(March 2004) Mary Marshall wrote:   "With regard to your posting on a permanently operational FMD Expert Group,
you can use these extracts from a message I sent to Defra on 28 August
2003, especially the expertise required to fulfill the responsibilities
specified in Article 78.1-3 of the Directive, which were based on the
detailed suggestions of David Paton' (IAH Pirbright)."
 

QUOTE:

I suggest that ..  there is a need for a complete re-examination of the
Government's interactions with and support for those engaged in livestock
rearing practices, including the following seven key points:

1. Open and accessible information to all relevant documents and
consultations, ...

2. Access by all to non-confidential comments sent by the public to Defra
in response to their consultations.  Currently these are open for
inspection only at Defra HQ in London.  The internet publication of the
Hutton Inquiry evidence is a model of truly open access.

3. A revised and updated FMD Contingency Plan which takes into account
individual electronic animal ID and the use of rapid portable virus
diagnostic tests which can and should be linked to an updated GIS database,
thus increasing the chances of prompt identification of an index case and
allowing for real-time management and enabling useful post-epidemic
epidemiological data analysis.

4. Simulation exercises to test/evaluate the practicality of the
contingency plans which involve stakeholders and lawyers so that the
practical and legal aspects can be considered.  .....

5. Demonstrable support for the concerns and problems, especially economic,
faced by livestock keepers.  Such support is necessary to ensure their
willingness to regularly inspect their livestock for unusual symptoms and
notify the SVS if there is a suspicion of FMD or other notifiable
disease.  Livestock keepers are in the front line, and their cooperation is
essential.

6. If there is to be a fundamental change in livestock rearing practices,
consideration should be given to a reform of the system of disease
insurance and veterinary involvement, ...., ideally partially state
subsided. Note that the benefits could include transfer of cumbersome
record keeping from the individual livestock keeper and holding to the
organisation and its vets.

7. Above all, the creation (which is a requirement in the EU FMD Directive)
of "a permanently operational Expert Group ... to maintain expertise and
assist the relevant authority in qualitative disease preparedness", with
assurance that the appointments to this Expert Group will be undertaken in
an open and transparent manner and that the composition will include
international expertise in FMD diagnosis, vaccination and in relevant new
technologies.  A written parliamentary question to Lord Whitty which
addresses the creation and composition of the Expert Group will be tabled
by Lord Plumb on September 1st.  This includes a list, which is based on
detailed suggestions from David Paton (IAH-Pirbright), of the expertise
required to fulfill the responsibilities specified in Article 78.1-3 of the
Directive, namely expertise in:

- FMD diagnosis

- vaccination as a control measure

- international developments of relevant new technologies, in diagnostics,
surveillance, electronic ID, vaccines and anti-virals, and robotics (for
lab tests)

- the workings of the state veterinary service

- animal husbandry practices in the UK, including commercial and
non-commercial, breeds at risk, minor breeds, companion animals and wildlife

- epidemiology of veterinary infectious diseases

- epidemiological modelling and cost-benefit prediction

- risk assessment and risk management

- legal matters relating to disease control

- environmental controls relating to carcass disposal

- general rural affairs, including tourism

Mary Marshall
 28 August 2003

* See also some of the references made to Rapid Diagnosis PCR tests on this website and comment about the way they seem to have been ignored. (new window)

 

Comments on Defra’s Foot and Mouth Disease Contingency Plan, Version 2.5

By Mary Marshall,

Member of Defra’s FMD Stakeholders Group, representing the Smallholders Forum.

(Also a member of the Foreign and Emerging Diseases Committee of the US Animal Health Association)

 

02 March 2003

 “Defra should not be re-fighting the last war, but planning and training for the next.” 

While welcoming the consultation process on the contingency plan, I find the current document woefully inadequate and hope that significant changes in strategy based on recent developments in diagnostics and surveillance will be implemented, and further relevant research and trials will be supported and funded.  Through my contacts with scientists in the UK, EU and North America, I am in possession of a considerable amount of information, some of which I have been asked to share only with government agencies.  In all cases, I have shared information which is not in the public domain with Defra.  In the comments that follow, I may refer to some of this information without providing full references, but all of this information is in the hands of Defra. 

There are major sections in the Contingency Plan on the press and internal press activities, and a curious phrase “Stakeholder Handling” (are we dangerous animals to be kept firmly under control?).  Absent from this document are the crucial topics on improving diagnosis and record/data acquisition and analysis. 

Professor Martin Hugh-Jones’ comments sum it up perfectly:

Some aspects which I hold are vital:

 

[1] Animal side tests of reliable sensitivity and high specificity. Nobody should or need wait for reference-quality laboratory confirmation.

 

[2] Wireless data acquisition from the farm at the time of examination and preliminary diagnosis by laptop or other suitable electronic device. Ditto updated data as the herd is processed. If "wireless" is difficult, it should be through a website or other access system that is available at all times. This should, if possible, include digital graphics acquisition and transmission -- if Page Street doesn't believe the VO, he can, for example, send a photograph of the lesions he has seen or of anything else.

 

[3] That data should be immediately omni-available, at least throughout Defra.

 

[4] The data loggers should have GPS chips installed so that there are no errors in accurately locating diseased, suspect, or healthy herds.

 

[5] Data should be GIS linked  so that situations on individual farms can be queried remotely -- e.g., klik on a farm icon on a quasi-3-D map display, as well as to either constantly updated frequent analyses or by idiot-able custom analyses.

 

Use my other comments as you like.

 

I don't think it is wise to firmly believe that all future FMD episodes will be like 2001. One of the commonest errors is to assume a worse-case scenario. Obviously the system should be able to be racked to deal with such an event. But as presently planned I get the distinct impression that there will be more veterinary officers at committee meetings or writing reports for committees than out in the field dealing with the problem…

 As a last word, Defra should not be re-fighting the last war, but planning and training for the next.”

 Note:

Martin Hugh-Jones is a UK (Cambridge)-trained vet, currently Professor of Epidemiology, Dept. of Pathobiological Sciences, School of Veterinary Medicine, Louisiana State University, and Moderator of ProMED-mail.  His other posts include:

Director, World Health Organisation Collaborating Center for Reference & Training in

  Remote Sensing and Geographical Information Systems for Veterinary Public Health

World Health Organisation/Veterinary Public Health,

   Chairman, Working Group "Anthrax: Epidemiology & Information";

   Coordinator, of Supervising Committee, "Anthrax Control & Research".

 

 

Diagnostics

From the Contingency Plan, the Template for First Report to Defra, includes:

 

samples taken to lab on: …..

(Diagnosis on basis of clinical symptom or Lab test): …..”

 

Comment: 

The draft EU FMD Directive does not allow for initial diagnosis only on the basis of clinical symptoms, but requires confirmation of the virus.

Objections to the use of the portable real-time RT-PCR tests (e.g. the test developed by the USDA/Tetracore) are still being raised.  At the recent Defra FMD Stakeholders meeting, on 25 February 2003, I reported that Professor Steven Edwards (Chief Executive of the VLA and participant at the November 2002 meeting at the IAEA on validation procedures for these new tests) told me that validation is an on-going process and that these tests are technically ready to use now, adding that what is required is training people to use them, as the tests are “only as good as the people who use them”. 

Fred Landeg’s reply: "Steve Edwards, Vice President of the OIE Standards Committee, is one of Defra's chief advisors. We are not behind on this!" (where is this then to be seen in the Contingency Plan?), and he went on to say that Defra relies on Pirbright which has full up-to-date expertise and knowledge.  Would that this were true!  Pirbright’s own portable PCR test is still in development, and Pirbright is under-staffed and under-funded.  But according to Landeg, “This is a small island…. we have no trouble getting samples into the laborarory.  Pirbright is the World Reference Library for FMD, and we use it in the laboratory, PCR that is. We are fully up to date". 

This is surely open to international expert discussion and peer review.  Defra may have no trouble getting samples to Pirbright, but in so doing, days will be lost and the disease likely to be out of control.

 

Suggestion:

 

In order to reduce time to detection, use should be made of portable real-time PCR tests that can identify all 7 serotypes of the FMDv within 2 hours, using samples taken by non-invasive procedures.  An immediate standstill of all animal movements should be declared.  The results of tests on samples sent for laboratory identification of the serotype, which would be available within 3 hours, should immediately trigger production and distribution of vaccine. I suggest that a programme of random PCR tests should also be considered for “peacetime”, for example at livestock markets and milk collection, to minimise the risks of lingering, undetected disease, whether naturally or intentionally introduced.

 

“The US Congress was just told that this test was available to use in an emergency.”  See message below from Roger Breeze (Associate Administrator, USDA-ARS, e-mail dated 1 March 2003):

 

“The Plum Island FMD real time PCR test has been published last June 2002. We are engaged in a large scale validation of this and other tests. The US Congress was just told that this test was available to use in an emergency. The test will identify all 7 types of FMD virus and not confuse them with any other virus but it will not differentiate the seven from each other. 

 

We have other new technology for rapid genomic sequencing of the virus - within 3 hours of getting it to the lab.  Currently, there is an antibody based method to decide what the best vaccine should be - a comparison between existing vaccines to decide which is closest and provides the best protection - assuming that there is not an exact match between the virus and the available vaccines in production.

 

The portable PCR should be used on farm or close to it for speed. The portable PCR is pointless in the lab where fixed machines and trained people exist.”

 

 

GIS surveillance

From Defra’s Contingency Plan, National Disease Control Centre:

‘Birdtable’ meetings are arranged around a map table showing details of infected premises.  They are short, outcome-focussed briefing meetings where key personnel stand around the table and give account of their logistical problems and progress against them.” 

 

Comment:

Pins on a map are fine, provided they are only for back up and discussion.  But nowhere is there mention in this document of a comprehensive computerised GIS database and tracing capability linked to field diagnostics which would provide real-time disease management.  The capability for this exists.  There are at least two such systems: both are available through private US companies working independently but in cooperation with the US government.  I have provided an outline of these and contact details to Defra. 

When I asked about UK GIS capability at the stakeholders meeting on 25 February 2003, Fred Landeg replied that “we have GIS capability now and that it is exactly the same system that was in place in 2001”.  I remember Neil Thornton telling the stakeholders in September 2001 that the Defra database needed improvements since some holding grid references were in the middle of the North Sea.  Just yesterday (27 February 2003) on BBC Farming Today, the public was informed that:

 

The failure to do the proper checks means that Defra will have to pay £15 million back to the EU.  An investigation by commission inspectors revealed shortcomings in on-farm inspections and inadequate controls of livestock. Defra says "most of the mistakes took place because the database system wasn't up and running".

 

According to Roger Waite of the agricultural newsletter Agrifacts, the commission inspectors identified 4 or 5 different areas, above all that the computerised database, traceability of cattle has certain shortcomings, there weren't the necessary minimum levels of on-farm inspections, cross checks were not done, and on the extensification premia there weren't sufficient checks with regard to stocking densities.  Also a slightly different issue, intervention purchases of roughly 500 tons in Northern Ireland were missing, and so it's because of the shortcomings that the commission applies a flat rate reduction to penalise the UK for not carrying out the necessary controls.

 

Miriam O'Reilly: Whose responsibility was it to make these checks, because some of these issues sound pretty serious?

 

Waite: it's undoubtedly Defra's responsibility because each government has the responsibility of making sure that the necessary checks are made and so the buck stops very definitely at Defra.

 

 

In contrast, from one of the US companies:

 

“In summary, we can identify an animal or product … at the farm, trace it through the supply chain, provide third party certification, use our newly developed biosensors to determine contamination …, utilize new RFID technology for ear tags and container tracing, all with web based seamless technology.  We can detect diseases with our sensors, provide immediate first responder information with contaminated area pictures, local supplier information, built in GIS/GPS analytical tools (water tables etc.), and provide check print outs for immediate producer payment. Our biosensors can detect any foreign-borne pathogen by contact or air. The new technology allows for rapid growth of the media cutting current standards in half. Most important we can do all of this economically.”

 

“We are working on a RFID system … that allows for immediate reading and recording of tags from large or small groups of live animals.  Essentially the process works like this: [details supplied to Defra]…. The technology is web based, and everyone who has a need to know the information, can easily access the database. A premises ID with GIS coordinates, one time entry, will allow for quick mitigation of diseases. We can trace back to the farm, provide a satellite image, for example topology, roads, water table data etc, of the infected area, provide all necessary local and government contacts for immediate handling of the disease. The first responder is in direct control of the situation. Everything they need can be downloaded immediately.”

 

An added benefit of this system is that it can eliminate the need for bulky double tags on sheep and goats and reduce the amount of paper work for the livestock keeper.  A uniform system should be considered for adoption by all EU countries.

 

The Polish government has requested a demonstration of the system developed by the other private company.

 

Contrast this with Roy Hathaway’s statement on 25 February 2003 that “we need a few days to type the strain and trace the movements and dangerous contacts….there would be a standstill on day 1 [when is day one according to these plans?], then tracing … vaccination would not start before 7 days”.   

 

 

Real-time alert (table top) exercises

 These are a requirement of the draft EU FMD Directive, but I could find no reference to them in the Contingency Plan.  I have passed on to Defra information about the recent US exercises.

A comment from someone who was involved in one of these exercises:

If DEFRA is relying on a seven day time table..."Good Luck". Twenty four hours is really stretching it in the states. In all our exercises FMD was out of control within that time frame.  In the UK you have greater animal population densities, in smaller confined areas, and closer proximities than we do in the states. Disease transmission is much faster. Technology is the only key to detection and mitigation.”

The exercises in the US have shown that stakeholder participation is essential, and has the added benefit of demonstrating to the livestock industry which regulations are important (and which are not important) in mitigating the effects of an outbreak (Roger Breeze, private communication).

 

 

Flexibility

Defra’s willingness to give special consideration to rare breeds and zoo animals (as in (draft EU FMD Directive) is welcome.  This is especially important for the UK, since it has the largest number of rare breeds in the EU.

 

Suggestions:

 

1) Rather than dispute definitions of what is a rare breed, any animal that the keeper/owner considers of particular (genetic) value (whether kept in a zoo or on a farm) should have the right to apply for special consideration, including vaccination and/or isolation with increased biosecurity measures.

 

2)  Special consideration should be given to species with varying degrees of susceptibility and risks of onward transmission.

 

Appropriate procedures should be included in the Contingency Plan.

 

 

Advice, oversight and leadership

We need balanced, focused leadership which can evaluate, but also rise above, the quite legitimate demands of narrow vested interest groups, researchers seeking funds which may not be strictly relevant, and political pressures.  This leadership should be centred on a strong CVO, advised by a group of government and independent scientists with a demonstrable predominance of veterinary expertise and experience. 

The draft EU FMD Directive requires just such a permanent “expert group” (Article 78).  Is it possible that such a group can be found amongst the numerous groups and committees outlined in the Defra’s Contingency Plan?  An explanation from Defra would be appreciated.  This expert group must be more open and accountable than the group which was formed in 2001.

 An institutional plan to formally and regularly review new scientific developments in animal disease control would be welcome, and should be part of the requirement in the draft EU FMD Directive to update Member States’ contingency plans every 5 years (Article 72, para 10).  I suggest that this interval should be reduced to one year.

 

 

Please, can we fundamentally review the contingency plan and open it up to international consultation?  This is not a trivial matter.  The stakeholders were told by Roy Hathaway on 25 February 2003 that the EU FMD Directive, which is legally binding in all EU countries, is a vague and loosely worded document, and consequently Defra will have broad powers of interpretation, including the full powers given in the Animal Health Act 2002.  Some of these powers should never be exercised: with the sensible use of new diagnostic technologies that can rapidly and accurately identify infected animals and herds, there is no justification now or in the future for a contiguous or “firebreak” cull.

 

The use of this technology would allow for the rapid implementation of targeted vaccination, thereby reducing the numbers of animals needing to be slaughtered and needing to be vaccinated.  The procedures (locally, regionally and at HQ) to implement this suggested strategy should constitute a substantial part of the Contingency Plan.

 

 

A new approach

Will Defra have the courage to accept this new approach to animal disease control? 

Will the government provide the necessary funding? 

If the answer to these questions is “no”, then one contributor’s comments should be noted:

 

“Business is going to be directly behind the change.  Class action litigation, demands from banks and financing agencies, lack of insurance coverage without exclusions, are having a global impact on the need for preventative measures.

Lending agencies and insurance companies are extremely concerned about the assets they are investing in or protecting.  Animal health and food safety issues are at the top of the list. Earlier this year, in the state of Kansas we had a false FMD rumor surface.  Within one hour, the commodity markets dropped the max, and every corporation that depended on beef did the same, many losing over a $1 share value.  Fast food chains, steak house chains, feed companies etc.  It took one hour to accomplish this, luckily the markets were closing, or it would have been worse.  Bureaucrats need to understand the consequences; they need to be shown they must invest in the protection of the economic future of their country.  All it takes is one incident. Unfortunately, FMD will be back in the UK, they must know how to immediately isolate and control the problem; every member of the EU needs to as well.”