Comments on the Draft Report of the EU FMD Inquiry

(EU Temporary Committee on Foot and Mouth Disease)

Published 16th Sept 2002

The draft report can be downloaded by clicking here [pdf].

A personal view

Dr James Irvine (FRSE DSc FRCPEd FRCPath FInstBiol, Previously a member of the Royal Society of Edinburgh FMD Inquiry that reported on 15th July 2002).

The working document produced by the Temporary Committee on Foot and Mouth Disease for the European Parliament came to my attention through the good offices of the National Foot and Mouth Group and through the excellent information channel of www.warmwell.com. It is remarkable that, in spite of my interest and concern over how FMD was handled in the past and how it should be managed in the future, awareness of this important new document might well have escaped me. Indeed it did from its date of publication on 16th September until 1st October.

With its usual admirable efficiency and promptness www.warmwell.com has already made a number of highly pertinent points. My purpose here is to encourage readers to look up warmwell and to complement the comments made there. Here my remarks are directed to specific paragraphs in the EU Report, which is available on his website in full (1).

Para 11

The authorities should have been well aware, not only of the high risk of FMD entering the UK, but what would happen if it did. Even if the UK Government Veterinary Services Agency had not realised the potential seriousness of the situation, then the research organisations substantially funded by the government should have been ringing the alarm bells long before February 2001. The reason for this unequivocal assertion is that globally FMD type O had been spreading east and west from Asia for the past few years as well documented by the Office International des Epizooties (OIE). It was a calamity waiting to happen.

Furthermore, it was very well known to all in the UK livestock industry (but remarkably apparently not to the UK government authorities) that livestock movements (especially of sheep) were very extensive throughout the UK. It had always been so (since the days of the drovers), but the distances were now greater and the movements faster. Movement of livestock is intrinsic to the UK livestock industry.

Add to that the long known facts that FMD can be difficult to diagnose in sheep, that the regulation of legal or illegal importation of meat or meat products from around the world into Europe (and therefore into the UK) was extremely lax and that there was no ban (although there was regulation) on the feeding of pigswill, we clearly did have a FMD crisis that was just waiting to happen. Today, apart from a ban on pigswill not a lot has changed.

There can be no doubt that the contingency planning should have taken adequate account of these facts, but sadly it did not. Although the UK’s contingency plan (2) was approved by the EU clearly the EU authorities, as well as those of the UK, were guilty of a serious lapse in applying common sense and in fulfilling their responsibilities.

Para 13

To say that large sections of the population would have considered an immediate nationwide ban on transporting FMD-susceptible animals as disproportionate, simply reinforces the lack of appreciation of just how vulnerable the UK and the EU were to a massive and rapid spread of FMD and its disastrous consequences. Indeed the lack of any ban within the UK for 3 days (whereas the ban on export of livestock from the UK to Europe was immediate) simply accelerated the movements of livestock throughout the UK at that crucial time.

Para 14

The endless delays by the authorities within the EU and the UK in coming up with a practical animal identification system that was durable and easily read (both by farmers and government officials) continues to this day. It must surely be possible to design a microchip that can be read not too expensively by both farmer and government bureaucrats and is compatible with animal welfare. We are still waiting.

Para 22

It is correctly stated that the British Government based its statements on epidemiological models. It reveals that the head of the UK scientific advisory group was aware that the models did not take into account the mode of transmission of the virus. It does not mention that these models were previously untried in such a veterinary disease situation, and that the four models were not so independent of each other as implied. To say that the appropriateness of the models used to anticipate the course of the epidemic remain scientifically controversial is an understatement in view of the poor quality of the data fed into the model(s) in the first place and the numerous assumptions made before the model(s) could function at all.

Para 50

Perhaps even more serious than the major lapses referred to above, is the statement made in para 50:

“The decision on vaccination is in any case not a scientific matter but a political one and therefore depends on the circumstance and interests which are taken into account and the priority objectives adopted for the purpose of controlling the epidemic”.

Such a statement justifies the long-held feeling that science was not being properly considered (let alone employed) either before or during the UK 2001 FMD crisis, and that political interests were to the fore. I am not aware of any disease that has been successfully controlled by putting politics before science. Surely every political effort should be made to apply known science and to expand scientific knowledge as quickly as possible, so that efficient and rapid methods of diagnosis, control and eventual eradication can be achieved. This is all the more distressing when it is remembered that the UK has an abundance of first class research establishments and relevant commercial enterprises with substantial scientific skills whose help was not asked for let alone encouraged (3). Giving priority to misguided politics also lead to the refusal of scientific help from major international organisations such as the United States Department of Agriculture (USDA) at Plum Island, New York.

Para 51

Also central to the problem of the disastrous handling of the UK 2001 FMD crisis was the persistent misinformation that was propagated at the start and throughout the crisis as to the existing state of scientific knowledge regarding vaccination for FMD and the diagnostic tests available. This revealed a serious lack of basic immunological knowledge amongst influential members of the veterinary profession. Further it appeared that certain key figures in the veterinary world were prepared to play politics with scientific knowledge as it suited their purpose, rather than act with the degree of intellectual honesty that one would expect from professional scientists - be they scientists in academia or in government service. It also appears incontrovertible that such scientists were prepared to advise powerful bodies, both within and outside government, from at best a base of ignorance or at worst from a base of misguided political expediency which was not directly related to the urgent problem of controlling the disease.

Sadly from the comments made in this section of the report this state of affairs seems set to continue. The advantages of vaccination in the control of a FMD outbreak have been established many times over. Politics needs to adapt to the benefits of applied science, not to try to use the science to suit some other agenda which in the medium to long term is bound to fail. In developed countries the most powerful tool in the control of disease is science, not politics. What we want to achieve is good science that is encouraged to flourish and that is effectively applied with the help of politics.

What this paragraph does not seem to appreciate is that good contingency planning is required for all eventualities. The application of vaccination must be made from the earliest date if it is to be used, and not waste time arguing the pros and cons for days, weeks or months as happened in the UK 2001 outbreak. Lessons should be learned from studying the almost contemporary outbreak in Uruguay, where they clearly had good contingency planning (4, 5). It is simply not true to say that it is too difficult to plan in general terms for all eventualities, but it does need some forward thinking. The latest Draft Contingency Plan from the Scottish Executive (6) (dated May 2002, predating the FMD Inquiry Reports) and from DEFRA (2) has vaccination as a separate strategy (i.e. they we will think about it at the time) and keeps the countryside open except in the area of the outbreak. Almost 3 months after the FMD Inquires had reported little has apparently changed except that the presumption will be that the countryside will remain open. That is not what the Inquiries recommended. The reaction of local farmers to the way in which a FMD scare was handled in Cornwall on 23rd September 2002 is described in Figure1.

Figure 1: Row over delays in new FMD scare (Farmers Weekly 27th September 2002)

Click here for enlarged image

Para 62

Here we have poor logic when the idea of systematic prophylactic vaccination is largely dismissed. In the first place there is again misguided information. There are seven different serotypes which cannot currently be tackled by a single vaccination, and there are 80 known subtypes within them. But that does not make systemic prophylactic vaccination ineffective or impractical.

What is not mentioned in this EU presentation is that in reality there is remarkable stability within FMD virus types. Thus it was still Type O PanAsia that came to the UK after spreading east and west from Asia over the previous years. Essentially the same vaccines can be used to counter the FMD outbreaks over these years in these different countries. The three million doses of FMD vaccine that were available to the UK at the beginning of the crisis in February 2001 came out of store and did not have to be made from scratch (i.e. there were stores a plenty of an appropriate antigen to make masses of appropriate vaccine within days). The half million doses of FMD vaccine that were sent to Cumbria (but not used) were made in 1990 and when tested were found to be appropriately effective against the UK 2001 outbreak strain. It was also not mentioned that certain of the recognised seven virus types are extremely restricted in their global distribution. In terms of risk assessment it would be quite feasible to put three (or possibly more) of the most common types of inactivated FMD virus into a single dose, with greatly enhanced protection. Polyvalent FMD vaccines are in current use under the auspices of the OIE.

In this context the authors of the EU Report seem to have forgotten that a programme of systematic prophylactic vaccination worked very well for many European countries until 1991. So successfully in fact that FMD was eliminated in these countries and the EC decided to become FMD-free without vaccination - putting politics in front of science with disastrous results that came relatively sooner than later to the UK in 2001. Is Europe going to do the same again?

Para 66

The EU Report rightly states that the most serious risk of entry of FMD is illegal imports of animal products from countries where FMD is endemic. It also goes on to say that to effectively control such imports is neither economically or logistically realistic. Is this why the efforts of EU member states to control imports are so poor? While the EU has extensive boundaries the UK, being a small island, does not. The remarks of visitors from outside the EU to a major international gathering of Aberdeen Angus Breeders in Scotland recently are revealing (Figure 2). But clearly politics gets in the way again. Everything has to be the same across the EU, so there must be free trade with no interstate obstructions. The argument therefore goes that since importation of meat products cannot be effectively monitored for all of Europe because its boundaries are so big, it is inappropriate and illegal to try and do it for the one country that is the most vulnerable and where it would be the easiest to put into effect. I would submit that this is bureaucratic nonsense.

Figure 2: Aberdeen Angus Breeders visit to Scotland - Disbelief at lack of security (Courier October 4 2002).

Click here for enlarged view

Para 8.

Going back to near the start of the EU Report, it is heartening to read in para 8 that

“The EU’s policy in the event of an FMD outbreak has hitherto been geared to culling livestock from infected herds and FMD-susceptible animals which might have come into contact with the source of infection or infected vectors or which were suspected of having been infected in any other way (a stamping out policy). As a general rule emergency vaccinations were to be avoided and performed only - at the request of the Member State concerned - by way of exception, in the event of a major epidemic. In the light of experience of FMD in 2001, this policy cannot continue in its present form”.

So what should the new policy be?

The Way Forward

The first thing to do is to bring science and education to the fore, ensuring that these activities are geared to a proper level of intellectual and ethical activity. By this I mean true science - not science that is selected, put aside or otherwise misrepresented for some political reasons that are not central to controlling the disease but have some other benefit to the perpetrator. The science and education must be seen to have ethical credibility and to be open to public scrutiny.

To achieve this an early step would be to urgently provide an ongoing review of what science has already achieved, what it is continuing to achieve and who is doing what on an international level. It is my belief that most of the public would be very surprised to learn how advanced science was before the UK 2001 FMD outbreak and how there was serious failure in its application.

Make valiant efforts to overcome the lethargy and obstructionism of the European Union (EC) bureaucracy with its knock on effect on how DEFRA and SEERAD operate in the UK. In turn this means that if the OIE is to continue to have such a regulatory role on what is perceived to be proper practice internationally regarding the management of FMD (i.e. as to what is and what is not acceptable in terms of international trading), then it must act much more efficiently and promptly. It too must been seen to give credence to good science rather than be a bargaining ground for political manipulation. It stands charged with much of the damage that was done in the UK and Holland on account of its outdated rules on international trading in the light of the science that was available to them for years previously. The OIE is perceived by many as a somewhat cosy club of the veterinary officials from countries around the world and which only meets at rare intervals when it may or may not make some outdated decisions that have immense impact elsewhere. To give it its due, however, the OIE does plot the outbreaks of FMD throughout the world very efficiently and makes the information available through the Internet for all to see. It is what it does with the information that is the trouble.

One of the main obstacles to applying known science in relation to the UK 2001 FMD outbreak was the endless reiteration that “tests are awaiting validation by the OIE”. Then it is revealed that the OIE do not have any role in getting the information put together, but only sits on judgment (very slowly) once evidence for validation or otherwise is put before them. How often do they meet - once or is it twice a year? In the eyes of the OIE it is up to individual countries or commercial organisations to submit the evidence to the OIE. So who organises tests to be validated that could benefit many countries - such as reliable, on-farm diagnostic tests for FMD virus and for FMD antibodies that can distinguish vaccinated from virus infected animals on a herd or individual animal basis? Who integrates how the data is collected as the requisite samples may be hard to find, as in the case of trying to determine whether the carrier animal is fact or more probably myth as far as FMD is concerned. Indeed one of the biggest problems in validating certain tests to distinguish between infected and vaccinated animals is the paucity of samples available from animals that have been vaccinated and that still harbour virus. If sufficient samples cannot be found because of their rarity then such tests will never be “validated” .

As far as the UK is concerned most of its international trade in livestock and livestock products is within the EU. The OIE only lays down rules or guidelines that can be used in an international court of law, but it does not debar any arrangement between countries that are mutually agreed. So why does the EU not draw up its own list of tests that meet criteria of quality assurance that suits the needs of the EU? Not only that, but why does it not get on and efficiently organise the gathering of the evidence required? It could surely do this much better and in a more relevant way than the never-never scheme of the OIE. The EU should also be in a position to fund such an enterprise.

As a step in this direction the EU Report states in para 100 that

“the Commission should immediately designate a Community Reference laboratory for vesicular virus diseases, which should maintain contact with the officially designated national laboratories, assist them and be in a position to make optimal methods of diagnosis of vesicular diseases of animals available, perform experiments and field trials relevant to FMD and provide information and further-training programmes”

My understanding is that a recommendation was previously made to set up a Community Reference Laboratory but it never got off the ground because it was never funded. The end result was that in the UK one laboratory had a monopoly, it could not cope, it had not done the basic development work, was thought by some that it might have a serious conflict of interest with its commercial wing, and allegedly did not cooperate as openly as it might with commercial companies that were in a position to contribute. Justifiably or not, there was a perception that Pirbright in the UK (recognised as a World Reference Laboratory and part of the UK government funded Institute of Animal Health) may not have been behaving as impartially as the FMD crisis demanded.

On account of the fact that controls of imports of meat and meat products into Europe will be difficult to effectively monitor (although this should not be the case for the UK), and on account of the fact that FMD is endemic in a number of countries throughout the world and some of them close to the EU, it would only seem common sense to seriously and urgently consider prophylactic vaccination throughout the EU.

No doubt because of all the problems so ably pointed out by www.warmwell.com in its analysis of the European Report, the Report states in para 84 that:

“The Commission should be in a position if necessary to determine the strategy for controlling FMD itself if this is required to protect the interests of Member States threatened by FMD or of the Community”

If it does take on this role it will need to convince Member States (including the UK) that it is capable of doing this efficiently, impartially, timely and in an open manner demonstrating good scientific principles. The current perceptions held by many of the workings of the EU/EC may make this an uphill task for these organisations. Do we go from the frying pan into the fire? A strong message that came out of the FMD Inquires was that effective local involvement in the face of an FMD outbreak was important. So it was perceived that the management of FMD in Scotland (for all its serious faults) was better done with Scotland’s partial devolution than in England and Wales (that suffered so disastrously under the dead hand of DEFRA).

A better answer might be to:

Sort out DEFRA so that it functions as a credible organisation in terms of disease control and takes a more positive interest in UK agriculture.
Ensure that the scientific advice given to the UK Government through its Scientific Advisor is properly constructed following existing guidelines (3) and its not put together as an ad hoc group of individuals the interests of too many of whom were over represented; i.e. experimental modellers with little or no practical veterinary experience or understanding of the uses of immunology.
The international guidelines (firstly within the EU and then through the OIE) as to how FMD should be controlled within the EU and beyond should be revised and kept up to pace with developing science.
The EU should fund and help organise international research into diagnostic tests and their application in the field. It should also act as a funder and facilitator for advances in vaccines and ensuring the availability of existing effective vaccines
The EU should ensure that it does not act as an inhibitor to effective control through unnecessary bureaucratic “correctness” and delays. Its role should be as a facilitator and communicator of advances and their application to the control of this dreadful disease to the benefit of all Member States and beyond. As few people seem to know who their MEPs are and which of them are serving on the Temporary Committee that produced the EC Report a list of their names is provided (7). Why do we so seldom hear from our MEP’s as to what is going on in the EU? Unless they can communicate better there must be some caution before delegating the future management of FMD to the EU.

References

1. European Parliament Temporary Committee on FMD. Working Document 5a. (16th Sept 2002). (View report [pdf]).

2. DEFRA FMD Contingency Plan. (Download report [pdf]).

3. Royal Society of Edinburgh FMD Inquiry Report (15th July 2002). (View report [pdf]).

4. Final report of a mission carried out in Uruguay from 25 to 29 June 2001 in order to evaluate the situation with regard to outbreaks of foot and mouth disease. European Commission Health and Consumer Protection Directorate-General. (Download report [pdf]).

5. Final report of a mission carried out in Uruguay from 1 to 4 October 2001 in order to evaluate the controls in place over foot and mouth disease. European Commission Health and Consumer Protection Directorate-General. (Download report [pdf]).

6. Scottish Executive FMD Contingency Plan, May 2002. (Download report [pdf]).

7. European Parliament UK Office website - UK MEPs.

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7 October 2002