Notes from Anne Lambourn to MEPs about the Draft Directive on FMD

 
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     vaccination. 
 
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 first place.
 
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 emphasised: 
 
"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 stakehoholders."
 
 
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 available.
 
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 vaccination: 
 
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 meeting tomorrow. 
 
Once again thank you for all your efforts on the Temporary Committee. They have been greatly appreciated.