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Bad EC rules lead to bad consequences:
incredibly NFU Scotland calls for a stop
to bluetongue vaccination

James Irvine

Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire

Filed 20 Aug 08,

Defra is forging ahead with its voluntary vaccination programme in a belated attempt to counter the threatened resurgence, and subsequent spread, of bluetongue virus serotype 8 in England and Wales. Defra ordered 22.5 million doses from Intervet for England & Wales on 20th December 2008. In addition, Defra has ordered, and is beginning to receive, further large supplies from Merial. Defra's vaccination strategy has been to extend the vaccination area according to perceived risk, creating new boundaries to the Protection Zone (PZ) as they do so. As of 11th August there will no longer be a Surveillance Zone (SZ), with the PZ extending close to the south of Cumbria and of Northumbria. This can be seen on the Defra Map of 11th August.

The Scottish Government, on the other hand, in its attempt to comply with the EC rules that relate to Bluetongue-free countries or zones, did not decide to order their vaccine supplies until the 7th March 2008, and did not actually place their order with Merial until 27th June 2008.

Scotland is scheduled to receive one million doses in August. The rest of the order is to be delivered in batches throughout October, November and December. The timing of these deliveries, according to the Scottish Government has been arranged around the view that "Scotland needs a contingency plan in case disease occurs in Scotland this summer, but that the main vaccination campaign (if declared) would be conducted during the Vector Free Period (VFP)." According to the Scottish Government the timing of the later deliveries also allows Scotland to obtain a supply of vaccine in 50 ml as well as 100ml bottles. The earlier deliveries are to be in the form of 100ml bottles, which are likely to cause problems for many livestock farmers.

The EC rule that persuaded Scotland to delay its vaccination programme, which it correctly has opted to be compulsory, until the VFP in December 2008 to March 2009, is the one that states that as soon as the first animal is vaccinated the Zone or Country has to be declared a PZ, and livestock must be given free access for livestock movements into it from any other PZ throughout the EU. That of course would be an open invitation for bluetongue disease to spread throughout Scotland, as it takes two months in cattle for fully effective immunity to be established. This EC rule is a very bad rule, as it flies in the face of the basic science of disease control: which is to vaccinate before the disease arrives rather than play catch-up after it has arrived. But, in spite of being asked to change this ruling, or to provide appropriate derogation from it, the EC has refused to alter the terms of its rule.

August and September are the months when the midges get going and new cases of bluetongue disease in livestock appear. Indeed, the inevitable has happened. With bluetongue vaccination far from being completed in time in northern Europe, an abundance of new cases are being reported in France and other EU Member States. Since bluetongue vaccination in England is voluntary, no one knows for sure what percentage of the livestock in England south of Cumbria and Northumberland have been vaccinated. It would seem inevitable that new cases of bluetongue disease will appear in England soon.

The predicted rate of spread of bluetongue disease is no longer likely to be largely determined by the distances at which midges can be carried by the wind, but by the regulation that permits livestock to be moved freely throughout PZs in the EU, including England: right up to just south of Cumbria, as of the 11th August. And shortly to the border with Scotland. The midges would then not have far to go to feast themselves on the high density of immunologically virgin livestock that is a feature of south west Scotland. Bluetongue, a disease with dire consequences for livestock both in terms of animal welfare and economics, could spread like wild fire.

There is also a high density of livestock in Cumbria and in Northumbria, with important auction marts at Carlisle and Hexham. In the area south of that the density of livestock is less. It could be argued, therefore, that - in the attempt to make the best of a bad situation emanating from bad EC rules - it might be advisable to stop vaccination from extending further north into Cumbria and Northumberland. But with free movements of infected livestock being allowed into areas south of Cumbria and Northumberland this would seem to be a forlorn hope.

Defra is due to meet next week with the UK's devolved organisations to assess the bluetongue situation. What is incredible is that NFU Scotland is reported in The Scottish Farmer of 9th August as trying to persuade the powers that be to suspend vaccination in the north of England. This, they argue, would allow northern |England to adhere to a similar disease control timetable as adopted by Scotland: i.e. wait until the next VFP.

However, the argument put forward by NFU Scotland is not based on a rational assessment of disease risk, nor on how science should be logically applied to defend against such an obvious risk of disease spread. Rather, their argument is based on trade considerations. There is indeed very significant trade between the north of England and Scotland. But that of course would be devastated if bluetongue disease reached the area. The damage done would be far worse than the comparatively short term damage to trade through restrictions on livestock movements in the absence of disease.

Nigel Miller, NFU Scotland vice-president and livestock convener, is reported as justifying such a stance by saying that so far England has not seen any new cases of bluetongue disease this summer, and that the vaccination programme in England may have sufficiently dampened down the risk. But it is too soon to place any credence on such a statement. As mentioned above, it is only in August and especially in September that we can expect to see a resurgence of new cases in England. Some 800 new cases have been reported in France in recent days. New cases have recently been reported in the north of Denmark. And free movements of livestock - whether they are carrying the virus or not - are permitted to the northern limit of the current PZ in England. NFU Scotland are taking an enormous gamble by advocating a policy that asks for vaccination to be stopped in England. Frankly, it beggars belief.

Just consider the profound mess that the EC rules on vaccination in a disease-free zone or country have created. If vaccination is extended in England to the Scottish Border, not only will trade from northern England to Scotland be halted, but the risk to Scotland getting the disease would be greatly increased. If Scotland were to declare a PZ in the south of Scotland, then trade between the south of Scotland and the rest of Scotland would be disrupted, but crazy EC rules would allow the disease to be carried by legitimate livestock movements towards Scotland's central belt.

Because Scotland has been so very late in ordering its supply of vaccine, if bluetongue disease breaks out in the south of Scotland it only has the relatively small number of doses that it has been promised as a contingency measure. Considering the heavy density of livestock in the south west of Scotland that amount of vaccine would not be nearly enough. And what might be available would be far too late.

Protracted consultations on who was going to pay for the vaccine supply for Scotland, the protracted bureaucracy over procurement procedures, plus allegedly waiting for the EPIC Report from Scotland's academic establishments (which in the event seemed to contribute remarkably little) were the reasons given for Scotland's lamentable delay in ordering its 12 million doses of vaccine.

Livestock movements during the summer months in Scotland are light, compared to those in the autumn and in the spring. Surely there was a window of some 3 months or more in the summer when vaccination could have been carried out with minimal disruption to trade. This, accompanied by a derogation that no livestock were to be imported into Scotland until compulsory vaccination had been effectively completed, would have seen Scotland safe from bluetongue serotype 8.

But vaccine was not ordered early enough and there was no derogation forthcoming from the EC. Endless delays in Scotland ordering its 12 million doses have contributed, along with the absurdity of the EC rules, to the incredible situation whereby NFUS Scotland is seeking, in the interests of trade, to halt further vaccination in England. The risk is, of course, that the north of England and Scotland may well be hit harder by bluetongue disease than elsewhere in England or in Wales. But clearly NFU Scotland is hoping to get way with it. That is not the way to logically control the spread of such a dire disease as bluetongue.