The RSPCA is concerned only with animal welfare.  Accordingly this submission will concentrate on matters which had a direct effect on animal welfare and will exclude other more peripheral matters except where they impinge on welfare.  Where possible the general questions will be addressed as will be a number of other issues.

The RSPCA is the largest animal welfare organisation in the United Kingdom (UK) with a total of around 1700 staff.  Of these, 328 are fully trained Inspectors and 146 are Animal Collection Officers deployed throughout England and Wales (the Scottish SPCA covers Scotland and the Ulster SPCA covers Northern Ireland).  In addition the Society employs over 200 veterinary and nursing staff.  The national Society headquarters also employs significant veterinary and scientific resources which are able to advise on matters relating to wildlife and farm animals. A proportion of these resources was available to government to assist in managing the Foot and Mouth (FMD) epidemic and in some instances was utilised.

The Society has collected many case studies during the process of the epidemic.  These are attached at Annex A and will be referred to during the text to illustrate specific points.  In addition there was a considerable amount of correspondence between Society staff and Ministers and officials of MAFF/DEFRA and this, where relevant, is attached at Annex B.

How adequate were the contingency plans at national and local levels for dealing with Foot and Mouth Disease in Great Britain?  What were the specific strengths and weaknesses?

The RSPCA was not invited to contribute to any contingency planning, had not been involved in any practice of any such plans and has not, to date, been invited to contribute to any planning which is being developed.  Given the level of resources detailed above the Society is surprised that it had not been included and consider this exclusion to be a significant weakness which appears to continue to be present.  The exclusion by MAFF/DEFRA of well-trained staff from other agencies appears to the Society to have been a theme throughout the epidemic.

In view of the lack of any sight of contingency plans it is therefore difficult for the Society to comment on their value.  However the experience of Society staff throughout the epidemic was that any contingency planning was minimal and out of date.  This deficiency seems to extend even to knowledge within MAFF/DEFRA of farming practices prevalent in the UK which seem to have contributed significantly to the spread of FMD.  In particular it seemed to Society staff that practices common among sheep dealers were not known to MAFF/DEFRA staff on the ground.

The RSPCA is not either aware of any contingency planning with regard to the involvement of wildlife in the epidemic.  The Society is aware that a risk assessment was undertaken but Society staff were, regrettably, not invited to contribute.  Society field staff (Inspectors and Animal Collection Officers) were instructed on the potential hazards of moving susceptible species and provided with appropriate biosecurity equipment.  However no clear definition of which species to regard as a hazard was available from MAFF/DEFRA.  Clearly for some other diseases wildlife are a potentially major issue and the Society therefore considers that this should be taken into account in contingency planning.  Furthermore it would be significantly more effective if welfare organisations which routinely deal with very large numbers of wildlife were consulted.

It would appear that MAFF/DEFRA were content to use the same basic approach which was in place from the previous major epidemic and that this had not been significantly changed even to take into account new regulations on carcass disposal enforced by the Environment Agency.  In addition information on vaccine efficacy seemed dated and no account had been taken of the reduced numbers of veterinary surgeons employed by the State Veterinary Service directly or as Local Veterinary Inspectors authorised to undertake production animal work.

What roles did MAFF/DEFRA, the State Veterinary Service, the devolved administrations in Scotland and Wales, Local Government, the Armed Forces and others play in the crisis?  Were they adequately organised, co-ordinated and resourced to do so?

MAFF/DEFRA and the State Veterinary Service:  RSPCA staff came into contact with MAFF/DEFRA staff at all levels during the epidemic.  Clearly in such circumstances the Ministry should be providing leadership and information on the progress of the disease and the lead in control measures.  The content should be identical across the country so that procedures do not differ between regions.  There is a dedicated animal welfare team to take the lead on such matters and the Society would expect to be informed and asked to assist wherever possible as this is clearly the major area of RSPCA staff expertise.  A welfare consultative group was established from 6th April 2001 and meetings of the group with the Parliamentary Under Secretary of State (Commons), Elliot Morley, and his officials were very constructive.

Regrettably this constructive attitude was not evident throughout and the resulting lack of coordination is likely to have lead to worse animal welfare.  An example of the difficulties experienced is at Case 1.

The RSPCA was closely involved in the running of the Livestock Welfare Disposal Scheme (LWDS) from 17th April 2001.  While difficulties with the Scheme were first raised at a welfare group meeting, the Society’s significant input followed a stakeholders’ meeting in Exeter with the Prime Minister at which RSPCA staff raised issues resulting from fodder shortages and movement controls.  It was very apparent then that LWDS was failing to prevent animals suffering because of the time taken to process applications and there were some graphic illustrations of the results in the national press.  Relevant correspondence is at Letters 7, 8, 12 and 13.  The details of Society involvement in LWDS are at Case 2. 

The RSPCA views the inability of MAFF/DEFRA to establish a properly functional LWDS in a timely fashion as an example of the inadequacy of their organisation.  While this is clearly a resource issue, and no organisation could be expected to be manned in ‘peacetime’ for a ‘war’, the apparent lack of contingency planning to bolster the resources available referred to above is nowhere more evident than in the operation of this scheme.  In particular the inability to prioritise applications to the scheme because of inadequate staffing, and poor organisation of transport resources contributed to unacceptable delays leading to animals suffering.  This lack of resources was exacerbated by the over-valuation of prices for livestock which lead to greatly increased applications under the scheme.  An example of the way in which some individuals sought to profit from the scheme because of the high prices is at Case 3.

Devolved Administrations:  The RSPCA operates only in England and Wales and so has no experience of dealing with the Scottish administration.  There has been little liaison with the Welsh Assembly with the exception of discussions about an incident of inappropriate slaughter which took place in South Wales.  Correspondence is at Letter 22.

Local Government:  The probable source outbreak at Heddon-on-the-wall was on a farm with which the RSPCA had some prior involvement.  Owing to the attitude of the farmer to RSPCA staff, further complaints were passed to local authority animal welfare staff.  In spite of fairly conclusive evidence that there were animal welfare problems on the premises, inadequate action was taken to close the farm. Were farms to be inspected and licensed such poor quality premises might be closed and disease risks reduced.  Licensing of farms forms part of the RSPCA proposal for the future of farming.  A copy of the RSPCA proposal is at Annex C.

Armed Forces:  The RSPCA came into contact with the Armed Forces in a number of areas.  The closest contact was undoubtedly at the mass slaughter and disposal site at Great Orton in Cumbria where the infrastructure provided and run by the Army was most impressive.  A report on the site is at Case 4.

How ready was the farming industry to handle a major infectious disease like Foot and Mouth and did the existing national and EU regulatory regimes have any influence?  What more could be done to prepare for possible future outbreaks of infectious disease?

The RSPCA considers that some of the farming community had become lax over biosecurity controls on farms in recent years.  This complacency has apparently been generated over the past few decades in the absence of any major outbreak of infectious disease.  The sole exceptions are the pig and poultry industries where the general level of biosecurity is good and this may be related to both the size of individual units and the more recent disease problems encountered.  There are also structural issues which make biosecurity more difficult in the dairy industry where milk must be collected at regular frequent intervals by a vehicle which goes from farm to farm.  In addition the difficult financial circumstances which have prevailed in recent years have encouraged reductions in manning levels which have in some cases mitigated against good farming practice.

The frequency with which animals may be moved had a clear effect on the spread of disease, and in particular this applied to sheep.  The manner in which dealers purchase and sell sheep several times over a short period for low profit margins had a clear influence on the spread of disease.  In addition, because of the stress of transport and multiple re-grouping of animals, the practice compromises the welfare of the sheep. To assist in reducing the frequency of movement of livestock to improve animal welfare and biosecurity a standstill period should be introduced following any movement onto a farmer’s premises.  This practice has been in effect in the pig industry for many years and is effective.  It is notable that the number of cases of pigs infected was low and this supports the contention that movement control is effective.  The introduction of the twenty day standstill for other species which has been introduced as a temporary measure should be retained.

The additional practice of ‘bed and breakfasting’ sheep which results from the subsidy payment mechanism is outlined in Case 5 and has similar welfare dis-benefits for the animals.  Clearly this relates to the manner in which subsidies are paid and this should be taken into account in any review of EU farming subsidy.

Once the scale of the crisis became clear, was the response proportionate to the impact on the wider rural and UK economy?

The initial report of disease came from an abattoir in Essex whose collection area was very significant. The possibility of infected animals having been transported a significant distance did not appear to have been recognised in the immediate response with the introduction of only local movement controls.  This allowed continuing movement of animals over the ensuing four days before national restrictions were introduced and it is likely that this contributed to further spread of the disease.  Although the immediate imposition of national controls would have caused some inconvenience, with hindsight the benefits of doing so would have greatly outweighed any difficulty.  In any future disease outbreak where there is any possibility of long distance movement, national controls should be introduced immediately until the epidemiology of the outbreak is more clear.

The RSPCA believes that, given the severity of disease to the individual animal and highly infectious nature of the disease, slaughter is the best outcome for infected animals.  Because of the close proximity in which farm animals live this must inevitably mean the slaughter of the entire herd or flock.  The efficacy of a vaccination regime is discussed later.

The RSPCA was dismayed at the policy of the contiguous cull and this was expressed in correspondence to DEFRA at Letter 2.  It is clear that symptomless animals which have been in direct contact with infected animals are almost certain to become infected and therefore reasonable to slaughter them before they excrete virus or show symptoms and are therefore a risk to others.  However the contiguous cull policy made no attempt to assess the likelihood of those animals having been infected and became a ‘blind killing machine’.  The Society is aware that there was local variation in the application of the policy and that some veterinary surgeons were empowered to undertake risk assessments and modify the blanket policy.  An example of the scenario where the policy was not modified is at Case 6.  However there is epidemiological evidence that the policy did not affect the course of the disease as it appears with hindsight that there was already a downward trend.  However it certainly increased the numbers of animals to be killed.

The slaughter of those animals had two inevitable effects: the already stretched slaughter and disposal systems were further stretched increasing diagnosis-to-slaughter interval leading to further spread of disease; and compensation payments have been higher.  Had proper basic risk assessment been carried out by the veterinary surgeon on the infected premises this could have been largely avoided.  Furthermore the increased local movements of people, machinery and carcasses must at the least have increased the likelihood of local disease spread.

The RSPCA is not in a position to assess the direct impact on the economy.  However the welfare implications of mass slaughter on the scale seen during this epidemic must have had some effect on the image of UK in the wider world.  The world was told of and saw pictures of millions of animals being killed or left to suffer in fields of mud in a country which was the self-proclaimed leader in animal welfare and this must have a negative effect on the UK’s image and therefore tourism.  Had the numbers killed been lower and the strategy used to control the disease been better explained the damage might not have been as great.

Would the use of vaccination have made any difference to the scale and/or duration of the outbreak, and its wider impact?

The RSPCA discussed the issue of vaccination on many occasions during the epidemic although the public debate was generally poorly informed.  The Society strongly supports any procedure which would reduce the suffering of animals in such circumstances and vaccination clearly has the potential to do so.  In principle the Society supports the concept of vaccination but believes that each epidemic should be dealt with on a case by case basis.  The Society finds it difficult to support the concept of general prophylactic vaccination with the current state of vaccine.  There are seven distinct strains of virus and up to eighty subtypes and no vaccine is available to induce immunity against all of them.  While it is said that there is a greater likelihood of some strains entering the country and this may be true, incomplete protection might produce a sense of security which was unwarranted.

Given that the strain of virus in the epidemic was rapidly identified, the use of strain specific vaccine would have been possible.  There are two possible means of use: ring vaccination and area vaccination.  With both techniques it is necessary to know the current extent of infection so that it is clear which animals are to be vaccinated.  In the early stages of the epidemic there was no clear indication of the extent of infection because of the large number of un-traced sheep movements and the presence of disease undetected for some weeks.  This would have made ring vaccination impractical.  It is accepted by all that rapid introduction of vaccination is essential if it is to be effective in controlling an epidemic.  Given the wide distribution of disease and limited supply of vaccine available at the early stages vaccination would have been impractical. The animal movements required to round up and vaccinate many millions of sheep might also have simply spread the disease further from those animals showing only mild symptoms.  At least in the early stages of the epidemic the Society therefore came to the view that vaccination would not assist in control and could have encouraged the spread of disease.

Once it seemed that disease was localised to certain areas of the country, area vaccination could then have been seriously considered.  Had such vaccination been undertaken the long term consequences also need examination.  Because there was no commercially available validated test to enable the differentiation between a vaccinated animal and naturally infected and immune animal, it would have been impossible to differentiate the two groups.  There is no real consensus between veterinary experts about whether naturally infected and/or vaccinated animals act as virus carriers and whether they are infectious.  It seemed therefore safe to assume the worst, that there is potential for them to be infectious.

In such circumstances it would therefore be unsafe to move vaccinated animals to an uninfected area and such animals would need to be restricted for a period of time or subsequently slaughtered.  The latter policy was adopted in the Netherlands and their ratio of total slaughtered to infected animals was five times higher than in the UK.  The post vaccination slaughter policy adopted by the Netherlands resulted from the imposition of trade sanctions which are imposed on a country which vaccinates its animals against FMD as agreed by the Office Internationale des Epizooties (OIE).  The RSPCA could not have supported such a policy.  If movement restrictions were to be imposed on vaccinated animals the Society would have had considerable concerns for their welfare.  The effects of movement restrictions are highlighted later but there was good evidence that welfare was generally poor.  Because of the inability to differentiate vaccinates from infected animals, any movement restrictions would have needed to be lengthy.  The additional impact on the community of such restrictions would also have been significant.  The RSPCA therefore did not support the concept of vaccination.

The technology to differentiate vaccinates from infected animals has been known for some time.  In October a commercially available blood test to differentiate them was marketed.  The Society understands that the test has yet to be fully validated.  The RSPCA believes that the government should treat validation of the test as a high priority so that, should FMD ever recur, the test is readily available and vaccine can be widely used.  The precise circumstances of vaccine use and the fate of product from such animals must be considered by governments.  This process was initiated at the FMD conference in Belgium in December.  The Society urges the government to continue this process of negotiation with other governments and OIE to ensure that the presence of vaccinated animals does not have the current economic consequences which are, in turn, likely to have animal welfare implications as a result of the reduced value of livestock.

Had this test been available at the start of the outbreak the use of vaccine would have been a viable option and the RSPCA believes that a combined policy of slaughter of infected herds and a vaccination regime in these circumstances would have very significantly reduced the impact of the disease.

What could have been done differently to alleviate the economic, social and animal welfare impact of the unprecedented level of culling and disposal?

The RSPCA believes any reduction in the numbers of animals killed would have improved animal welfare.  It is hard to justify the killing of many millions of animals to control a disease and in particular when many of those animals were entirely healthy and would probably have remained so. The issue of vaccination discussed above and the avoidance of the mandatory contiguous cull discussed earlier would both have reduced significantly the number of animals killed.  The issue of inappropriate slaughter is discussed later.

The transport and disposal of carcasses caused the RSPCA considerable disquiet.  In theory carcasses were transported in sealed vehicles to disposal sites and in some instances this seems to have been undertaken over considerable distances.  The Society has good video evidence provided by a member of the public that the sealing was ineffective and received many other reports that this was the case.  It seems clear that there was little contingency planning for carcass disposal on this scale.  The scale of the problem was exacerbated by the introduction of the contiguous cull as mentioned above.  While there is no firm evidence that it occurred, the Society is very concerned that inadequate carcass transport arrangements may have contributed to the spread of disease.  Clearly this is a major issue which should be rigorously addressed in contingency planning.

How effective were the communications systems for handling and responding to the outbreak?

At an early stage of the epidemic the Society established an internal crisis management group lead by the Chief Veterinary Officer.  The group met daily initially with the aim of coordinating the Society response to the animal welfare issues raised by the epidemic and to ensure that no actions by Society staff dealing with animals would add to the spread of the disease.  The group provided operational guidelines for staff and acted as the focus for communication within the Society and with other agencies.  This was an effective mechanism and provided good liaison with other non-government agencies.

The poor communication between government agencies and others involved in the control of the epidemic was a major feature of the epidemic.  It seemed to the RSPCA that on many occasions the Society was positively excluded which therefore prevented staff from doing their best to safeguard animal welfare.  The assistance of Inspectors was offered to assist in monitoring transport of animals but declined.  The Society received none of the routine communications and staff found it difficult to obtain any response from MAFF/DEFRA at a national level.  At a local level relationships were very variable.  Some DVMs were extremely helpful and appreciative of the assistance offered by Society staff.  The attitude of others was unhelpful and bordering on the obstructive, particularly when investigating complaints of inappropriate slaughter.

In view of the shortage of trained staff experienced by MAFF/DEFRA the Society found the reluctance to use the staff offered surprising and disappointing.  This was particularly so when dealing with the animal welfare staff of MAFF/DEFRA.

The establishment by Elliot Morley, of a welfare consultative group meeting was the sole exception.  The group first met on 6th April 2001 and at regular intervals throughout the epidemic until September.  The ministerial briefings and subsequent discussion were invaluable and enabled the organisations represented to raise welfare concerns at the highest level.

The MAFF/DEFRA website did provide a useful source of information to the Society and general public.  However reliance on a single means of information dissemination using a method not available to all cannot be efficient.  The effectiveness of the website could be improved by partitioning to allow restricted access by password to information which needs to be known by a limited community.  Passwords could be issued to all veterinary surgeons and this would undoubtedly improve information dissemination.  If a system of interactive information dissemination could be used it would undoubtedly be welcomed.

Inappropriate slaughter

RSPCA call centres received 130 complaints of inappropriate slaughter from members of the public and farmers.  A small cell was established to investigate these complaints to ensure a rapid response and consistency.  83 complaints contained enough substance to obtain statements.  The investigating officer received a generally poor level of cooperation from MAFF/DEFRA staff and a lack of recognition of the Society’s role in investigating cruelty to animals.  Again the attitude of DVMs was variable and in one case obstructive.  Such response is both unhelpful to a professional officer undertaking a valid investigation and also gives the impression of having something to hide.  Sadly a similar response came from some senior police officers. 

There was considerable correspondence concerning inappropriate slaughter at Letters 4, 9, 10, 11, 17, 19 and 21.  Although all the replies gave assurances that welfare was at the forefront of minds, experience did not support this.

Slaughter Technique:  The great majority of animals were killed by stunning with a captive bolt followed by pithing to actually kill the animal.  Regrettably, modern abattoir practice disbars the pithing procedure as a precaution against BSE and so a significant number of slaughtermen from abattoirs appeared not to pith animals.  As a result there is good evidence that many regained consciousness and some were found standing the following day. These animals would have suffered greatly.  MAFF eventually issued an instruction to all slaughtermen telling them to pith all animals but the Society understands this was not done until 28th March and by this time many animals will have suffered.  It should have been possible to foresee that this would happen and the slaughter instruction should have been issued at the start of the epidemic.

Where there was difficulty in restraining animals free bullet weapons were used and on several occasions the results were disastrous for animal welfare.  The best documented incident is at Case 7.  While the RSPCA appreciates that there are occasions when the use of a free bullet weapon is preferable, there must be adequate facility for some form of restraint and the authorities must ensure the weapon is of sufficient calibre and that adequate ammunition is used.  There were a number of occasions when this was clearly not the case and DEFRA must consider now issuing adequate instructions on such matters.

There has been considerable discussion about the efficacy of intra-cardiac Pentobarbitone for the euthanasia of lambs.  The drug is licensed for such use and the experience of Society staff is that, in skilled (veterinary) hands, it is pain free and therefore efficacious.

The RSPCA also highlighted the efficacy of captive bolt stunning/pithing as a means of slaughter for animals close to parturition.  Because of the time of year, many of the animals slaughtered in the early stages of the epidemic were heavily pregnant ewes.  In such circumstances the foetus is likely to be fully formed and viable.  In other words if a caesarian section were to be performed the lambs would be alive.  When the ewe is stunned and pithed there is no direct effect on the foetus and it must therefore die of asphyxia.  This clearly has the potential to cause suffering although there is no evidence that it does.  On the precautionary principle the Society suggested in Letter 4 that heavily pregnant animals should be sedated before slaughter to ensure that the foetus was insensible to prevent suffering.  There is no evidence to suggest that any action was taken by MAFF/DEFRA.  Clearly this is an area where further research is required and DEFRA should initiate this at the earliest opportunity.

Staffing and supervision:  The RSPCA understands that a significant proportion of slaughtermen were employed on ‘piece rates’.  Evidence was received from farmers that such slaughter teams had less regard for animal welfare in the interests of getting the job done and moving to the next.  While this may be natural, the Society considers that the payment of a daily rate would help to prevent any tendency to downgrade the welfare of animals to be killed.

At early stages of the epidemic each slaughter site was supervised continuously by a veterinary surgeon.  The motivation seems to have been two-fold: to ensure proper regard for biosecurity; and to protect animal welfare.  However in May MAFF issued instructions that veterinary surgeons should be tasked with the supervision of up to ten slaughter sites.  The response from the veterinary surgeons involved and from the RSPCA was very negative and is raised in Letters 16, 17 and 19.  The Society believes that the supervision of more than one site is unacceptable and would like to see this requirement incorporated in the Welfare of Animals (Slaughter and Killing) Regulations (WASK).

Transport of animals

The commercial transport of animals in UK is governed by the Welfare of Animals (Transport) Order (WATO).  The Regulations state in Article 4(3) that no animal shall be transported if it is about to or has just given birth except in exceptional circumstances which will not cause unnecessary suffering.  The RSPCA has considerable anecdotal and some personally observed evidence that WATO was widely ignored, particularly for sheep.  The Society is aware that many such instances were followed up by veterinary staff at the Great Orton slaughter site.  However, the fact that such incidents occurred does illustrate the attitude of staff employed by MAFF to the welfare of the animals with which they were dealing.  This issue was also raised personally with senior MAFF staff and in Letters 5 and 6.  In spite of the assurances received no reinforcement instruction was issued to the best of the Society’s knowledge.  In times of crisis animal welfare is arguably even more important and the Society believes it should be given even greater attention.

Movement Restrictions

Movement restrictions were, quite correctly, imposed at the early stage of the epidemic.  Comment has already been made about the timing of their imposition.  The restrictions had a dramatic impact on the welfare of many animals; indeed it could be argued that those animals stuck for months on farms suffered more than those directly affected by the disease.  The welfare problems induced took broadly two forms.

Inappropriate accommodation:  In many instances animals were stuck in fields which were adequate for short term accommodation.  However because of movement restrictions their owners were unable to move them and conditions deteriorated in the very wet weather.  Correspondence is at Letter 1.  An example is at Case 8.

Inadequate food:  Where farms were subjected to long term movement restrictions, the ability of the farmer to provide adequate food reduced over time.  This was particularly so for animals on farms served with a Form D notice, many of which were under restriction for many months, and particularly in the worst affected areas of Devon and Cumbria.  On such farms the inability to remove animals, continuing production of new animals from those pregnant when the epidemic started, and limited ability to produce food on farm produced a deficiency of food.  This was exacerbated by the inability of the farmer to sell as much product and so reduced income.  The RSPCA dealt with many cases of severe financial hardship underlying severe animal welfare problems.  Some cases were so extreme that slaughter of the animals on farm was the only solution.

To assist such farmers the RSPCA instituted a brokerage scheme which initiated in the South West and grew to become a national scheme.  It was run in close liaison with the ARC Addington Fund and resourced from both sources.  A full description of the South west scheme is at Case 9.

Both of these circumstances were a direct result of movement restrictions.  However the remedy to alleviate the severe animal welfare consequences were left to charities to provide a solution.  The RSPCA recommends that, where general movement restrictions are imposed for a protracted period the government must take some responsibility for the effect of those restrictions at farm level.  Clearly a safe means of allowing efficiently licensed normal production movements to re-commence at an early stage would be an effective means of alleviating such welfare problems.

Individual identification of sheep and movement tracking

Key to the epidemiology underlying the management of epidemic diseases such as FMD must be the ability to track individual animals.  Clearly this is currently possible with individual cattle because they are identified.  However the fact that sheep are not identified as individuals must complicate any tracking.  The RSPCA considers that the government should take immediate action to enable individual identification of sheep.  The Society accepts that ear tags have significant disadvantages which may cause welfare problems and encourages the government to implement identification by electronic means.  No identification scheme would be useful without the national database and record management scheme to support it.

Import of animal products

The RSPCA understands that the most likely means of entry to UK of FMD virus in this epidemic is by imported meat and that this is likely to have been introduced either by a returning holidaymaker or by smuggled meat.  The Society is dismayed that there is still insufficient information presented to persons entering the country about the prohibitions on importing animal products.  Whereas other countries insist on announcements on inbound aircraft and notices are prominent at airports, no such action has apparently been taken by UK.  The Society believes that serious consideration should be given to banning the private import of animal products into UK.

As the UK animal population is entirely susceptible to FMD and other non-indigenous diseases such simple precautions would seem essential.  As many of these diseases are as significant a threat to animal health and welfare as FMD the Society finds it inexcusable that more action is not being taken.  The fact that human health is also at risk makes the rapid implementation of such measures even more important.




During the FMD epidemic the RSPCA was literally inundated with telephone calls and e-mails asking for advice or reporting apparent cruelty.  Below are some examples used to illustrate some points made in the submission.

Case 1:  Failure to Assist

In mid April it was clear that many flocks in East Anglia were stranded on winter keep and about to lamb.  On one particular farm the RSPCA was given about a week’s warning that lambing was due to start.  There was no shelter available and the Society’s assessment was that it could only be provided by using tents.  A search for suitably large tents revealed that most contractors were unwilling to hire tentage for a purpose which was likely to render them unusable in future.   MoD was therefore identified as a source of suitable tents and they were approached.  Society staff were told that tents were available and would be erected by soldiers if MAFF would provide funding for replacement and labour as the tents were unlikely to be useable again for military purposes.

Accordingly senior RSPCA staff approached senior MAFF animal welfare staff at Page Street.  After consultation at Page Street Society staff were told that there was no budget to fund the provision of tentage.  Consequently Society charitable funds were used to provide tents to protect the welfare of the sheep and they were successfully lambed by Society staff.

Case 2:  Society involvement in LWDS

LWDS was established on 22nd March 2001 to enable the numbers of stock on farms where there was insufficient food or accommodation to be reduced.  Because of movement controls many animals were suffering from very poor welfare conditions and urgent action was required to alleviate their suffering.  However the scheme was bureaucratic and often the period between application to enter the scheme and animals being removed was forecast to be as long as six weeks.

The RSPCA deployed staff to the Intervention Board offices in Newcastle on 17th April 2001.  They were briefed to assist in prioritising applications to LWDS in liaison with RSPCA Inspectors.  Eighty Inspectors were given refresher training in biosecurity and suitably equipped.  The Inspectors were then tasked to visit farms where reports of adverse welfare had been received, often from the farmer himself but also from the Intervention Board and ADAS.  The Society received over 1,750 such reports concerning approximately 250,000 animals.  The Inspectors prioritised according to need.

Welfare conditions on almost half (850) of these farms were considered so bad that in more normal circumstances the RSPCA would have prosecuted the farmer under the Protection of Animals Act 1911 for causing unnecessary suffering and immediate action was considered necessary.  In many other cases the conditions would have initiated a verbal warning.

The entire operation was controlled by one of the Society’s ten Regional Control Centres.  To enable this all other work was diverted to other centres.  In addition to RSPCA staff at the Newcastle office there was close liaison with the Intervention Board at Reading and ADAS.

Case 3:  Result of Over Pricing of Livestock

A Regional Control Centre received a report of dead sheep in a field on land owned by MoD.  On investigation an RSPCA inspector found a flock of about 1,200 sheep on waterlogged land and approximately twenty dead sheep amongst them.  The owner of the animals was traced and informed the inspector that application had been made for the heavily pregnant sheep to be slaughtered under LWDS.  The inspector enquired why the sheep had not been given access to large sheds adjacent to the fields and the owner claimed that he had not been allowed to do so by MoD staff.  The inspector spoke to MoD staff who said they had not been approached and readily agreed to allow access to the sheds for lambing and provided water and power to enable this to be done.

When the owner was informed of this decision he objected.  It required the intervention of Society senior veterinary staff and solicitors talking to the farmer’s veterinary surgeon and solicitor to ensure the sheep were given access to the sheds.  The sheep were withdrawn from LWDS and successfully lambed in the sheds.  It appeared to the RSPCA that the primary motivation of the farmer was financial and that the sheep need never have been in LWDS.  At that time in-lamb ewes would have been worth approximately #45-50 on the market but were valued at #81 by LWDS.  The potential income for the farmer was therefore of the order of #100,000.

Case 4:  Mass Slaughter Site Great Orton

The mass slaughter site was established by the Army at Great Orton airfield.  In spite of there being no intrinsic infrastructure (water, electricity, sewage) a field slaughterhouse was constructed using temporary and agricultural buildings over a period of a few days.  The technical aspects of the site were supervised by veterinary surgeons provided by the Army and their involvement at an early stage meant that the design intrinsically provided good biosecurity.

Shortly after it commenced operation RSPCA inspectors were granted full time access to the site whenever slaughtering was in progress.  The Chief Inspector supervising Society activity on the site says “From a welfare point of view, given a blank sheet of paper, I feel it would have been very difficult to design a better field slaughter site.” 

Although short-term penning was provided on site, the time spent by animals on the ground was very brief and always less than 25 minutes.  Lambs at foot were segregated immediately on arrival and euthanased by veterinary surgeons using intra-cardiac Pentobarbitone.  Older animals were herded calmly in groups of about thirty into slaughter pens and stunned by four or five slaughtermen using captive bolt.  Because of the calm handling this process caused minimal stress to the animals.  Each animal was then pithed by additional staff and certified dead by a veterinary surgeon before disposal.

Case 5:  Bread and Breakfasting Sheep

Bed and Breakfasting of sheep is a practice associated with the payment regime for the Sheep Annual Payment Scheme.


The payment is a headage payment for all female sheep who have lambed once or who are at least one year old at the end of the retention period (100 days after the application period).


Farmers may apply between the 4th December and the 4th February. Farmers must keep sufficient sheep to cover their claim throughout the entire retention period, and must maintain accurate flock records in accordance with the legislation.


If somebody has decided that they do not want to keep the number of sheep which they have claimed for on the farm for the entire retention period or indeed they have claimed for more sheep than they actually have (which should not be possible because the claim is also based on the farmer having sufficient quota for the number of sheep that he/she has), they often borrow sheep from someone else for a nominal fee and keep them on their farm until the retention period is over. The sheep can then return to their original holding or another holding. Hence when they are checked for numbers the farmer has the required amount. You can therefore get many movements of sheep and because they are not properly identified there is significant potential for fraud.

Case 6:  Contiguous Cull Policy

This is but one of many examples of a contact from a concerned farmer.  Often they would give neither their name nor location.

A report was received by the RSPCA that MAFF were to slaughter animals on a farm under the contiguous cull policy.  The farmer contacted the RSPCA because he considered this unjustifed as all his stock had been housed for six weeks and hence prior to the start of the epidemic and he considered his biosecurity good.  Furthermore he was some three miles from the nearest infected farm although his farmland abutted that of the infected farm.  He was advised to contact his DVM.  The Society understands that all animals were slaughtered.

Case 7:  Inappropriate Slaughter

On 11th April 2001 the Brecon Regional Control Centre received a report that sheep were being shot in a field in a 'willy-nilly' fashion; they were not being killed with the first shot; the police were in attendance and had told neithbours to go indoors as 'MAFF are doing the killing'. The caller had video footage of some of the proceedings.


The Society’s nearest officer was deployed but it was some 45 minutes before she arrived, by which time the carcasses of all the sheep involved had been loaded into a trailer, and those responsible were packing up ready to leave. Two Trading Standards officers identified themselves but the police officers would only give their collar numbers.


RSPCA Inspectors were able to establish that the animals had been straying on the nearby busy A465 'Heads of the Valleys' road. There was a history of the animals' owner allowing them to stray in this way and the Trading Standards officers, in consultation with their superiors, had made the decision to put the sheep down on this occasion in view of  the Foot and Mouth crisis. The field in which the animals were shot was not that from which they had strayed, nor was it connected with the animals' owner in any way.


The video footage was given to the Daily Mirror and to the television companies. It caused an enormous reaction and brought about the involvement of the Health and Safety Executive, who initiated an investigation which included seizing the weapon in question.


The RSPCA investigation involved the taking of a great number of statements from witnesses.  The Prosecution Department was in correspondence with the local authority, Monmouthshire County Council; the police co-operation was limited; the HSE had suggested a joint investigation initially but then quickly retracted. In summary, it was a difficult enquiry and ultimately Counsel’s advice was that no prosecution should be taken.


Case 8:  Assistance to Farmers with Lambing

It is common farming practice for in-lamb ewes from hill farms to be over wintered in lowland areas, often feeding on root crops.  The sheep are normally returned to their home farm prior to lambing. Many ewes were at winter keep when the epidemic started and were therefore stuck once movement restrictions were imposed.  The RSPCA detected this as an issue primarily in East Anglia where many ewes were on root crops with no shelter.  Their welfare was clearly compromised by this situation and the onset of lambing induced a dramatic worsening of the situation.  Many flocks were knee deep in mud and any lambs born were in severe danger of dying from hypothermia.  At the time no MAFF licence was available to return the sheep to their home farms which were often many hundreds of miles away.  Similarly their shepherds were unable to travel to the ewes because of the distance involved and other commitments on their home farms.

The RSPCA mobilised staff and gave them short lambing courses.  Shelter was provided using tented accommodation and bales.  Over a period of approximately six weeks eleven thousand sheep were successfully lambed and were returned with their lambs to home farms once movement restrictions were relaxed.  The Society provided this service free of charge to protect the welfare of the animals involved.

Case 9:  Brokerage Scheme in South West England

Ten Inspectors and the South West Regional Control Centre (RCC) Controllers spent a great deal of their time trying to source the necessary supplies of feed and bedding to alleviate shortages on farms.  With good local publicity, the RCC was receiving many offers of help.  We had offers of free hay or straw, of cheap hay, of free lorry-loads of woodchips, of lorries for transport, even offers to deliver our supplies in cars and on roof racks.


The sourcing of supplies needed to be a full-time job.  This role was taken over by a monitor for Freedom Foods, who could not continue with her role because of FMD.  She was based in the Regional HQ for the majority of her time.  The offers of help, and requests for help were logged onto the RSPCA computer system by the RCC, printed out, and given or faxed to her.  She then had the complicated job of working out which offers could be used.  So much of the feed was trapped in infected areas that it was often difficult to match offers to the needs.  She built up an invaluable record of good suppliers who would work with us to ensure good value, and a quick response.  We worked closely with the ARC Addington Fund during this period, and were able to arrange for feed banks to be set up to minimise delays in responding to requests for help. 


Much of this brokerage work was done late at night, when farmers returned home, and could be contacted by telephone.  This personal contact was, in many cases, as valuable as the practical help being offered.

Farms assisted by supplying feed

Farms assisted once                 83

Farms assisted twice                19

Farms assisted three times        8

Farms assisted four times         7


Total number:               171

Farms assisted by brokerage

(matching offers of help with requests for help)

Total number                            108

Animals benefiting from the work of the FMD Inspectors and brokerage

Total number                            441,012

Details of supplies to farmers

7        69,000 bales of hay, straw and bedding

7        139 tons of feed

7        10 lorry-loads of wood chips

Total cost of supplying feed and bedding:            #67,980.



For completeness all correspondence between the RSPCA senior staff and Ministers or senior government officials is included in this Annex.  Letters are referred to in the body of the document by their first number.  Hence letter 1/1 and its reply is referred to as Letter 1.

Letters have been paired so that the letter from the Society is immediately followed by the relevant reply, where one was received at all, and annotated accordingly.  So letter 1/1 is followed by the reply annotated as letter 1/2.  The originating letters are in chronological order although replies are not.