The Law Has a One Health Problem

Biology is connected. The laws governing it are not.

Imagine a virus circulating quietly in an animal population. A veterinary laboratory detects it and produces a genome sequence; several weeks later, a farm worker becomes ill and a clinical laboratory identifies the same virus; and related infections subsequently appear in another country. The genome travels into international databases, researchers begin investigating it, pharmaceutical companies consider diagnostic and vaccine development, governments introduce controls on animals and animal products, and international organisations begin assessing the risk. Nothing about this progression is particularly difficult to understand biologically — the same pathogen is moving through a connected system.

Legally, however, it has travelled through a remarkable number of worlds. It began as an animal-health issue; when the first person became infected, human public-health law became important; when the pathogen was shared internationally, access-and-benefit-sharing questions emerged; once its genome became a globally accessible research resource, questions concerning digital sequence information appeared; when governments restricted animal products, international trade law became relevant; if international transmission became sufficiently serious, the International Health Regulations could provide the principal health-security framework; if the threat escalated further, the new pandemic-emergency provisions could become relevant; and if a vaccine were developed, manufacturing, regulation, intellectual property, procurement and equitable access would enter the picture. The biology remained connected throughout. The governance did not. This is the One Health problem hiding inside international law — and the synthesis of our Rules of Outbreaks series.

We have more law than it first appears

The obvious response to a governance gap is often to call for another treaty — but that is not necessarily the problem here, because global biological risk is already surrounded by substantial international law and institutional architecture. The International Health Regulations govern important aspects of surveillance, notification, preparedness and response to international public-health threats; the WHO Pandemic Agreement is intended to strengthen pandemic prevention, preparedness, response and equity once its remaining PABS architecture is completed; the World Organisation for Animal Health maintains international animal-health standards and disease-reporting systems; the Convention on Biological Diversity and Nagoya Protocol govern access to genetic resources and benefit sharing; the emerging PABS system is intended to create a specialised multilateral mechanism for pathogen access and benefit sharing; the WTO SPS Agreement governs sanitary and phytosanitary measures affecting trade; and Codex, WOAH and the International Plant Protection Convention provide internationally recognised standards across food, animal and plant health, with environmental law, data protection, national emergency legislation and product regulation adding further layers. The problem is therefore not an empty legal landscape. It is a crowded one.

Each system sees a different object

International legal regimes do not merely regulate different organisations; they can effectively see different versions of the same biological event. Animal-health governance sees an infection in an animal population; public-health governance sees a threat to human health; biodiversity law sees a genetic resource and potentially digital sequence information; trade law sees a sanitary or phytosanitary risk capable of justifying restrictions on commerce; pandemic preparedness sees a pathogen with pandemic potential; and a pharmaceutical regulator may later see a vaccine, diagnostic or therapeutic product. These are all legitimate descriptions — but none automatically carries the complete history of the biological event with it. The pathogen is continuously translated as it crosses institutional boundaries, and something can be lost in translation. It is the same pattern our analysis of one pathogen moving through four legal systems follows step by step.

One Health has often diagnosed the problem correctly

One Health exists partly because these divisions do not reflect the way biological systems actually behave: human health depends on animal health, animal health depends on ecosystems, food production connects animals, plants, environments and people, antimicrobial resistance moves through healthcare, livestock, food and environmental systems, vectors connect climate, ecology, animals and human populations, and zoonotic pathogens exploit interactions between species rather than administrative responsibilities. The standard One Health response has therefore been to call for collaboration — human-health professionals working with veterinarians, environmental scientists involved, food-safety expertise included, governments adopting multisectoral approaches. All of this is correct. It is also no longer enough.

Collaboration is not an architecture

Consider two laboratories, one part of an animal-health system and the other part of human-health surveillance. Their directors may have an excellent professional relationship, attend the same One Health meetings and agree completely about the importance of cooperation. But what happens at 02:00 on a Saturday when the veterinary laboratory sequences something unusual? Who receives the information? What threshold triggers escalation? Which metadata can legally be shared? Which identifier allows a later human isolate to be connected to the animal finding? Who decides whether the signal is internationally significant, and how quickly does it reach the people responsible for the International Health Regulations? Professional goodwill cannot answer those questions — the interface has to be designed. This is the difference between One Health collaboration and One Health architecture.

The interface is the neglected unit of preparedness

Health-security planning frequently concentrates on organisations: does the laboratory have sufficient capacity, does the public-health agency have a contingency plan, does the veterinary authority conduct surveillance, does the government have emergency powers? Each question matters — but a connected biological event introduces another: what happens between them? That interface can contain legal uncertainty, different data standards, different terminology, different thresholds for escalation, different geographical units, different definitions of a case, different confidentiality requirements, different institutional incentives and different international reporting systems. A system can therefore contain highly competent organisations while performing poorly as a whole. That is the governance gap — and it is the recurring theme of when surveillance systems connect but institutions do not.

Salmonella showed us system visibility

Consider a foodborne outbreak. Whole-genome sequencing can reveal that bacterial isolates obtained from patients hundreds of kilometres apart are closely related, so the pathogen becomes visible — but investigators then have to reconstruct the food network connecting those patients: restaurants, suppliers, distributors, products, batches, farms and samples. The scientific system may therefore identify a microbial relationship before the governance system can reconstruct the physical system through which the organism travelled. We described this as the difference between pathogen visibility and system visibility, and the law has the same problem: it can classify individual components extremely well while struggling to represent the relationships between them.

Bluetongue showed us the reporting interface

Animal-disease surveillance exposes another part of the architecture, because the first useful signal may not come from government. It may come from a farmer: a stockperson notices something unusual, a veterinary surgeon examines an animal, and someone decides that the signs might justify reporting a notifiable disease — only then does the formal surveillance system begin. The individual therefore becomes part of the biological sensor network, which means legislation cannot simply impose a reporting obligation and assume the surveillance problem is solved. The economic and administrative consequences of reporting matter; trust matters; communication matters; compensation policy may matter. A surveillance system partly dependent on voluntary observation and mandatory disclosure must understand the incentives experienced by the people producing the signal, as our analysis of farmers and the surveillance system argues. That is another interface.

Wastewater showed us the environmental interface

Environmental surveillance turns the problem around. Wastewater may reveal a pathogen before clinical surveillance identifies substantial disease, so the signal already exists — and now somebody has to decide what it means. Is it increasing? Does it indicate sustained transmission? Should clinical laboratories alter testing? Should local public-health authorities investigate? Does animal-health surveillance contain relevant information? The environment has become a sensor, and the governance problem lies in turning the environmental observation into cross-system action. This led us to another distinction: detectability is not the same as actionability. Better sensors do not automatically create better preparedness; they create more information, and governance determines whether that information becomes useful.

Mosquitoes showed us the intervention interface

Vector control creates a different One Health problem. Government can map invasive mosquitoes, entomologists can operate traps, public-health agencies can assess disease risk and local authorities can manage public land — yet breeding habitat may exist across thousands of private gardens, so the intervention cannot be delivered entirely by the institution formally responsible for public health. It becomes distributed biosecurity, in which households, businesses and communities control parts of the environment on which successful intervention depends. The interface now lies between public authority and private behaviour. Again, the biology ignores the administrative distinction.

International law multiplies the interfaces

At international level, every domestic boundary acquires another layer: a national animal-health signal may need to reach human-health authorities; the national human-health system may need to notify WHO; a pathogen sample may need to enter an international laboratory network; its sequence information may become globally available; benefit-sharing obligations may become relevant; a trading partner may impose an SPS measure; and international organisations may issue different assessments concerning different components of the event, after which governments translate those international signals back into domestic decisions. The result is not a chain. It is a governance network — which is why simply asking who is in charge? produces an unsatisfactory answer: nobody is in charge of the entire biological system.

Distributed governance is not necessarily bad

This is an important distinction, because One Health does not require a single global authority governing humans, animals, food, biodiversity, trade and the environment; such an institution would be extraordinarily difficult to design and potentially undesirable. Specialisation exists for good reasons: veterinary authorities possess expertise that human-health institutions do not; environmental regulators have different responsibilities from disease-control agencies; trade law has to balance interests extending beyond epidemiology; biodiversity law protects legitimate interests surrounding genetic resources; and national governments possess constitutional and democratic responsibilities that international organisations cannot simply replace. The objective should therefore not be to eliminate boundaries. It should be to make boundaries permeable to relevant information and coordinated action — a very different ambition.

From institutional integration to interoperability

Technology provides a useful analogy: two computer systems do not need to become the same system in order to communicate; they need agreed interfaces. The same principle can apply to governance. An animal-health system and a human-health system do not need identical legislation; they need an agreed mechanism for escalating relevant biological signals. Two countries do not need identical databases; they need enough common data structure to exchange information during an incident. A laboratory does not need access to every commercial traceability record; it needs identifiers capable of connecting its biological observation to the relevant part of the physical system. Biodiversity and pandemic law do not need identical objectives; they need predictable rules explaining how pathogen access and benefit sharing interact during emergencies. This is governance interoperability, and it may be one of the most useful practical interpretations of One Health.

A minimum One Health interface

What would that look like? Every major biological surveillance system should be capable of answering several questions. What has been observed? The pathogen, syndrome, resistance mechanism, mortality event or environmental signal. Where and when was it observed? Using sufficiently consistent geographical and temporal information. What biological object did the observation come from? Human, animal, food, vector, environmental sample or another source. How confident are we? Suspected, probable, confirmed, genomically related or another agreed evidential state. What might it connect to? Other cases, animals, samples, locations, products or environmental observations. And, critically, what threshold requires another system to know? Interoperability does not mean everybody receives everything; it means the conditions for crossing the boundary are established beforehand.

Escalation should follow biology

Current systems often escalate according to institutional rules; a One Health architecture should additionally recognise biological transitions. Animal circulation plus unusual human exposure could trigger enhanced occupational surveillance; an animal isolate plus a related human isolate could trigger a joint investigation automatically; environmental detection plus a rising clinical signal could trigger a cross-system incident assessment; a food isolate plus a matching human genomic cluster could trigger enhanced supply-network reconstruction; and a novel zoonotic pathogen plus international spread could trigger accelerated consideration under national IHR arrangements. The system does not wait for one sector to finish its investigation before the next begins; evidence moves iteratively.

Build incident graphs, not institutional silos

One practical approach is to represent significant biological incidents as temporary networks. Nodes might include human cases, animals, farms, food products, batches, laboratory samples, pathogen isolates, genomic sequences, environmental sampling sites, vectors, businesses and locations; relationships might represent exposure, movement, production, sampling, genomic similarity, transformation, distribution or epidemiological association. Different institutions could retain control of their underlying information while contributing the relevant relationships to the incident view. This is not a proposal for a permanent global database containing everything. It is visibility on demand.

The law needs temporary permeability

This principle could apply legally as well as technically. Normal governance should remain distributed, but during significant biological incidents predefined mechanisms should allow relevant information, authority and expertise to cross institutional boundaries more quickly — emergency data-sharing agreements, pre-agreed laboratory transfer arrangements, cross-sector escalation protocols, temporary incident-management structures, clear interfaces between animal-health reporting and national IHR systems, predetermined rules for pathogen access and benefit sharing, and rapid mechanisms for reviewing SPS restrictions as epidemiological evidence changes. The objective is not emergency deregulation. It is avoiding emergency improvisation.

Measure the time lost between systems

This leads to one of the central concepts emerging from the One Health Security framework: governance latency. Traditional preparedness measures often ask whether an organisation has a plan or whether a laboratory meets a performance target; we should also measure how long information spends crossing interfaces. A biological incident might produce a sequence from first signal to sector recognition, cross-sector recognition, national escalation, international notification, shared situational awareness and intervention — and each interval can be measured. This allows us to distinguish scientific latency from governance latency: perhaps sequencing took twelve hours and recognising the genomic relationship took another six, but perhaps three days passed before animal and human investigations realised they were looking at the same event. The laboratory was not the bottleneck. The governance architecture was.

Measure interpretation latency too

Environmental surveillance demonstrates that detection alone is insufficient, so we should distinguish at least three forms of delay: detection latency (how long before the biological signal is observed), interpretation latency (how long before its significance is understood) and governance latency (how long before relevant institutions connect the information sufficiently to make and implement a decision). Different interventions reduce different forms of latency — better diagnostics reduce detection latency, better analytics may reduce interpretation latency, and better institutional interfaces reduce governance latency. This is a much more useful preparedness framework than simply demanding “more surveillance”.

Governance should preserve provenance

There is another requirement connecting the legal and technical sides of One Health: information should retain its provenance. A genomic sequence should remain connected to the sample from which it came; the sample should remain connected to the animal, patient, food or environmental location from which it was collected, subject to appropriate privacy and confidentiality protections; a food product should remain connected to relevant production and transformation events; and an animal-health signal should retain information about species, place, time and epidemiological context. Provenance matters scientifically, and it also matters legally, because benefit sharing, responsibility, traceability, risk assessment and evidential confidence can all depend on knowing where information originated and what happened to the biological material before it became data.

Equity is part of surveillance design

PABS reveals another lesson. Global surveillance depends on cooperation, and countries are more likely to share pathogens rapidly when they trust the system receiving them. If biological material and genomic information travel rapidly out of an affected country while resulting diagnostics, vaccines and therapeutics travel back slowly, the surveillance architecture contains an incentive problem. Equity therefore should not be treated as charitable distribution after the scientific work has finished; it can influence the willingness of participants to generate and share the information on which global preparedness depends. In that sense, benefit sharing is part of biosecurity infrastructure — and trust is part of surveillance infrastructure.

Trade rules are part of the same system

The SPS Agreement shows why One Health governance cannot end with public-health institutions, because disease-control decisions affect economic systems. A government facing a serious livestock outbreak may need to restrict trade; trading partners need confidence in surveillance and regionalisation; farmers need predictable rules; and restrictions need to change as evidence changes. The better the underlying system visibility, the more precisely interventions can be targeted, while poor visibility encourages broad precaution. Once again, information quality becomes resilience.

One Health law should begin with interfaces

If we wanted to make the international legal architecture more One Health without creating another enormous treaty, there are several places to begin.

1. Define cross-sector escalation triggers. Countries should establish explicit criteria determining when an animal, environmental, food or vector signal must be assessed jointly with human-health authorities.
2. Connect those triggers to national IHR architecture. Potentially internationally significant zoonotic or environmental events should have a clear route into National IHR Authorities and Focal Points.
3. Create minimum interoperable biological data. Systems do not need identical databases, but they should share enough identifiers and metadata to connect relevant observations rapidly.
4. Pre-negotiate pathogen access. The PABS system should make the route from detection to legitimate international access predictable before an emergency begins.
5. Preserve benefit sharing. Rapid pathogen access and rapid benefit sharing should be treated as reciprocal preparedness capabilities.
6. Build temporary incident graphs. Complex cross-sector events should be represented as biological networks rather than collections of separate institutional reports.
7. Exercise the interfaces. Pandemic exercises should begin with ambiguous animal, food or environmental signals rather than convenient confirmed human outbreaks.
8. Measure governance latency. After-action reviews should record when evidence first existed, when it crossed institutional boundaries and when it became actionable.
9. Give emergency measures exit criteria. Trade restrictions, movement controls and other temporary interventions should specify the evidence required for modification or removal.
10. Treat interoperability as preparedness infrastructure. Funding should support not only laboratories and surveillance programmes, but also the mechanisms allowing them to work together.

A One Health stress test for legislation

There is a simple question legislators and policymakers could apply to almost any biological-security framework: if the important signal appears in another sector, can this law see it? For public-health legislation: can it see an animal-health warning? For animal-health law: can it respond when genomic evidence connects animal infection to human disease? For environmental surveillance: can a wastewater signal trigger a health investigation? For food law: can genomic evidence connect contamination with human cases rapidly enough to reconstruct the supply network? For biodiversity law: can benefit sharing occur without delaying urgent pathogen access? And for trade law: can restrictions change as rapidly as epidemiological understanding changes? This is a more useful One Health test than simply checking whether the phrase “One Health” appears in a policy.

The problem is not the number of laws

International biological governance will always be plural. There will always be a public-health regime, an animal-health regime, a biodiversity regime, a trade regime and a set of national legal systems, because each protects genuine and different interests, and no single body could absorb them all without becoming both illegitimate and unworkable. The problem was never that there are too many laws, or too few. It is that each regime describes the same biological event as though it were a different one — an animal disease here, a genetic resource there, an SPS measure somewhere else — while the pathogen experiences none of those distinctions. It simply moves.

So the task is not to build one more law on top of the others, nor to collapse the others into a single super-institution. It is to treat the connections between existing regimes as objects of design in their own right: to decide, before an emergency, which signal crosses which boundary, in what form, to whom, and on what trigger. That is unglamorous work. It produces no founding treaty and no headline institution. But it is the difference between a set of competent systems and a system that can actually see the whole event.

Every article in this series has arrived at the same place from a different direction. The architecture is crowded, not empty; the journey of a single pathogen crosses regime after regime; the IHR, the Pandemic Agreement, PABS, the Nagoya Protocol and the SPS Agreement each govern one representation of the same thing; and no one is finally in charge. Biology is connected. The laws governing it are not. The central task of One Health security is to make sure that information, evidence and action can cross the boundaries between our institutions at least as fast as a pathogen crosses the boundaries between our species. Until they can, the law will keep seeing many small problems where biology has only ever presented one.

Related One Health Security analysis

This is the synthesis of our Rules of Outbreaks series on global health law. It draws together Who Governs a Global Outbreak?, One Pathogen, Four Legal Systems, The International Health Regulations, The WHO Pandemic Agreement, PABS, The Nagoya Protocol, Can You Close a Border to Disease? and Who Is Actually in Charge?, and looks forward in What Happens Next?

Correct at the time of writing (August 2026): the 2024 IHR amendments are in force; the WHO Pandemic Agreement was adopted in May 2025 but not yet in force, with its PABS annex still under negotiation.

Questions & Answers

References and further reading

1. World Health Organization. International Health Regulations (2005), as amended.
2. World Health Organization. WHO Pandemic Agreement — including the One Health and PABS provisions.
3. World Organisation for Animal Health. World Animal Health Information System (WAHIS) and the Terrestrial Animal Health Code.
4. Convention on Biological Diversity. Nagoya Protocol on Access and Benefit-Sharing; and World Trade Organization, Agreement on the Application of Sanitary and Phytosanitary Measures.