e-mail from Mary Marshall 13th August 2002:

In response to Alan Beat's editorial on the 20 day standstill in his latest Smallholders Online Newsletter and an editorial on the warmwell site, I would like to offer my own suggestions which I have given to DEFRA.
I am a participant at the large Stakeholders meetings, and was present at the large meeting on 29 July when the FMD Inquiries and the 20 day standstill were discussed, but I had not been invited to the smaller meetings which have taken place with the livestock industry last week (as reported in Farmers Guardian).

Here are extracts from two emails I sent to DEFRA: one the day following the large meeting (29 July 2002) and another in response to a reply from DEFRA to that first message.

By way of background, at the invitation of the CVO to all stakeholders earlier this year on the future structure of the stakeholders meetings, I had proposed that they should be enlarged to include a broader representation of stakeholders, including independent and Pirbright scientists, and that major items and decisions should be available on the internet. This proposal was rejected, but I hope that it will be reconsidered, perhaps in a modified form.

Extracts from my two messages to DEFRA:

"I don't think I was alone in finding disappointing the inflexible and sometimes inconsistent responses from DEFRA to many of the points raised yesterday by stakeholders.

FMD Inquiries

I had the impression that DEFRA is comparing the recommendations made by the Royal Society and the Lessons Learned inquiries, and selecting whichever of the two suits its policies. This was evident in David King's response to my question on whether DEFRA would confirm that, if an outbreak should occur next week, the RS recommendation not to implement a contiguous cull will be accepted. He chose to ignore this and instead referred to the LL recommendations.

Suggestion: an open and public discussion between the chairmen of the two inquiries, participants to include stakeholders and scientists, to resolve conflicting recommendations. If greater weight is given to one of the inquiries - especially on matters pertaining to science - it should be the RS, not the LL.

...... Thank you for your prompt reply to my email. The issues are so important that they deserve more than superficial discussion, both within DEFRA and with Stakeholders. Below, I only highlight some of the main points as I see them.

I urge DEFRA to widen the input into the decision-making process, and in particular to balance the advice given by David King, with advice from a representative who is involved with FMD science, such as David Paton from Pirbright. This would be especially helpful in resolving issues which are vague and leave room for interpretation, or were identified by the RS report as needing further discussion - this applies to both the 20 day standstill and the contiguous cull.

Contiguous cull

You are right that the RS report gives no categorical recommendations for, or refutations of, the contiguous cull. My necessarily brief comment was based on the Summary and main recommendations part of the report which on page 3 first paragraph and in the section on "Dealing with an outbreak" recommends rapid culling of all IPs and known DCs, and where these measures are insufficient, in addition the early deployment of emergency vaccination. On page 5, "emergency vaccination could be far more appropriate than the alternative of extensive culling". Surely this indicates that the contiguous cull should, at best and if at all, be held in reserve? In the main report, paragraph 9.38 refers to the risk of further spread by lax biosecurity: "Unless biosecurity can be guaranteed, the strategy will at best be less effective and at worse counterproductive". In paragraph 9.39, "We note that the interim contingency plan proposes the culling of IPs and DCs plus "contiguous premises informed by field epidemiology" within 24 and 48 hours respectively, and we believe that this should be studied further in the light of the data from the 2001 epidemic to determine under what circumstances this would be appropriate. Furthermore, it is clear that any initial strategy would need to be reassessed at the end of the first week." This strongly suggests to me that the contiguous cull should not be adopted as policy without further research and endorsement by FMD experts. Paul Kitching's submission in July 2002 to the EU Temporary Committee on Foot and Mouth Disease is also relevant here. I would welcome a thorough and open discussion with the RS Inquiry chairman and panel, DEFRA and scientists to resolve the role of the contiguous cull.

Non-compliance with the 20 day standstill rule

In the light of the escalating threats of non-compliance by farmers and following comments from David Paton and Keith Sumption, I have revised my suggestions. Lord Whitty stated on the BBC Radio 4 Farming Programme today that "there are no gaps in the scientific advice". My revised suggestions include other options/advice.

1. treat farmers with respect and give them a choice between several options:

• . 20 (or shorter) day standstill - for those who are willing and cannot take up other options. Note: Chris Lewis stated at the Stakeholders meeting that, in his veterinary opinion, a 6 day standstill would be sufficient.

• quarantine/isolation - for those with the facilities. This option has been taken up by 600 Scottish farms, and might be attractive to some UK farmers. A system of spot checks can work.

• thorough clinical inspections. In a telephone conversation this morning, David Paton said that while he agrees that the 20 day standstill would be the most effective policy, he suggests that the culture at the moment is not right for these measures. He says that thorough clinical inspection would have the added advantage of controlling all diseases.

• . use of portable real-time RT-PCR tests

  Keith Sumption sent me the following comment (30 July):

  "I really enjoyed reading your analysis of the stakeholder's meeting and your thoughtful suggestions. I have also argued from the start that there are alternatives to the 20 day rule if we were to introduce testing as an option - which stakeholders might part pay - there would be public benefit in building up the capacity for testing and also building the market place for such tests. The (pen-side) testing to be used could depend on period since animal introduction -e.g. virus tests from day 0, antibody tests from day 10, no tests after 21 days (although 14 days is more reasonable for FMD if incubation period is the criterion)."

  and, just received from Keith Sumption today (13 August): "I would add that the figures of the time since animal introduction when tests could be used are illustrative only, and needs a fuller consideration. The amount of risk reduction (benefit) and the cost to the industry needs to be estimated for any measure or combination. But in principle, recent entry animals could be tested, or the animal groups into which they have been introduced; testing recent entrant animals at least allows the date of entry and therefore possible date of infection to be assumed, allowing a rational selection of tests according to period post introduction and characterisitics of the tests. Any widescale use of tests would eventually result in false positives which could have serious implications unless confirmatory tests can be undertaken in hours."

• closed herds/flocks. As David King explained, the greatest risk is from animals that may be incubating FMD coming on to a farm. This risk is absent on farms which do not take in animals. Consequently, animals leaving these farms should not trigger a standstill on the destination farm. In response to your comment ("The reason why we cannot agree to the exemption you have asked for is due to the possibility of airborne spread. The "closed" holding may be adjacent to a pig holding where virus is being emitted."), I ask, is it reasonable to exclude from this option closed holdings which are NOT adjacent to a pig holding? and note, this should be a large pig holding, not a few pet pigs (MAFF vs. UPTON).

2. On the general point of an individual's breach of compliance with rules, I offer a slightly different transport analogy to yours of the 30mph speed limit. While the London Underground requires every passenger to walk through a turnstile both on entry and on exit, the metro system in Lyon has no such barriers to flow and operates on a high level of trust with severe penalties for spot checks of non-compliance.

3. further points on portable real-time RT-PCR tests:

• The following quote is from the RS report. Since the comments refer to control of an epidemic, they must surely also apply to the less threatening situation of peacetime surveillance: /index/547.pdf Focus Group on Diagnosis of Exotic Infectious Animal Diseases meeting at the Royal Society, 10 December 2001 International Validation 29. It was also very important to ensure that there were international standards for antigens, antibodies and genomes as positive test controls. However, in controlling a national epidemic additional use of sensitive and reliable though incompletely validated tests may be considerably more effective than relying solely on obsolescent though OIE validated tests.
• . you will be aware that the peer-reviewed publication of the USDA/Tetracore test was published on 1 June 2002: Title: Use of a portable real-time reverse transcriptase-polymerase chain reaction assay for rapid detection of foot-and-mouth disease virus
  Journal of the American Veterinary Medical Assoc.; vol. 220, #11, June 1, 2002; pp 1636-42

  Objective: To evaluate a portable real-time reverse transcriptase-polymerase chain reactoin (RT-PCR) assay designed to detect all 7 viral serotypes of foot-and-mouth disease virus (FMDV).
  Authors: Johnny D. Callahan, Fred Brown, Fernando A. Osorio, Jung H. Sur, Ed Kramer, Gary W. Long, Juan Lubroth, Stefanie J. Ellis, Katina S. Shoulars, Kristin L. Gaffney, Daniel L. Rock, William M. Nelson

4. DEFRA should treat animals kept as pets or companions seriously. They are important to those who keep them and are just as vulnerable to disease as any other animal.

It is in everyone's interest for DEFRA to be seen to be listening to farmers' concerns and to be seen to be making a serious effort to restore their confidence and their compliance with regulations they perceive as reasonable.

END

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I did receive constructive and helpful replies to my messages. I have been trying to argue for REASONABLE options, perhaps easier for me since I have no vested interest.

It is sad but true that in some ways DEFRA has been more responsive than other stakeholders. When I started attending the stakeholders meetings in September of last year (not at DEFRA's invitation, but having invited myself), representing camelids, I presented the scientific evidence which has now resulted in the deregulation of camelids from the movement regime. I was not present during the height of the epidemic. Who was? The question must be, why are other representatives not at the stakeholders meetings? Where is the Soil Association? Why did the British Goat Society only decide to attend recently (not during 2001, but only in February 2002)?

It is up to us to ensure that DEFRA hears our concerns. They do listen to and consider (if not always act on) the evidence that we present: "I can assure you we do consider all of the points put to us, and we very much value the input from stakeholders in policy formation. However, we are not always able to adopt all of the suggestions made to us". It is up to us to present the evidence and reasonable arguments so that they are able to adopt our suggestions, or at least have a fair and open discussion about them. Mary Marshall's proposed changes to future structure of the stakeholders meetings