EU FMD Draft Directive can be viewed here in a new window

 

Comment on Draft Directive

By Alan Beat of Smallholders Online, an international forum for small-scale farmers

 

Extracts from Draft shown below in bold type, with comment in blue text

 

5.3  It must also be possible to apply a preventive stamping out programme to reduce the number of susceptible animals in the vicinity of an outbreak

 

Modern rapid diagnostics (such as penside PCR tests) have removed all need for pre-emptive slaughter, a relic of the nineteenth century that should now be consigned to history.  Rapid field testing in the vicinity of outbreaks, under virus plumes etc. will accurately identify any infected animals for targeted slaughter, while avoiding the counter-productive pre-emptive killing of uninfected stock.

That such tests have yet to be fully validated by the OIE, several years after their initial development, is an international disgrace that demands immediate political action.

There should be NO pre-emptive slaughter permitted under the new Directive.

 

 

5.5.      It is necessary to prevent any spread of the disease as soon as an outbreak occurs by carefully monitoring movements of animals and the use of products liable to be contaminated and, where appropriate in exceptional severe cases, particularly in densely populated livestock areas, by vaccination

 

 

There are well-established techniques for predicting the extent and scale of an outbreak as soon as initial data from “first day incidence” is available (see references below).  The decision to vaccinate or slaughter must be made at the very beginning of an outbreak if control is to be optimised.  The use of the phrase “in exceptional severe cases” is not acceptable in this Directive and has no place in a decision process based on scientific, economic, social and animal welfare criteria.

 

 

5.12 Such contingency plans, when reviewed in the light of this Directive, must however include provisions on the use of emergency vaccination

 

 

There is no such provision within the UK contingency plans currently published.

 

Crucially, the Draft Directive makes no mention of consideration being given to the wider economic impact of control measures.  This is a glaring omission in the light of the 2001 experience, as detailed within the report of the Temporary Committee.  Economic assessment should be central to the decision-making process; it is counter-productive to eliminate disease by using the most expensive control policy available, as happened in the UK (#20 billion overall cost to preserve #600 million annual exports).  The EU meets a significant proportion of disease control costs incurred by member states, and has a duty to minimise and control those costs.

 

 

Article 8

Preventive eradication programme

The competent authority may, where epidemiological information or other evidence indicates, implement a preventive eradication programme, including preventive depopulation of holdings of animals of susceptible species likely to be contaminated and, if considered necessary, of epidemiologically linked production units or adjoining holdings.

In that event, the taking of samples and clinical examinations of animals of susceptible species shall be carried out in accordance with Annex III.

 

Comments to paragraph 5.3 apply – preventative slaughter is not necessary, desirable, economic or efficient and should not be permitted under any circumstances by the Directive.

Article 35

Additional measures applied by Member States in the protection zone

In addition to the measures applicable in the protection zone in accordance with this Directive, Member States may take additional national measures which are deemed necessary and proportionate to contain the foot-and-mouth disease virus taking into account the particular epidemiological, animal husbandry, commercial and social conditions prevailing in the affected area.

 

 

There is no point in issuing such a wide-ranging and detailed Directive, when this Article permits any additional measures to be taken at will.  For example, it can be abused to enforce massive pre-emptive slaughter without scientific or economic justification, precisely as happened in the UK during 2001.  It is worth repeating that since the EU meets a large part of the disease control costs incurred by member states, it has a clear duty to minimise and control those costs.

 

This Article has no place in the Directive.  

 

Article 78

Expert Group

1.      Member States shall create a permanently operational expert group to maintain expertise in order to assist the competent authority in ensuring preparedness against an outbreak of foot-and-mouth disease.

 

The so-called “Science Group” established in the UK to advise on the 2001 epidemic was incorrectly constituted (according to the UK government’s own guidelines) with a considerable majority of mathematical modellers overshadowing a small minority of veterinary scientists with any expertise in FMD, and no virologists at all; this was sharply criticised in the report of the subsequent “Lessons Learned” official inquiry.

Article 78 should therefore be prescriptive, and specify an appropriate range and balance of scientific disciplines to be represented within the expert group of each Member State.

 

ANNEX X

Criteria for the decision to apply protective vaccination
and guidelines for the emergency vaccination programmes

1.          Criteria for the Decision to introduce emergency vaccination

              Taking into account the additional criteria in point 2, emergency vaccination shall be introduced, if for more than two consecutive days:

(a) infected herds on holdings referred to in Article 10 cannot be stamped out within 24 hours after the confirmation of the disease, and

(b)   the pre-emptive killing of animals likely to be infected or contaminated cannot be safely carried out within less than 48 hours.

 

These criteria are a recipe for disaster in the event of a major epidemic occurring, almost guaranteeing a re-run of the UK crisis during 2001.  In addition to comment made above on the lack of all need for pre-emptive killing, there are three main points here.

First, there is no scientific basis whatever on which to base a 48-hour pre-emptive slaughter target.  This notional target, introduced for the first time during the UK epidemic of 2001 was never intended to be more than an easily understood objective in a crisis situation.  However, the epidemic was already in decline before such targets began to be implemented; while no independent epidemiological analysis of field data has yet clarified the impact, if any, of that policy.  It is NOT acceptable for the Directive to base the crucial decision to introduce emergency vaccination upon such ad-hoc criteria THAT HAVE NOT BEEN VALIDATED.

Second, if the decision to vaccinate were left until this advanced stage of an epidemic, it would already be far, far too late!  The decision should instead be based upon the scientifically established criteria of first-day incidence data; and if vaccination is then chosen as the most effective policy, it MUST be deployed as early in the outbreak as possible.

Third, an economic assessment for alternative control strategies must be central to the decision process; whereas these Draft criteria are based solely upon the logistical capacity for mass slaughter, and nothing else.

   

 

2.          Additional criteria for the decision to apply protective vaccination

Criteria

Decision

 

For vaccination

Against vaccination

Population density of
susceptible animals

High

Low

Clinically affected species

Predominantly pigs

Predominantly ruminants

Movement of potentially infected animals or products out of the protection zone

Evidence

No evidence

Predicted airborne spread of virus from infected holdings

High

Low or absent

Suitable vaccine

Available

Not available

Origin of outbreaks (traceability)

Unknown

Known

Incidence slope of outbreaks

Rising rapidly

Shallow or slow rise

Distribution of outbreaks

Widespread

Restricted

Public reaction to total stamping out policy

Strong

Weak

Acceptance of regionalisation after vaccination

Yes

No

 

Clinically affected species –

 

Whilst appreciating that pigs may pose a higher risk of airborne spread, this is just one factor among many, and was shown to play a relatively minor role during 2001 – certainly of little consequence compared to the large-scale movement of sheep, for example; so this criteria has no place in the Directive.

 

Incidence slope of outbreaks –

 

This can only be correctly interpreted by veterinary scientists, otherwise false conclusions can be drawn; as happened in the UK during March 2001, when the epidemic was wrongly perceived by politicians and modellers to be “out of control” through rising case numbers, when in fact this was due to the continuing disclosure of existing but hidden disease in sheep.

 

Public reaction to total stamping out policy –

 

A central lesson to be learned from the 2001 epidemic was that in future, the serious and inevitable social and psychological impact of large-scale slaughter should be avoided.  Such a criteria argues in favour of vaccination.

And missing from the table of criteria altogether is –

Impact of control policy on the wider economy; which argues in favour of vaccination

 

References:

“Predicting the level of herd infection for outbreaks of FMD in vaccinated herds” by AM Hutber, RP Kitching and DA Conway.  Epidemiology and Infection 1999, 122, 539-544

“The use of vector transition in the modelling of intraherd FMD” by AM Hutber and RP Kitching.  Environmental and Ecological Statistics 1996, 3, 245-255

“Control of FMD through vaccination and the isolation of infected animals” by AM Hutber, RP Kitching and DA Conway.   Tropical Animal Health and Production, 1998, 30, 217-227

 

ENDS