Extract from Draft Opinion with comment in red
2001 epidemic and lessons learnt
The foot-and-mouth disease (FMD) epidemic of 2001 was of exceptional severity, with over 2000 recorded outbreaks in the UK alone.
This is surely a misleading statement - but one that occurs in nearly all papers and reports read. Repetition does not, however, make it true. The exceptional severity was in the carrying out of the chosen policy to deal with the disease. Also, "recorded outbreaks" suggests that there were 2000 proved cases of FMD. This is not the case. In fact only 1153 cases were proved to be positive in the laboratory.
It devastated the UK (the policy adopted devastated the UK) where this strain of the virus first appeared and posed major problems for three adjacent Member States. The FVO annual report from 2001 describes it concisely. "The initial delay in identifying the first outbreak, and the high number of sheep movements around that time allowed the disease to spread widely before it was detected. This was exacerbated by insufficient control over livestock dealers and markets...The scale of the epidemic caused considerable problems in the implementation of the necessary control and eradication efforts, since the resources required could not immediately be mobilised."
Over 171 farms in this epidemic where the disease remained undetected for up to 6 months were classified as "clinically negative, laboratory positive" This means that by the time these were tested, all signs of the disease had gone. Healthy recovered animals, with immunity developed, were slaughtered because they had developed antibodies. This was for purely financial and trade reasons not veterinary ones.
Highly detailed records for all cattle were kept (since BSE) on computer but these could not be accessed because - unbelievably -of incompatible IT systems at DEFRA. This was duly noted by the Public Accounts Committee report. It is not right or just to suggest all would be well if only more rigid controls were put in place over markets and dealers
As they were, the sheer scale of the cull required
( "required" is the wrong word. The scale of the cull was not required; it was imposed as a result of the faulty modelling based on falsely assumed constant farm infectivity
From the Imperial College modelling team's paper: "The FMD Epidemic in Great Britain: Pattern of Spread and Impact of Interventions" by NM Ferguson, CA Donnelly and RM Anderson, Science Vol 292, 1155-1160, 11th May 2001:
"We assumed constant infectiousness from 3 days after infection until slaughter, for an average of eight infectious days." )
raised public misgivings about its extent, its environmental consequences, the human and animal distress in badly affected areas. This in turn led to legal challenges to the cull in some parts of the UK, and a passionate debate on the alternative of vaccination - either as a general long-term alternative to the EU's ten-year prohibition of prophylactic vaccination or for emergency ring vaccination of animals subsequently killed. The Netherlands employed the latter strategy, in extremis with the Commission's agreement.
(They did - but it really MUST be pointed out in any discussion of the Netherlands use of vaccination that the farmers has been assuming that vaccination was to live not, as was later imposed on them without their consent, supressive vaccination where the vaccinates were then slaughtered.)
The issues involved were extensively discussed immediately the epidemic subsided, at a public symposium in Brussels, by a number of national and local enquiries in the UK, and by the Temporary Committee on foot and mouth disease of the European Parliament. All reached broadly similar conclusions about prevention, but varied the approaches to cure. Those who object strongly that large concentrations of non-vaccinated livestock will always be at unacceptable risk of received infection will contest the Commission's determination to recover and maintain the OIE status "free of foot-and-mouth disease without vaccination". It remains very much the majority view of the Community institutions and the member states. Your draftsman shares it, with the proviso that emergency vaccination should be seen as a realistic option in containing future epidemics, rather than as a desperate last resort. The more effective the methods of diagnosis set out here become, the better the information will be for a targeted "vaccinate to live" strategy.
Draftsman's position on the Commission proposal
The Commission has produced a considered response to the proposal of the Temporary Committee which draws on the experience of the affected Member States; the UK, Ireland, France and the Netherlands, and on subsequent deliberations. Your draftsman generally welcomes the Commission proposal. It is not rigidly prescriptive, but Member States may take more stringent action beyond the necessary minima setting up Temporary Control Zones (TCZ) around suspect premises. Your draftsman believes that it must be made clear that the 72 hours movement ban in a TCZ (which could be the entire territory of a Member State) can and should be extended, if required, for effective testing. The Directive allows (Article 15) for the protection of animals in laboratories, zoos, wildlife parks and rare breeds centres by preventive vaccination. It should be clearly set out that the public interest is best served by the preservation of rare bloodlines and the retention of the animal gene pool.
The establishment of Protection Zones (3 km) and Surveillance Zones (10 km), and the special precautionary measures for meat and milk products derived from the latter are to be welcomed. The more effective they are, the greater the flexibility with which they can be used. Equally, a regionalised approach, based on epidemiological assessment of the restricted areas, will assist the best use of resources which are always likely to be overstretched in an emergency. Adjacent Member States' assent will be needed if border areas are declared "FMD free".
There remains the issue of what kind of emergency vaccination would be permitted in a Member state stricken with a fresh outbreak of foot-and-mouth disease. Suppressive vaccination in the Protection Zones would be introduced in densely populated areas of susceptible animals (especially pigs) if the disease cannot be stamped out by slaughter within 24 hours of confirmation, and by culling of animals at risk (What exactly is meant by "at risk" here? It is not clear.) within 48 hours.
(Why "suppressive vaccination"? There is no reason to slaughter vaccinated animals when subsequently infected animals can now be so easily detected.)
Member states will need to make a balanced judgement on the appropriate methods, including the use of "vaccination to live" in the Surveillance Zones. The draftsman believes that all stakeholders, producers, consumers and citizens alike will need to be fully informed and consulted about the further testing of vaccinated animals, and the entry and labelling of meat products derived from them into the food chain.
"..at no time did retailers lobby for or against the vaccination of animals as an alternative to slaughter"
Extract from article in the Western Morning News.
"William Moyes director-general of the British Retail Consortium (BRC) has revealed that he told the Prime Minister that he and other members who were consulted at the time were happy to let the Government decide.
Addressing the committee in Strasbourg, set up to examine the outbreak in Britain and it implications for Europe, he said his members would have had no objection to vaccination, as long as certain conditions were met.
"It is important to realise that at no time did retailers lobby for or against the vaccination of animals as an alternative to slaughter," Mr. Moyes told members of the committee..." " Mr. (Nick) Brown told the European committee: "We were only 24 hours away from vaccinating. However representations made to me from large retailers and in particular Cadburys stating they would not take products from vaccinates persuaded us not to vaccinate. Mr. Moyes was part of a delegation brought to address the committe by South West Conservative MEP Neil Parish, who has urged members of the Westcountry business and farming community to contact him if they have ionformation the European Committee should consider.
He said the committee had already seen evidence of the Governments's reluctance to accept responsibility for the handling of the crisis.
He referred to comments from the Parliamentary Under Secretary to DEFRA , Elliot Morley, who revealed that the Government would consider seeking emergency powers if it could not push the Animal Health Bill through Parliament, which would allow civil servants to force entry to slaughter animals.
"It is just sheer arrogance and shows they have learned nothing from the last outbreak," Mr. Parish said...."
We have not seen the last of foot-and-mouth disease within the EU. But the response to the 2001 epidemic has provided new rules of engagement if it returns. Vigilance is paramount, even if some of the controls are irksome for producers. So is research, so the most effective use of vaccination as a supplementary defence can be achieved. Most of all we need to understand that the more intensive the concentrations of animals, the greater care must be taken over both their movements and the products derived from them. The Commission's proposals are sensible. They follow the line of the European Parliament's own Temporary Committee. It should be the opinion of this committee that they be endorsed.
(Where issue is taken with amendments they are mentioned. If not, they have been skipped)
3. The decision to introduce emergency vaccination shall be adopted in accordance with the procedure referred to in Article 89 (3), either on request of the Member State directly affected or at risk, or on the Commission's own initiative
3. The decision to introduce emergency vaccination shall be adopted in accordance with the procedure referred to in Article 89 (3), either on request of the Member State directly affected or at risk, or on the Commission's own initiative in collaboration with the Member State concerned.
This amendment reflects the provisions of the existing Directive on Foot and Mouth Disease and gives the Member State concerned flexibility in deciding what action to take to eradicate the disease.
"Flexibility" was what we claimed to have last time - and an obdurate refusal to use vaccination last time resulted in outrageous loss - to our rural economy, our international reputation and to the trust of our farmers in the very Ministry they thought was there to guide them for their good. The same year in Uruguay, the disease was eradicated in 15 weeks, and fewer than 7,000 animals were killed. Meat has to be hung and de-boned -although,, apparently, Dr Paul Sutmoller sees no scientific reasons for this. Even so, this would be a small price to pay, compared to the multibillion - pound cost of our own UK epidemic and its tragic social costs.
Why are we continuing to protect farm exports at all costs, instead of using every opportunity to make the case for good science and humane practice? Why is everyone so frightened of the NFU and the meat industry?
Article 72, paragraph 10
10. In any case, every five years each Member State shall update its contingency plan in particular in the light of real-time alert exercises referred to in Article 73, and submit it to the Commission for approval in accordance with the procedure referred to in Article 89 (2).
10. In any case, every three years each Member State shall update its contingency plan in particular in the light of real-time alert exercises referred to in Article 73, and submit it to the Commission for approval in accordance with the procedure referred to in Article 89 (2).
The review process should be on a more regular basis.
Yes it should. Why not every year?
Amendment 9 Annex X, point 1, introductory phrase
Taking into account the additional criteria in point 2, emergency vaccination shall be introduced if for more than two consecutive days:
Taking into account the additional criteria in point 2, emergency vaccination shall be seriously considered, if for more than two consecutive days:
Flexibility is again needed here as it may not be appropriate to automatically introduce a vaccination policy if the 24/48 hours deadlines are not met.
(This is odd. There seems no need for this amendment except to give a loophole to interested parties. "Seriously considered" sounds like a political fudge. What is to stop the undue influence of a vociferous minority with an unpublicised agenda? If 24/48 hour deadlines are not met then the disease is in control. Vaccination is the only sensible way to stop it - what else will be done? If infected animals can't be put down fast enough then more extensive culling won't be fast enough either. )
The BCVA, may be a good example of the powerful vested interests that seem to lead UK policy by the nose.
Vaccination has been an issue all week. The growing calls for some form of vaccination strategy have been coming from all directions, including some vets and scientists. The recent paper (by Prof Brownlie) that we commissioned gave a good insight into the pros and cons of vaccination, but the messages were not getting through..... Now we have the Soil Association, Prince Charles, and all sorts of “we know best” individuals pontificating on the virtues of vaccination and alternative control strategies. ( BCVA Diaries 1st April 2001)
The fiercely anti-vaccination stance of the BCVA President (few vets in Britain understood the real state of the art in FMD vaccination) was built on very questionable information but supported solidly by self-interest and a highly confident and persuasive manner.
The Sibley approach - shared by many - leads to a vicious circle of
- refusal to vaccinate because of profitable trade restrictions against other countries
- refusal to demand accelerated validation of excellent new rapid diagnosis and testing advances
- because of unwillingness to consider vaccination
- unvalidated tests used as argument not to consider vaccination
- complacency at not having "given in" to pressure to vaccinate and determination not to give in next time either....
Who at DEFRA would dare openly to blame him for wanting to protect his own interests rather than the cattle?
"Our function as an Association is to look after the interests of our members. Those interests could simply be served by providing knowledge and information, and preparing members to face a changing world. However, many groups are now having influence on the decisions being made by Government, many of which are against our own interests. We cannot sit back and let this persuasion by media, and control by popularity, work against our own interests, which depend upon the long-term survival of an efficient, and productive cattle industry."
"Push forward with our vaccination policy, which is to only allow vaccination of cattle in contiguous herds while they await slaughter. Any vaccination should only be carried out on animals that are to be slaughtered, and the vaccine must only be used to buy time and slow virus spread where keeping up with slaughter targets is proving impossible. Any “vaccination and live” policy will be vigorously resisted."
This sort of thinking will continue to hold sway over British policy (they will demand loopholes in the Directive) unless the independently offered scientific, veterinary arguments are listened to.M Critchley http://www.warmwell.com