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12 March 2003
Comments on DEFRA’s FMD Contingency Plan,
Version 2.5
Mary Marshall
Member of DEFRA’s FMD Stakeholders Group,
representing the Smallholders Forum:
Member of the Foreign and Emerging Diseases Committee
of the US Animal Health Association
Submitted to Land-Care 28th February,
revised and updated 3 March and 11 March, 2003
www.land-care.org.uk
(Filed 12 March 2003)
“Defra should not be re-fighting
the last war,
but planning and training for the next.”
(Professor Martin Hugh-Jones, School of Veterinary Medicine, Louisiana
State University, USA)
While welcoming the consultation process on the
contingency plan, I find the current document woefully inadequate
and hope that significant changes in strategy based on recent developments
in diagnostics and surveillance will be implemented, and further
relevant research and trials will be supported and funded.
Through my contacts with scientists in the UK,
EU and North America, I am in possession of a considerable amount
of information, some of which I have been asked to share only with
government agencies. In all cases, I have shared information which
is not in the public domain with Defra. In the comments that follow,
I may refer to some of this information without providing full references,
but all of this information is in the hands of Defra.
There are major sections in the Contingency Plan
on the press and internal press activities, and a curious phrase
“Stakeholder Handling”. Are we dangerous animals to be
kept firmly under control?
Absent from this document are the crucial topics
on improving diagnosis and record/data acquisition and analysis.
Professor Martin Hugh-Jones
(Department of Pathobiological Sciences, School of Veterinary Medicine,
Louisiana State University, USA) made the following highly relevant
comments about the future control of FMD:
“I believe that some aspects are vital. They include:
[1] Animal side tests of reliable sensitivity and high specificity.
Nobody should or need wait for reference-quality laboratory confirmation.
[2] Wireless data acquisition from the farm at the time of examination
and preliminary diagnosis by laptop or other suitable electronic
device. Ditto updated data as the herd is processed. If “wireless”
is difficult, it should be through a website or other access system
that is available at all times. This should, if possible, include
digital graphics acquisition and transmission — if Page Street
doesn’t believe the VO, he can, for example, send a photograph
of the lesions he has seen or of anything else.
[3] That data should be immediately omni-available, at least
throughout Defra.
[4] The data loggers should have GPS chips installed so that
there are no errors in accurately locating diseased, suspect,
or healthy herds.
[5] Data should be GIS linked so that situations on individual
farms can be queried remotely — e.g., click on a farm icon
on a quasi-3-D map display, as well as to either constantly updated
frequent analyses or by idiot-able custom analyses.
I don’t think it is wise to firmly believe that all future
FMD episodes will be like 2001. One of the commonest errors is
to assume a worse-case scenario. Obviously the system should be
able to be racked to deal with such an event. But as presently
planned I get the distinct impression that there will be more
veterinary officers at committee meetings or writing reports for
committees than out in the field dealing with the problem.
As a last word, Defra should not be re-fighting the last war,
but planning and training for the next.
You may use my comments as you like.”
Martin Hugh-Jones, a UK (Cambridge-trained) vet,
is also Director, WHO Collaborating Center for Reference & Training
in Remote Sensing and Geographical Information Systems for Veterinary
Public Health; and WHO/Veterinary Public Health, Chairman of the
Working Group “Anthrax: Epidemiology & Information”
and coordinator of Supervising Committee on “Anthrax Control
and Research”.
He is co-author of the paper
Pfeiffer, D. U. & Hugh-Jones, M. (2002). Geographical information
systems as a tool in epidemiological assessment and wildlife disease
management. Rev. sci. Off. Int. Epiz., 21 (1), 91-102.
A
pdf version of this informative paper is available here (1.5MB).
Diagnostics
From the Contingency Plan, the Template for First
Report to Defra, includes:
“samples taken to lab on ...
(Diagnosis on basis of clinical symptom or Lab test): ...”
Comment:
The draft EU FMD Directive does not allow for
initial diagnosis only on the basis of clinical symptoms, but requires
confirmation of the virus.
Objections to the use of the portable real-time
RT-PCR tests (e.g. the test developed by the United States Department
of Agriculture in collaboration with the commercial company Tetracore)
are still being raised.
At the recent Defra FMD Stakeholders meeting,
on 25 February 2003, I reported that Professor
Steven Edwards (Chief Executive, Veterinary Laboratories
Agency, Weybridge, England: an Agency of DEFRA) told me that validation
is an on-going process and that these tests are technically ready
to use now, adding that what is required is training people to use
them, as the tests are “only as good as the people who use
them”.
Fred Landeg (Head
of the Veterinary Exotic Disease Division at DEFRA) replied:
“Steve Edwards, Vice President of the OIE Standards Committee,
is one of Defra’s chief advisors. We are not behind on this!”
Where is this then to be seen in the Contingency
Plan?
Fred Landeg went on to say that Defra relies
on Pirbright which has full up-to-date expertise and knowledge.
Would that this were true! Pirbright’s own portable PCR test
is still in development, and Pirbright is under-staffed and under-funded.
But according to Landeg:
“This is a small island. We have no trouble getting samples
into the laboratory. Pirbright is the World Reference Library
for FMD, and we use it in the laboratory, PCR that is. We are
fully up to date”.
This is surely open to international expert discussion
and peer review. Defra may have no trouble getting samples to Pirbright,
but in so doing, days will be lost and the disease likely to be
out of control.
Suggestion:
In order to reduce time to detection, use should
be made of portable real-time PCR tests that can identify all 7
serotypes of the FMDv within 2 hours, using samples taken by non-invasive
procedures. An immediate standstill of all animal movements should
be declared. The results of tests on samples sent for laboratory
identification of the serotype, which would be available within
3 hours, should immediately trigger production and distribution
of vaccine.
An e-mail to me dated 1 March 2003 from Roger
Breeze (Associate Administrator, USDA, Agriculture Research
Service) read:
“The Plum Island FMD real time PCR test has been published
last June 2002 (1). We are engaged in a large
scale validation of this and other tests. The US Congress was
just told that this test was available to use in an emergency.
The test will identify all 7 types of FMD virus and not confuse
them with any other virus but it will not differentiate the seven
from each other.
We have other new technology for rapid genomic sequencing of
the virus - within 3 hours of getting it to the lab. Currently,
there is an antibody based method to decide what the best vaccine
should be - a comparison between existing vaccines to decide which
is closest and provides the best protection - assuming that there
is not an exact match between the virus and the available vaccines
in production.
The portable PCR should be used on farm or close to it for speed.
The portable PCR is pointless in the lab where fixed machines
and trained people exist.”
I suggest that a programme of random (or systematic?)
PCR tests should also be considered for “peacetime”, for
example at livestock markets and milk collection and at abattoirs,
to minimise the risks of lingering, undetected disease, whether
naturally or intentionally introduced.
GIS surveillance
From Defra’s Contingency Plan, National Disease
Control Centre:
“‘Birdtable’ meetings are arranged around a map
table showing details of infected premises. They are short, outcome-focussed
briefing meetings where key personnel stand around the table and
give account of their logistical problems and progress against
them.”
Comment:
Pins on a map are fine, provided they are only
for back up and discussion. But nowhere is there mention in this
document of a comprehensive computerised GIS database and tracing
capability linked to field diagnostics which would provide real-time
disease management. The capability for this exists. There are at
least two such systems: both are available through private US companies
working independently but in cooperation with the US government.
I have provided an outline of these and contact details to Defra.
When I asked about UK GIS capability at the stakeholders
meeting on 25 February 2003, Fred Landeg replied that “we have
GIS capability now and that it is exactly the same system that was
in place in 2001”. I remember Neil Thornton telling the stakeholders
in September 2001 that the Defra database needed improvements since
some holding grid references were in the middle of the North Sea.
Very recently (27 February 2003) on BBC Farming Today, the public
was informed that:
The failure to do the proper checks means that Defra will have
to pay £15 million back to the EU. An investigation by commission
inspectors revealed shortcomings in on-farm inspections and inadequate
controls of livestock. Defra says “most of the mistakes took
place because the database system wasn’t up and running”.
According to Roger Waite of the agricultural newsletter Agrifacts,
the commission inspectors identified 4 or 5 different areas, above
all that the computerised database, traceability of cattle has
certain shortcomings, there weren’t the necessary minimum
levels of on-farm inspections, cross checks were not done, and
on the extensification premia there weren’t sufficient checks
with regard to stocking densities. Also a slightly different issue,
intervention purchases of roughly 500 tons in Northern Ireland
were missing, and so it’s because of the shortcomings that
the commission applies a flat rate reduction to penalise the UK
for not carrying out the necessary controls.
Miriam O’Reilly: Whose responsibility was it to make these
checks, because some of these issues sound pretty serious?
Waite: it’s undoubtedly Defra’s responsibility because
each government has the responsibility of making sure that the
necessary checks are made and so the buck stops very definitely
at Defra.
In contrast, from one of the US companies:
“In summary, we can identify an animal or product at the
farm ... trace it through the supply chain, provide third party
certification, use our newly developed biosensors to determine
contamination ..., utilize new Radio Frequency Identification
(RFID) technology (2) for ear tags and container
tracing, all with web based seamless technology. We can detect
diseases with our sensors, provide immediate first responder information
with contaminated area pictures, local supplier information, built
in GIS/GPS analytical tools (water tables etc.), and provide check
print outs for immediate producer payment. Our biosensors can
detect any foreign-borne pathogen by contact or air. The new technology
allows for rapid growth of the media cutting current standards
in half. Most important we can do all of this economically.”
“We are working on a RFID system ... that allows for immediate
reading and recording of tags from large or small groups of live
animals. Essentially the process works like this: (details supplied
to Defra) ... The technology is web based, and everyone who has
a need to know the information, can easily access the database.
A premises ID with GIS coordinates, one time entry, will allow
for quick mitigation of diseases. We can trace back to the farm,
provide a satellite image (for example topology, roads, water
table data etc,) of the infected area, provide all necessary local
and government contacts for immediate handling of the disease.
The first responder is in direct control of the situation. Everything
they need can be downloaded immediately.”
An added benefit of this system is that it can
eliminate the need for bulky double tags on sheep and goats and
reduce the amount of paper work for the livestock keeper. A uniform
system should be considered for adoption by all EU countries.
The Polish government has requested a demonstration
of the system developed by the other private company.
Contrast this with the statement by Roy
Hathaway (Head of Animal Movements and Exotic Diseases Division,
DEFRA, Page Street, London) on 25 February 2003 that
“we need a few days to type the strain and trace the movements
and dangerous contacts ... there would be a standstill on day
1 (Comment - when is day one according to
these plans?), then tracing ... vaccination would not start
before 7 days”.
Real-time alert (table top) exercises
These are a requirement of the draft EU FMD Directive,
but I could find no reference to them in the Contingency Plan. I
have passed on to Defra information about the recent US exercises.
A comment from someone who was involved in one
of these exercises:
“If DEFRA is relying on a seven day time table...”Good
Luck”. Twenty four hours is really stretching it in the states.
In all our exercises FMD was out of control within that time frame.
In the UK you have greater animal population densities, in smaller
confined areas, and closer proximities than we do in the states.
Disease transmission is much faster. Technology is the only key
to detection and mitigation.”
In a private communication Roger
Breeze points out the exercises in the US have shown that
stakeholder participation is essential, and has the added benefit
of demonstrating to the livestock industry which regulations are
important (and which are not important) in mitigating the effects
of an outbreak.
Flexibility
Defra’s willingness to give special consideration
to rare breeds and zoo animals (as in draft EU FMD Directive) is
welcome. This is especially important for the UK, since it has the
largest number of rare breeds in the EU.
Suggestions:
1) Rather than dispute definitions of what is
a rare breed, any animal that the keeper/owner considers of particular
(genetic) value (whether kept in a zoo or on a farm) should have
the right to apply for special consideration, including vaccination
and/or isolation with increased biosecurity measures.
2) Special consideration should be given to species
with varying degrees of susceptibility and risks of onward transmission.
Appropriate procedures should be included in the
Contingency Plan.
Advice, oversight and leadership
We need balanced, focused leadership which can
evaluate, but also rise above, the quite legitimate demands of narrow
vested interest groups, researchers seeking funds which may not
be strictly relevant, and political pressures. This leadership should
be centred on a strong CVO, advised by a group of government and
independent scientists with a demonstrable predominance of veterinary
expertise and experience.
The draft EU FMD Directive requires just such
a permanent “expert group” (Article 78). Is it possible
that such a group can be found amongst the numerous groups and committees
outlined in the Defra’s Contingency Plan? An explanation from
Defra would be appreciated. This expert group must be more open
and accountable than the group which was formed in 2001.
An institutional plan to formally and regularly
review new scientific developments in animal disease control would
be welcome, and should be part of the requirement in the draft EU
FMD Directive to update Member States’ contingency plans every
5 years (Article 72, para 10). I suggest that this interval should
be reduced to one year.
Please, can we fundamentally review the contingency
plan and open it up to international consultation? This is not a
trivial matter. The stakeholders were told by Roy
Hathaway on 25 February 2003 that the EU FMD Directive, which
is legally binding in all EU countries, sets out the minimum
measures Member States would have to take, and that where the epidemiolgoical
situation requires, Member States can take additional
measures to those in the Directive. Consequently Defra will have
broad powers of interpretation, including the full powers given
in the Animal Health Act 2002. Some of these powers should never
be exercised: with the sensible use of new diagnostic technologies
that can rapidly and accurately identify infected animals and herds,
there is no justification now or in the future for a contiguous
or “firebreak” cull.
The use of this technology would allow for the
rapid implementation of targeted vaccination, thereby reducing the
numbers of animals needing to be slaughtered and needing to be vaccinated.
The procedures (locally, regionally and at HQ) to implement this
suggested strategy should constitute a substantial part of the Contingency
Plan.
A new approach
Will Defra have the courage to accept this new
approach to animal disease control?
Will the government provide the necessary funding?
If the answer to these questions is “no”,
then one contributor’s comments should be noted:
“Business is going to be directly behind the change. Class
action litigation, demands from banks and financing agencies,
lack of insurance coverage without exclusions, are having a global
impact on the need for preventative measures.
Lending agencies and insurance companies are extremely concerned
about the assets they are investing in or protecting. Animal health
and food safety issues are at the top of the list. Earlier this
year, in the state of Kansas we had a false FMD rumor surface.
Within one hour, the commodity markets dropped the max, and every
corporation that depended on beef did the same, many losing over
a $1 share value. Fast food chains, steak house chains, feed companies
etc. It took one hour to accomplish this, luckily the markets
were closing, or it would have been worse. Bureaucrats need to
understand the consequences; they need to be shown they must invest
in the protection of the economic future of their country. All
it takes is one incident. Unfortunately, FMD will be back in the
UK, they must know how to immediately isolate and control the
problem; every member of the EU needs to as well.”
Mary Marshall
References
1. Callahan, J. D., Brown, F.,
Osorio, F. A., Sur, J. H., Kramer, E., Long, G. W., Lubroth, J.,
Ellis, S. J., Shoulars, K. S., Gaffney, K. L., Rock, D. L. and Nelson,
W. M. (2002). Use of a portable real-time reverse transcriptase-polymerase
chain reaction assay for rapid detection of foot-and-mouth disease
virus. J. Am. Vet. Med. Assoc., 220:1636–1642. (View
Abstract).
2. RFID: www.aimglobal.org/technologies
Further Reading recommended by Land-Care
DEFRA Consultation on FMD Contingency Plan. Response by National
Foot and Mouth Group (NFMG).
(Filed 11 March 2003, www.land-care.org.uk,
click here
to view).
Royal Society of Edinburgh. Inquiry into Foot and Mouth Disease
in Scotland. July 2002. (Download
PDF).
Foot and Mouth Disease Inquiry Reports. Land-Care. (Click
here to view).
FMD Forum (2003). Response to DEFRA FMD Contingency Plan.
(Filed 23 January 2003, www.land-care.org.uk,
click
here to view).
DEFRA’s proposals for management of future outbreaks of FMD.
(Filed 3 January 2003, www.land-care.org.uk,
click
here to view).
DEFRA's Foot and Mouth Disease Contingency Plan, Version 2.5. (Download
PDF).
Final Report of the European Parliament Temporary Committee on Foot
and Mouth Disease (Filed 18 December
2002, www.land-care.org.uk, click
here to view).
EU Temporary Committee on FMD: Compare Draft Report (20th Sept 2002)
with Final Report (20th Nov 2002).
(Filed 28 November 2002, www.land-care.org.uk,
click
here to view).
Irvine, W. J. (2002). Comments on the Draft Report of the EU FMD
Inquiry. Land-Care.
(Filed 7 October 2003, www.land-care.org.uk,
click
here to view).
Government response to FMD Inquiries (6/11/2002). (Download
PDF).
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