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11 March 2003
DEFRA Consultation on FMD Contingency Plan
Response by National Foot and Mouth Group (NFMG)
NFMG have produced a formal response
to the DEFRA consultation on the FMD contingency plan, decision
tree and slaughter protocol.
NFMG’s two over-riding concerns are:
1. a lack of proper provision for vaccination,
and
2. the inclusion of pre-emptive culling as a control measure.
Below is a covering letter from Janet Bayley
of NFMG to Susan Ivory, DEFRA. This is followed by the NFMG response
to the consultation.
Covering Letter from Janet Bayley (NFMG)
to Susan Ivory (DEFRA)
For the attention of:
Susan Ivory
DEFRA
1a Page Street
London SW1P 3PQ
27 February 2003
Dear Ms Ivory
CONSULATION ON DEFRA’S FMD CONTINGENCY
PLAN, DECISION TREE & SLAUGHTER PROTOCOL
Please find attached our response to Defra’s
consultation on the above and the relevant supporting papers.
We also append our Draft Programme for the Containment,
Control and Eradication of FMD incorporating Emergency Protective
Vaccination and would be grateful if this could also be taken as
part of our submission.
We would be grateful to receive a copy of the
revised Contingency Plan in due course.
If you have any queries regarding the attached
papers please do not hesitate to contact us.
Yours sincerely,
Janet Bayley
NFMG Co-ordinator
DEFRA Foot and Mouth Contingency Plan, Decision
Tree
& Slaughter Protocol
NFMG Response to consultation:
Contents
1. Introduction
2. Emergency Vaccination
2.1 Requirement for Emergency Vaccination
Protocol
2.2 Scope and Extent of Vaccination Protocol
3. Pre-emptive and firebreak culling
3.1 FMD Contingency Plan – Version
2.5, Decision Tree and Slaughter Protocol
3.2. Validity of Pre-emptive and ‘Firebreak’
Culling to Control FMD
4. Response to particulars in contingency play
5. Response to FMD decision tree
5.1. The Decision Tree Flow Chart
5.3 FMD Decision Tree – Factors to
be considered
5.3.1 Decision Box 2 –
Is vaccination permissible and possible?
5.3.2 Decision Box 3: Is
the exit strategy “vaccinate to live”?
6. Disease control (slaughter) protocol
Appendix 1
Appendix 2
1. Introduction
The NFMG welcome the publication and consultation
on the Government’s intended Contingency Plans for use in the
event of a future outbreak of Foot and Mouth (FMD). We are also
pleased to note that many of the issues we have raised and advanced
in our various submissions to the FMD Inquiries have now been incorporated
into the Plan.
However, we have two over-riding concerns:
a. that the key issue of Emergency Vaccination,
as a means of controlling FMD, does not appear, as yet, to have
been sufficiently developed and taken forward, and
b. the inclusion in the Contingency plan of the
use of pre-emptive and ‘firebreak’ culling of animals
not exposed to disease, as a means of FMD control.
We wish to first address these concerns and then
respond to the particulars within the Contingency Plan, the Decision
Tree and the Slaughter Protocol.
2. Emergency Vaccination
2.1. Requirement for Emergency Vaccination Protocol
The revised Animal Health Act which has recently
been adopted has placed upon the Secretary of State a “Duty
to consider vaccination” in relation to any occurrence of FMD,
and whether “treating animals with serum or vaccine is more
appropriate than any other means of preventing the spread of disease.”
See Section 14B.
In addition, the Draft EU Directive for the Control
of FMD also states in Annex XVII – Criteria and Requirements
for Contingency Plans, that:
“Member states shall ensure that contingency plans meet
at least the following requirements:
Para 10 “Detailed plans shall be available
for emergency vaccination”
See EU Draft Directive, Page 106
While a detailed Contingency Plan, Decision Tree
and Slaughter Protocol has been prepared and submitted for consideration
and consultation, thus far, the Contingency Plan contains little
in relation in emergency vaccination and no equivalent Vaccination
Protocol has been drawn up for consultation and to be used in the
event of a future outbreak.
Given that both the UK Animal Health Act and
the proposed revised EU Directive now provide for the use of Emergency
Vaccination as a means of FMD control it is imperative that such
a Vaccination Protocol should now be drawn up to form part of the
UK FMD Contingency Plan.
We submit that this is a major deficiency within
the Contingency Plan and should be addressed with urgency.
2.2. Scope and Extent of Vaccination Protocol
As part of our submission to the Royal Society
Inquiry we developed a Draft Programme for the Containment, Control
and Eradication of FMD incorporating Emergency Vaccination. We attach
the Programme and its supporting papers at the end of this submission
and hope that this may be of assistance.
The document was not intended to be prescriptive
– but to illustrate how such a process could be applied and
to stimulate debate and discussion. However there are several factors
which we submit should be included within the Government’s
own Emergency Vaccination Protocol, namely:
- Criteria and Thresholds for determining use
of vaccination
- Provision and availability of appropriate NSP
free vaccines and relevant differential tests for different sero-types
of FMD
- Procedures determining when, what, where and
how vaccination will be applied and how this will be recorded
- Bio-security and other measures to be employed
in the vaccination zone;
i. during vaccination,
ii. post vaccination and prior to the commencement of sampling,
and
iii. during sampling and awaiting results.
- Post vaccination surveillance – measures
and application
- A sampling and sero-surveillance programme
to determine which flocks and herds have been exposed to infection
and to define what additional screening may be needed.
Note: Such
a sampling programme should be agreed in advance with the OIE
to define what data and information will need to be submitted
in order to determine Disease free status in accordance with Article
2.1.1.7 of the Animal Health Code, Chapter 2 relating to FMD and
as per Item 6.
- Similarly there is need for agreement within
the EU to determine that intra-community trade will be determined
in accordance with the OIE declaration of Disease free status.
- To disseminate the relevant information and
instigate appropriate training prior to a future outbreak with
veterinarians, farmers, and all others likely to be involved in
delivery of a vaccination protocol.
- To establish a clear timetable setting out
the necessary time scales that each process would require and
the implications for all those involved in the rural economy –
including the time frame for the re-opening the countryside post
vaccination.
As set out in the Draft EU Directive, principally
but not exclusively in Section 8 dealing with Vaccination, some
of these elements have been developed. Articles 49 – 58 provide
the initial framework as to how vaccination will be utilised to
control an outbreak.
However there would appear to still be substantial
areas which need clear and full detail and articulation if Emergency
Vaccination is to be meaningfully applied.
We submit that until the UK Government has prepared
and submitted such a Protocol for Emergency Vaccination for consultation,
and it has been adopted, it will not be possible for Emergency Vaccination
to be duly considered in accordance with the revised Animal Health
Act.
Furthermore, it may be very difficult to implement
such a control if the relevant ‘Stakeholders’ have not
had an opportunity to consider and understand how such a process
would operate.
We note from your covering letter on consultation
that a revised Contingency Plan is due to be laid before Parliament
at the end of March 2003. We consider that the revised Contingency
Plan must make detailed provision for emergency vaccination and
how it would be utilised.
3. Pre-emptive and firebreak culling
3.1. FMD Contingency Pland - Version 2.5, Decision
Tree and Slaughter Protocol
At Page 8 of the Contingency Plan in the continuation
of Para 7 – Outline of Policies and Initial Procedures –
“If FMD is confirmed” it states that other additional
strategies and options are available including:
“pre-emptive or ‘firebreak’ culling of animals
not on infected premises not dangerous contacts or not necessarily
exposed to disease, in order to prevent the wider spread of the
disease out with the area”.
The Decision Tree sets out the factors which are
to be taken into account in deciding which strategy to adopt to
control the disease, while the Slaughter Protocol outlines the processes
and actions that may be taken to slaughter animals in order to control
and eradicate the disease.
3.2. Validity of Pre-emptive and ‘Firebreak’
Culling to Control FMD.
We submit that until the full epidemiological
data relating to the UK 2001 FMD epidemic has been independently
and scientifically analysed and assessed the legitimacy for the
use of pre-emptive and firebreak culling, as a means FMD control,
has not been determined. We contend that all the other measures,
as detailed within the Contingency Plan and supporting papers, provide
the necessary controls to bring an outbreak under control and eradicate
the disease.
Furthermore, the information relating to incidence
of disease in 2001 that has been made available, indicates that
the use of pre-emptive culling as a control method resulted in massive
numbers of healthy animals being slaughtered, with the attendant
logistical problems of disposal and compensation payable –
and many other socio-economic impacts.
We append our most recent assessment of the data
we have obtained regarding this – Appendix 1. We draw your
attention to the very low number of positive cases of FMD that were
confirmed when laboratory tested. Also, the figures we have obtained
for the Great Orton burial site provide compelling evidence that
such measures are neither a proportionate nor rational response
to control the disease. These are also included in Appendix 1.
We urge that pre-emptive culling should not form
any part of the disease control process, or at the very least be
deferred until the analysis referred to above has been undertaken.
We also note that the EU Draft Directive does
not make provision for pre-emptive culling of animals which are
considered not to have been exposed to the disease. See Article
8 ‘Preventive Eradication Programme’ – which only
refers to animals ‘likely to be contaminated and, if considered
necessary, of epidemiological linked production units or adjoining
holdings.’
Therefore the draft Directive does not provide
for the firebreak culling as detailed in the UK FMD Contingency
Plan.
4. Response to particulars in contingency plan
Firstly we welcome the clarity and detail that
has been provided in the Contingency Plan, that the document is
now freely available in the public domain and is to be subject to
widespread consultation and revision.
Our response refers to the relevant pages and
paragraphs within the document:
Page 8, Para 7 - Re Pre-emptive culling - see above
Page 8, Para 7 - Issues still requiring resolution.
Para 7 also states “For a vaccinate-to-live
strategy to work, a number of logistical, technical and trade problems
need to be resolved in consultation with interested parties.
Response: May
we suggest that a fully detailed Vaccination Protocol should be
drawn up as soon as possible to deal with the logistical issues.
As regards technical and trade problems – these are addressed
to some degree in the Draft EU Directive.
The issues relating to the treatment of un-vaccinated
and vaccinated meat and milk, etc are dealt with in detail in the
draft Directive. We urge that DEFRA, in its discussions with Europe,
query whether such treatments are necessary and are based on science-based
risk assessment. It is our understanding that meat, milk and meat
products sourced from Protection Zones and Surveillance Zones during
the 2001 epidemic were not subject to such treatments. It is therefore
questionable whether such treatments should be applied in vaccination
zones – where it could well be argued there is even less likelihood
of virus circulation.
The issue of whether vaccinated products need
to be labelled is also covered in the EU Draft Directive. Here again
the EU is suggesting some parity between meat and milk sourced from
non-vaccinating protection and surveillance zones and that sourced
from vaccinating areas.
There needs to be a clear distinction drawn between
those measures which are designed and put in place to prevent any
onward transmission of FMD to susceptible animals, and those measures
which relate to human health.
Regard must be had to both the Food Standards
Agency Press Release of 20 April 2001 and the respective views of
the National Consumer Council – both of which agree there is
no need for FMD vaccinated animal products to be labelled –
or any risk posed from the consumption by humans of FMD vaccinated
animal products.
It is better to prepare statements now –
and resolve these issues with the food industry and public education
– rather than they be raised mid-epidemic with confusing and
contradictory advice being provided for the consumer.
Page 25, Para 7 - Disposal - 7.1 Disposal Hierarchy
We note that policy developments and environmental
constraints have now determined that commercial incineration, followed
by rendering are the preferred disposal methods. However at para
7.2.2. it states that “Incineration capacity is limited and
will only be able to deal with small isolated outbreaks or the first
few days of a new outbreak or disease recrudescence.”
Thus, recourse to rendering would soon have to
be taken up. Here again disposal capacity is limited.
Response: Given
the additional constraints on the disposal of carcasses that would
be imposed in the event of a future outbreak we consider that this
limitation should be given greater weight in determining the control
method, and inter alia, the number of animals thus requiring slaughter,
ie whether to use culling or vaccination for disease control. The
full constraints on disposal must be properly factored in to the
decision making process and the decision tree.
Page 27, Para 8 – Serology capacity
Response: We
understand that several types of real time RT-PCR tests are under
development by various commercial companies world-wide and at the
IAH, Pirbright.
Given the importance of fast and accurate diagnosis
in determining presence and extent of infection we submit it would
be very helpful for DEFRA to publish a position statement (similar
to the references in the Decision Tree relating to what vaccine
is being obtained and from where) to make clear what the current
and emerging situation is.
If the situation is that such tests require validation
in order for recognition by the OIE in its Manual of Standards for
Diagnostic Tests and Vaccines, and for licensing for use in the
UK and the EU, then it would be very helpful to know what time scales
are likely to apply.
If Government funding is needed to bring this
work forward may we suggest that this would be a worthwhile investment.
Rapid diagnosis is a key tool in control and eradication.
Page 85 Annex I – Veterinary Risk Assessment, etc
Response: We
welcome the publication of the factors to be considered in this
exercise – although it appears the provisions of this Annex
were drawn up to respond to a re-occurrence of the 2001 outbreak.
In the event of a future outbreak we assume such
risk assessment would be used to determine rights of way closure.
We submit that, properly modified, this paper forms a very good
basis for such assessment.Page 93 Annex L – Biosecurity Advice
and Guidance
Response: While
welcoming an explicit and detailed list of recommended precautions
we consider a major possible vector has not been addressed. Namely
the transmission of the disease by persons having had contact with
infected animals and subsequently carrying the virus in the throat
or nasal passages.
Such persons may be unaware that they have been
in contact with the disease – particularly in the early stages
of infection. We suggest that the use of appropriate face masks
for personnel visiting the premises must also be included.
Also disposable gloves should be used.
Additional Bio-security Advice
May we suggest that the Bio-security Section should
also provide a protocol for:
Effective farm quarantine – explicitly detailing
how farms and holdings can isolate stock from possible infection,
via:
- safe animal separation distances from neighbouring
stock and possible housing to minimise risk of infection from
airborne transmission.
- the measures to be used for all personnel
and visiting service vehicles, eg, feed and milk tankers, etc.
The issue of milk is particularly important given the possibility
of early virus circulation – during the last outbreak detailed
plans addressing this and the requisite air filter maintenance
of milk tankers were issued.
- Such measures should also detail how a vaccination
plan would be delivered – and how vaccination would be applied
without compromising the farm’s quarantine and bio-security.
In addition each farm/holding should have a bio-security/farm
quarantine plan pre-agreed with DEFRA – via the local DVM –
which should be put into place as soon as disease is confirmed in
the country.
Such plans could be based on the effective and
thorough approach which was implemented with the Blue Box protocols.
5. Response to FMD Decision Tree
Firstly, may we re-iterate our concern regarding
the inclusion of pre-emptive culling as a means of FMD control-
see above.
We cite the relevant Section – and then
our Response.
Para 7 - Vaccination Policy
Response: This
paragraph now appears out of date. Please note there is now a draft
EU legislative framework to provide for Emergency Vaccination –
as detailed in the draft Directive 92/46/EC of 13 December 2003.
Articles 49 – 58 specifically deal with this approach.
Para 9 - Vaccination Policy
Response: While
accepting that there are still unresolved issues relating to Emergency
Vaccination, given that the draft EU Directive has progressed and
advanced this means of control, and that Defra itself is also undertaking
significant discussions with Stakeholders to address these issues,
it is sincerely hoped, and anticipated, that an early resolution
of outstanding matters will be achievable.
Para 12 Suppressive Vaccination (Vaccinate to kill)
Response: We
note that this Para states “It (suppressive vaccination) could
also be used where there is an urgent need to reduce the amount
of virus circulating in an areas and reduce the risk of spread beyond
that area.”
However this rationale is not applied to the
section on Protective Vaccination (Vaccinate to live) Paras 10 and
11. We submit that this outcome would apply equally whether used
for a ‘vaccinate to live’ or a ‘vaccinate to kill’
regime – as vaccination would substantially reduce the amount
of virus circulation in both circumstances. We therefore consider
the same paragraph should be added to the Protective Vaccination
section.
Para 17 Animals which are believed to have been exposed to infection
Response: We
welcome the inclusion of the caveat that where animals are believed
to have been exposed to the disease these will be “subject
to a veterinary inquiry to determine if, in the opinion of the Veterinary
Inspector, they have been exposed to disease.” to determine
if they are to be slaughtered.
A major concern in the 2001 outbreak was that
little veterinary risk assessment was undertaken to determine the
likelihood of infection – with the obvious trauma and distress
when farmers and owners truly held that there animals had not been
exposed to infection – and no risk assessment was undertaken
prior to slaughter.
Para 18 - Same section as above
Response: Again
we welcome the inclusion of the sentence “A decision to slaughter
will be taken by the veterinary inspector based on information gathered
during the inquiry and account will be taken of levels of bio-security.
The action that we take will depend on risk assessment.”
However we urge that for all farmers and livestock
holders should be fully briefed and kept updated on farm bio-security
and effective farm quarantine – perhaps on a bi-ennial basis
– so that should a future outbreak of FMD occur they know immediately
how to isolate themselves, their farm, their animals and put in
place all necessary measures to protect against infection.
Para 20 - To prevent the spread of disease
Response: Pre-emptive
culling etc. Please also have regard to our earlier statements regarding
this. See Section 3.
Our main concern is that a decision to impose
a blanket cull will again result in many healthy animals being needlessly
killed, create major logistical problems, rule out proper veterinary
risk assessment, generate distress and despair amongst farmers and
livestock owners and adversely impact on the wider rural economy
and society.
We cannot stress enough how little evidence has
been advanced to substantiate this approach post the 2001 epidemic.
We submit that once nation wide movement restrictions
are imposed, effective farm quarantine established and the requisite
bio-security enforced – via the ‘Blue Box’ approach
if necessary, transmission of the disease will be halted.
If some form of firebreak is needed – then
a recourse to fire-break vaccination, on a vaccinate to live approach,
would reduce virus amplification and transmission to a far greater
extent than ‘firebreak’ or pre-emptive culling.
We urge that pre-emptive culling should be removed
from the Contingency Plan and Decision tree as a means of controlling
disease – we note that it does not feature in the draft EU
Directive.
5.1. The Decision Tree Flow Chart
Response: It
is our understanding that vaccination is now to be considered ‘as
a tool of first resort’ in line with the Royal Society recommendations
and the EU FMD Report. Therefore we question why its consideration
(Box 2) is linked with an ‘And’ to Box 4 ‘Are there
additional culling strategies?’
There should also be a link from the box asking
‘Are resources and disposal capacity available for additional
cull strategies’ back to the vaccination line if there is ‘No’
disposal capacity available. It should not result solely in endemic
FMD as the Decision Tree shows or to the box ‘Stamping out
and additional cull strategies’.
5.3. FMD Decision Tree – Factors to be considered
5.3.1. Decision Box 2 –
Is vaccination permissible and possible?
Response 1:
We note that it is suggested that ‘A 2-dose strategy (followed
by a booster at 6 months) would be necessary for a vaccinate-to-live
strategy’.
It is our understanding that the EU Directive
appears to advance only a 1 dose strategy in the Articles relating
to Vaccination 49-58.
Please could DEFRA clarify with the EU and others
if a 2 dose strategy is necessary. We submit that the NSP free vaccines,
of high potency and delivered at suitable payload rate would enable
a 1 dose strategy to be used with all the attendant benefits.
Response 2:
With reference to the validation of differential tests to be used
for post vaccination surveillance. We understand that proposals
are currently under consideration with the OIE to design the appropriate
sampling and surveillance regime to determine which herds and flocks
have been exposed to disease and those which have solely responded
to vaccination.
This regime may enable submission of appropriate
data to the OIE to recover DFS before the validation of the specific
differential tests is completed. No doubt DEFRA is aware of this
situation – and will be able to utilise this approach should
a further outbreak of FMD occur.
5.3.2. Decision Box 3: Is
the exit strategy “vaccinate to live”?
Response 1:
With reference to the controls on products from vaccinated animals.
We urge that the UK Government question whether
all such controls are necessary when evaluated in terms of science
based risk assessment.
The purpose of the treatments is to prevent any
onward transmission of FMD to further susceptible animals. In the
2001 epidemic many animal products from Protection and Surveillance
zone where allowed to enter the human food supply chain without
the need for such treatments. On the condition that certain provisions
and caveats for movement of animals to slaughter and milk for consumption
were followed.
It would therefore seem reasonable to question
whether such treatments are needed for animal products destined
for human consumption from Vaccination Zones, where, if anything,
there is likely to be an even lower possibility of virus circulation
than in the un-vaccinated Protection and Surveillance Zones. The
provisions which were applied in the Protection and Surveillance
in 2001 would be sufficient to prevent any onward transmission of
disease.
Furthermore with the banning of all swill feeding
the possibility of FMD contaminated food being fed to susceptible
animals should now be non-existent.
We also note that the various time scales that
have been applied for the application of these treatments have now
been superseded by the draft EU FMD Directive. Please see Articles
49-48.
Also ditto for the movement of vaccinated animals.
Response 2: With reference to food labelling.
During the 2001 epidemic we became very concerned
at the confusing and contradictory statements which were being repeated
by many involved in the discussions on vaccination. Eventually we
wrote to the NFU in response to this situation and attach the letter
and supporting papers as our position statement on the issue of
the labelling and sale of vaccinated animal products. Appendix 2.
We understand from the Food Standards Agency
and the National Consumer Council that FMD vaccinated products do
not require labelling at point of sale, nor do they pose any risk
to human health.
We urge that DEFRA seeks to resolve these issues
with the FSA, NCC, food producers and retailers as soon as possible.
The confusing and often erroneous statements that were made during
the 2001 epidemic appeared to result in widespread opposition to
FMD vaccination that was not founded on fact or reality.
6. Disease Control (Slaughter) Protocol
Response: While welcoming the explicit nature
of the document in identifying which animals are to be slaughtered,
and the provision of explanations thereto, we consider that an equivalent
document relating to a Vaccination Protocol is also required. Furthermore,
our main concern is the legitimacy of the use of slaughter to prevent
the spread of disease, ie ‘firebreak’ and preventative
culls.
In particular:
Animals exposed to infection:
a) Direct contact with infected animals
Response: As
stated earlier, a clear and detailed farm quarantine and bio-security
plan, which includes pre-determined safe animal separation distances,
should be put in place as soon as FMD is confirmed. This would reduce
the likelihood of infected animals having direct contact with susceptible
animals – and thus reduce onward transmission. Such plans should
be agreed in advance of an outbreak – and adherence to them
taken into account in assessing these criteria of the Slaughter
Protocol.
b) Airborne Spread
Response: In
the 2001 epidemic the issue of airborne transmission gave rise to
grave concern. We are mindful of the papers subsequently published
in the Vet Record regarding the relative risks of uncontrollable
(airborne) spread and the relative resistance of pigs to infection
by natural aerosols of FMD. *
We urge that in assessing this possible transmission
route DEFRA will consult widely with FMD scientists to ascertain
the true level of risk which airborne spread may pose so that it
is correctly ascertained and not over-stated.
In general:
We submit that all the criteria detailed in this section on Animals
exposed to infection would benefit from inclusion in a detailed
Farm Quarantine and Bio-security protocol, explaining what precautions
need to be taken.
Such a protocol should show what measures should
be put in place to limit possible transmission of the disease in
each section, a – j, as soon as the first case is confirmed.
To prevent the spread of disease – new
slaughter powers for pre-emptive culling
Response: As
detailed earlier in Section 3 and in response to Para 20 of the
Decision Tree we remain extremely concerned as to the inclusion
of this approach within the control measures.
Once movement restrictions have been imposed
and all other farm quarantine and bio-security measures implemented,
including the effective enforcement of the ‘Blue Box’
schemes, the likelihood of being unable to control the disease are
effectively nil. Should preventative measures be needed then it
would be far more effective to confer immunity by vaccination, rather
than through the logistically difficult and far more risky approach
of pre-emptive culling, with all its attendant socio-economic impact.
However, what needs to be made clear is that there
will almost inevitably be a time delay from the imposition of these
measures to the reduction in the number of FMD cases continuing
to occur on a daily basis. This is not because the disease is spreading,
but because clinical symptoms will continue to appear on farms and
holdings which had become infected before the standstill and other
measures were imposed.
This is exactly what happened in 2001. Indeed
by the time the Contiguous Cull was introduced on the 28 March 2001,
the disease had already peaked and the number of new cases per day
had begun to fall.
We respectfully ask DEFRA and the Secretary of
State to repeal this provision from the Animal Health Act, and from
the FMD contingency plan. Much trust and good will has been lost
between the Department and the farming and rural communities through
the 2001 FMD outbreak.
Such a gesture, coupled with clear and sound bio-security
guidance and a workable vaccination protocol could go a long way
to restoring the much needed trust and co-operation that must be
re-established if we are to have a secure and workable future for
UK farmers and the associated rural economy and society.
NFMG - February 2003
Appendix 1:
Lab test results for FMD which demonstrate very low
numbers of premises were actually infected
Source of Data: Parliamentary Question 2164
& DEFRA Website
As of 20 February
2003, the total number of a AFFECTED
PREMISES on the DEFRA website now stands at 10,472.
This is the total number of premises where animals
have been slaughtered.
According to Parliamentary Question and Answer
PQ 2164:
The total number
of premises that were sampled
is 2,372
Of those that were sampled only 1,328 returned
positive results demonstrating that they were either infected or
had been infected and animals now carried antibodies.
Therefore, although 10,472 farms and premises
were slaughtered only 1,328 were
definitely confirmed to have had the disease when lab tested.
We know from the papers and letter of Dr Paul
Kitching and Dr Alex Donaldson in the Vet Record of the 19 May 2001
that if samples were sent to Pirbright for testing, from animals
that were either exhibiting clinical signs or had been exposed to
the disease, the tests would provide positive results.
(Note: If DEFRA now has further epidemiological
data which does not support the above it would be timely for such
information to be published).
Furthermore, the level of incidence of disease
that was confirmed in the lab, county by county, shows that some
counties had hardly any infection confirmed, yet massive numbers
of farms and premises were slaughtered.
For example, Gloucestershire, Hereford & Worcestershire,
Shropshire, Wigtownshire. At Great Orton burial pit – where
approximately a million animals were slaughtered, only 1 farm was
definitely confirmed to have antibody positive sheep.
SEE FOLLOWING INFORMATION
INFECTED PREMISES CONFIRMED BY LAB TESTS - RATIO TO NUMBER OF FARMS
CULLED - IN GLOUCESTERSHIRE, HEREFORD/WORCESTERSHIRE & SHROPSHIRE,
WALES, AND WIGTOWNSHIRE
Source of data:
Answer to Parliamentary Question 2164
County No of IPs* No tested No +ve Total Farms
Ratio
Culled
Glos 72 46 13 346 1:26
Here/Worc 66 49 15 394 1:26
Shrops 12 8 5 131 1:26
Wales 115 102 60 806 1:13
Wigtownshire 15 13 2 218 1:109
*An IP was a premise declared as infected by DEFRA
either on the basis of clinical signs or if testing positive. It
is important to note that the reliance on clinical signs to confirm
the presence of the disease, particularly for sheep, was considered
unreliable. The total number of farms slaughtered includes all Infected
Premises, Dangerous Contacts, Contiguous Culls and Slaughter on
Suspicion cases.
Note: We understand that if
samples from animals showing clinical signs were submitted for
laboratory testing then the lab test results would have provided
positive results if the animals were infected with FMD.
This view of Dr Paul Kitching and Dr Alex Donaldson
of IAH Pirbright – is expressed in the Vet Record of 19 May
2001, p640. They also write:
“We believe that laboratory support for a diagnosis of FMD
in sheep, in particular, is essential.”
Anglesey
We understand that there were 13 IPs on Anglesey.
Of these:
5 tested +ve
5 tested –ve
3 were not tested.
Of approx. 244 farms culled as a firebreak, only
7 were tested - all were negative.
We also understand that the 1st outbreak was
in Gaerwaen abattoir.
Apparently there was some delay in the slaughter
at the abattoir of a matter of days which allowed the virus to spread,
possibly by the movement of vehicles and personnel, or by other
vectors and thus infect other premises. As shown above it appears
only 5 became infected and have been confirmed on laboratory testing.
We draw your attention to the number of farms
culled on the basis of only 5 positive IP’s identified in laboratory
test results.
The ratio is 244 divided by 5. This is 1:49.
The Anglesey figures were supplied to NFMG and
submitted to the Anderson Inquiry.
Great Orton
These figures were supplied by DEFRA Carlisle
and submitted to the Cumbria Inquiry by Will Cockbain – NFU
County Chairman – NFMG also then submitted them to the Anderson
Inquiry.
Will Cockbain – NFU County Chairman –
Giving evidence to Cumbria Inquiry
“Reference to the 3km cull was also made
by county NFU chairman Will Cockbain of Rakefoot Farm,Keswick, who
told the inquiry that chief vet Jim Scudamore had justified the
slaughter by claiming the sheep flock was “heavily infected”,
although MAFF had failed to produce any evidence at the time to
support this.
According to Mr Cockbain, the results of blood
tests carried out at Gt Orton had only been revealed to him a short
time before the inquiry and these had shown that sheep from 115
farms had been tested. Sheep from only one farm had tested positive,
with one additional “mild positive” and three “inconclusive”.
“This shows that Jim Scudamore’s initial reason for the
3km cull was wrong,” he said.”
Will Cockbain’s data as supplied to NFMG:
Great Orton
There were sheep from 115 farms tested, 5786 animals
in total, between the 7th and 23rd of April 2001.
One farm had a positive test on 9 sheep.
One farm had what Andrew Hayward (DVM Cumbria)
termed “mild” positive with 2 sheep testing positive.
Three farms were inconclusive and the rest, 110
farms had negative tests.
No farms were culled as a result of finding clinical
signs of FMD, I asked if any clinical signs had been found and he
said no. To the best of my knowledge 451,000 sheep were slaughtered
at Gt Orton.
NFMG - 20 February 2003
Appendix 2:
Letter from Janet Bayley (NFMG) to Martin Hayworth (NFU)
23 August 2001
For the attention of Mr Martin Haworth
NFU Headquarters
Agriculture House
164 Shaftesbury Avenue
London WC2H 8HLDear Martin Haworth
RE: NFU VIEWS ON VACCINATION, FOOD LABELLING,
FSA & NCC
Thank you for our conversation yesterday.
Our concern is that the NFU’s recently expressed
views at a public meeting in Carlisle last week, regarding vaccination
and food labelling, do not concur with statements from the FSA or
NCC. I have attached files of the FSA press release
and NCC statements for you to consider.
In addition, the opinions expressed about the
need to slaughter vaccinated animals, and how vaccination would
affect the return to disease free status do not appear to reflect
the EU decisions, or the provisions of the OIE on FMD and vaccination
- as contained within the International Animal Health Code - 2001,
concerning FMD - Chapter 2.1.1
As regards the provisions of the EU legislation
regarding vaccination, it appears that the NFU are still of the
opinion that all vaccinated animals have to be slaughtered. However,
the EU Decisions sought and obtained by the UK Government to vaccinate
cattle in Devon and Cumbria, and later in Somerset, Cornwall and
Dorset, 30 March and 24 April, respectively, were for protective
vaccination, not suppressive vaccination, which meant that it was
not necessary to slaughter such animals, under EU legislation.
As regards comments, at the same meeting, that
under EU regulations it did not say that vaccinated animals could
live, the NF&MG have searched through the legislation and can
find no reference to this. What the EU decision of 30 March does
say is how vaccinated animals and milk products are to be prepared
to enter the food chain. See Annex V and VI of the Decision - 2001/257/EC
- 30 March 2001.
The view expressed by Mr Gill, based on a letter
from a friend in Argentina, that FMD can be transmitted between
vaccinated animals and their progeny, is also worrying. The view
of many leading world scientists in FMD is that this is not the
case.
Regarding the view that FMD vaccinated meat and
meat products would have to be labelled - it is the opinion of the
Food Standards Agency and the National Consumer Council that this
is not the case. FMD vaccinated meat and milk products imported
into the EU and UK are not labelled so there should be no necessity
for home produced meat and products be to disadvantaged and treated
differently. May we take this opportunity to say that it has always
appeared odd that the NFU has sought to have more onerous restrictions
placed on the domestic market as opposed to the import market.
We feel the expression of such views may give
rise to foundless consumer resistance to vaccination.
One of the most worrying aspects regarding FMD
vaccinated imports is that despite lengthy research and communication,
mostly with DEFRA, the NF&MG have still not been able to ascertain
the amount of FMD vaccinated meat and meat products entering the
UK from countries where FMD is endemic or vaccination takes place.
Ultimately DEFRA referred us to the OIE website. The assumption
we have been forced to make is that it is not known by DEFRA, or
Customs and Excise, or anyone, how much vaccinated meat is actually
being imported into the UK.
One of the key difficulties is that once the meat
and meat products enter the EU, which they can do through many Border
Inspection Posts across the EU, there are no further controls as
they pass from Country to Country. Therefore it is extremely difficult
to determine where the country of origin actually was, the only
reference is the country of despatch. Source DEFRA.
As we discussed in our conversation, the Group
has submitted a report on the Control and Eradication of FMD in
the Hefted Flocks to both the Welsh Assembly and DEFRA. Copies have
also been sent to Peter Rudman and Keith Baker and to NFU Cymru.
We have already had a meeting with Huw Richards and Mary James of
NFU Cymru and would be very grateful to have the opportunity to
discuss the above and the submitted report with yourself, Peter
and hopefully Ben Gill.
If you have any queries, or would like a further
copy of the report please do not hesitate to contact me.
Yours sincerely
Janet Bayley
National Foot & Mouth Group
CC to Mary James – NFU Cymru
FSA Press Release
FOOT AND MOUTH DISEASE
What does it mean for the consumers?
The Food Standards Agency advised on 21 February
that foot and mouth disease does not pose a threat to food safety.
This remains the case. The Agency has continued to monitor the outbreak
and today issued further advice on the public health implications
of the measures being taken to control foot and mouth.
USE OF A FOOT AND MOUTH VACCINE
The Food Standards Agency is satisfied that the
use of such a vaccine would not have any implications for food safety.
All vaccines for food animals have to be given
a licence before they can be used. As part of the licensing process,
the Government’s independent expert committee, the Veterinary
Products Committee, thoroughly assesses the safety of the vaccine
to ensure that its use will not pose any threat to human health.
This was done for the Foot and Mouth vaccine in 1992 and again when
the licence was renewed in 1997, and on both occasions the Committee
was satisfied that there would be no safety problems for anyone
eating products from animals that have been treated in this way.
SALE OF MEAT FROM FOOT AND MOUTH SURVEILLANCE
ZONES
The European Commission and the Government have
agreed arrangements for the slaughter of animals from FMD surveillance
zones for human consumption, providing the animals are certified
as not showing clinical signs of disease. For disease control reasons
a special round GB health mark will be stamped on export-standard
meat produced in Great Britain to show that the meat can not be
exported. This mark will be used on all meat processed in Great
Britain. It is not an indication as to the origin of the meat, as
it applies equally to imported meat that has been processed in Great
Britain. The round health mark will replace the oval EU health mark.
These arrangements are expected to come into force on 23 April.
The Food Standards Agency is satisfied that the
meat from animals slaughtered under these arrangements would have
no implications for food safety.
FOOD SAFETY AND FOOT AND MOUTH VACCINATION
How safe is it to consume meat and milk from animals
that have been vaccinated against FMD?
- The vaccine uses a dead virus, so it isn’t
active and therefore cannot spread the disease.
- The vaccine has been through rigorous safety
assessment by independent experts (the Veterinary Products Committee)
before being given a licence.
- Millions of doses of FMD vaccine have been
given world-wide with no adverse effects on human health. Foot
and mouth disease vaccines are widely used throughout the developing
world in parts of Africa, South America and Central America.
- If people go abroad on holiday to countries
where the FMD vaccine is routinely used and eat meat, that meat
has probably been vaccinated and has never been shown to cause
any human health problems. In mainland Europe (including The Netherlands,
France, West Germany, Belgium, Italy, Spain and Switzerland, people
were drinking milk and eating meat from animals vaccinated against
FMD up until 1991.
- In the Netherlands, meat from vaccinated animals
does not enter the human food chain. This is as a result of concern
about animal safety (vaccination may mask the presence of infection)
rather than any risk to human consumers. Milk from vaccinated
animals is being used for human consumption within the Netherlands.
Why is the FSA not proposing to label food products
derived from animals that have been vaccinated against FMD? Doesn’t
this deny consumers choice?
- Animals are vaccinated against a number of
diseases, about 33 in total, none of these vaccinations are known
to pose any threat to human health. This is the case with FMD.
Therefore, the FSA sees no reason to treat animal products from
FMD vaccinated animals differently to products from animals vaccinated
against other diseases.
- The Agency is satisfied that the use of the
FMD vaccine does not adversely affect the quality or safety of
animal products.There is therefore no difference, from a human
health point of view, between products from vaccinated and non-vaccinated
animals. The FSA thinks it would be inappropriate if FMD vaccinated
meat was labelled while other vaccinated meat was not.
If meat and milk from animals vaccinated against
FMD is safe to eat, why is the Government talking about additional
measures for these products, such as heat treatment for milk and
de-boning of meat?
- These are not food safety measures. They are
disease control measures drawn up by Maff. The disease is highly
contagious for animals and these extra controls are aimed at preventing
the disease from spreading to non-infected animals.
It has been reported that shops say they will
only stock milk and meat from FMD vaccinated animals if consumers
want to buy them. Surely there is a danger that consumers will simply
stop buying all British meat and milk if they are not confident
of what they are buying?
- We understand the supermarkets concern about
consumer confidence. But, we are dealing with a situation that
is very well understood. The disease is well known, it has been
around for a long time. It has been studied very extensively and
we are confident that there is no human health risk from vaccinated
milk or meat from vaccinated animals.
What about the farmers’ opposition? Surely
this sends a message to consumers that there is something to worry
about?
- Not at all. We have to be clear about different
concerns here. Farmers are quite rightly concerned about their
animals’ welfare and controlling the spread of the disease.
These concerns are not prompted by food safety issues.
Vaccinations are used regularly for cattle in
the UK. Which ones and on what scale? Do they result in antibodies
or virus in the milk or meat?
- There are currently 33 vaccines for cattle
in the UK. Most of these are inactivated vaccines for calves and
cattle against a range of diseases endemic to the UK. There are
also a number of live vaccines, such as those against respiratory
disease caused by bovine rhinotracheitis (IBR) virus and parainfluenza
virus (PI3) and a vaccine against lungworm. There is a zero withdrawal
period for these vaccines, as they do not present a risk to human
health. Both live and inactivated vaccines do result in serum
antibodies being excreted in the milk. Sales of some of the vaccines
are very extensive; for instance tens of millions of doses of
inactivated clostridial vaccine for sheep and cattle and of live
parainfluenza virus vaccine are sold each year.
Statement from Deirdre Hutton
(National Consumer Council), Chairman of National Consumer Council
on Vaccination
and Foot-and-Mouth Disease
20 Apr 2001
Food from vaccinated beasts can go into the food
chain and need not be labelled. But we must review our agricultural
policy thoroughly and quickly too.
Consumers have made the link between animal feeding
practices, health and welfare and food safety and they are inevitably
worried. In our recent research 23 per cent said that they have
changed, or are thinking of changing, their eating habits in the
light of foot and mouth. Consumers are right. Animal health and
welfare is closely linked with human health and food safety. But
consumers are wrong if they think that foot and mouth carries the
same risks as BSE or genetic modification (GM).
It is our view that consumers need to be reassured
of this before they will accept meat or other food from livestock
that has been vaccinated. Our research showed that 71 per cent believe
they are not getting enough information about the way in which agricultural
practices affect the meat we eat.
To overcome these difficulties, foot and mouth
must be treated as more than an animal problem. The Food Standards
Agency (FSA ) is a trusted public health agency and needs to give
out information about the whole range of potential concerns. The
Chairman of the FSA, Sir John Krebs, has begun this task by saying
quite plainly that there is no health risk from eating meat and
dairy products from animals that have been vaccinated. Indeed animals
are already vaccinated against a variety of things, all of which
we accept without question and some of the beef we import is undoubtedly
from animals that have been vaccinated. As one of those bodies that
called for an independent agency like the FSA, we accept the agency’s
view.
Nor do we believe that such food needs to be
labelled to distinguish it from other produce. The National Consumer
Council, and other consumer organisations, have of course argued
that labelling should be applied in the case of GM, so why the difference?
Simply that in the case of genetic modification we are dealing with
a new technology where there is inevitably some uncertainty. We
do not know what, if any, the problems might be, because we simply
haven’t got enough experience or all the science. The same
remains true for BSE. In the case of foot and mouth there are several
hundred years of experience in the UK and abroad, which tell us
that there will not be a problem for human health.
But the public should demand more than information
about the effects of foot and mouth. There are some much bigger
questions that need to be addressed.
For example:
? to what extent has this outbreak of foot and
mouth been made worse by modern practices in the food chain?
? what is the best way of farming sustainably in this country?
? why do we continue with a Common Agricultural Policy that has
let down all consumers?
Questions like this will only be addressed if
the next government commits itself to a thoroughgoing review of
UK agricultural policy and the food chain. That’s why I wrote
to the Prime Minister on 14 March calling for a Food and Agriculture
Commission to be established which would explore options for more
sustainable farm policies in the interests of farmers and consumers
alike. It is also vital that such a debate embraces the interests
of low income consumers. The EU’s CAP has let down all consumers
- especially disadvantaged consumers - badly. It overcharges them
for food, reduces choice, undermines food quality and disregards
the nutritional consequences of its policies.
We have a unique opportunity to reform our agriculture
for the benefit of society as a whole. The next government must
seize that opportunity.
END
Further Reading Recommended by Land-Care
Royal Society of Edinburgh. Inquiry into Foot and Mouth Disease
in Scotland. July 2002. (Download
PDF).
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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