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Defra’s Consultation on the Transposition of the FMD Directive

 

Comments from Mary Marshall and Paul Roger, Animal Health Resources Ltd

 

with addendum indicating the support of the BVCS

 

1 September 2005

 

 

The proposed changes to the legislation include three different, but related, pieces of legislation. 

 

We ask for an extension to the deadline for responses, since (a) the consultation process has not been sufficiently open and transparent; (b) the period from announcement to deadline only covers the summer break; and (c) for one of these pieces, the “minor technical amendment” (Defra’s description) to the Animal Health Act (Amendment) Regulations 2005, was only released by email to stakeholders on 25 August, when the email also informed us that the consultation for this part alone will be extended from the original deadline of 1 September to 15 September. The announcement of an online link to the draft Animal Health Act (Amendment) Regulations 2005 was only given on 30 August, just before a bank holiday, allowing us only a very short time to review this important legislation, and only two days to consider its relevance to the other pieces of legislation.

 

Inadequate consultation process.  We therefore argue that both insufficient time and insufficient dissemination of information has been provided for this to be considered a true consultation, which is a requirement under the EU FMD Directive.

 

Openness and transparency.  As a member of at least one of Defra’s FMD Stakeholders groups, I attended a meeting on 29 June to discuss the transposition of the FMD Directive. The letter of invitation and background documents are available online on Defra’s website. However, Defra has not yet provided any minutes or notes from this meeting, so that those who were not present can be informed about this discussion, including the questions and concerns raised by other stakeholders around the table.

 

One of the requests asked at this meeting was for Defra to provide a list of their various consultation meetings. So far, we have had no response. This is of concern because there appears to be many separate, uncoordinated consultation meetings, amongst groups and individuals who are therefore unaware of the concerns of other groups and individuals, even amongst those invited to consultation meetings. The publication by Defra on their website of minutes or notes from these meetings would help to correct this shortcoming.

 

Defra appears to place most weight on consultations with “key stakeholders” (Defra’s terminology). While this sector is certainly important, there is some danger in excluding from the consultation process other sectors, including small and family farms, that play a role in disease control but have no coordinated, funded means of communicating with government.  

 

Our comments are directed mainly at the proposed changes to the Animal Health Act, but all of the proposals are inter-related, and it does not make sense to have separate deadlines.

 

General – and fundamental - comments

 

None of the new proposals contain anything which would increase our capability to protect from and respond to the introduction of FMD or any serious animal disease.

 

There is still no recognition of the role, or acceptance of, new diagnostic tools which can provide rapid identification of disease on site. 

 

There is still no mention of enhanced surveillance at entry points to identify and test both legal and illegal imports of live animals and meat products.

 

Shared responsibilities.  While much is asked of livestock keepers to maintain and enhance on-farm biosecurity according to current risks, government is not accompanying this with a means to ensure that this happens: (a) by implementing an automatic communication and alert notification system to livestock keepers and their local veterinary practitioners; and (b) by providing funding or assistance to producers, mostly, if not entirely, the non-intensive producers, who often have no regular veterinary support or streams of funding and may not belong to any “key” livestock organisations. In response to a heightened alert, and especially in the event of an emergency, measures may need to be taken which are not economically sustainable, especially to small scale holdings, including for example installing quarantine or separation facilities. This is best exemplified by the current heightened alert for avian influenza (which is also relevant to FMD since we now have a Generic Contingency Plan), where separation (not necessarily by indoor housing) and protection of feed and water supplies, of poultry from both wild birds and domestic waterfowl is accepted as the most effective preventive measure. Similar separation of livestock with regard to FMD should also be considered as a preventive measure.

 

Surveillance.  It is not enough to rely on clinical inspection. This was demonstrated during the 2001 FMD epidemic, especially with regard to sheep, and is now evident – and we fear, not sufficiently appreciated - with regard to the current threat of avian influenza, which can be transmitted by migratory and (legally and illegally) imported birds which are sub-clinically infected. A programme of active surveillance, using diagnostic tools such as RRT-PCR (real-time RT-PCR) which can identify infection in less than 3 hours (personal communications and publications, Roger Breeze for FMD and David Suarez for avian influenza), should be written into the contingency plans, practiced in emergency exercises and implemented.

 

The current government approach to cost sharing with regard to disease control and other farming regulations does not encourage local production of food. We submit that this lack of national protection of a secure, local food supply is unwise especially considering the accepted disruption to trade that would be caused by a serious disease emergency, whether naturally or intentionally introduced. Recent articles on the consequences of avian influenza spreading to Europe should wake us all up to this possibility, and encourage us to fundamentally change our approach to food production, and to take steps to support local producers and local distribution networks.

 

From http://www.defra.gov.uk/footandmouth/disease/methods/vaccinationqanda.htm

 

“Why can’t the Government decide now how it would control a future FMD outbreak?
As circumstances can vary widely, it is not possible to prescribe a detailed response in advance of an outbreak. The decision to adopt a particular control strategy will depend on a wide range of factors as indicated in the “Decision Tree”, many of which cannot be determined until we have knowledge of the nature and extent of the outbreak. Veterinary and scientific advice and judgement remain vital in determining disease control strategy.”

 

We appreciate that a response to an outbreak is complicated, but we need confidence that (a) the best tools will be used to identify and confirm the disease, and to inform the control measures (including movement restrictions and vaccination strategies) that will be taken and (b) the best strategy will be implemented, based on the advise of the permanently operational, balanced, Expert Group, as specified in the EU FMD Directive. The words “permanently operational” and “balanced” are critical, so that we can ALL have confidence in the disease control measures.

 

 

Specific concerns

 

Infected Premises: How will Defra decide which premises are infected - by proximity? proof by PCR? culture at Pirbright? If we were overwhelmed logistically in 2001, what assurance do we have that we wouldn’t be again, especially since the current contingency plan does not include the use of any new diagnostic or communication tools?

 

“Dangerous contact”: How is a “dangerous contact” defined?

 

Decision to slaughter / decision to vaccinate: What animals would be slaughtered / vaccinated? On what basis would these decisions be taken? We would prefer that rather than have a blanket policy (based sometimes on arbitrary considerations such as the number of breeding boars on a holding), the decision should be taken on a case by case basis, in consultation with local veterinary expertise, the on-farm management system and the species involved. A special registration system should be considered, whereby livestock keepers can register their animals and in return receive alerts and information relevant to their circumstances, and the government can have immediate access, in times of emergency, to the geographical location of livestock, by species and management system.

 

We believe that disease control should be a cooperative effort between government and the livestock sector, and that major efforts are needed to enhance communication and increase trust. The cooperation of the livestock sector is essential to the rapid identification of disease. See our invited paper for the EUFMD Research Group Open Session in 2004 : “Policy and science of FMD control: the stakeholders’ contribution to decision making.  A call for Integrated Animal Disease Management”:

http://www.fao.org/ag/againfo/commissions/en/eufmd/crete.html (paper no 78):

http://www.fao.org/ag/againfo/commissions/docs/greece04/App78.pdf

 

 

Flexibility, and hence “discretion” rather than “duty” in decision making.  Both the variable risks from differing management systems and the variable susceptibility of species, and hence the response to a disease situation, should be recognised in legislation.

 

 

Camelids. The British Camelid Association seeks the agreement of Defra to recognise that, due to their physiological characteristics, camelids are not naturally susceptible to FMD and do not contribute to onward spread. This has been recognised in the United States by the USDA’s Decision Memorandum on FMD and Camelids, and by Defra in 2001/2 in the relaxation of movement restrictions for camelids, based on evidence submitted to both the USDA and Defra. Further evidence has also recently been / will be presented to the scientific community by Ulrich Wernery, Scientific Director of the Central Veterinary Research Laboratory in Dubai, United Arab Emirates, in two publications:

 

1. “FMD and camelids: International relevance of current research”, available on-line at: http://www.fao.org/ag/againfo/commissions/docs/greece04/App40.pdf

 

Camelids belong to the suborder Tylopoda; they are not ruminants. Camelids possess a low flow susceptibility to FMD, and do not appear to be long-term carriers of the FMDV. These are the main two reasons to remove them from the OIE chapter as possessing the same degree of susceptibility as cattle, sheep and goats.”

 

2. In a soon-to-be-published issue of the Veterinary Record, Dr Wernery reports an experiment, part funded by Defra, that indicates that dromedaries are less susceptible (than heifers) or non susceptible to FMDV.

 

In standard texts on taxonomy, the separate development of camelids is clearly outlined:

“… the Camels have been a separate stock since the Eocene and are so distinct from the remainder that it is convenient to keep them in a separate sub-order Tylopoda….. The Tylopoda show some features retained from the Eocene condition, some developments parallel to those found in the Ruminantia, and various special features of their own …The ruminating mechanism is different from that of the Pecora and simpler….” {J.Z. Young, The Life of the Vertebrates, Oxford University Press, 1962, 2nd edition, p751-2).

 

We are disappointed that Defra continues to classify camelids – although, the wording in this proposed legislation only refers to alpacas and llamas, not to camelids - as a species of equal susceptibility to cattle, sheep, goats and pigs. We hope that you will reconsider your position with regard to camelids and review the evidence.  We believe, in the interests not only of disease control, but also of animal welfare, that this is not the correct way to proceed since there is no evidence to suggest that camelids actively propagate FMD virus even when naturally cohabiting with other infected animals.  In previous submissions, we quoted experts such as Paul Kitching, who attest that camelids are not carriers of FMDv.

 

We ask Defra to recognise camelids as a separate group, belonging to the suborder Tylopoda, not ruminants: this includes Old World Camelids (Bactrian and Dromedary Camels) and New World Camelids (alpacas, llamas, guanacos and vicunas).

 

We would, with reluctance, agree to the slaughter of camelids, but only in the case of evidence of infection based on virus testing, not on clinical inspection. We would prefer any enforcement of slaughter to be accompanied by the owners’ agreement and a veterinary assessment of the risk of onward transmission.

 

 

In summary

 

We find it difficult to understand the need to change the wording from a “discretion” to slaughter to a “duty” to slaughter.  Such a change implies that the more draconian measures must be the preferred option, rather than allowing the permanently operational, balanced Expert Group to advise on the appropriate response in differing circumstances, which, we believe, is more compatible with the spirit of the FMD Directive.

 

These proposed changes have been rapidly and quietly instituted and we feel that further open discussion is warranted, given the continuing expansion of our knowledge and diagnostic capabilities, in these areas. Before making such changes, we urge Defra to update the Generic Contingency Plan to take account of advances in diagnostic and communications capabilities.

 

We believe that the consultation process has been inadequate, and that if the proposals are changed to take account of the points raised, we would all be better prepared for the next animal disease threat.

 

 

Mary Marshall and Paul Roger

 

Animal Health Resources Ltd.

 

 

 

Addendum: 

 

This submission has the full support of the British Veterinary Camelid Society.