1. There are very real fears that Defra will implement
killing on a major scale in the event of another outbreak of FMD, and will be
able to do this in spite of the EU Draft Directive as it stands:
i) in their proposed Contingency Plan, there is a detailed slaughter
protocol, with no correspondingly detailed protocol for
ii) The Contingency Plan (Version 2.5, Decision Tree and Slaughter
Protocol) states that there will be "pre-emptive or firebreak culling of animals
not on infected premises, not dangerous contacts or not necessarily exposed to
disease, in order to prevent the wider spread of the disease out with the
area". This is not the same as the "preventive killing" mentioned in the
Directive, where the animals are thought to have been contaminated by FMD. (The
NFMG refer to this area of concern in their submisssion to DEFRA).
iii) The Draft Directive allows for member states to take "more stringent
action in the field covered by this Directive". The Directive sets out
"the minimum control measures to be applied"
iv) I believe there is still an old guard within Defra, and also among the
Stakeholders e.g.Dick Sibley (BCVA and very influential), and NFU, who have been
strongly opposed to vaccination.
v) The government is still advised by Prof David King, and also, "on
hand", is the Prof Anderson team who advocated the widespread killing in the
vi) There has not been the rigorous scientific scrutiny of the
epidemiological data which is necessary to expose the full scale of killing of
healthy animals. (See copied below the Appendix 1 of National Foot and
Mouth Group submission to Defra re Contingency Plan. I also have further
detailed info on the true scale of unnecesssary killing in Wigtownshire,
obtained through a PQ additional to PQ 2164).
2. The Expert Group referred to in the Directive must actually be
an expert group in FMD, and in all aspects of the disease, including mechanism
of disease spread, and vaccination.
I feel that the Directive does not detail this carefully enough, although
other parts of the Directive require specifically trained veterinarians.
Individual countries (as shown so disastrously by the UK) cannot be relied
upon to use the relevant experts, as the following illustrate:
i) Dr Paul Kitching, the Director (as he was at the time) of
Exotic Diseases (FMD) Research and Development at the IAH, Pirbright, was
ignored, and had to go on television to try to expose the flawed models of Prof
Anderson. He was, I believe, the leading UK veterinary scientist on the
mechanics of FMD spread.
ii) There were no FMD vaccination experts on the Science Group.
iii) The Science Group was made up of primarily bio mathematical modellers,
not veterinay experts.
iv) The way in which the Science Group was put together was, I think, both
questionable and highly unscientific (See Prof. Roy Anderson's evidence to EFRA
Select Committee) .
3. There is a very real fear that a government obsessed
with image and spin will continue to refuse to acknowledge
past mistakes, and thereby carry on with the same "successful policies" for FMD
eradication (namely the contiguous and wider culling).
4. As the Directive stands, there is still the possiblity
for political interference with the FMD control polices - these
policies should be based on sound veterinary expertise, and proper
scientific risk assessment.
There is no doubt in my mind that in the 2001 FMD epidemic, political
factors overrode good science. In the report "FMD, Risk and Europe" by
John Ryan, veterinary consultant on behalf of EUFMD, FAO, the necessity for
clear scientific guidelines in a disease control strategy is
"The uncertainty around such difficult decisions (e.g whether,
when, where to vaccinate etc) leaves gaps for political exploitation and sub
optimal decision-making. The only effective defence against such
politicking is sound science, hard information, good communication and good
emergency preparation where these isssures have already been discussed with key
5. The need for accurate diagnosis of every case before killing is
essential for epidemiological, social/human, economic, and animal welfare
purposes, as well as to prevent fraud. The technology is
Clinical diagnosis on its own cannot be relied upon, as shown by the
disastrously high number of misdiagnoses in the 2001 epidemic, resulting in the
unnecessary killing not only on the IP itself but also on the related
contiguous premises, and in Cumbria and Dumfries and Galloway on the 3 km
and firebreak premises as well. (PQ 2164, and NFMG App.1)
6. Taking the initiative regarding
I understand Mr Kreissl-Dorfler suggests that only the adjoining state
(besides the Commission and the affected Member State) can take the initiative
over implementing/requesting implementation of a vaccination strategy. I
disagree with this for several reasons e.g. what state is adjoining to the
UK? Does that mean that a member state with considerable veterinary
expertise on FMD vaccination and with genuine concerns cannot ask that the UK
implement a vaccination policy, simply because it is not adjoining?
I would be extremely grateful if you were able to raise my concerns in the
Once again thank you for all your efforts on the Temporary Committee. They
have been greatly appreciated.