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1 May 2003
Disposal of Fallen Stock
Dr James Irvine
Teviot Scientific Consultancy, Edinburgh,
Teviot Agriculture, Cultybraggan Farm, Perthshire,
Scotland
(Filed 1 May 2003)
© www.land-care.org.uk
The way this issue has been handled by the EC,
DEFRA and SEERAD is symptomatic of the serious problems that face
those who try to make farming work in the UK.
As Land-Care understands it, the initial EC Directive
followed consultation with member countries. It appears that DEFRAs
contribution was to achieve some derogation for remote areas. It
is not clear that they questioned the need for such a Directive
in the first place.
There is also the worry that EC Directives might
be written on tablets of stone, making them inflexible to changing
circumstances. As described earlier in Land-Care (1,
2, 3) circumstances have changed
with the risk of BSE in UK cattle being greatly reduced, and with
the inevitable introduction of BSE testing for cattle over 30 months
entering the food chain (as currently practiced in Continental Europe).
Furthermore, following the FMD UK 2001 crisis there is much more
detailed knowledge available as to the nature of the ground and
the height of the water table in different parts of the country.
There seems to be no opportunity in the foreseeable future to review
whether the EC Directive regarding the disposal of fallen livestock
is still relevant, although its enforcement will no doubt be with
us for a long time to come.
One way whereby its relevance could be reviewed,
however, is through the clause as to what constitutes a remote area.
It could well be that remote need only refer to being
sufficiently far away from water tables and from where the nature
of the soil might facilitate seepage into water tables.
The only rationale that Land-Care can deduce is
that prions which are alleged to be the cause of BSE might get into
the water supply, or otherwise come into contact with man or grazing
livestock. With the detailed knowledge which will undoubtedly be
available as to where BSE remains within UK livestock, the chance
of appropriately buried carcases transmitting BSE to anything seems
to be vanishingly small. Surely the bogey man of BSE possibly being
in sheep can be laid to rest after all these years of negative findings,
and the active steps that have been, and continue to be, taken to
greatly reduce the prevalence of scrapie within the UK through genotyping
for resistance (4).
But what happens?
The consultation paper on what constitutes a remote
area states that the consultation ends on 15th May 2003 (5,
click to view). But in
a letter dated 17th April 2003 SEERAD informs Scottish farmers that
the Directive takes force on 1st May, and invites them to enter
a contract which will given them a good deal in reducing
the horrendous cost for which they would otherwise be liable (6,
Click to view). The letter
goes on to indicate that the good deal will gradually
evaporate with time with the farmer having to meet more and more
of the total massive cost.
Even at the start such a contract is still a substantial
financial burden on any livestock farm. It also raises serious questions
about biosecurity, and creates a lack of confidence as to whether
either DEFRA or SEERAD have any adequate arrangements in place to
deal with the problem that takes effect from today, 1st May.
Dr James Irvine
References
1. 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).
2. 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).
3. Irvine, James (2003). Why is
it necessary to ban the burial of all fallen stock? Part 2: The
view of the EC Scientific Steering Committee.
(Filed 10 April 2003, www.land-care.org.uk,
click
here to view).
4.National Scrapie Plan - Recent
Developments.
(Filed 2002, www.land-care.org.uk,
click here
to view).
5. Scottish Executive Environment
and Rural Affairs Department - Food and Agriculture Group (2003).
Implementation in Scotland of the EU animal by-products regulation:
remote area definition. Letter to interested parties, organisations
etc in Scotland, 19 March 2003.
(Click here to view).
6. Scottish Executive Environment
and Rural Affairs Department - Agriculture Group (2003). New Rules
on Disposal of Fallen Stock from 1 May 2003. Letter to all Livestock
Farmers, 17 April 2003.
(Click here to view).
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