); group stress (red fox), locomotory disorders and isolation stress (raccoon dog); and inability to perform comfort behaviour, resting problems and predation stress (chinchilla). In the majority of cases, it is concluded that neither prevention nor substantial mitigation of the identified WCs is possible in the current system. The SO also includes conclusions on limited or substantial mitigation measures in the current system and, when not possible, on substantial mitigating measures which would require a change to a different system.
The objective of this Scientific Opinion is to assess the hazards and welfare consequences associated with the slaughter of horses for human consumption. The entire slaughter procedure, from arrival at the slaughterhouse until death, is divided into three phases: Phase 1 - pre-stunning, Phase 2 - stunning and Phase 3 - bleeding. Phase 1 includes the following processes (in chronological order): (a) arrival, (b) unloading of the animals from the vehicle, (c) lairage, (d) handling and moving to the stunning area and (e) restraint before application of the stunning method. Phase 2 encompasses the stunning methods, while Phase 3 involves the bleeding process (i.e. exsanguination following stunning). Stunning methods for horses include penetrative captive bolt and firearms. Welfare consequences that horses may experience (such as handling stress, restriction of movement and injuries) and potential hazards were identified for all the phases along with preventive and corrective measures. For arrival and unloading during phase 1, this Opinion refers to a previous EFSA assessment on the transport of Equidae. Animal-based measures (ABMs) to assess all identified welfare consequences are proposed. A flowchart of ABMs to assess the state of consciousness is provided to allow monitoring during the stunning and bleeding phase at three key stages ((1) between the end of stunning and shackling, (2) during neck cutting or sticking, (3) during bleeding). Additionally, specific practices deemed unacceptable on welfare grounds are listed.
A risk assessment framework was developed to evaluate the zoonotic potential of avian influenza (AI), focusing on virus mutations linked to phenotypic traits related to mammalian adaptation identified in the literature. Virus sequences were screened for the presence of these mutations and their geographical, temporal and subtype-specific trends. Spillover events to mammals (including humans) and human seroprevalence studies were also reviewed. Thirty-four mutations associated with five phenotypic traits (increased receptor specificity, haemagglutinin stability, neuraminidase specificity, enhanced polymerase activity and evasion of innate immunity) were shortlisted. AI viruses (AIVs) carrying multiple adaptive mutations and traits belonged to both low and highly pathogenic subtypes, mainly to A(H9N2), A(H7N9), A(H5N6) and A(H3N8), were sporadic and primarily detected in Asia. In the EU/EEA, H5Nx viruses of clade 2.3.4.4b, which have increased opportunities for evolution due to widespread circulation in birds and occasional cases/outbreaks in mammals, have acquired the highest number of zoonotic traits. Adaptive traits, such as enhanced polymerase activity and immune evasion, were frequently acquired, while receptor-specific mutations remained rare. Globally, human cases remain rare, with the majority overall due to A(H5N1), A(H5N6), A(H7N9) and A(H9N2) that are among the subtypes that tend to have a higher number of adaptive traits. The main drivers of mammalian adaptation include virus and host characteristics, and external factors increasing AIV exposure of mammals and humans to wild and domestic birds (e.g. human activities and ecological factors). Comprehensive surveillance of AIVs targeting adaptive mutations with whole genome sequencing in animals and humans is essential for early detection of zoonotic AIVs and efficient implementation of control measures. All preparedness, preventive and control measures must be implemented under a One Health framework and tailored to the setting and the epidemiological situation; in particular, enhanced monitoring, biosecurity, genomic surveillance and global collaboration are critical for mitigating the zoonotic risks of AIV.
Annually, more than 30 million weaner pigs cross borders between EU member states mainly transported for further production. The current EU regulation states that the internal deck height of the transport vehicles must on no account hinder natural movements and provide adequate ventilation but without including specific norms. The aim of the present study was to examine impact of deck height (60 vs 80 cm and 70 vs 90 cm) on behaviour reflecting natural movements and adequate ventilation during 16 short (8 h) and 16 long (23 h) journeys of 20-25 kg pigs, mimicking commercial conditions. A secondary aim was to describe the behaviour progressed from departure to arrival including the driver break during short journeys. To address the aim, the first task was to select appropriate behavioural measures that could robustly be annotated with the limited vertical space. As a consequence, head butting against the ceiling and drinking behaviour were omitted in pilot observations. The final behaviours were body posture including huddling and huddling location analysed using 15 min interval instantaneous scan sampling. The frequency of aggression and a pig standing on another pig was recorded using continuous sampling during selected 20 min recording sessions (in total 160 and 120 min for short and long journeys, respectively). During short journeys, this included recording sessions placed immediately before, during and after the mandatory break of the livestock driver. Mixed effects models were used to analyse effects of deck height and the following co-variates: hour since departure, microclimatic conditions and vehicle speed. No effect of deck height was found on any of the selected behavioural measures. When examining behaviour of the pigs before, during and after the break, no differences in lying behaviour were found, but for one of the vehicle elements, the trailer, an increase in aggressive behaviour was observed during the break. Overall, the results showed a complex pattern of relations affecting the behaviour of the pigs, such as the microclimatic conditions and driving speed interacting with hour since departure. These findings varied to some extent depending on vehicle element (lorry or trailer) and journey duration (8 h or 23 h, with the associated different stocking densities). Taken together, the results showed that increasing the deck height did not lead to detectable changes in the behaviour of the weaner pigs, but that many other factors influenced the behaviour of weaners during transport and may thus also influence their welfare.
EFSA was requested by the European Commission to provide a scientific opinion on new developments in biotechnology, including new genomic techniques, as applied to animals for food, feed and other agricultural uses. A horizon-scanning exercise identified a variety of animals obtained with new genomic techniques, with the potential to reach the EU market in the short, medium and long term. No novel hazards have been identified that are linked to either the modification process or the newly introduced trait, when SDN-1, SDN-2 and comparable techniques (e.g. base editing or prime editing) were compared to established genomic techniques (EGTs) or conventional breeding. Hazards posed by SDN-3 are of the same nature as those posed by EGTs and the targeted insertion may reduce the potential hazards associated with the disruption of endogenous genes and/or regulatory elements in the recipient genome. Hazards posed by the new trait resulting from the introduced transgenic or intragenic DNA sequence are of the same nature as those posed by EGTs. Hazards posed by the new trait resulting from the introduced cisgenic DNA sequence are of the same nature as those posed by conventional breeding. Off-target mutations from genome editing are similar in nature to those from conventional breeding and do not pose novel hazards. Consequently, based on the currently available data, no new potential hazards, and thus, no new risks to humans, animals or the environment have been identified. A thorough evaluation of existing EFSA guidance documents for the risk assessment of GM animals revealed that their principles and recommendations provide the basis for assessing the risks of new genomic technique (NGT) animals for food, feed and other agricultural uses; however, the current texts cover only partially some areas (e.g. animal health and welfare) and may need updates, adaptations or enhancements on a case-by-case basis to fully address NGT-related risks.