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10 April 2003
Why is it necessary to ban burial
of all fallen stock?
Part 2: The view of the EC Scientific
Steering Committee
James Irvine
FRSE DSc FInstBiol FRCPath FRCPEd
Teviot Scientific Consultancy, Edinburgh,
Teviot Agriculture, Cultybraggan Farm, Perthshire,
Scotland
www.land-care.org.uk
(Filed 10 April 2003)
Land-Care published part 1 of this topic on 3rd
April (1). Donny Morrison of Scottish
Environmental Protection Agency (SEPA) - having stressed that SEPA
had no input into this subject, had not been asked to comment, and
was not to be involved in the monitoring of the implementation of
the Directive when that occurred - suggested that I contact Martin
Morgan of the Scottish Executive. This I did. I also looked up the
website that Donny Morrison of SEPA had helpfully suggested.
In discussion with Martin Morgan I was informed
that the impending Directive was the outcome of the deliberations
of the “distinguished scientists” that make up the Scientific
Steering Committee of the EC. However, I replied that if the science
is soundly based it should be understandable to the general public
and also to other scientists. For the reasons that are described
in Part 1 of this article (1) the logic was not
apparent to myself. I further asked if the science behind this impending
Directive had been reviewed by Scotland’s own scientists to
see if they agreed. Scotland is rich in academia, including research
institutes concerned with animal and human health. Indeed Scotland
has the National CJD Surveillance Unit, based in Edinburgh. I was
given to understand that none of these organisations had been asked
by the Scottish Executive for their opinion concerning this impending
EC Directive. Martin Morgan kindly sent me the only paper he had
on the subject - which is entitled:
“Opinion on The use of burial for dealing with animal carcasses
and other animal materials that might contain BSE/TSE: adopted
by the Scientific Steering Committee (SSC), Meeting of 16-17 January
2003"
For convenience this document has been reproduced
here.
It would appear to me that the "distinguished
scientists of the scientific steering committee" had not been
doing their science very conscientiously. Indeed it would appear
that they had not considered modern science that is certainly available,
dismissing it with such a statement as:
"In the absence of any new data the SSC confirms its previous
opinion that animal material which could possibly be contaminated
with BSE/TSEs, burial poses a risk except under highly controlled
conditions (.e.g. controlled landfill)"
Modern science says (as already described in
Part 1 of this article) that the current incidence of BSE in UK
cattle is falling rapidly and is now very low. The incidence in
Scotland must be especially low as much of the livestock in whole
regions of Scotland are to do with beef production rather than dairy.
The Food Standards Agency (FSA) is clearly indicating that the Over
Thirty Months Slaughter (OTMS) Scheme is up for review on account
of the now very low prevalence of BSE in UK cattle (2,
3).
Moreover, post mortem tests for BSE with results
available within 24 hours have been in operation for some years
within Continental Europe (where no OTMS scheme operates). The test
must be negative before the carcase can enter the food chain. Although
the UK authorities through DEFRA appear to be quite unprepared for
the necessary provision of such a BSE screening service, nevertheless
it will have to be made available for the public to be convinced
that all of a sudden all meat is now safe as regards BSE.
The provision of such prompt post mortem tests
for BSE in cattle presented for the food chain would give excellent
data on where BSE may still be lurking in UK cattle. After all the
animal’s passport is still sitting right there with the animal
at the slaughterhouse. Restrictions on burial on farm could then
be more sensibly applied to those few farms where evidence of risk
is presented. No farm wants to have fallen stock on its farm. At
present ageing cattle or cattle that are not productive or are not
otherwise thriving go through the OTMS scheme with a financial incentive.
If that incentive is withdrawn (and already it is due to be reduced
in a few months time) with the abandonment of the OTMS scheme, such
cattle will be presented to the food chain and will have to go through
the BSE screening process. Young cattle under 30 months dying on
farm from accident, lack of good mothering, or diseases of cattle
with no implications for humans, are incredibly unlikely to have
BSE.
As stated previously in Part 1, there is no evidence
that BSE affects sheep or that scrapie infected sheep can affect
man. If the recommendations of the EC Scientific Steering Committee
were to be followed we would be waiting an eternity for a negative
to be proven. Scrapie has been present in UK sheep for over a hundred
years and is presently in rapid decline (4).
The Environmental Protection Agencies in the UK
have good knowledge of the water table and soil conditions throughout
the country in relation to existing regulations regarding waste
disposal. A site chosen for the disposal of fallen stock would have
to comply with these regulations.
Rather than spend such vast financial resources
on preventing the burial of all fallen livestock (except in very
limited areas that have achieved derogation), surely it would be
better to use tests that are currently available and to invest in
research to develop new tests that are even better. Teviot
Scientific Publications published on-line the preliminary results
of an antemortem test for BSE in cattle by Professor Ebringer’s
group (5). The results look promising
but as I understand it DEFRA have shown little interest in helping
the further assessment of this line of research. Further assessment
of the test cannot be done without DEFRA’s cooperation as they
hold authority over all samples from BSE infected cattle and access
to relevant data. A further area of great potential would be the
rapid development of membrane technology to concentrate and detect
prions (6).
The lack of application of research facilities
and talent currently available within the UK to projects of national
importance is illustrated by the fact that, although the UK has
suffered the most from BSE and has spent vast sums on the subject,
the UK failed to develop a credible postmortem test for BSE, being
beaten to it in terms of the application of science developed by
France, Ireland and Switzerland (7).
The UK would have to buy these tests now in kit form from Continental
Europe.
Interestingly, Professor Peter Doherty FRS and
Nobel Laureate working in Australia and who was delivering a prize
lecture ("Cell-mediated Immunity and Viruses") at the
Moredun Institute, Roslin, Edinburgh recently, lamented the fact
that major scientific advances were too often poorly understood
by Government bodies who consequently failed to facilitate their
development. Too often the government civil servants were primarily
concerned in ensuring that the “back legs of government ministers
were protected, rather than taking the necessary risks involved
in promoting such developments”.
At the recent Scottish Countryside Alliance Conference
in Edinburgh entitled “Connecting Communities”, members
of the ruling Liberal/Labour coalition in the Scottish Parliament
were forced to confess that they had not paid enough attention to
scrutinising projects that were being proposed for development into
Directives by the EC. They just sat and waited for them to arrive
in final form. Interestingly, with regard to the fallen stock Directive,
the period for public consultation was not due to close by the time
the Directive was supposed to be in force.
The ruling party in the Scottish Parliament seems
to think all it had to do was to implement such Directives however
illogical they may be. The research institutes in Scotland largely
funded by the Scottish Executive feel that they cannot comment on
poorly constructed EC Directives unless they are asked to do so
by Government, lest they be accused of being political. What a sorry
sate of affairs - no doubt it is just as bad in England and Wales.
"Don't rock the boat unless my face doesn't fit and my funding
is threatened", is an appalling philosophy that is apparently
necessary for current survival.
One also has to seriously wonder what our MEPs
are supposed to be doing when they are in Brussels.
Quite apart from the illogical knee-jerk reaction
of the EC Scientific Steering Committee which demands one formula
for all, this same steering committee with incredible unity of focus
apparently did not appreciate the risks to farm livestock of transporting
fallen stock from farm to farm in the process of collection. Nor
did they seem to appreciate the risks associated with fallen stock
lying about waiting for such collection to occur. It is my belief
that these risks currently outweigh risks of burying fallen stock
on farm using approved sites in an approved manner.
© www.land-care.org.uk
References
1. Irvine, James
(2003). Why is it necessary to ban the burial of all fallen stock?
Part 1: Is it do with the supply of drinking water?
(Filed 3 April 2003, www.land-care.org.uk,
click
here to view).
2. FSA Press
Release (2003). OTM Rule public meeting - 7 March 2003. (Click
here to view).
3. Irvine, James
(2003). The Food Standards Agency reviews the OTMS rule - are they
going to scrap it?
(Filed 12 March 2003, www.land-care.org.uk,
click
here to view).
4. Scrapie Statistics
for Great Britain.
(Filed 2002, www.land-care.org.uk,
click
here to view).
5. Wilson, C.,
Hughes, L. E., Rashid, T., Ebringer, A. and Bansal, S. (2003).
Antibodies to Acinetobacter Bacteria and Bovine Brain Peptides,
Measured in Bovine Spongiform Encephalopathy (BSE) in an Attempt
to Develop an Ante-Mortem Test.
J. Clin. Lab. Immunol. Published
online, 13 March 2003. (Downoad
PDF).
6. Detection
of Prions: Developing Technology
(Filed 13 February 2003, www.land-care.org.uk,
click
here to view).
7. Irvine, James
(2003). Where has UK Biotechnology gone?
(Filed 21 March 2003, www.land-care.org.uk,
click
here to view).
Further Reading Recommended by Land-Care
Post-mortem Tests for BSE in Cattle: Further Correspondence with
Prof Wilesmith.
(Filed 24 March 2003, www.land-care.org.uk,
click
here to view).
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