See original Page as HTML (it is a pdf file on the DEFRA website)
"This paper sets out the Defra responses to the SAC Epidemic Diseases Sub-group on the Plan and explains how work is developing on the areas to which the SAC sub-group drew attention. " DEFRA
My comments are in red.
Mary Critchley warmwell.com
Recommendation 1: It would be useful if the key changes (relative to the Foot and Mouth Disease Contingency Plan that was in place before 2001) were stated, including information on new research instigated and how social science lessons have been analysed and incorporated into the revised plan.
My reading of Recommendation 1 is that the SAC sub-group, like many of us, would like clear and simple information about what exactly HAS changed since the policies of 2001. New research that has taken place since the outbreak has presumably yielded some new information. What? What has been learned about the social fallout and distress caused by the 2001 policies that can be incorporated into new Contingency Planning? This is DEFRA's response:
Prior to 2001 the Foot and Mouth Disease Contingency Plan was that required by the EU FMD Directive. It focused on meeting the requirements of the Directive and did not set out the policies that would be implemented or many of the other elements of the Plan, finance, procurement, human resources, and ways of managing the rural impact that are now present. The current Plan has evolved from one initially prepared and consulted on in early 2002 and has been revised before laying before Parliament in March 2003 and March 2004. Detailed veterinary instructions were in place before 2001 and these have been revised and placed on Defraweb. The purpose of the Plan is to provide guidance for operations in an outbreak rather than to explain in detail the policies and the research on which it is based.
Disease profiles are now being prepared and placed on the Defraweb for all the main exotic diseases so that the public will be able to read about the disease and the control strategies. In addition the summary of policies as set out in the Contingency Plan, together with consultations on policy as it is developed, help to inform the public.
Information on the research programme is available on Defraweb.
Warmwell comment: The point of the recommendation seems to have been missed. Putting things on the DEFRA website to give information about policies, research and disease profiles does not ensure that anyone can find or read them there. The response does not begin to say what has changed - nor is there anything in Defra's response here about new research - nor about lessons learned from the social distress the 2001 policies caused. It would be hard indeed to find reference to these in any Contingency Plan.
Recommendation 2: The Government should clearly state its policy priorities in terms of control during an outbreak. Priorities in the event of different outbreak scenarios should be considered.My reading of Recommendation 2 is that DEFRA needs to make plain what it is trying to achieve with its policies. Perhaps its priorities would be different according to the size and scale of outbreak. If so, this needs to be thought out properly.This is DEFRA's response:
It is proposed that in the next version of the Contingency Plan due to go out for consultation in February 2005 the objectives in a future FMD outbreak will be set out. These are:-
“The Disease Control Strategy adopted will be consistent with the UK’s EU obligations and in line with the appropriate EU legislation. The Government’s objective in tackling any fresh outbreaks of FMD will be to eradicate the disease and to restore the UK’s disease free status as quickly as possible. In doing so, Government will seek to select control strategies which balance:-
- Minimising the number of animals which need to be slaughtered either to control the disease or on welfare grounds, and which keeps animal welfare problems to a minimum;
- Causing the least possible disruption to the food, farming and tourism industries, to visitors to the countryside, and to rural communicates in the wider economy;
- Minimising damage to the environment and protecting public health; and
- Minimising the burden on tax payers and the public at large.Warmwell comment: It's all very well to say that the priority is "to eradicate the disease and to restore the UK’s disease free status as quickly as possible" It was that same priority in 2001 and, as Roger Breeze says, "....the government belatedly realized that the critical monetary yardstick was not the animal product export sector but the rural economy as a whole and that protecting animal agricultural interests by not vaccinating was causing huge financial losses in tourism and other sectors that had never been factored into the calculations of outbreak costs.". (From Roger Breeze's paper Agroterrorism: Betting Far More than the Farm - now available freely on the internet as a pdf file at www.liebertonline.com ) - but HOW will the 4 elements of the balancing act that is then envisaged actually be prioritised? How will the "number of animals which need to be slaughtered" be minimised? The answers are mere vague and optimistic statements of intent. The SAC question about different types of outbreak is not answered at all. DEFRA misses the point that a small and easily controlled outbreak could certainly have as its priority "to eradicate the disease and to restore the UK’s disease free status as quickly as possible" - but that multi foci outbreaks that cannot be controlled quickly - as in 2001 - will require different handling from that of 2001.Recommendation 3: A strategy document should be produced to set out a framework for decision-making based on the different scenarios and policy priorities.
My reading of recommendation 3 is that DEFRA really does need to do some more work to produce an actual document setting out in clear and simple terms the different priorities that each possible scenario would call for. This is DEFRA's response:
The overall objectives are as set out in response to recommendation 2. Further work may be initiated on different scenarios using work commissioned through the Modelling Consortium. This brings together Defra policy officials, vets, epidemiologists and scientists with animal disease modellers from a range of establishments to coordinate and advise on the best use of science, epidemiology and modelling in a major exotic animal disease outbreak.
Warmwell comment: Even here, where SAC asks for a document, the response is fudged. No document. No framework for decision making. Responsibility is not shouldered. Phrases such as "Further work may be initiated", "a range of establishments" and "the best use of science" are vague and woolly in the extreme..
Recommendation 4: Defra should build UK epidemiological modelling expertise into further refinement of its Contingency Plan. A range of different outbreak scenarios should be modelled and the best approach available for each should be established.
The point of Recommendation 4 seems to be - once again - to encourage DEFRA to realise that a one-size-fits-all policy is not correct. An FMD outbreak could be shocking in its scale - or it could be immediately spotted,reported on and controlled. The modelling expertise that initiated the policies of 2001 was not based on understanding of the way the virus behaved nor the situation that had been allowed to develop.
This is DEFRA's response:
The work being considered within the Modelling Consortium and that undertaken by the Cost Benefit Analysis (due to conclude in February 2005) will provide a greater input from epidemiological modelling, both to deliver further refinement of the Contingency Plan and a more effective deployment of resources during an outbreak.
Warmwell comment: DEFRA appears to feel that Risk Solutions' cursory look at different scenarios gives the Department a let-out here. But the CBA admits in its own report that it is more a cost analysis than a cost benefit analysis. Section 8 looks at epidemiological modelling but the final section of the report suggests SEVEN areas of further work to be done before any "best approach" can be assumed.
Recommendation 5: Constraints on electronic data capture, transmission and access that could limit use of real-time information for prediction during an outbreak should be addressed.
Recommendation 5 tactfully suggests that DEFRA's woefully inadequate IT systems have not yet been properly addressed.
This is DEFRA's response:
It is clearly in Defra’s interest that data should be gathered as efficiently as possible for disease control purposes, to enable it to report on progress in disease control and to provide data for modelling purposes. IT systems are being reviewed by the SVS with its system provider to develop an integrated system enabling a more efficient management and rapid transmission of data.
Warmwell comment: DEFRA has been saying it will improve its IT capability for a long time. There was no integrated system in 2001 and - in spite of promises to introduce an expensive new system, this, said Sir Edward Leigh in February's NAO report, has been delayed. " ..The introduction of an improved management information system – the Exotic Disease Control System – was delayed whilst the Department outsourced its information technology...." (Section 7 of the Executive Summary) What state has the Exotic Disease Control System reached now?
Recommendation 6: Independent experts should be involved in the development of data capture systems.
Recommendation 6 uses the word independent. This means that data capture systems used should be independent of DEFRA and government. This is DEFRA's response:
The collection of data during a disease outbreak is currently being reviewed by the Defra veterinary epidemiologists who will staff the National Expert Epidemiology Group in the event of an outbreak and by the State Veterinary Service and AHWDG who will use the information for disease control purposes. This data will also be discussed within the Modelling Consortium to ensure that it will meet the needs of the independent academic modellers.
Warmwell comment: Good news if "currently being reviewed by" means that DEFRA's veterinary epidemiologists and the SVS really are currently engaged in refining ways of collecting and using data properly. But how if the IT is lacking? What ever did happen to the Exotic Disease Control System ? A search on the Parliament website reveals no match at all so presumably no report has been given to Parliament or to the EFRA Select Committee. And who exactly are the "independent" experts who will be involved?
Recommendation 7: In peacetime, mechanisms that provide the proposed independent modelling consortium with easy access to the modelling data collected at the centre must be agreed and tested.
Recommendation 7 implies that the fact that in 2001 data was not available for analysis was disastrous. It says that easy access needs to be shown to be possible and tested well in advance of a possible outbreak.
.This is DEFRA's response:
Agreed. The development of the Modelling Consortium and discussions on the way in which independent academic modellers would operate in an outbreak will ensure that this recommendation is fully met. The outcome will be captured in the Contingency Plan.
Warmwell comment: Pure Sir Humphrey. The response is vague and indicates some time in the future - what mechanisms and when and how will they be tested is evidently unknown. What exactly does "The outcome will be captured in the Contingency Plan" mean?
Recommendation 8: A review of the experiments and epidemiological data on the efficacy of vaccines should be undertaken as a high priority.
Recommendation 8 is about urgency. A review of what has been found out about the efficacy of the latest vaccines should be "high priority" This is DEFRA's response:
Agreed. There are several research projects ongoing at the Institute for Animal Health that seek to address aspects of the efficacy of vaccines. These include work on potency testing funded by Defra, a new BBSRC project on transmission and immunology and collaborations with EU partners and Indian immunologicals on cross protection. A review as recommended would be beneficial.
Warmwell comment: DEFRA may say it agrees - but why has it taken so long to "address aspects of the efficacy of vaccines" when it has now been four years since FMD 2001? We know that vaccines worked well four years ago. Uruguay in 2001 showed what could have been done here. Why has DEFRA not already carried out a review?
Recommendation 9: Modelling, including systematic sensitivity analysis, should be done to determine how vaccine efficacy, availability, deployment. post vaccination monitoring and other factors will influence a success of a given vaccination strategy in different outbreak scenarios.
Recommendation 9 was made at the very time that Risk Solutions were working on their "Cost Benefit analysis". It is difficult for a layman to understand why the factors that influence the success of a given vaccination strategy in different scenarios was not considered part of their brief - yet here is DEFRA's response
Agreed. There are benefits to be gained from carrying out this work and we are assessing how best to take it forward.
Warmwell comment: "We are assessing how best to take it forward" doesn't mean anything beyond a vague gesture towards the possibility that some rigorous work to do with different outbreak scenarios might one day be done. Possibly. One wonders why Risk Solutions were unable to do something so obvious.
Recommendation 10: Discussions to better define a dangerous contact (DC) should continue.
Recommendation 10 urges DEFRA to explain exactly what is meant by a dangerous contact. In 2001 it was the very vagueness of this term that allowed the slaughter of many uninfected animals. DEFRA responds with:
Agreed. This work is being taken forward within the FMD Expert Group chaired by Fred Landeg, Deputy CVO.
Warmwell comment: "Taken Forward"? After four long years this hardly seems too soon. And when is it to report? It would be useful to know why the definition of "Dangerous Contact " is proving so very hard to pin down.
Recommendation 11: The non-outbreak standstill time of cattle and sheep should be reviewed. If there are overriding factors favouring six days then these must be clearly stated.
Recommendation 11 recommends that good reasons need to be stated and explained for standstill times and that the whole question needs to be reviewed. DEFRA responds:
The standstill time for cattle and sheep relates to current conditions and it is not therefore appropriate for it to be justified in the Contingency Plan. The decision by Ministers in 2002 to set it at 6 days, was based on commissioned modelling and fully explained at the time that it was introduced. The decision balanced a diverse range of views from the industry, vets and scientific modellers. The current standstill now appears to be accepted by the bulk of the industry. Preliminary modelling for the control strategy Cost Benefit Analysis suggests that the 6 day standstill means that FMD is unlikely to get the same foothold through silent spread as it did in 2001.
Warmwell comment: But what ARE the overriding factors favouring six days? Why can they not be "clearly stated" in the response to the recommendation?
Recommendation 12: Defra should explore innovative ways to work with farmers to encourage adoption of good biosecurity at national, regional and local levels. Options might involve new selective incentives e.g. a scaling of the levy burden on farmers according to the level of biosecurity adopted.
Recommendation 12 gets to the heart of successful biosecurity. Farmers are to be "worked with" and "encouraged" at local and regional levels not just have a stick wielded from on high at Page Street. It even makes a suggestion about how to offer a carrot to encourage cooperation. This is what DEFRA has to say:
We intend to explore this further in the consultation on proposals for an exotic disease levy. There are some technical issues to resolve, but the general approach is to see the levy as incentivising good biosecurity and changing farmer behaviour
Warmwell comment: Who pays for the costs of an outbreak seems DEFRA's obsession and it is all that they see in the recommendation. Encouraging farmers by incentives to be readier to cooperate and to report disease is vital - working with them rather than seeking to "change their behaviour" is of the first importance. (And who on earth thinks that "incentivising" is a real word?)
Under the Animal Health and Welfare Strategy, work is being taken forward to encourage farm health planning in all livestock farming sectors. Farm health planning is considered by most as the most suitable way to increase standards of animal health and welfare, including disease prevention. Under the “Positive Animal Health Action Pan” ideas are being developed for communicating the importance of farm health plans to farmers. This is being underpinned by research on the costs of disease and the benefits of preventing disease.
We also have a new initiative to promote personal biosecurity at livestock markets aimed at all users of markets.
Warmwell comment: Again, "telling farmers what to do" - even when the advice is sensible, is not the same as encouraging helpful practice and giving incentives for cooperation.
Recommendation 13: Accurate pen-side tests should be developed for the diagnosis of FMD in cattle and pigs. The Department should develop the capability to identify further research needs, including a review of current technology and the identification of novel technologies.
This recommendation 13 is encouraging. It acknowledges that advances in rapid diagnosis on site and other "novel technologies" (such as instant location and electronic transmitting of information using GPS and so on) must be reviewed. DEFRA says:
RT-PCR tests have been developed for laboratory diagnosis of FMD, which are shown to be at least as sensitive as current diagnostic protocols, and much quicker. Current work is ongoing to validate this technique and also to develop portable PCR based tests for use in the field.
Defra is currently funding research into the development and validation of chromatographic strip tests for pen-side detection, based on serology. The use of serological tests (including the NSP based test) to identify vaccinated livestock that carry FMD will provide a basis for differential diagnosis. Work is currently ongoing on the development and validation of these tests.Defra is also the sponsor Department of a Foresight project on the Detection and Identification of Infectious Disease (DIID). The project will look at future threats posed by infectious diseases of animals (as well as humans and plants), part of which will include a review of current and future technologies for disease detection and identification. This work is largely futures based and will review possible technology developments over 10-20 years.
Warmwell comment: But pen--side tests already exist for use in the field! DEFRA's apparent lack of knowledge is frightening. What IS this obsession about validation? It has been going on since March 2001 (Can this answer about "funding research" really be about the commercialisation of UK tests for the UK's financial benefit - and not about reviewing "current technology" at all?)
Recommendation 14: During any future outbreak the Science Directorate should ensure the production of a daily email of scientific briefing, outlining the science and underpinning the various policy options.
Recommendation 14 refers obliquely perhaps to the poor communication in 2001 which left many in the dark, not knowing where to turn for proper advice, scientific understanding or news. It is why independent, concerned websites such as warmwell.com had to come into being in the first place. DEFRA says:
An emergency site on the Defra website for Foot and Mouth disease is being developed to provide information on the disease control policies and their operation to keep the public informed in the event of an outbreak. We plan to include scientific background and briefing on such a website.
Warmwell comment: Because of incompetence or as a result of deliberate policy, clear communication on an easily navigable website has not, to date, been DEFRA's forte. Keeping the public informed about exactly what science underpins the various disease policy options assumes that DEFRA itself knows and can communicate this adequately . This does not , unfortunately, seem necessarily to be the case.
Recommendation 15: It is important that the Plan be presented in an accessible format to all including clear explanations of objectives and strategy and risk.
Recommendation 15 grasps the nettle of the need for proper clear communication. Explanations of objectives, strategy and risks must be clearly set out. DEFRA says:
Current proposals for disease contingency plans are to develop a generic plan covering the structures and systems that would apply in any outbreak of exotic animal disease and specific disease chapters for Foot and Mouth Disease, Avian Influenza, Newcastle Disease and Classical Swine Fever. The plans focus on what has to be done in an outbreak to control the disease, not, other than in summary, on the policies that lie behind the operations that are being delivered.
Warmwell comment: Unfortunately, the "generic plan" is just as verbose, muddling and hard to follow as any previous Contingency Plan - in fact more so since it is trying to suggest that FMD policy is the same fundamentally as that for bird flu, Newcastle Disease and CSF. The Plan is too long and the sections very hard to follow. SAC is recommending clarity of language and logical, clear and simple layout explaining objectives and strategy and risk for FMD Again, DEFRA's answer does not get to grips with the point of the recommendation.
Separately, as part of the Veterinary Surveillance Strategy, disease control strategies will be published on the Defra website that will include explanations of the objectives and the strategy for dealing with outbreaks of disease.
Warmwell comment: But "accessible to all" implies the inclusion of farmers who have no time to wade through difficult text and who may well not have access to the internet. They are the front line in disease control and unless they are properly in the loop and not merely ordered about, they will have no incentive to cooperate - in fact, very much the reverse after last time. DEFRA simply cannot seem to grasp this dangerous fact.
Recommendation 16: Defra should take proactive steps to ensure the engagement of farmers, vets and the public with the Plan. Uncertainties influencing the Plan should be identified and made public.
Again, recommendation 16 is saying again that the understanding of people not used to jargon and long paragraphs is vital. Understanding needs to be checked - and where there are gaps in understanding these need to be rewritten properly. DEFRA responds with:
We agree with the importance of ensuring the engagement of farmers, vets and the public in understanding the purpose and method of disease control. We are seeking to do this through the engagement of the Divisional Veterinary Managers with their Local Veterinary Inspectors and with other bodies at a local and regional level. Using representative bodies such as the National Farmers Union and British Veterinary Association provides an easy and usually effective way of contacting a wide range of farming and other interests and gathering their views and comments, but we are also exploring other avenues including the Rural Affairs Forums. One of our most important concerns has always been to set out the range of policies that would be implemented, but always to make clear the factors that constrain the development of decisions until an actual outbreak.
Warmwell comment: DEFRA appears to miss the point of the recommendation which is again about the quality of communication with grass roots farmers and vets by DEFRA itself. The "engagement" of farmers is also implying something in the nature of the building of bridges since trust in DEFRA is at an all time low. DEFRA's response is again a vague suggestion that the DVMs, the BVA and the NFU can do this for them - but has it been done? When will it be done? Will understanding of the plans be checked before or after the next outbreak?
Recommendation 17: Defra should produce clear explanatory notes for the public on what the policy would be in the event of another outbreak and what it would mean for them in terms of access to rural areas.
Recommendation 17 reinforces the previous point but this time as far as ordinary members of the public are concerned. DEFRA says:
In the period between outbreaks it is difficult to set out precisely what an outbreak would mean in terms of access to rural areas: this will depend on the nature of the virus. The statement in the Contingency Plan that the aim is to keep the countryside open and that footpaths would not be closed, except in the protection zone, is probably as far as it is possible to go at this time. We will however consider whether further advice for the public should be prepared alongside the advice currently provided to farmers and vets on foot and mouth disease.
Warmwell comment: This is just not adequate. DEFRA's reluctance to spell out what will happen in the event of another outbreak is because it has no clear idea itself - as has been shown in stakeholders meetings when questions about what will actually happen have been asked and not answered. Different scenarios have not been mapped out - perhaps because DEFRA seems convinced that another outbreak on the scale of 2001 could not happen. It could.
Recommendation 18: The sub group should meet again to consider what scenarios should be modelled and how best to take this work forward.
Recommendation 18 comes back yet again to the question of different scenarios in suggesting that there is much more work for the sub group to do. DEFRA appears to reject this:
This work is being picked up by the Modelling Consortium, which has been set up to engage independent academic modellers with those in Defra who would be using the models. The aim is to ensure that models are developed that meet the needs of policy makers and are soundly based in the policy and operational issues.
Warmwell comment: It is hard to follow this. What actually is meant by "to engage independent academic modellers with those in Defra who would be using the models"? Who are they? What is implied by "meet the needs of policy makers and are soundly based in the policy and operational issues" Where is the "permanently operational Expert Group" in all this?
Recommendation 19: Members of the sub group should visit the Institute of Animal Health (Pirbright) to follow up on some of the issues raised.
The sub group visited the Institute for Animal Health and has followed up on some of these issues.
Warmwell comment: Which issues, when, and how were they "followed up"?
Recommendation 20: The operations of the SAC during an outbreak, including their interaction with policy colleagues and the modelling consortium require formalising.
Recommendation 20 shows that SAC needs a formal statement of how the modellers, DEFRA and SAC itself will operate in the event of an outbreak. It may be referring also to the question of an Expert Group as required by the EU Directive to be permanently operational, independent and to be balanced in its areas of relevant expertise.
DEFRA responds with:
All the structures for the operation of the SAC, the Animal Disease Policy Group and senior management within Defra are currently being reviewed and will be set out in the revised Contingency Plan to be laid before Parliament in July 2005. They will be tested in future exercises and revised accordingly.
Warmwell comment: Again, "currently being reviewed" is not an adequate response. If SAC can come up with such good recommendations then how they will mesh with the policy makers and the modellers really does need spelling out long before an emergency arises.