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Comments on
"Stopping illegal imports of animal products into Great Britain.
UK National Audit Office report"

Dr James Irvine FRSE

Previously a member of the Royal Society of Edinburgh FMD Inquiry
Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire

Filed 25 Mar 05
©www.land-care.org.uk

On 23rd March 2005 the UK National Audit Office published its report "Stopping illegal imports of animal products into Great Britain" (1). It makes alarming reading. While it documents what improvements have been made since Customs took over responsibility for import controls in April 2003, these improvements have been small compared to what is required.

Confirming what has been previously emphasised (2), the report shows that there continues to be a serious lack of import controls at the borders of our EU neighbours as well as our own, remembering that once an item has entered any EU member state there are no further controls in place in the interests of free trade. Thus animal health issues take second place to the political agenda for free trade within the EU member states.

The Report quotes the Veterinary Laboratories Agency estimate that between 4,000 and 29,000 tonnes of illegal meat or meat products enter Great Britain per annum.

The report clearly states (para 1.5) that

"About 220,000 tonnes of meat products are imported each year into Great Britain from countries outside the EU. In addition between 4,000 and 29,000 tonnes (with an estimated average of nearly 12,000 tonnes) is estimated to enter the country illegally."

It goes on to state (para 2.1)

"Since Customs took over the responsibility for tackling illegal imports in April 2003, the total number of seizures of animal products has more than doubled from 7,800 in 2002-2003 to 15,800 in 2003 - 2004. In the six months from April 2004 there have been nearly 11,000 seizures. The weight of the seizures was 186 tonnes in 2003-2004, an increase of 70% on the previous year. The weight of the seizures in the six months from April 2004 was been 109 tonnes"

In round figures it could therefore be said that, for the year 2003-2004, only 186 tonnes of illegal imports were detected out of an estimated average of 12,000 tonnes of illegal imports entering Great Britain from non-EU countries each year - a success rate of just 1.55% in terms of weight. Even if Customs managed to detect 300 tonnes in 2004-2005 with their improved performance that would only amount to a success rate of 2.5%.

The claim by NFU Scotland (3) that

"98% of illegal meat imports escape UK controls"

is therefore clearly justified, even although the NFUS refers to the UK (England, Wales and Scotland) while the report refers to Great Britain (which of course includes Northern Ireland).

It appears from the Report that the Irish situation in terms of the movement of illegal meat products is a serious one, especially in relation to the Republic of Ireland which is an EU member state but not part of GB. The figures for Eire cannot distinguish between passengers entering the country from EU or from non-EU countries (Report: Table 16, p 23). One can but speculate on the performance of cross border controls between Northern Ireland and the Republic of Ireland in terms of efficiency.

The Report states that GB compares favourably with other EU member states, but little comfort can be taken from that as the controls within these states are apparently even more lax than in GB. What is clear is that the GB performance is sadly behind the efforts and achievements of Australia, New Zealand, USA and Canada (Table 1).

* based on all incoming passengers whether from EU or non-EU countries
as the Republic of Ireland cannot distinguish between the two.

In 2002 (the latest figures available) over 27 million passengers from countries outside the EU arrived in GB at 28 airports and about 110,000 arrived at seaports (Report: Para 3.1). A trained dog can screen the baggage of a whole flight in a short time, indicating to its handler if it detects any meat products. Table 2 shows the striking differences in the use of detector dogs in New Zealand, Australia, USA and Canada compared to GB.

GB was the first country within the EU to introduce detector dogs. GB is the only country
within the EU to have detector dogs for only animal products.

Table 2:
The extent to which selected countries use detector dog teams
(from NAO Report Table 17, p24)

Customs' 3,500 detection staff are responsible for tackling smuggling including illegal imports of animal products. Most of these staff concentrate on the smuggling of illegal drugs and tobacco but may come across illegal animal products during the course of their work. In 2003-2004, only 51 of these staff with 6 dog teams were deployed specifically for the detection of illegal imports of animal products.

Just how little Great Britain spends on controlling the import of illegal animal products is shown in Table 3: just 25 pence per incoming passenger compared to £3.15p for Australia and £2.50p for New Zealand.This is particularly galling in view of the many hundreds of millions of pounds sterling that Her Majesty's Customs and Excise have squandered in lost revenue, as alleged in the BBC One Panorama programme 'Nothing to Declare' Wednesday 23rd March 2005. Two of the most senior officials in Customs were suspended last year. These missing multiple millions could have been put to good use reducing the vast amounts of illegal imports of animal products and the attendant risks to animal health and the rural economy.

Customs expenditure is the total amount allocated for 2004-2005 for tackling illegal imports of agricultural products including animal products and plant products in passengers' baggage, in freight and mail

The expenditure for Australia and New Zealand is their expenditure on border controls at airports
for tackling illegal imports of agricultural products

The Report estimates (Report:Table 10, p18) that the probability of outbreaks occurring from illegal imports of meat or meat products as

once in every 3 years for Classical Swine Fever (pigs),
once every 65 years for Foot and Mouth Disease (FMD),
once every 1,500 years for African Swine Fever (pigs), and
once in every 1.5 billion years for African Vesicular Disease (pigs).

Incredibly these estimates are claimed to be to 90 percent confidence levels.

With regard to FMD it is difficult to comprehend how anyone can reasonably arrive at such a figure: once in every 65 years. Over the years international travel has greatly increased and so has the cosmopolitan nature of the UK population, making such an estimate and its claim for accuracy absurd. Such unjustifiable guess work (whether or not it is based on modelling) does little to enhance the reputation of statistics - nor of those who concoct them. The situation is akin to the statistical assessment of how often flooding would occur in different parts of the UK, which led in some areas to a sense of false security and lack of adequate funding for prevention.

Where statistics can also be misleading is when the figures for agriculture are quoted as showing that it contributes relatively little to the UK economy, but neglecting the role farming has played over generations in terms of the environment and other aspects of the UK's natural heritage.

Quite mistakenly, with the decoupling of farm subsidies from production in favour of the environment consequent to the reform of the EC Common Agricultural Policy, the UK government (including its Scottish devolved component) is undermining those who have cared well for the environment and who have also achieved an international reputation for breeding livestock that produces high quality meat. The government, as a consequence of lobbying by evangelical, single interest ecologists, now wants to control what the farmers do without understanding the business of farming or indeed having any real interest in it.

In what may be interpreted as a political attempt to maintain the tourist industry, the Scottish Executive overruled the recommendation (2) that access to the countryside by the general public should be closed in the event of another outbreak of FMD. But there is little doubt that the tourist industry would still be greatly hit should another outbreak occur. Another outbreak of FMD (or other exotic disease of livestock) would further the UK's reputation as being the "dirty man of Europe" with consequences that would spread for wider than farming.

In a future article I hope to comment on the inadequacy of the new version of the contingency plan that has been drafted by DEFRA to tackle an outbreak of FMD in the UK (4). That such an outbreak will occur would appear to be inevitable - given the present global situation, the painful lack of adequate border controls, the nature of the offending virus, and the lack of progress to achieve neither early diagnosis nor the efficient use of vaccination.

©www.land-care.org.uk

References

1. UK National Audit Office (2005). Press Report. HM Customs & Excise - Stopping illegal imports of animal products into Great Britain,
http://www.nao.org.uk/pn/04-05/0405365.htm Click Here to View (547KB

2. Royal Society of Edinburgh (2002). Inquiry into Foot and Mouth Disease in Scotland.
ISBN 0 902198 48
http://www.royalsoced.org.uk

3. NFU Scotland (2005). News Release: 22 March. "98% of illegal meat imports escape UK controls"
To view pdf file Click Here

4. DEFRA (2005). Generic animal disease contingency plan covering foot and mouth disease, Asian influenza, Newcastle disease and classical swine fever.
Replacing the FMD contingency plan version 4.0 and avian influenza/Newcastle disease contingency plan version 1.0
A consultation document: the closing date for responses is 15th June 2005
http://www.defra.gov.uk/corporate/consult/animaldisease-plan/consult.pdf Click Here to View (837KB)