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THE NATIONAL FOOT & MOUTH GROUP

An affiliation of organisations affected by 2001 UK epidemic

 

Co-ordinating Office:              3 The Common, Siddington, Cirencester, Glos  GL7 6EY

Tel: 01285 644319 / 01285 656812

 

 

 

Mr J Cavanagh

Director, Value for Money Studies

Environment, Food and Rural Affairs

Room C319, National Audit Office
157-197 Buckingham Palace Road
London, SW1W 9SP

 

                                                                                                                                        17 March 2005

 

 

Dear Mr Cavanagh

 

UK FMD EPIDEMIC 2001 – COSTS OF PRE-EMPTIVE SLAUGHTER &  IMPLICATIONS FOR FUTURE CONTROL

 

Thank you for our meeting of the 3 March with yourself and Tom Wallace and for the opportunity to discuss the above and related matters.

 

We would like to take this opportunity to put in writing and on record our concerns, to the NAO, as we consider that it is important that these be noted.  Also we wish to express and record our regret that the NAO has declined to investigate further the issues we have raised.

 

We would like to submit the following:

 

 

1          Why an evaluation of the 2001 FMD pre-emptive slaughter is needed

 

The NAO has now published the report of its second investigation into the expenditure incurred during the 2001 Foot and Mouth Disease (FMD) epidemic.  Whilst the NAO reports have addressed many issues, there is one key factor of the 2001 epidemic which has not yet been determined.  This is the costs incurred as a result of pre-emptive slaughter.  Pre-emptive slaughter categories included ‘firebreak’,  ‘3km’,  ‘contiguous’ and ‘slaughter on suspicion’ culls.

 

The use of this extensive pre-emptive slaughter in 2001 was a novel, untested and un-validated approach.  Never before has the control of FMD utilised such a policy, either nationally or internationally.

 

Several scientific papers, including those commissioned by Defra, have now evaluated the role of pre-emptive slaughter in the 2001 epidemic and questioned the scientific validity and efficacy of this approach in controlling FMD.      See Appendix 1

 

We particularly draw your attention to the two recent papers published in the Veterinary Record, Volume 156, Number 8 & 9, of the 19 and 26 Feb 2005 respectively.  It is clear from the results of the nationwide,  sero-surveillance programme that the employment of pre-emptive slaughter did not contribute to the control of the disease.  See Vet Record, Vol 158, No 9, Feb 26 Page 277. 

 

In the light of these scientific papers we believe it is timely for the costs of pre-emptive slaughter to be now quantified and assessed by the NAO, in order to determine whether this method of control is cost effective.

 

It should be noted that these papers were not available at the time of either of the two previous NAO investigations and reports into the 2001 UK FMD epidemic.  Also they were not available for consideration by either the UK Lessons Leaned FMD Inquiry or the EU Parliament FMD Inquiry.

 

 

2          Other related factors which also need to be addressed

 

During 2001 this organisation became very concerned at the very low incidence of disease that was actually confirmed when samples were laboratory tested.  Investigations during the epidemic, and subsequently, have demonstrated that in many situations the confirmation of disease was considerably lower than had been portrayed, even in so-called ‘Infected Premises’.   Many contiguous culls arose from premises which were ‘clinically diagnosed’ as ‘Infected’  but which later proved negative when laboratory tested.   Also many contiguous culls took place long after the incubation period, and when animals had not developed FMD.     See Appendix 2

 

In all these instances the use of pre-emptive slaughter greatly increased the number of animals slaughtered, and subsequently the amount that then needed to be paid in compensation or compulsory purchase, and all the attendant costs of slaughter, transportation and disposal, and in some cases cleansing and disinfection.

 

 

3          The cost implications of pre-emptive slaughter in 2001

 

It is our contention that nearly 80% of the costs incurred in the control procedures adopted in 2001 have arisen as a result of pre-emptive slaughter.

 

As stated earlier this was a novel, untested and unvalidated approach and we therefore submit that it is crucial to determine the full extent of the costs that these experimental control methods incurred.

 

The NAO is fully aware of the total costs incurred in the 2001 FMD epidemic, both fiscally and to the wider economy.  Also, as the EU has now decided not to fully recompense the UK for expenditure in 2001, it appears that a further tax burden of £600 million will now have to be met from UK tax revenue.

 

While we accept that the EU has withheld payments arising from such issues as over-valuation of stock and inflated contractor costs, the sheer number of animals which required compensation and the costs of their disposal, etc are a consequence of the adoption of a pre-emptive slaughter policy.  Given the tax burden which then arose from the slaughter, compensation, etc of such high numbers of animals this then directs that the cost of this method of control deserves scrutiny and evaluation.

 

4            Defra’s Cost Benefit Analysis

 

During the course of our discussion it was suggested by yourself and Tom Wallace that the Cost Benefit Analysis, which is currently being undertaken by Risk Solutions on behalf of Defra, would suffice to evaluate the various disease control strategies and also address the role and effectiveness of pre-emptive slaughter.

 

Our concern here is that from the presentation that we have had from Risk Solutions, as FMD Stakeholders, and in the correspondence we have seen, it appears that the study is not evaluating pre-emptive slaughter as a discrete and separately costed entity.  It appears the study has not been designed to assess the role, costs and effectiveness of pre-emptive slaughter per se, but only in combination with other measures.

 

Furthermore, we submit that we do not need to model hypothetical situations to assess the efficacy, effectiveness and costs arising from the adoption of pre-emptive slaughter because we have the reality as demonstrated in 2001 – which are actual, not hypothetical, situations and financial implications.  We have the real data.

 

 

5          The Public Accounts Committee Hearing – 23 February 2005

 

It was also suggested by yourselves that the responses given by Defra to the PAC on the 23 February, when it considered the 2nd NAO FMD report, indicated that Defra would not use pre-emptive slaughter again in the way it was employed in 2001.

 

We have studied the responses of Sir Brian Bender in this regard: 

 

The Government does not rule out a contiguous cull in the future but it would not be the preferred approach.  The EU Directive requires slaughter on infected premises and dangerous contacts and then the next stage would be whether or not vaccination can be part of the armoury.”

 

Firstly, it is important to point out that both ‘Contiguous’ and ‘3km’ culling were classified as Dangerous Contact culls during 2001.  However it appears that Sir Brian Bender is not aware of this. 

 

Also ‘Contiguous culling’ was not initially the preferred approach in 2001 – it was only adopted on March 26 2001, when advocated by the co-opted modelling team of Imperial College and advanced by the Government’s Chief Scientific Adviser.

 

Our concern here is that having taken part in the evolution of Defra’s FMD Contingency Plan (Version 4.0 being the current version), we note that there is still extensive provision within Defra’s Contingency Plan for contiguous culling and other pre-emptive culling.

 

See Annex C of Defra FMD Contingency Plan: Decision Tree Disease Control Strategies Against FMD Page 94.

 

Here the Contingency Plan states that culling of Infected Premises and Dangerous Contacts, which includes contiguous culls, see Para 3 – first Bullet point: - is the first in a range of options:

 

We append Annex C – Page 94.

 

As we raised at the meeting the amended Animal Health Act Section 14B has now also extended the Government’s powers for slaughter to include ‘Firebreak’ culls’ – which is also described as pre-emptive slaughter.

 

See Defra FMD Contingency Plan – Annex D – Page 110, Para 1 & 2 – Appended.

 

It may be helpful to read all of Annex ‘D’. 

 

While we accept and welcome the various provisos and safeguards that are to be adopted in pursuing ‘firebreak’ culls these do not apply to the loosely defined Dangerous Contacts.

 

Both these points we have raised with Defra.

 

Thus our concern is that contiguous and 3km culling could well be included in future disease control strategies under the auspices of Dangerous Contact – even though the validity and efficacy of this approach has not been demonstrated.

 

 

6          What evaluation is needed?

 

We submit that the following investigations are needed:  These would evaluate the control methods which have been previously applied and compare them with those adopted in 2001.  The investigations would also identify the additional costs that arose from the use of the novel strategies applied in 2001, which we have detailed above

 

6.1       A comparison with the FMD outbreak of 67/68 to determine the number of Infected Premises and their ratio to the number of Dangerous Contacts.

 

            Also to evaluate the ratio of costs of each Infected Premise and Dangerous Contact premises that were slaughtered.

 

6.2       To determine the efficacy and cost effectiveness of the pre-emptive slaughter in 2001.

 

1            Determination of category for each affected premise:

 

Infected, Dangerous Contact , Contiguous Cull, 3 km cull, voluntary Firebreak cull or Slaughter on Suspicion.

 

2          Identify and apportion the costs of each premise to each of the 6 categories. Such costs will include compensation/compulsory purchase paid, cleansing and dis-infection where appropriate, and a pro-rata evaluation for slaughter, transportation, disposal and ensuing on costs.  The costs should also include for the on-going costs generated by the long term maintenance of burial sites.

 

3          It should also be ascertained how many premises in each of the 6 categories were subject to laboratory testing and what results were obtained.

 

 

 

 

We therefore ask the Public Accounts Committee to ensure that the crucial and valid investigation of the costs of pre-emptive slaughter in 2001 is now undertaken in order to determine a proper cost/benefit analysis of this approach.  Such inquiry should also have regard to the attendant costs which arose from the transportation, disposal and ongoing site maintenance costs which these extensive culls necessitated.

 

We submit that until this exercise is carried out it will not be possible to ascertain the cost effectiveness of pre-emptive culling as a means of FMD control, and thus, what role it should play in the Government’s future FMD policies.

 

In furtherance of the above we very much welcome the opportunity to meet you on Tuesday, as Chairman of the Public Accounts Select Committee, to present further evidence to support our requests and to draw your attention to information which was not available for consideration by the earlier UK inquiries into FMD.  We much appreciate being able to submit this prior to the Public Accounts Select Committee’s consideration of the second NAO report, which is due to take place on the 23 February 2005.

 

Yours sincerely

 

 

 

 

Janet Bayley

Co-ordinator NFMG

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

   

                                                                                                            APPENDIX 1

 

 

 

SCIENTIFIC PAPERS WHICH REVIEW THE ROLE OF FMD PRE-EMPTIVE SLAUGHTER IN UK EPIDEMIC OF 2001

 

 

Honhold, N., Taylor, N.M., Mansley, L.M., Paterson, A. D., 2004. Relationship of speed of slaughter on infected premises and intensity of culling on other premises to the rate of spread of the foot-and-mouth disease epidemic in Great Britain, 2001. Veterinary Record 155, 287-294.

 

 

Honhold, N., Taylor, N.M., Wingfield, A., Einshoi, P., Middlemiss, C., Eppink, L., Wroth, R., Mansley, L. M., 2004.  Evaluation of the application of veterinary judgement in the pre-emptive cull of contiguous premises during the epidemic of foot-and-mouth disease in Cumbria in 2001.   Veterinary Record 155, 349-355.

 

 

Kao, R.R., 2002. The role of mathematical modelling in the control of the 2001 FMD epidemic in the UK. Trends in Microbiology 10, 279-286.

 

 

Kitching, R. P., Hutber, A. M., Thrusfield, M. V. 2004., (2004). A review of foot-and-mouth disease with special consideration for the clinical and epidemiological factors relevant to predictive modelling of the disease. The Veterinary Journal - In press

 

 

Taylor, N. M., 2003 Review of the use of models in informing disease control policy development and adjustment. Report for Department of the Environment Food and Rural Affairs pp94.

 

 

Taylor, N. M, Honhold, N, Paterson, A. D., Mansley, L. M., 2004. Risk of foot-and-mouth disease associated with proximity in space and time to infected premises and the implications for control policy during the 2001 epidemic in Cumbria. Veterinary Record 154, 617-626.

 

Additional papers published since 17 Feb 2005

 

 

Thrusfield, M., Mansley, L., Dunlop, P., Taylor, J., Pawson, A., Stringer, L., 2005. The foot-and-mouth disease epidemic in Dumfries ad Galloway, 2001.  1: Characteristics and Control.  Veterinary Record 156, 229-252.

 

Thrusfield, M., Mansley, L., Dunlop, P., Pawson, A., Taylor, J., 2005.  The foot-and-mouth disease epidemic in Dumfries and Galloway, 2001.  2: Sero-surveillance, and efficiency and effectiveness of control procedures after the national ban on animal movements.   Veterinary Record 156, 269–278.

 

 

 

 

 

                                                                               APPENDIX 2

 

THE NATIONAL FOOT & MOUTH GROUP

An affiliation of organisations affected by 2001 UK epidemic

 

Co-ordinating Office:              3 The Common, Siddington, Cirencester, Glos  GL7 6EY

Tel: 01285 644319 / 01285 656812

 

 

 

 

LAB TEST RESULTS FOR FMD WHICH DEMONSTRATE VERY LOW NUMBER OF PREMISES WERE ACTUALLY INFECTED

 

 

Source of Data:  Parliamentary Question 2164 & DEFRA  Website

 

 

As of the last listing of the 20 February 2003, the total number of a AFFECTED PREMISES on the DEFRA website stood at  10,472

 

This is the total number of premises where animals were 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.

 

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 ½ 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.

 

 

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".

 

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 -  FEBRUARY 2005

 

 

 

 

 

MEETING WITH THE NAO

 

 

 

3 MARCH 2005

 

 

UK 2001 FMD EPIDEMIC – COSTS OF PRE-EMPTIVE SLAUGHTER & IMPLICATIONS

 

 

POINTS FOR CONSIDERATION

 

To assess the efficiency, effectiveness and economy of the novel pre-emptive slaughter utilised in 2001 and to determine its role in the control of future outbreaks of FMD.

 

 

1                    Introduction

 

2            Definitions

 

3          Brief history of examples in 2001which raised doubts as to the efficacy of pre-emptive slaughter – with reference to NFMG figures and experiences.

 

4            Concern expressed during 2001 by RCVS and other veterinary personnel, etc, as to the efficacy of pre-emptive slaughter.

 

5            Consideration of the models which advocated pre-emptive slaughter and comparison with recent and current papers which have evaluated the efficacy of this control method.

 

6          What evaluation is needed to assess the efficiency, effectiveness and economy of the novel pre-emptive slaughter adopted in 2001 – and to determine its role in future FMD outbreaks.