Mary Marshall's Proposal

Message from Mary Marshall to Alan Beat at
Defra are in the process of consultation on standstill options.  See below two of their proposed options. 
 I would like to draw two issues to your attention:

A. The consultation process.

Defra do listen and respond.  In fact, I have found that in many ways Defra is more open and responsive than are the stakeholders.  The problem, as I see it, is that those who feed into the consultation process do not represent the broad spectrum of interests.  In particular, there is no strong voice for small and mixed farms and for relevant science.  Consequently, Defra does not know what is happening and, with no pressure applied from these potential stakeholders, Defra is left to respond to the pressures from the major livestock industry who are able to fund representation at meetings.

I have tried to represent the interests of both small, mixed farms and of the relevant scientists, but my voice is small compared to the others.  The three strongest voices come from John Thorley for sheep and Dick Sibley and Robert Forster for cattle.  At least these three speak openly and effectively at the "large" stakeholders meetings; other groups may speak in private meetings with Defra.  The British Goat Society has recently joined the stakeholders meetings and is making progress, and of course representatives from the NFU, FUW, CLA and RBST feed into this, although perhaps more through private meetings.  I would urge any of you who have concerns that you feel are ignored to make these known to these representatives, as well as to others who can try to make them heard (e.g. breed associations and other farming groups, including this smallholders newsletter).   At the moment, the major stakeholders speak effectively for their own interests, but not for the broad picture.  The sheep people do not want to comment on cattle, and vice versa - so who, for example, speaks for farmers with both sheep and cattle?  I have never understood why the Soil Association does not participate.

You will see below the two options which Defra are proposing.  I have submitted a proposal which would give farmers a choice between options.  At the discussion last week, the first comments were from Dick Sibley who said (and here I must agree with him!) that the regulations should be flexible and from John Thorley who said they should be simple.  When I  outlined my own proposals, which had the support of key scientists, the stakeholders were silent, but the two Ministers (Lord Whitty and Elliot Morley) were interested and I was asked to provide more details.

B.  The regulations. 

Here is a summary of my proposal

followed by a message from Defra with their own proposal.

Farmers should be allowed a choice between options:
    1. standstill - time to be determined in consultation, but could be flexible according to species and management systems - for those who are willing (e.g. farms with few movements or which cannot take up other options). .

    2. quarantine/isolation - for those with the facilities.  A system of spot checks can work.

    3. thorough clinical inspections.  In a telephone conversation on 1 Aug, David Paton (Pirbright) said that while he agrees that the 20 day standstill would be the most effective policy, he suggested that the culture is not right for these measures.  He said that thorough clinical inspection would have the added advantage of controlling all diseases.  This would also be a way of getting more vets onto farms.

    4. use of rapid diagnostic tests, including Pirbright penside and USDA/Tetracore real-time RT-PCR tests.  Validation is an on-going process, and it is recognised by many experts that these devices have an important role to play now, even before they have been fully validated (as discussed during a session of the Foreign and Emerging Diseases Committee of the US Animal Health Association meeting in October 2002 in St Louis).
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).”

In St Louis, Paul Kitching suggested to me that no movement restrictions would be necessary if two conditions are satisfied: movement records accurately kept and individual animal identification.

I have argued that Defra should make concessions to try to win back the trust of farmers.  The cooperation of farmers is essential in identifying and reporting diseases - and not just FMD - and for traceability if/when there is an outbreak.

The onus should be on the  farmers whose practices are not good, but a system of self-declaration (with veterinary approval) and checks which can be easily verified should be able to identify and punish them, while leaving others free to continue farming.

I would really welcome comments on these proposals, especially any help with some practical and workable details that can be added to the choice of options - the detail that Defra has requested.

Mary Marshall
14 December 2002

Mary Marshall hopes that comments on her proposals will be sent to Alan Beat

Message from Defra to Stakeholders:



1.  This note invites comment from stakeholders on possible changes to the 20 day standstill for Spring 2003.   Defra wishes to seek industry comments on possible options now  before any cost benefit research findings are available  in order to gain time to implement any agreed changes as quickly as possible. 


2.  The 20 day whole farm standstill has been a central feature of the interim animal movements regime from the outset, though in response to industry requests, a number of exemptions have been provided where alternative risk mitigation measures have been agreed.  The most recent exemption was that provided from 6 September for breeding cattle and sheep isolated on arrival  and inspected between 14 and 20 days later.   In Scotland, a separation exemption is in place which applies less strict biosecurity conditions and does not require a veterinary inspection.

3. In view of the continuing strong scientific and veterinary advice in its favour,  and the recommendations from both FMD Inquiries that it should remain in place pending a detailed risk assessment and wide ranging cost benefit analysis, the Government decided to retain the 20 day whole farm standstill for Autumn 2002. Independent researchers have been commissioned to carry out the studies and work is underway. Emerging findings will be considered as decisions are taken about the shape of the movement regime to apply from Spring 2003.  However, the “emerging findings” have not yet been quality assured or peer reviewed.  


4.  A number of different suggestions  including a shorter standstill, no standstill for cattle and a “traffic lights” scheme  have been made by stakeholders and others.    If possible, our aim would be to arrive at a simpler system, so that  farmers would find it easier to understand and comply with the rules.

5.  On the understanding that any options will need to be re-examined when we have reviewed the emerging findings from the cost benefit analysis,  Defra would welcome industry views on the relative benefits and disadvantages of the following:

a) 20 day whole farm standstill but with revised conditions for the isolation or “separation” exemption.   Industry views are sought on the categories of animals to be covered and the precise conditions to be applied.  Since this option carries an increased risk of disease spread, all incoming isolated/separated animals would have to be inspected by a private veterinary surgeon between 14 and 20 days after arrival.

b) a shorter standstill but with no exemptions.   Exemptions for moves direct to slaughter, to and from veterinary treatment and in emergencies could still be permitted, but we would expect a reduced standstill to remove the need for the remaining exemptions, unless they can be individually justified. Stakeholders are invited to indicate whether there are other exemptions they think should be kept.

Defra - 9 December 2002


Mary Marshall hopes that comments on her proposals will be sent to Alan Beat