THE NATIONAL FOOT & MOUTH GROUP

 

 

 

 

SUBMISSION

TO

 

 

 

 

 

THE LESSONS LEARNED INQUIRY

 

 

INTO

 

 

THE 2001 UK FMD EPIDEMIC

 

 

 

 

 

 

 

 

MARCH 2002

 

 

 

 

THE NATIONAL FOOT & MOUTH GROUP

An affiliation of organisations affected by 2001 UK epidemic

 

Co-ordinating Office: 3 The Common, Siddington, Cirencester, Glos GL7 6EY

Tel: 01285 644319 / 01285 656812

 

 

 

 

 

 

EXECUTIVE SUMMARY

 

 

Foot and Mouth Disease in a developed European economy is not just a disease of agriculture but affects all areas of the community. It carries with it a huge human, social and economic cost.

 

The purpose of this submission is to set before the Inquiry the far-ranging consequences of current control policies and, in responding to the issues raised by the Inquiry, consider how alternative controls could be effected.

 

We consider that the key factors for consideration are; the role and nature of contingency plans, speed of response, provision of sufficient facilities to deal with the disease and for control procedures to be founded on well-substantiated scientific principles. The issue of vaccination is of paramount importance.

 

We have sought to demonstrate the wide, and often disproportionate impacts of the disease and its control, that have affected the rural economy, rural communities and their social fabric, during the current epidemic. Of great significance is the need to maintain normality for other sectors of the rural economy and ensure a form of disease control that does not cause extensive harm and financial loss to these interests.

 

We have also considered how the control of Foot and Mouth Disease must be viewed in relation to international trade and in conjunction with control procedures used both in mainland Europe and the rest of the world.

 

The role of modelling in forecasting disease spread and its subsequent control is addressed and regard is also had to the need for empirical evidence to direct future control procedures. We have considered the adopted policies and their impacts and detailed alternative methods of control.

 

With regard to vaccination we have put forward how we view its use and application to control future outbreaks We examine the current policies and practices that have militated against the use of vaccination in the current epidemic and suggest how these should be addressed.

 

Finally, in the construction of this response, we have sought to ensure that future control policies never again cause the indiscriminate slaughter of healthy animals in such vast numbers to maintain an economic market.

 

Acknowledgements:

 

The National Foot & Mouth Group gratefully acknowledge the help and assistance of various scientists and vets in the production of this submission and for the contributions from the many who have been affected by the disease.

 

 

 

CONTENTS

 

 

 

1 INTRODUCTION

 

 

2 CONTEXT & BACKGROUND

 

 

3 CONTINGENCY PLANNING &

HOW EFFECTIVE AND TIMELY WAS THE GOVERNMENT'S RESPONSE?

 

3.1 National Movement Restrictions

 

3.2 Contingency Planning

 

3.3 The Impact of Lack of Provision for Laboratory Diagnosis

 

 

4 WHAT MORE COULD BE DONE TO PREPARE FOR POSSIBLE

FUTURE OUTBREAKS OF FMD?

 

4.1 The Risks of Future Outbreaks and the Importation of Infection

 

4.2 Surveillance & Monitoring

 

4.3 The Need for Pre-Agreement as to Methods of Control

 

4.4 Preparing to Deal With Possible Future Outbreaks

 

 

5 WAS THE RESPONSE PROPORTIONATE TO THE IMPACT ON THE WIDER RURAL AND UK ECONOMY?

 

5.1 Adopted Policies & Their Impact

 

5.2 Were all the 3KM & Contiguous Cull, Slaughter on Suspicion and Dangerous Contact Culls Necessary?

 

5.3 Capacity for Laboratory Diagnostic Testing

 

5.4 Diagnostic Procedures

 

5.5 Conclusions on the Handling of the Outbreak

 

 

6 WOULD THE USE OF VACCINATION HAVE MADE ANY DIFFERENCE TO THE SCALE AND/OR DURATION OF THE OUTBREAK AND ITS WIDER IMPACT?

 

 

 

 

 

 

 

CONTENTS, contd

 

 

 

7 WHAT COULD HAVE BEEN DONE DIFFERENTLY TO ALLEVIATE THE ECONOMIC, SOCIAL AND ANIMAL WELFARE IMPACT OF THE UNPRECEDENTED LEVEL OF CULLING & DISPOSAL?

 

 

7.1 DRAFT PROGRAMME FOR THE USE OF EMERGENCY, PROTECTIVE VACCINATION FOR THE CONTAINMENT, CONTROL & ERADICATION OF FMD

 

 

7.2 CONTROL IN THE FUTURE & THE ROLE OF VACCINATION

 

Modern Vaccines & Tests

 

 

7.3 THE ROLE OF THE OIE

 

Sale of Meat and Animal Products Post Vaccination, Disease Free Status and Export Markets

 

 

 

8 RECOMMENDATIONS

 

8.1 The Adoption of Process and Procedures to deal with future outbreaks

 

 

 

9 CONCLUSIONS

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

THE NATIONAL FOOT & MOUTH GROUP

An affiliation of organisations affected by 2001 UK epidemic

 

Co-ordinating Office: 3 The Common, Siddington, Cirencester, Glos GL7 6EY

Tel: 01285 644319 / 01285 656812

 

 

 

SUBMISSION TO LESSONS LEARNED INQUIRY INTO FMD

 

 

1 INTRODUCTION

 

The National Foot & Mouth Group came together in April/May of 2001 and comprises organisations and individuals who were concerned at the adopted control methods used to deal with the UK 2001 FMD epidemic.

 

The Group was particularly aware of the effect of these control methods on farmers and livestock owners, and the huge scale of impact on the rural economy, animal welfare and the social fabric of rural communities.

 

The Group was involved in ensuring advice and support was provided to farmers and animal owners in dealing with the epidemic and in providing information for those who did not want their animals slaughtered if they did not have the disease. Many of those involved advocated that an appropriate vaccination strategy should be adopted to assist in controlling the outbreak.

 

Throughout the course of the outbreak representations were made to the UK Government. Subsequently the organisation has made full and detailed submissions to both the Royal Society Inquiries of London and Scotland and the Welsh Assembly Inquiry.

 

This submission is based on our experiences during the course of the epidemic, information gathered during that time and on subsequent research and investigation.

 

We also submit our proposals for an emergency, protective vaccination programme for the control of a future outbreak of FMD.

 

While we appreciate the work and application that has been demonstrated by Dr Iain Anderson and his team we wish to make it clear that this organisation has always maintained that a full public and open inquiry should be conducted to consider the 2001 UK FMD outbreak.

 

We consider that it is only through such a format that those affected will be able to establish exactly what happened during the course of the epidemic. Most importantly there are many unanswered questions and issues that have arisen in the past 12 months. Without the ability for these matters to be publicly raised and the evidence questioned and tested we feel that much will remain undisclosed.

 

Our greatest concern is that much of the advice and information provided to, and acted upon by the Government, has gone unchallenged and implemented without the appropriate scientific justification or the relevant cost benefit analysis

 

In particular the evidence presented to the EFRA Select Committee should be subject to rigorous scrutiny and cross-examination, which has been informed by expert witness opinion. The views expressed during these sessions were based for the most part on assumptions, assertions, suppositions and perceptions. Taking this evidence without provision for it to be properly tested is a major cause for concern. Many of the views expressed have not been supported by any scientific data or rationale.

 

We now know that the laboratory test results for Infected Premises, Slaughter on Suspicion, Dangerous Contact, Contiguous & 3km Culls are so incomplete as to be meaningless. There is no factual and objective method available to justify or demonstrate the validity of the adopted policies.

 

Without the opportunity to test, question and cross examine the evidence of these witnesses it will never be known if their advice to Government has any basis in sound, reliable data and fact. It is only by pursuing a course of informed questioning that the flaws and shortcomings of this evidence will be revealed.

 

Having experienced the impact of the adopted policies, scrutinised the subsequent results and had regard to many of the scientific papers, we would welcome the opportunity to discuss with the Inquiry the specifics of the evidence which we feel deserves the closest scrutiny.

 

 

2 CONTEXT & BACKGROUND

 

We submit that it was not the disease itself which created the massive and disruptive impact of the UK 2001 FMD epidemic, but rather the methods adopted to control the disease. The delayed response to impose nation wide movement restrictions and the control measures which were then effected resulted in the catastrophic and unprecedented financial, social, animal welfare and environmental disaster.

 

A key concern is whether the defence of a meat and livestock export market worth circa £550 million per annum warranted the approach and control measures which were then imposed.

 

The control procedures of stamping out', with slaughter and contiguous culling was utilised because this would enable a return to Disease Free Status and export markets 3 months after the last case, as opposed to 12 months after the last case if vaccination was used. There appears to have been no evaluation that it may be better to use vaccination to control the disease, and lose Disease Free Status for a year, rather than inflict the major losses and socio-economic costs which resulted from the adopted policy. The effect of the slaughter policy resulted in:

 

1 The slaughter and destruction of circa 10 million animals, the vast majority of which were healthy. Many of these animals represented the life's work of many farmers and were the product of years of commitment to animal husbandry. They also included many prized herds and flocks and irreplaceable blood lines.

 

2 A cost to the Exchequer of £ 2.7 billion. Farmers have been paid £ 1.72 billion in compensation. The epidemic also caused massive and disproportionate losses to other sectors of the rural economy, however they have received no compensation.

3 A cost to the tourism industry of £ 4 -5 billion and an estimated total cost to the nation of circa £ 20 billion - Source English & Welsh Tourist Boards & Institute of Directors. Many employed in tourism and other sectors of the rural economy have faced financial hardship, bankruptcy or lost their employment.

 

4 Massive welfare problems of animals that could not be moved - and faced starvation, adverse weather conditions with no shelter, and had to remain in totally inappropriate circumstances for calving and lambing.

 

5 Major breaches of the regulations regarding humane slaughter

 

6 Despoilment of the countryside and rural areas as funeral pyres and mass burial pits were constructed to deal with the vast numbers of animals to be disposed of.

 

7 Stress and emotional upheaval for those involved in the loss of livelihoods, their animals, and their life's work of breeding and rearing livestock. These effects also applied to those under Form D's who were unable to move, sell or often feed their animals and faced financial hardship and bankruptcy.

 

8 Psychological impact on individuals and rural communities in witnessing the wholesale destruction of so many animals and farms. Also the effects on those who had to endure funeral pyres and burial pits in their vicinity.

 

9 Loss of 9,700 jobs - Source ITN News - 21 February 2002

 

10 Irreversible changes to farming practices and land management - nearly 25 % of affected farmers have not restocked.

 

The Inquiry has no doubt heard verbatim accounts of the many and varied effects and impacts of the epidemic during the course of its visits to Devon, Wales and most recently Cumbria and in the near future, Yorkshire.

 

It is against this background and context that we make our submission.

 

 

3 CONTINGENCY PLANNING &

HOW EFFECTIVE AND TIMELY WAS THE GOVERNMENT'S RESPONSE?

 

 

3.1 National Movement Restrictions

 

3.1.1 Although the disease was first confirmed on the 20 February 2001, following identification of clinical symptoms at Cheale Meats in Essex on the 19 February, it was not until 5pm on Friday 23 February that nation wide movement restrictions were imposed.

 

3.1.2 It should be noted that Holland imposed immediate movement restrictions as soon as the disease had been confirmed on the 20 February 2001.

 

3.1.3 In the 3 = days that elapsed massive animal movements continued across the UK, and many major livestock markets were held. (J Scudamore's evidence to Brussels Conference and Vet Record of Dec 15 - Descriptive epidemiology of the 2001 FMD epidemic in Great Britain: the first five months.)

 

3.1.4 This failure to impose national movement restrictions on the 20 February allowed the disease to become distributed across most of western England, southern Scotland and eastern Wales. Creating in effect 12 separate outbreaks across the UK.

 

3.1.5 Prof Mark Woolhouse of Edinburgh University giving evidence to the EFRA Select Committee on the 7 November 2001 stated:

" if we had imposed a national movement ban on February 20, three days earlier, our estimation is the epidemic would have been between one third and one half smaller than it actually was." See para 214

 

3.1.6 The question we hope the Lessons Learned Inquiry will put to the UK Government is why national movement restrictions were not imposed as soon as the disease had been confirmed by laboratory testing. This may well have prevented the disease from becoming distributed across the UK and confined the outbreak to only one or two counties.

 

3.1.7 It may be worthwhile for the Inquiry to consider in detail the EFRA Select Committee report and in particular the maps showing the time scale of distribution of the disease to ascertain precisely when FMD become distributed across England and entered Wales and what effect national movement restrictions imposed on the 20 February would have had.

 

3.1.8 Certainly in any future outbreak we submit that national movement restrictions should be imposed immediately the index premise has been confirmed.

 

 

3.2 Contingency Planning

 

3.2.1 Despite the existence of an EU Contingency Plan drawn up and adopted in 1993 there appeared to be little evidence of appropriate contingency plans, either at national or local level. Both these scenarios are considered in detail in the EU Contingency Plan. Similarly, in 1999 the EU adopted a Strategy for the Use of Emergency Vaccination to Control FMD - but neither its findings nor recommendations have been adopted by the UK Government.

 

3.2.2 The impact of the inability to reliably and accurately determine the presence of FMD through clinical diagnosis alone is detailed below. The adopted control methods of slaughter and cull created massive logistical problems in that huge numbers of dead animals were generated which had to be transported and disposed.

 

3.2.3 No doubt the issue of burial pits such as the Epynt site, the Great Orton site, and others have already been considered by the Inquiry but in addition the very haulage of contaminated carcasses along major routes, such as the A40, A470, in Wales and along the haul routes used to other pits, etc may well have contributed to the spread of the disease.

 

3.2.4 Despite the best endeavours of the army and other personnel drafted in to deal with animal carcasses the problem of disposal still remains as many pits and pyres are having to be dug up and reburied.

 

3.2.5 The sheer number of TVI's that were needed far exceeded the meagre supply of SVI's and many of the TVI's recruited were not used to dealing with large animals, the language, the farm environment or knew how to communicate with farmers. Between 1979 and 2001 the number of SVI's fell from 597 in 1979 to 286 in 2001 vets employed by the State Veterinary Service - see attached Parliamentary Answer of 26 March 2001. Appendix 1

 

3.2.6 One of the greatest criticisms made at the Builth Wells meeting of the Lessons Learned Inquiry was the breakdown in communication at all levels and in relation to so many issues ranging from disease control, issuing of forms, livestock welfare schemes, licensing of movements, etc, etc

 

3.2.7 An even stronger area of concern is that animal welfare was abandoned during the epidemic. The issues of sheep lambing and cattle calving in totally unsuitable circumstances in open fields without shelter, coupled with dreadful weather conditions, gave rise to major and unacceptable breaches of animal welfare.

 

3.2.8 The lack of fodder and grazing resulting in animals starving because they could not be moved and because the farmer could not afford supplementary food to feed them was unacceptable.

3.2.9 The strongest condemnation, however, arose from the methods of slaughter adopted in certain situations. Perhaps the most prominent of these incidents, although many were reported, was the situation at Gilwern. Certainly we have evidence of totally inappropriate methods of gathering, coralling and slaughter which are contrary to the legislation for humane slaughter.

 

3.2.10 The image that emerged was that neither the Government nor other agencies were prepared or ready to deal with the outbreak of the disease. Advice from the EU to prepare contingency plans was not followed up. Similarly warnings from world wide bodies that the pan Asia O' strain of FMD was spreading globally and posed risks of importation were ignored. - see Submission from Mrs Valerie Lusmore - re meetings of the EU FMD Committee and its recognition that the spread of the pan Asia O' strain must be considered and plans put in place to deal with possible outbreaks.

3.2.11 The apparent net effect was that neither at national, regional or local level was an adopted Contingency Plan in place.

 

The Welsh Local Government Association stated in its Report into the Handling of the Disease: October 2001 (We ask the Inquiry to read all of this Report.) Appendix 2

 

"2.5 Despite this, it quickly became apparent that local authority contingency plans alone lacked sufficient scope for the scale of the crisis. The disease was more widespread and longer lasting than most had anticipated, veterinary advice changed, and the impact went much wider than the terms of reference of many plans.

 

2.6 Even more problematic was the absence of a national contingency plan that set out the roles and responsibilities of the various organisations involved and gave clear direction on how to tackle the problem. The National Assembly established a strategic control centre in Cathays Park. Three months into the crisis a Local Government Desk was secured (see Figure 2) following the efforts of local authority officers and proved invaluable to keeping animal health officers informed of progress. However, most local authorities are of the view that it should have happened from day one of the FMD crisis.

 

And at Para 2.12

 

Interim Conclusions on Emergency Management and Communications

2.12 The issues here relate to wider questions about responsibility for handling emergencies in general that are still under review. Further thought and reflection is needed but at this stage it appears that a key requirement is the preparation of detailed contingency plans for FMD and other animal disease by the National Assembly, that spell out its responsibilities and how they relate to those of others. Local authorities will also need to review their own contingency plans in the light of the experience of FMD and any plans developed by the Assembly."

 

3.2.12 The epidemic has had a catastrophic effect on the economy, (£2.7billion cost to the Exchequer, a cost of between £4 to 5 billion for tourism and an overall cost to the nation of £20 billion according to the Institute of Directors), it is therefore crucial that proper provision is made to deal with a future outbreak. In addition there have been impacts and effects suffered by individuals and communities which must not be allowed to re-occur

 

3.2.13 There is now an urgent and fundamental need to ensure that Contingency Plans not only exist but that they are in the public domain. That they have been formulated with contributions from all the key interest groups and that all the main stakeholders know what procedures are likely to be adopted and, most importantly, how these are to be executed.

 

3.2.14 Update - Post publication of the DEFRA Interim report on the Control of FMD which appeared on the DEFRA website on 12 March 2002.

 

This is the first UK Government Contingency Plan that we have seen. Although one was reported to exist it was never made public or published on the DEFRA website - certainly it was not made available during the UK 2001 FMD epidemic.

 

Although we have not had the opportunity to fully consider this paper it appears not to have been subject to the involvement of key interest groups and stakeholders as we suggest above. Also, vaccination only merits a brief mention. Still no regard has been had to the provisions for vaccination as provided in both the EU Contingency of 1993, or the EU Emergency Strategy for Vaccination of 1999.

 

Considering the impact of the last outbreak and its control through the slaughter and cull policies we submit that this is not acceptable.

 

 

3.3 The Impact of Lack of Provision for Laboratory Diagnosis

 

3.3.1 It is impossible to determine the true scale of the epidemic because many of the Infected Premises were not laboratory tested to confirm the presence of the disease. Only 1728 of the 2030 Confirmed Cases in the UK were tested. In Wales 102 of the 115 Confirmed Cases were tested.

 

3.3.2 Also very few of the Contiguous Cull, Dangerous Contact, Slaughter on Suspicion cases were laboratory tested.

 

In total there were 9461 Affected Premises culled across the UK and only 2372 were sampled, of these only 1327 had positive results.

 

In Wales a total of 806 farms were culled but only 147 were sampled of these only 60 showed positive results.

 

All the figures quoted are derived from the Answers given by the Secretary of State to Parliamentary Question 2164 - 8 January 2002

 

3.3.3 Clinical diagnosis, particularly in sheep, is extremely difficult. It was for this reason that Alex Donaldson and Paul Kitching both from the Animal Health Institute at Pirbright wrote to the Vet Record on the 19 May 2001 to say that

 

"While it is never the intention that laboratory diagnosis would replace clinical diagnosis, we believe that laboratory support for a diagnosis of FMD in sheep, in particular, is essential." Appendix 3

 

3.3.4 The net result in England was that of the 1724 Infected Premises only 1458 were sampled and of these only 1157 proved positive on laboratory testing.

 

The net result in Wales was that of the 115 Infected Premises only 102 were sampled and of these only 60 proved positive on laboratory testing.

 

3.3.5 In total 7083 farms were culled in England, only 1992 were sampled and of these only 1158 proved positive

 

In total 806 farms were culled in Wales, only 147 were sampled and of these only 60 proved positive.

 

3.3.6 It will no doubt be argued that the laboratory testing may not have picked up the early stages of the disease but it is clear from the Donaldson/Kitching letter that the testing at Pirbright was very sensitive and should have done so.

 

3.3.7 It should be noted that out of the total of all the SOS's, DC's and Contiguous Culls in England 5359 only 534 were sampled for the whole of England - only 1 proved positive.

 

In Wales, out of the total of all SOS's, DC's and Contiguous Culls 691 only 45 were sampled - all proved negative on testing.

 

The Inquiry is now also aware of the situation regarding the incidence of disease as demonstrated by the lab test results and the number of farms slaughtered in the Gloucestershire, Herefordshire, Worcestershire and Shropshire region and the Anglesey situation and the controversy that surrounds the extent of the cull relating to the abattoir.

Appendices 4 & 5

 

3.3.8 Two issues are clear. It is not acceptable to rely on clinical diagnosis alone to determine the presence or otherwise of FMD.

 

Secondly much greater provision of laboratory testing needs to be made available to enable swift, accurate and reliable diagnosis.

 

3.3.9 Furthermore the implications of inaccurate or unreliable diagnosis has major and far-reaching implications. The fundamental inter-relation and inter-dependency of agriculture, the rural environment, tourism, the rural economy and communities has been manifestly apparent during the course of this epidemic.

 

In our submission to the Policy Commission on the Future of Food and Farming we set out how each sector cannot be viewed in isolation, but as part of a cohesive whole.

 

"The FMD epidemic has clearly demonstrated that the impact of an animal disease on the agriculture sector is only one consideration and the economic, social and environmental implications of such a disease, or event, can extend far beyond agriculture and create major impacts for other businesses and the wider rural community." NFMG October 2001

 

Given the massive implications of the disease and the manner of its control to the farming industry, animal welfare, the tourism sector and the wider rural economy it is imperative that diagnosis must be accurate. It is crucial that the impact of the disease is minimised to reduce the massive and disproportionate effects on the rural environment, its economies and its communities.

 

3.3.10 As an example we submit a brief Case Study of the impact of misdiagnosis on the inter-related and inter-dependent nature of agriculture, tourism and the economy. This is with reference to the cancelling of last year's Cheltenham National Hunt Festival.

 

It has been estimated that the cancelling of this event caused a loss of between £10 million and £25 million to the local economy. Also lost were 5,000 part time jobs and 150,000 visitors to the event and the County. - Figures derived from Gloucestershire County Council submission to the LLI and Carlton TV Central News.

 

The farm suspected of having FMD adjacent to Cheltenham Race Course was confirmed as an Infected Premise on clinical grounds - however the lab test results came back negative.

 

Speaking recently the owners of the farm said that they did not believe that anyone around the area had had the disease. We include the relevant article from the Gloucestershire Echo of the 12 March 2002.

 

 

From The Gloucestershire Echo

CALF KATIE IS A SIGN OF HOPE

10:30 - 12 March 2002 Farmers survive virus scare
The first calf of 2002 has been born at a farm devastated by foot and mouth disease. The scare at Bozard Farm, Woolstone, near Bishop's Cleeve, also led to the cancellation of last year's National Hunt Festival.

The Prestbury Park racecourse was within a five mile exclusion zone around the Gilders' farm. Now the family is looking forward to the future with the birth of this year's first calf. Katie was born early on Friday to Zoe - one of a herd of 48 cattle brought to the farm when it restocked in September. Another calf was born on Sunday night and more are expected over the next few weeks.

For David, his wife Caroline, and children William and Emily, it is a sign of hope. David, 34, said: "We will probably build the herd up to the size we had before in a couple of years."

The Friesans were bought from a farming couple in Aston-on-Carrant, near Tewkesbury, who were retiring.

Caroline, 33, added: "Obviously they are not our old cows but we were very lucky to get them. "They have been very well looked after by their previous owners. We couldn't have asked for a nicer herd."

The family faced their worst nightmare when their 64-strong dairy herd, 122 beef cattle, 190 ewes and 100 lambs were slaughtered. They were victims of a controversial policy of killing all animals on suspicion of having the disease.

The family was distraught a few weeks later when their animals were given the all-clear from the disease.

Officials at the Department for Environment, Farming and Rural Affairs still count the case as confirmed because clinical signs of the disease were found in animals.

The family is angry and would like to see a proper investigation of the crisis.

Caroline said: "There was nothing wrong with those animals. I am sure it was just political.

"I don't believe anyone round here had the disease. How they cannot allow a public inquiry I don't understand. "There was so much of an effect in this area alone with the races. Just look at the knock-on effect from that."

She said the new clutch of calves was lovely and offered the family a new start.

Eventually Mr Gilder, who runs the farm with Ralph Sharp, hopes to restock sheep as well."

 

3.3.11 The over-riding concern is that wherever the disease is suspected it is paramount to ensure that it is properly confirmed by laboratory testing.

 

3.3.12 The extent and scale of the epidemic has been made far worse because of the significant scale of incorrect and mis-diagnosis.

 

3.3.13 It is therefore paramount that provision must be made for accurate, swift and reliable diagnosis with the support of laboratory testing to truly define the presence of the disease and thus for appropriate action to be taken.

 

 

 

4 WHAT MORE COULD BE DONE TO PREPARE FOR POSSIBLE

FUTURE OUTBREAKS OF FMD?

 

4.1 THE RISKS OF FUTURE OUTBREAKS AND THE IMPORTATION OF INFECTION

 

4.1.1 We submit that the most likely source of the FMD epidemic was as a result of legally' imported meat which may have contained illegal' meat derived from areas that have endemic FMD, or which vaccinate and whose meat and meat products have not been appropriately treated.

4.1.2 Through the course of the epidemic we have sought accurate figures from MAFF/DEFRA of the volume of meat from vaccinating countries entering the UK and EU - no definite figures are available and it is not known how much vaccinated meat and meat products are entering the UK.

 

4.1.3 During the course of the epidemic it became clear that if animals were to be vaccinated there was a perception' that there may be consumer resistance to the purchase and consumption of vaccinated meat and meat products.

 

4.1.4 In order to determine whether this perception' had any basis in reality the NFMG sought to determine what quantities of FMD vaccinated meat and meat products were already being readily purchased and consumed in the UK. Such products would obviously be imported as there is no FMD vaccination in the UK and the EU.

 

4.1.5 This information was sought from the Meat and Livestock Commission who directed us to DEFRA.

 

What emerged was that there are no accurate figures available to determine what quantities of meat and meat products from FMD vaccinating and FMD endemic countries are entering either the EU, or more specifically, the UK.

4.1.6 We append the correspondence with DEFRA at Appendix 6. We also append a note of conversation with DEFRA on this specific issue. Appendix 7

 

It appears that meat and meat products can be imported into the UK, via any EU Border Inspection Post, without any further checks or controls. Furthermore, the controls at the country of despatch may not necessarily be the controls at the country of origin. DEFRA were at pains to point out that their figures only relate to country of despatch not Country of Origin.

 

4.1.7 In addition it is not known how well regulated and enforced are the boundaries between FMD free and FMD occurring regions in certain areas of the world which the UK imports from, particularly in third countries.

 

4.1.8 Finally, the methods of determining whether animals are FMD free at the point origin or despatch relies solely on clinical pre mortem inspection with no laboratory testing to conclusively determine the presence of FMD.

See Appendix 7

 

4.1.9 Although much attention has been paid to the likelihood of the UK 2001 FMD epidemic originating from illegal imports, it is our contention that the infection may well be the result of legal' imports but derived from meat originating from an area of endemic FMD, which has passed through un-regulated or un-managed borders, into an FMD free area for exporting.

 

4.1.10 Given that it appears impossible for borders between FMD free and FMD endemic areas to be properly controlled and regulated, and given that many animals are transported and moved considerable distances prior to importation either into the EU or the UK, it would seem only a matter of time before further FMD outbreaks occur either in the UK or elsewhere in mainland Europe.

 

4.1.11 In addition there may be many other means by which infection could again enter the UK. It is by no means clear what the origin of the current infection was, or how it was transmitted. We need to have regard to other novel vectors, as yet unconsidered.

 

The emphasis on uncontrollable routes of infection, such as airborne transmission has diverted attention from the more traditional routes. In the current outbreak in the UK it was the movement of personnel and vehicles which posed the greatest risk of disease spread. There may be implications that contaminated containers or human carriers may be involved in further re-introduction into the UK.

 

4.1.12 The issue regarding swill being fed to pigs is by no means conclusive. Currently 4% of the UK pig population is swill fed. However it is not known what proportion this is of the total volume of swill or catering waste.

 

With the disposal of waste food currently costing £80 per tonne the banning of swill feeding is of some economic significance to the catering industry. The quantity of waste food is likely to increase as new Food Safety Measures are introduced; however the use of land fill as the means of disposal is environmentally unsound.

 

This volume of waste that is increasingly sent to landfill may also be a contributory cause; as waste vehicles may be carrying infection and will probably not be subject to any form of bio-security or bio-sanitary protocol.

 

There are real and logistical problems in handling waste food and maintaining bio-security; and as disposal costs increase there will be incentives to look at alternative illegal methods. The processing of waste food at designated sites would seem to be a better alternative.

4.1.13 The difficulty in tracing the source of an outbreak, identifying the various

vectors that are involved, and establishing how, when and where the disease emerges and disperses, coupled with the subsequent problems of traceability, all militate against the likelihood of further outbreaks in the future being prevented, and, more importantly, contained.

 

 

4.2 SURVEILLANCE & MONITORING

 

4.2.1 There is no other more effective surveillance system than one based on consensus and trust between the farmer and the local general veterinary practitioner.

 

In most cases, the State Veterinary Service is reliant upon the farmer calling in either his local vet or the DEFRA vet, if he finds a suspect animal.

 

4.2.2 Formal surveillance is restricted to Veterinary Inspection at abattoirs and markets. Occasional Veterinary Surveillance at collecting centres and other ad hoc events have proved useful.

 

4.2.3 Routine patrols of farms are very demanding on veterinary resources and not effective. There are logistical problems in handling and examining stock that may be dispersed over a very wide area.

 

4.2.4 Mass screening of milk or blood samples is an exceptionally efficient method of surveillance for slow spreading diseases. Strategic use of PCR for virus detection at dairies or abattoirs could be useful.

 

 

4.2.5 What are the barriers, implications and costs of moving to more active surveillance?

 

4.2.6 Veterinary practitioners now rarely get onto farms, as vet visits have become uneconomical in certain sectors of the industry. In the current outbreak there were insufficient veterinary resources to allow routine patrol inspections of flocks and herds in suspect infected areas. There was also the possibility that farmers hiding animals could hamper formal on-farm inspections.

 

4.2.7 In addition, someone has to pay both for the veterinary practitioner and the cost of any laboratory tests. The LVI system of contracting work out to private vets could be used to address this.

 

4.2.8 Furthermore, there are now uncertainties facing the farmer and the large animal practitioner. Changes within the agricultural industry have subsequently made any significant veterinary input into certain sectors totally uneconomic.

 

4.2.8 However, there is no doubt that the general practitioner still has a very important role in communicating with the livestock sector of the industry. In the past this role has proved to be very effective at delivering cost effective services.

 

4.2.9 In an environment where financial resources are limited it may be more cost effective for some of the statutory duties (including surveillance) of DEFRA to be managed and implemented by general practitioners.

4.2.10 As in other areas, the development of a public/private partnership to deliver a surveillance strategy, may be an efficient, cost effective and reliable solution.

 

4.2.11 The use of local practitioners, acting as appointed, certified agencies, would also enable the restoration of trust and confidence in a process and relationship with the Ministry, which has become seriously undermined during the current epidemic.

 

 

4.3 THE NEED FOR PRE-AGREEMENT AS TO METHODS OF CONTROL

 

We consider that it is vital for pre-agreement as to the methods and protocols to be adopted in the event of a future outbreak.

 

As raised in Section 3.2 there is now an urgent and fundamental need to ensure that Contingency Plans not only exist but that they are in the public domain. That they have been formulated with contributions from all the key interest groups and that all the main stakeholders know what procedures are likely to be adopted and, most importantly, how these are to be executed.

 

We are not aware that this process was adopted in the preparation of the Interim Contingency Plan that has appeared on the Defra website on the 13 March 2002.

 

 

4.4 PREPARING TO DEAL WITH POSSIBLE FUTURE OUTBREAKS

 

In this section we address:

 

Provision of facilities for accurate diagnosis of the disease

 

Procedures and Protocols to be adopted to contain, control and eradicate future outbreaks

 

 

4.4.1 Provision of Facilities for accurate diagnosis of the disease

 

We insert here our recommendations as suggested in our evidence to the Royal Society Inquiry:

 

DIAGNOSIS - CONCLUSIONS & RECOMMENDATIONS

 

We believe the case is duly made for a reliable, fast, accurate diagnostic protocol to replace the provisions that were used in the UK 2001 epidemic.

 

Our recommendations are:

 

1 Recognising the limitation of existing techniques there is a need to immediately validate PCR viral assay testing to provide a swift, reliable, accurate test to confirm FMD. Development of a cow side/ sheep side or farm gate test would be optimal. We understand that development of such tests is now advancing - Vet Record 17 Nov 2001 P621-623 Appendix 8

 

2 There need to be contingency plans to enable a swift scaling up of facilities and to increase the number of tests that can be undertaken within a very short space of time

 

3 To enable this increase in facilities, private diagnostic laboratories must be involved and commissioned to undertake some of the testing controlled by appropriate guidelines and regulations

 

4 Local vets with a knowledge of the area and circumstances should be responsible for diagnosis.

 

5 Their diagnosis should be supported by a second opinion, particularly in cases where there is uncertainty or a farmer requests this. There is a need for mentors to be available to assist vets who are inexperienced in FMD.

 

6 Testing facilities to confirm diagnosis should be available within the locality - if (3) is followed this should enable regional testing facilities to be set up.

 

7 Diagnostic decisions must not be government based, taken at a central office with little knowledge of local conditions or circumstances

 

8 Diagnosis must be free of any political constraint and purely based on scientific diagnosis supported by laboratory testing,

 

 

4.4.2 Procedures and Protocols to be adopted to contain, control and eradicate future outbreaks

We submit later in this document our detailed proposals for a Draft Programme for the Use of Emergency, Protective Vaccination for the Containment, Control and Eradication of FMD - and would ask the Inquiry to consider this as relevant to this Section of our report.

 

In principle the Programme incorporates the need for agreement and adoption of procedures and protocols such as:

 

1 the imposition of immediate national movement restrictions

 

2 protocols for effective farm quarantine

 

3 protocols and enforcement of bio-security/bio-sanitary arrangements

 

4 detailing of safe animal separation distances on adjacent farms

 

5 the means and methods of slaughter and disposal of infected animals

 

6 protocol for the incorporation of emergency, protective vaccination to contain, control and eradicate the disease.

 

 

5 WAS THE RESPONSE PROPORTIONATE TO THE IMPACT ON THE WIDER RURAL AND UK ECONOMY?

 

The response was not proportionate to the wider rural and UK economy. Also it was not proportionate in the context of social, welfare, or community interests.

 

Fundamentally, the response to the FMD epidemic was not proportionate to the risk of onward transmission of the disease.

 

We have therefore incorporated in this section our detailed concerns at how the epidemic was handled.

 

 

5.1 ADOPTED POLICES & THEIR IMPACT

 

5.1.1 The adopted Control Policies, including the Slaughter and Cull Policy created a major, unplanned cost to the Exchequer of £2.7 billion, a massive and disproportionate loss to tourism of £4-5 billion and an estimated overall cost to the nation of £20 billion.

 

5.1.2 The value of the export market that this approach was supposed to protect is worth circa £550 million. (Also, although in theory export status has been regained, there is very little export demand for beef in the wake of BSE and the FMD epidemic.)

 

5.1.3 In addition, the control measures resulted in untenable animal and human suffering.

 

5.1.4 Circa 10 million animals were destroyed, the vast majority of which were healthy, and many people lost livelihoods and their life's work.

 

5.1.5 The stress, emotional and psychological damage to individuals and communities has been unbearably apparent to all of us closely involved in the outbreak.

 

5.1.6 The breaches of respect for people and their animals, together with the enforcement of what now appear to have been illegal culls, has created great mistrust in the offices of Government and its manner and means of execution.

 

5.1.7 To be blunt, many of the scenes witnessed by those involved in this Group, had no part in a civilised, western democracy of the 21st century.

 

5.1.8 What lay at the heart of this cost in terms of the economy, society, welfare and individuals was the adoption and execution of the unprecedented and unjustified cull and extensive slaughter of animals which did not have the disease.

 

5.1.9 It is for this reason that those responsible for advocating this policy and repeating their assumptions and predictions to the EFRA Select Committee should be subject to the most rigorous, informed and analytical questioning and cross examination.

 

5.1.10 The Science Committee, Government advisers and the modelling teams who based their decisions on hypothetical theories and predictions must be accountable and answerable.

 

At what stage will the exponents of this strategy be able to demonstrate that the hypotheses and theories that they advanced have been practically vindicated and proven by the publication of the details of the laboratory test results.

 

5.1.11 The insistence that this data is governed by the Data Protection Act can not be sustained because it would not be necessary to name the farmers concerned.

 

5.1.12 As it is only the Inquiry which may have access to this information we urge you to truly determine what the actual extent of the epidemic was and how few premises were actually infected.

 

5.1.13 We would ask that you also consult those such as Dr Paul Kitching, formerly of the Institute of Animal Health at Pirbright, Prof Bob Michell, formerly President of the Royal College Veterinary Surgeons and Alan Richardson and Roger Windsor, both Council members of the RCVS, for their views as to the efficacy and need for the extensive slaughter policy.

 

5.1.14 From the papers they have published and the conversations we have had with Paul Kitching, the need for the extensive slaughter was not proven nor necessary to contain and control the disease.

 

Prof Bob Michell writing in the Vet Record of 22/29 December about how the down turn in cases began before the imposition of the contiguous cull policy started states:

 

"At that time (May 19), I wondered how contiguous culling could have exerted its influence on the downturn of the epidemic, since the decline in the weekly number of cases for the UK began in the last week of March and took a course very similar to the decline curve for the 1967/68 outbreak.

.. If the peak precedes the implementation of the contiguous cull, it suggests that the 1967 methods' were already achieving control and that the subsequent killing of almost 10 times as many animals as in 1967/68, for slightly fewer outbreaks, when herd/flock sizes have merely doubled, was an unnecessary source of economic loss, animal suffering, human misery and a key factor in the logistical logjams hampering both diagnosis and dispersal."

For full communication please see Appendix 9

 

Members of this organisation and others also had discussions with Dr Paul Kitching about the various transmission vectors of the disease and the various testing procedures that had been adopted

See Attached File Note of 31 May Appendix 10

 

We are firmly of the opinion that if the key measures of animal movement restrictions, effective farm quarantine and appropriate bio-security and bio-sanitary provisions had been applied and maintained, together with surveillance, monitoring and testing, the disease would have been brought under control without vast and indiscriminate slaughter.

 

5.1.15 As we have detailed earlier it was the failure to impose nation wide movement restrictions as soon as the disease was confirmed that allowed the outbreak to become so dispersed and widespread.

 

5.1.16 Once all movement restrictions and other measures were in place the risk of airborne transmission was extremely unlikely. Further dispersal of the disease is far more likely to have arisen from the slaughter, haulage and disposal along key haul routes to the major pyres and pits.

 

5.1.17 Another key area of concern was that the certification for culling and the signing of A' forms by TVI's was not founded on proper veterinary appraisal and risk assessment.

 

Elliott Morley, the Animal Health Minister, has now conceded that the Government did not have the power to enforce the slaughter of healthy animals. Giving evidence to the EFRA Select Committee on the 6 November 2001 he stated that:

 

"At the present time, we do not have the powers for a firebreak cull. There was the three kilometre cull in Cumbria but that was a voluntary cull and people were invited to participate in that." Answer to Question 8

 

Veterinary surgeons on entering the RCVS swear an oath that includes the statement "that my constant endeavour will be to ensure the welfare of animals committed to my care."

 

While this may not be legally binding - the RCVS rightly expects vets to observe this oath. Not surprisingly, so do the majority of the population.

 

The signing of A' forms without the proper veterinary assessment for disease or any appropriate determination of whether there was any risk that animals had been infected or exposed to disease meant that the provisions of the oath, for those who consented so to do, had to be set aside.

 

Without in any way determining whether an animal might be infected and need to be slaughtered, under the direction of the Government, vets in agreeing to sign A' forms, had to commit millions of perfectly healthy animals to death.

 

Not surprisingly the ethics and morality of this situation will cast a long shadow over the profession and their utilisation by the Government to condemn animals to slaughter without any demonstrated or justified need.

 

The pursuance of slaughter and cull without proper veterinary inspection, appropriate risk assessment that animals may have been exposed to disease and therefore where no justification had been advanced for animals to be culled has been one of the most distressing and contentious elements of the outbreak.

 

In conclusion, the economic, social, human, animal welfare, and community costs and impacts of the control measures were not a proportionate, reasonable or rational response to the disease and the risk of its onward transmission.

 

 

5.2 WERE ALLTHE 3KM & CONTIGUOUS CULL, SLAUGHTER ON SUSPICION AND DANGEROUS CONTACT CULLS NECESSARY?

 

5.2.1 The issue of the 3km/ contiguous cull, and to some extent the slaughter on suspicion and dangerous contact culls, have caused some of the greatest dissent and controversy of the total handling of the epidemic.

 

5.2.2 For those farmers and livestock owners who took immediate action to ensure their animals were subject to tight bio-security and effective farm quarantine the imposition of slaughter of stock, which they firmly believed was healthy, caused traumatic and emotional upheaval.

 

5.2.3 Some farmers who had lived through the '67 outbreak did not wait for instructions to isolate their animals and put in place appropriate measures to prevent the infection entering their premises, they did so on February 20th.

 

5.2.4 Throughout the course of the epidemic we become ever more concerned at the accuracy of the diagnosis of FMD.

 

5.2.5 At the outset it was not appreciated that the diagnosis in some species, particularly sheep in this epidemic, was likely to be due to responses to other agents or infections and not necessarily FMD. As time progressed and it became public knowledge that laboratory testing was not bearing out clinical diagnosis conducted in the field, there was increasing anxiety amongst farmers and the rural community that the necessity for some of the culls, and in particular the contiguous culls, was not proven.

 

5.2.6 In addition there was mounting distrust at the manner in which confirmed cases were being determined, via discussions with, and directions from, Page Street, as opposed to experienced and informed veterinary opinion on the ground, and without recourse to scientific laboratory testing to confirm diagnosis.

 

5.2.7 By mid April so great was the concern of many members of the public that they were prepared to publicly challenge the need for the Contiguous cull in many areas. Notably the Forest of Dean became one of the first areas of the country where public distrust of the control process resulted in protests to stop the contiguous cull.

 

5.2.8 Here local people had first been concerned that the free roaming sheep had not been rounded up and quarantined at the start of the outbreak. They were then appalled at the manner in which the cull was then carried out. In some areas the roads through the Forest were closed and the slaughter was executed by the culling teams moving through the Forest and shooting the sheep with rifles.

 

5.2.9 Several weeks later contiguous culls were still being authorised although it had never been made clear which of the free roaming sheep were, if at all, infected. Also these culls were proceeding 3 -5 weeks after the free roaming sheep had been culled and therefore long after the incubation period for the disease had elapsed. Animals were showing no clinical symptoms of the disease and their owners could demonstrate they had maintained full bio-security.

 

5.2.10 It was the appeal of Oaklands Community Farm, at Newnham on Severn, in the Forest of Dean, which highlighted this situation. We append the report prepared by them detailing the situation as it pertained to them and others in their circumstances. Such circumstances were apparent not only in the Forest of Dean but also in other areas of the country. Appendix 11

 

5.2.11 Of the 34 contiguous culls that were authorised in the Forest of Dean none showed positive results for FMD when laboratory tested.

 

In the intended cull of animals as dangerous contacts from Welshpool Market, where 40 local farmers refused to let their animals be killed, not one later proved positive.

 

We understand from Burges Salmon, solicitors, that of the 9 cases that were taken to appeal - no positives were subsequently found. Of the 140 cases where their advice was sought only 2 subsequently proved positive.

 

In the cases dealt with by Alayne Addy, of Stephens-Scown solicitors, of the 200 cases they were involved in, only 1 went on to prove positive.

 

Where all were involved in resisting the culls it was only on the basis that the farmer could demonstrate that he had undertaken rigorous bio-security and firmly believed that his stock was healthy and had not been exposed to the disease.

 

 

5.2.12 A nation-wide picture was beginning to emerge that:

 

1 the accuracy of diagnosis was a major cause for concern,

 

2 the need for the contiguous cull was not scientifically proven and no account was being taken of local circumstances, experience and expertise.

 

3 risk assessments to determine the likelihood of the presence of infection were not being used to assess whether the disease could have spread.

 

 

5.2.13 In addition it was becoming clear through papers and reports in scientific journals that not only was there growing public concern regarding diagnosis, how the disease was spreading and the adopted methods of control, but that recognised scientists in the field also did not support the contentions that were being advanced to justify the control policies.

 

Principle amongst these were:

 

1 Paper in the Vet Record of 12 May 2001 on Relative risks of the uncontrollable (airborne) spread of FMD by different species - Alex Donaldson, et al. Appendix 12

 

2 Paper in the Vet Record of 12 May 2001 on Relative resistance of pigs to infection by natural aerosols of FMD virus - A Donaldson & S Alexanderson Appendix 13

 

3 Letters in Vet Record of 12 May from various Ministry Vets on FMD control strategies and the number of negative test results from confirmed cases and contiguous culls. Appendix 14

 

4 Letter to the Vet Record of 19 May 2001 from Dr Alex Donaldson and Dr Paul Kitching on FMD diagnosis Appendix 3

 

 

5.2.14 So great was our concern as to what constituted a confirmed case and how it was being diagnosed that we wrote on the 1 May 2001 to the Secretary of State asking to be informed.

 

"1 What is the legal definition of a "confirmed case" of foot and mouth?

 

2 Does the definition refer to:

 

a Clinical signs

 

b The presence of live virus in the animal

 

c The presence of post viral antibodies in the animal

 

or a combination of a&b, or a&c, or b&c or all 3 criteria?

 

 

3 Has the legal definition changed over time?

 

4 Of the 1525 confirmed' cases to date (source: MAFF web site - 19.00 on Tuesday, 1 May 2001) what number have been, and will be, subject to serological testing?

 

How many of the 1525 confirmed' cases have subsequently shown no presence of either live virus or post viral antibodies, (ie, proved negative with no evidence of the disease), when serologically tested?"

See Appendix 15 for full text

5.2.15 We also wrote 14 days later, as our concerns were extended to consider what the equivalent situation was regarding the testing of contiguous culls, dangerous contacts, slaughters on suspicion.

 

See Appendix 16

We are still awaiting replies to both letters.

 

In addition to the many problems that the lack of laboratory testing created, it is also our contention that the determination of a confirmed case', on clinical grounds alone, was not in conformity with sampling and testing principles set down in the EU Directive 85/511 on FMD. This may also result in the EU withholding funding for compensation payments for FMD and that these costs will then fall solely on the UK tax payer.

 

5.2.16 The Royal Society posed the question:

 

"How good are existing techniques"

 

We understand that Pirbright tested all the samples it received for antibodies and vireamia using ELISA, PCR and tissue culture

 

We understand from Dr Paul Kitching, former head of FMD at Pirbright Animal Health Institute:

 

1 that if we assume that samples were collected on IP's from animals with suspect clinical signs, the tests are very sensitive and specific, approximating 100%.

 

2 samples were tested by ELISA, PCR and tissue culture

 

3 if blood was submitted, this was tested for virus and antibody, virus appears before clinical signs, so if an animal had suspect FMD, it would be virus or antibody positive, sometimes both, never neither. again the tests approach 100%.

 

Also from Warmwell. com: Dr Paul Kitchings 's response to Prof Ray Anderson of Imperial College "Blood samples received at Pirbright are tested for both virus and antibodies; if both are negative then it would not be possible for that animal to have or have had FMD assuming they sent samples from the animals they suspected of having the disease."

 

 

In the letter to Vet Record of May 19th Paul Kitching and Alex Donaldson write "On epithelial samples we carry out an ELISA and virus isolation using sensitive tissue culture, while in blood samples we look for viraemia and antibody. The viraemia starts before clinical signs and is replaced around three to four days later by high anitbody titres, so animals with FMD have either virus or antibody or both in their blood. We are also comparing the sensitivity of virus isolation with direct PCR on the epithelium samples, and so far we have a very strong correlation in the results - close to 100 %...........While it is never the intention that laboratory diagnosis would replace clinical diagnosis, we believe that laboratory support for a diagnosis of FMD in sheep, in particular, is essential. For samples collected in the UK and submitted as recommended, we would expect a very high success rate and certainly above 90 %.

 

 

5.3 CAPACITY FOR LABORATORY DIAGNOSTIC TESTING

 

5.3.1 Clearly, the samples that were received by Pirbright for testing were subject to sufficient tests to establish whether animals were infected.

 

5.3.2 However, there was insufficient capacity at Pirbright to deal with the rapid increase in the number of samples that needed to be tested. This problem became even more acute when the cull was extended to contiguous premises and 3 km.

 

5.3.3 There was no ability to scale up the number of tests that could be undertaken, nor was it feasible to speed up the process. Although PCR testing was undertaken it appears this was only to re-inforce the indications from the virus isolation tests, as its seems that PCR still remains unvalidated by the EU as a test for FMD, and therefore only the time consuming virus isolation test could be used to identify viraemia.

 

5.3.4 No other facilities for testing were made available and offers from private firms and individuals to assist in speeding up the rate and processing of testing were dismissed. For example Dr Colin Fink of Micropathology, who undertakes testing for the NHS, offered to undertake PCR testing but was not allowed to obtain the necessary material to develop his test facilities to respond to FMD.

 

5.3.5 This lack of capability to increase a)facilities, b) speed of diagnosis and the inability to respond to the huge increase in the number of samples which required testing resulted in even more cases of mis-diagnosis occurring.

 

 

5.4 DIAGNOSTIC PROCEDURES

 

5.4.1 Many vets who confirmed' cases on clinical signs had never seen FMD. Many TVI's were drafted in at short notice from outside the UK, they too were not familiar with the clinical symptoms. There was little time to train these vets and it was not possible for them to receive experience in the field before being immediately placed in the position of diagnosing' and confirming' case.

 

Many vets did not have the relevant experience but were small animal vets, not used to dealing with large animals, farm conditions, or with farmers. As a result they were often not in control of the situation or able to deal with farmers and the farmers questions. Some lacked language and social skills and came from very different cultural backgrounds. All this led to a lack of trust and confidence with the Ministry and the way it was dealing with the situation.

 

 

5.4.2 In addition the process of diagnosis which was conducted via Page Street did not improve the accuracy of diagnosis, but in many cases led to cases being confirmed', against the view of the vet on the ground, and which later tested negative in laboratory tests.

 

This was especially the case when additional probangs were taken on the ground.

 

Vets were often dealing with tense and difficult situations, and needed social skills and an ability to communicate with farmers and explain what needed to be done. Many were unable or untrained to deal with these circumstances. As a result communications and relationships between the Ministry and farmers became distrustful and threatening.

 

5.5 CONCLUSIONS ON THE HANDLING OF THE OUTBREAK

 

5.5.1 We attach our submission to the Government regarding the Animal Health Bill amendments which details all the opposed culls we are aware of and ask the Inquiry to note that none went on to develop the disease.

Appendix 17

 

5.5.2 We do not believe that scientific justification has been provided to support the extensive culls that were carried out. In particular we are extremely concerned that the basis for this policy was founded on an extrapolation of results in the early stages of the disease. We now know how few tests were subsequently carried out to support the hypotheses that such culls were either required or of any benefit.

 

In addition risk assessment to determine the likelihood that animals had been exposed to the disease were very rarely undertaken.

 

5.5.3 In particular we would draw the Inquiry's attention to the evidence of Prof King, head of the Government's Science Committee, to the EFRA Select Committee of the 7 November 2001. Here Prof King asserts repeatedly that 17% of contiguous farms are likely to have the disease.

 

5.5.4 However to date not one piece of scientific evidence has been produced to support this contention. As explained earlier in the Section on Diagnosis, so few premises were actually sampled that neither we, nor the Government, nor the Science Committee will be able to determine the true extent and scale of the disease.

 

5.5.5 The only facts that have been established is that of the 9461 Affected Premises in the UK only 2372 were sampled and only 1327 were positive.

 

We also know that only 220 Dangerous Contacts, of which 120 were Contiguous Premises Cases, and 54 Slaughter on Suspicion cases were sampled and later returned positive results These cases are now included in the Infected Premises number.

 

This total of 274 premises, which were identified as infected from the DC's/Contig Culls and SOS's, taken as a percentage of all the DC's, Contig Culls and SOS's (7435) that were slaughtered, is only 3.69%.

- not 17% as per Prof King's statements.

 

5.5.6 As stated earlier, until there is an opportunity to question and examine Prof King, and the various epidemiologists, and have access to the full test results it will never be known whether there is any scientific basis to these assertions or whether they are no more than assumption and speculation. The evidence to date directs such a conclusion.

 

5.5.7 We would also like to draw your attention to the article on Dr Shannon regarding the control of the disease. Dr Shannon was Chief Scientist at DEFRA until December and was involved in the outbreak. He recently published his views in the journal Science and Public Affairs' on the adopted control methods. He does not support the Science Committee's rationale for the control of the disease. He states that it ignored the science of FMD and that the Science Committee did not understand how the disease was spread and how it should have been contained and controlled. We enclose a copy of his paper. Appendix 18

 

5.5.8 We submit that the methods of diagnosis and control that resulted in enormous collateral damage to agriculture, to other economic sectors and the social fabric of rural England, Wales and Scotland, were not an appropriate and proportionate response to the disease.

 

Without any empirical data to substantiate such draconian control measures we do not believe that the models and the adopted approach can ever be shown to have been vindicated or proven.

 

There has been no scientific or statistical evidence or justification advanced for the use of such measures to control a future outbreak.

 

5.5.9 The process generated a huge logistical problem in dealing with the number of carcasses generated. The very mechanisms of slaughter and haulage may well have contributed to the disease spread and the financial impact inflicted across the rural economy was immense.

 

5.5.10 There is a justifiable case to consider other means and methods of control, based on a scientific appraisal and rationale of the disease and its spread. Clearly the issue of exports and the return to Disease Free Status is a key consideration.

 

5.5.11 However, we consider that there are definite advancements in the efficacy of vaccines and tests which direct that there should be no distinction between the return to Disease Free Status based on control via a stamping out' policy or one of vaccination.

 

We address this in much greater detail in the later Section on Vaccination.

 

 

6 WOULD THE USE OF VACCINATION HAVE MADE ANY DIFFERENCE TO THE SCALE AND/OR DURATION OF THE OUTBREAK AND ITS WIDER IMPACT?

 

6.1 It was apparent that the use of vaccination was not properly considered by the Government until the disease was well established.

 

6.2 The Government had not prepared contingency plans in line with the EU 1993 Contingency Plan, which incorporated the provision of emergency vaccination Also, there had been no take up by the Government of the EU Strategy for Emergency Vaccination adopted by the EU in 1999.

 

6.3 A great deal of misinformation and misconception was put forward during the discussions on vaccination in March/April 2001 and subsequently, regarding the modern scientific situation relating to vaccination, and specifically the modern vaccines and tests that were and are available.

 

6.4 Many in this organisation, concerned at the scale and impact of the disease and the vast numbers of healthy animals that were being slaughtered, sought to obtain information and advice as to alternative methods of dealing with the epidemic.

 

6.5 In particular the papers of Dr Keith Sumption and the media interviews of Dr Barteling of the Netherlands demonstrated an informed and constructive means of dealing with the outbreak which did not result in such wholesale slaughter.

 

6.6 Several people, many of whom went on to form the NFMG, wrote and lobbied Government for a change of policy and for the utilisation of a vaccination protocol to control the disease.

 

6.7 By the middle to end of March, when the vaccination debate was most focused, we thought the Government would act and introduce a vaccination policy - but at the last moment they did not.

 

6.8 We are now reliably informed that the Government was within one hour of introducing a vaccination policy - but that pressure from certain sectors such as the British Cattle Veterinary Association and the NFU persuaded the Government not to accept this approach.

 

6.9 Those that argued for a policy of non-vaccination must be rigorously questioned as to their justification for this stance and it must be determined on what knowledge of vaccination, advice and direction they based their views.

 

Furthermore, while the primary commitment of these organisations must be to their membership, this does not mean that their decisions and actions can be divorced from social, ethical and moral responsibility to the wider community or to the detriment of the broader public interest.

 

6.10 At that stage in the epidemic a totally different vaccination protocol would have been needed than if vaccination had been utilised at the outset. By then the disease was manifest in most of the 30 affected counties. While we would still have advocated a protective, vaccination to live, approach - it may not have been necessary for all animals to have been vaccinated. The country would have needed to have been zoned into vaccinating and non-vaccinating areas with strict border controls. Depending on what livestock was in the vaccinating areas and how they were farmed - ie whether in intensive lowland situations or as flocks dispersed on hill farms, different regimes for vaccination could have been assessed and adopted.

 

6.11 The Government and its advisers appeared reluctant to fully investigate and adopt a vaccination policy. Those scientists such as Dr Sutmoller and Dr Barteling who had had many years of experience of FMD control using vaccination were not consulted. Scientists in the UK who had espoused vaccination were often left feeling isolated and vulnerable - as their employment was in many cases reliant on Government funded institutions or on Government experts who were advising the Government not to accept vaccination.

 

6.12 Two key matters are clear. Firstly that no preparation had been put in place to apply any Emergency Protective Vaccination policy in the event of an outbreak - and no cognisance or implementation of the EU Strategy for Emergency Vaccination had been undertaken.

 

6.13 Secondly, that even when faced with the massive scale and impact of the outbreak in mid to late March there was a reluctance to seek advice from non UK experts who had had immediate first hand experience of controlling outbreaks of FMD with vaccination. Similarly those scientists based in the UK who were pro vaccination were sidelined.

 

6.14 The Government treated vaccination as a retreat from its adopted policy, a defeat and a last resort. Against this negative approach it was difficult for them to see and accept that there were many positive attributes to the use of vaccination.

 

6.15 Furthermore, it has become apparent since then that those who vigorously opposed vaccination preferred not to accept the modern development and evolution of refined, purified inactivated vaccines and tests. Even as late as August 2001 Ben Gill of the NFU was still maintaining that vaccinated meat could not be eaten and that vaccinated animals could not be differentiated from non vaccinated animals. Ultimately we wrote to the NFU on the 23 August regarding FMD vaccination and the safety of vaccinated meat, milk, etc to express our deep unease that the NFU were still repeating statements that were not founded in fact or truth. See Appendix 19

 

 

6.16 We are very concerned that a body such as the NFU, which has had a major influence on Government policy, should have been so ill informed on the issues of vaccination. If Ben Gill's comments formed the basis of the NFU's advice to farmers not to accept vaccination then the NFU deserve to be rigorously questioned as to why they misinformed their members in this way.

 

Indeed, Ben Gill has now said on the 14 March 2002 that the NFU were responsible for the vaccination policy not being agreed by the Government. Given the lack of knowledge that the NFU has demonstrated regarding vaccination, vaccines and tests, this is unacceptable.

6.17 As you will see in the later section we have now utilised these vaccines and tests to formulate a control protocol for the use of emergency, protective vaccination, from the outset of an outbreak, to control and eradicate FMD.

 

6.18 We contend that if Cost Benefit Analysis had been undertaken to determine the loss of export markets for meat and livestock for a year, due to vaccination, compared with the emerging losses and impacts due to the slaughter policy, that even by mid March, the economic argument for the wider rural economy would have directed that a vaccination policy should be adopted.

 

6.19 A vaccination policy would have enabled the re-opening of footpaths and rural areas far sooner.

 

It would have dramatically reduced the huge number of animals which required slaughter. Used in conjunction with accurate diagnostic provisions only those animals which had been infected would need to have been killed - not the vast numbers of animals from contiguous, 3km and dangerous contact cases. Thus the need for extensive facilities for slaughter, haulage and disposal would have been far reduced.

 

The need for the funeral pyres and burial pits would not have arisen as smaller numbers of animals could have gone for render.

 

The need for animal movement restrictions would have been much reduced and therefore the unacceptable welfare problems would not have occurred.

 

The cost to the rural economy and the wider social and community damage would have been greatly reduced

 

Vaccination would also provided time for over stretched resources and personnel to take stock - rather than rushing to slaughter and testing post mortem.

 

Perhaps, most importantly, the nation's reputation would not have been internationally sullied by the primitive and crude scenes that were broadcast round the world - and we would have emerged as a modern, scientific and socially responsible culture.

 

6.20 Although some of the differentiation tests to distinguish vaccinates from non vaccinates had not been validated by the OIE, the OIE was still prepared to accept the use of these tests to demonstrate subsequent freedom from FMD post the epidemic - as was witnessed in Uruguay and Argentina.

 

If the UK had chosen to adopt vaccination as a means of control similar criteria could have been applied here.

 

6.21 We have never advocated the use of widespread prophylactic vaccination - but only the use of an emergency, protective, vaccination protocol. This is a vaccination to live policy where the vaccine is administered to provide immunity for the time the virus is circulating. After a standstill period followed by surveillance testing to demonstrate freedom from FMD, we could then have applied to the OIE for the return to Disease Free Status and export markets.

 

6.22 If the OIE had insisted that vaccinated animals had to be kept for UK/home consumption it would have been possible to offer farmers compensation for any loss of value - derogation for this could and should have been sought from the EU. There is provision for this in the EU Emergency Vaccination Strategy of 1999. This would have been a far more cost effective option than wholesale compensation for 10 million culled animals and caused far less animal suffering.

 

Animals from non vaccinating zones or areas would not have been subject to this regime.

 

6.23 Also, if the OIE had insisted on treating the UK as a whole as the vaccinating region the loss of the total export market is still only £550 million as opposed to the total UK food industry which is estimated to be £ 55 billion (See CLA submission to LLI - page 20 para 66) This would still have been a more cost effective option.

 

It is crucial to note that in his evidence to the EFRA Select Committee on the 7 November Prof Roy Anderson said that they had not carried out a review of whether the loss of export trade for a year and treating the animal welfare problems might have been an option because it was not their area of expertise.

 

6.24 It will be important for the Lesson Learned Inquiry to ascertain if any cost benefit analysis was undertaken to assess whether vaccination and the loss of export markets would have proved less onerous than the costs of mass culling, compensation and the subsequent economic, social and community impact.

 

We hope that the Government will produce evidence to demonstrate that these Cost Benefit Analyses were carried out and rerun during the course of the epidemic, and that they are published by the Lessons Learned Inquiry.

 

6.25 What has emerged is that with no Contingency or Emergency planning to include vaccination, and a reluctance to investigate and embrace alternative approaches, the whole paradigm of control in the UK became founded and resolutely committed to following only a Slaughter and Cull policy.

 

6.26 Despite an overwhelming need for a different approach due to the enormous financial, social and community costs incurred by the slaughter policy there was an unwillingness to even consider, let alone adopt, a major review of the adopted control policy or a meaningful implementation of a vaccination protocol.

 

6.27 It has also become increasingly clear that those that advocated the 3km and contiguous cull policy have become increasingly defensive that this was the only means of control.

 

6.28 Without the necessary lab test results it will never be known how far adrift this approach was as a means of controlling the disease. What evidence does exist demonstrates that the policy of non- vaccination caused massive collateral damage not only to farming but to the wider rural community and that its legacy has resulted in deep and irreversible damage to many people, their lives and their livelihoods.

 

6.29 The view of this organisation is that there is no doubt that an implementable policy for vaccination should have been evolved before the outbreak, regularly updated and constantly reviewed through the course of the epidemic.

 

6.30 We are firmly of the opinion that if the Policy that we are advocating in our Programme for the Control and Eradication of FMD incorporating Emergency, Protective Vaccination had been adopted at the outset of the outbreak, the disease would have been controlled far sooner, with much less animal and human suffering and with much reduced costs to individuals, the Exchequer and the nation.

 

 

7 WHAT COULD HAVE BEEN DONE DIFFERENTLY TO ALLEVIATE THE ECONOMIC, SOCIAL AND ANIMALWELFARE IMPACT OF THE UNPRECEDENTED LEVEL OF CULLING AND DISPOSAL?

 

In this submission we have raised many concerns as to the efficiency and impact of the adopted control measures and in particular that of the Contiguous Cull. Also the lack of certainty that Dangerous Contacts and Suspicion cases were infected and required slaughter.

 

During the course of the epidemic and subsequently we have discussed the various means and methods of control that can be effected to contain and eradicate the disease.

 

In response to the question posed by the Inquiry as to what could have been done differently we submit that a prepared and rehearsed programme of control incorporating vaccination would provide a far less disruptive and more humane method of containing, controlling and eradicating the disease.

 

To this end we submit the following as an outline of a suggested means of Containment, Control and Eradication for FMD. The rationale for our suggested use of vaccination is contained in Section 7.2 and the Role of the OIE, Sale of Meat and Animal Products Post Vaccination, Disease Free Status and Export Markets is contained in Section 7.3

 

We have submitted the Draft Programme to Intervet, producers of the 3ABC marker tests, for their comments and once we have had an opportunity to discuss the Programme with them will send any revisions to the Inquiry in due course.

 

 

7.1 DRAFT PROGRAMME FOR THE USE OF EMERGENCY, PROTECTIVE VACCINATION FOR THE CONTAINMENT, CONTROL & ERADICATION OF FMD

 

1 Although we acknowledge that there are statutory procedures that must be followed, once clinical symptoms have been identified and the presence of the disease is suspected, there is also a need for the subsequent process to be clear and easily understood by all those involved.

 

2 Given the implications of the extensive animal movements now occurring daily in the UK and Europe, the length of time taken to confirm the suspect case is critical. An explicit Contingency Plan must set out and determine precisely how, when and where the laboratory confirmation of the first suspect case is to be undertaken. Most importantly it must define the time scale for these actions.

3 An agreed course of action, also specified and detailed in an adopted Contingency Plan, must then be followed.

 

4 Such actions which are crucially time dependent and must involve:

 

a Rapid and accurate laboratory diagnostic tests, if possible in regional facilities (or if developed - cow side/ farm gate) using PCR viral assay. - to ascertain definite confirmation, or otherwise, of the disease in the shortest possible time.

 

b Immediate isolation of suspect premise(s), imposition of movement restrictions and effective farm quarantine, involving full bio-security, bio-sanitary arrangements to the premise.

 

c Notification and temporary holding position to neighbouring farms and small holdings.

d A placing on alert of the relevant authorities and agencies

 

5 If laboratory confirmation is negative then it may be sensible to consider compensation for any losses to the farmer incurred through the imposition of restrictions and bio-security arrangements. The purpose being to inculcate a culture of responsibility and incentive for farmers to swiftly report suspect cases without loss of earnings, even if the case subsequently proves to be a false alarm.

 

6 In the event of positive confirmation then the following procedures should be implemented:

 

Again a pre-agreed, adopted contingency plan must detail operations and involve:

a Immediate imposition of nation wide movement restrictions

 

b Immediate slaughter of index premise

c Immediate effective farm quarantine

 

d Tracing of dangerous contacts

 

e Surveillance and laboratory testing of contiguous premises,

 

7 Should it be found that the disease has not been contained, but that it has already been dispersed and seeded before movement restrictions have been imposed, as happened in the current outbreak, then an emergency, protective, vaccination to live policy should be applied.

 

8 The vaccination to live procedures should be effected without the need for a pre-determined and pre-agreed threshold of confirmed cases, but should be introduced as the primary method for control for the high risk area surrounding the location of confirmed IPs.

 

9 This procedure should be introduced in conjunction with the following provisions:

 

a Immediate, enforced, effective farm quarantine - with a pre agreed protocol, including safe animal separation distances from neighbouring farms

 

b Immediate, enforced bio-security - with pre agreed protocol, measures etc -these plans should cover all animal, vehicle, personnel, feed and milk tanker movements - (milk should not be collected from Form D farms without strict adherence to air filter maintenance.)

10 Monitoring and surveillance - Any clinically identified infected stock - preferably supported by pcr viral assay confirmation, would be slaughtered.

11 Immediate implementation of ring, zonal, administrative area protective, emergency, vaccination programme - around IP(s), dependent on geographical dispersal, local conditions - extent and scale of vaccination zone to be determined via pre-detailed criteria, and current assessment of on the ground situation and circumstances.

 

The principle consideration is to rapidly achieve a protected zone around the area with high herd immunity 5 days or more ahead of anticipated first virus challenge, together with vaccination at the "heart" of the area to reduce potential virus amplification at the centre, and protect farms at highest risk.

 

The vaccination programme should aim for completion in less than10 days, so that response to vaccination is seen from about 5 -7 days post-commencement and cases should cease by day 24 post-commencement.

 

12 Standstill period to allow response to vaccine, or response to viral challenge pre or post vaccination. (this time scale should be a minimum of 14 days, preferably 21 days)

 

13 Regular Monitoring and surveillance for clinical signs

 

14 21/30 days post vaccination commence screening with 3ABC marker test to differentiate and determine which animals have responded to vaccine and those who have responded to viral challenge, either pre or post vaccination - if not previously identified by clinical means during monitoring. These animals which have responded to viral challenge will then be slaughtered. The incidence of these animals may be highest close to the index IP but in the majority of herds and flocks would not be present.

 

15 Vaccination should be applied from edge of zone or area towards centre of outbreak(s), and simultaneously with different teams on contiguous premises at the highest risk of receiving and amplifying infection at the heart of the zone, and to all susceptible livestock.

 

16 All tracings back from index premise should be traced, tested and could be vaccinated as a precautionary measure.

* PCR - polymerase chain reaction

 

* 3ABC Marker test - papers available on request

 

 

7.2 CONTROL IN THE FUTURE & THE ROLE OF VACCINATION

 

MODERN VACCINES AND TESTS

 

7.2.1 The issues of efficacy, potency and availability of vaccines are key to the acceptance of the incorporation of vaccination as part of a control programme.

 

We have considered the published documents of Merial, Intervet and United BioMedical*, consulted with vets and virologists and raised this issue with the Chief Veterinary Officer regarding vaccination of the hefted flocks (Aug 2001).

 

*All these papers are available and we can forward them if required.

7.2.2 Modern vaccines are highly purified and inactivated. If administered in the appropriate form and in the right conditions they can provide effective immunity when used as part of a programme to control the disease with subsequent surveillance and testing. Ref Drs Sutmoller, Barteling, Watkins, Merial publication, etc

 

7.2.3 The main opposition that we have encountered to the use of vaccination is that the non structural protein test, used to distinguish between response to vaccine as opposed to response to infection, has not yet been fully validated to the guidelines of the OIE.

 

Intervet have now introduced a 3ABC marker test which is capable of differentiating between response to vaccination and response to viral challenge. This has been extensively tested and trialled and provides a definitive tool to differentiate between those animals that have responded to vaccination or viral challenge, for use at herd level.

 

Merial have also produced a similar test and had the test independently assessed although the test is a described' test, but it is not yet proscribed', as it has not yet been validated.

 

7.2.4 The benefits of such tests is that they provide the key tool to screen herds to determine the presence, or otherwise, of animals which have met FMDV infection. Herds with a low proportion of reactors on a primary screen could then be re-tested by serology in a complete herd test, with possible addition of a second test to determine if virus or viral RNA, or anti-FMDV IgA was present in a pharyngeal sample of positive animals.

 

Such a system was used in Korea in 2000 following emergency vaccination with results presented to OIE as part of the process of regaining FMD freedom. This means that rapid surveillance methods can be used as a means of demonstrating freedom from infection, which is paramount in regaining disease free status.

 

We refer to attached paper from Dr Sutmoller and Dr Barteling presented to the Royal Society Inquiry. Appendix 20

 

In our discussions regarding the vaccination of the hefted flocks, the subsequent surveillance and testing, using the NSP test to differentiate between response to vaccination as opposed to challenge pre or post vaccination, was to have provided an effective method of establishing the extent of disease spread, response to vaccination and in determining disease free status.

 

 

7.3 THE ROLE OF THE OIE

 

Sale of Meat and Animal Products Post Vaccination, Disease Free Status and Export Markets

 

7.3.1 The Office International Epizooties (OIE) based in Paris is the international body responsible for conferring disease free status (DFS). Currently, return to DFS post vaccination requires 12 months, while only 3 months is required following a stamping out' method of control.

 

7.3.2 However "These trade regulations are not based on risk assessments, but rather:

* on the notion that vaccination might perpetuate carriers in the population and that those carriers may pose a risk for FMD free countries that do not practice vaccination.

* that there are no methods available for the detection of carriers in vaccinated populations"

 

"Normal export should be resumed, when after any outbreak, the veterinary services would show the absence of FMD.

*This should be independent of whether stamping-out plus ring vaccination or vaccination only was used to control the outbreak.

*There should not be a set time limit.

*The sooner the country or region shows the absence of viral activity the earlier normal trade can be resumed."

 

See attached paper of Dr Sutmoller's presentation to the Royal Society.

Appendix 20

 

7.3.3 Because the tests now exist to determine between response to infection and response to vaccination those animals which have responded to infection can now be identified and slaughtered. Such infection may have arisen as a result of pre or post vaccination viral challenge before the vaccinated animal has responded to the vaccine.

 

Those animals which have responded only to vaccination can thus be identified.

 

7.3.4 Animals which have been vaccinated and not responded with anti-NSP antibodies to infection might not be detected if tests of low sensitivity are used. Therefore tests should be used on herd basis where the probability of non-detection can be estimated and would be extremely low with a well designed screening program. Further, there has been no scientific evidence to show that such animals they have ever infected other animals, so non-detection carries exceptionally low risk.

 

"Carriers or persistently infected animals

*The fear that vaccination causes FMD carriers and interferes with the eradication effort is completely hypothetical and scientifically unfounded.

*There is much more chance of getting FMD carriers among cattle and sheep with clinical or sub-clinical FMD."

 

See attached paper from Dr Sutmoller's presentation to the Royal Society.

 

7.3.5 The vaccine used is an inactivated antigen and is highly purified.

 

7.3.6 It is therefore necessary to move to a science based risk assessment to determine absence of disease, rather than rely on an arbitrary time scale.

 

7.3.7 Post vaccination surveillance and serology, with the use of the 3ABC marker tests, provide the definitive tool to determine disease free status and can thus be used to restore DFS possibly sooner than with stamping out. There is certainly no justification to apply a penalty of a longer time period with vaccination.

 

In future, undoubtedly the use of robotic molecular tests for viral RNA, e.g. as used in human health services will be used, and this will further increase the speed of the process.

 

7.3.8 Similarly the restraints placed upon the use of vaccinated meat, meat products and milk are not required as it can be clearly demonstrated that the animals have not responded to infection, and herds proven to be clear of past exposure present no risk.

 

7.3.9 It is therefore fundamentally important that the criteria governing return to DFS and export markets are based on science based risk assessment. If this basis is established then the current penalties incurred with the use of vaccination are no longer applicable. Vaccination as a modern, humane approach to FMD control can be used without the need for any pre-determined or pre-agreed thresholds, but as the preferred and primary means of control for at-risk farms, together with immediate slaughter of animals where acute infection is confirmed.

 

 

 

8 RECOMMENDATIONS

 

The Adoption of Process and Procedures to deal with future outbreaks

May we respectfully ask the Inquiry to consider:

 

1 Agreeing a process and procedure with farmers, livestock owners, local veterinary practitioners and the State Veterinary Service to establish surveillance regimes.

 

2 The drawing up of national, regional and local contingency plans which are in the public domain and produced in consultation with local communities representing all sectors and stakeholders.

 

3 That the Contingency Plans should include clear protocols detailing diagnostic facilities, effective farm quarantine, safe animal separation details, and bio-security arrangements for farms, personnel, vehicles and animals.

 

4 The Contingency Plan should make provision for vaccine banks and determine how, and who should deliver the vaccine and how this is to be regulated, recorded and monitored.

 

5 The Contingency Plan should make proper provision for humane slaughter and disposal of infected stock.

 

6 The Contingency Plan should also define a regime and protocol for post vaccination surveillance, monitoring and testing programmes.

 

7 Discussions should be undertaken now with the OIE and EU to agree such protocols and define all procedures. Particular regard should be had to the process to be adopted to demonstrate freedom from FMD.

 

 

 

 

 

9 CONCLUSIONS

 

This FMD epidemic has been one of the worst post war experiences of the UK. It is imperative to ensure that it is not repeated.

 

It is therefore incumbent on all authorities and organisations to contribute to and own the Contingency Plan to deal with another outbreak, should this occur.

 

One of the greatest problems encountered in the 2001 epidemic was that the control polices did not have the total support of the community. The control measures were draconian, and often implemented with scant regard for the law and for human rights. It is for these reasons that opposition to culls occurred. All the people we dealt with were firmly of the opinion that they had undertaken rigorous bio-security and farm isolation and that their animals were healthy.

 

They all said that if testing showed presence of the disease they would willingly help round them up and agree to slaughter. So often their genuine beliefs were treated with ill-considered dismissal. Often it was only after they had asked for legal representation that proper risk assessments were undertaken. As stated earlier, none of the opposed culls with which we were involved went on to develop the disease.

 

No one can be proud of the record of incorrect and mis-diagnosis and the generation of impact and disruption to so many people's lives and livelihoods.

The test results clearly show that the unprecedented slaughter was not justified or warranted.

 

There must be a political will to ensure future control of FMD is reasonable, proportionate and rational to the scientific risk posed of onward transmission of the disease.

 

We sincerely hope that the Lessons Learned Inquiry seeks to provide a method of future control that does not result in such collateral damage and which protects the rich diversity of the rural areas of the United Kingdom and its communities.

 

 

NATIONAL FOOT & MOUTH GROUP MARCH 2002

 

 

 

Acknowledgements:

The National Foot & Mouth Group are very grateful for the assistance and advice from various vets and scientists in the preparation of this paper. In particular we would like to thank Mr Peter Wood of Vets for Vaccination for his support and contributions and Dr Keith Sumption for his guidance in the preparation of the Section relating to Vaccination and Control of FMD in the Future.

 

 

APPENDICES

 

 

Appendix 1 Parliamentary Answer of 26 March 2001 regarding decline in number of vets employed in SVS between 1979 to 2001

 

Appendix 2 The Welsh Local Government Association Report into the Handling of F&M Disease: October 2001

 

Appendix 3 Letter to the Vet Record of 19 May 2001, p640 from Dr Alex Donaldson and Dr Paul Kitching on FMD diagnosis.

 

Appendix 4 Infected Premises Confirmed by Lab Tests - In Gloucestershire, Hereford/Worcestershire & Shropshire - Answer to Parliamentary Question 2164

 

Appendix 5 Infected Premises Confirmed by Lab Tests for Anglesey - as above

 

Appendix 6 Correspondence with DEFRA - re Imports

 

Appendix 7 Note of Conversation with DEFRA on Imports & Treatment and inspection for meat entering UK

 

Appendix 8 Paper in the Vet Record 17 Nov 2001, p621-623 on Diagnosis of

FMD by real-time fluorogenic PCR assay.

 

Appendix 9 Letter to the Vet Record of December 22/29 2001 from Prof Michell regarding FMD Control Strategies

 

Appendix 10 File Note of Conversation with Paul Kitching prepared by Judith Bell of Burges Salmon of 31 May 2002

 

Appendix 11 Submission from Camphill Village Trust - Oaklands Park Farm

 

Appendix 12 Paper in the Vet Record of 12 May 2001 on Relative risks of the uncontrollable (airborne) spread of FMD by different species - Alex Donaldson, et al.

 

Appendix 13 Paper in the Vet Record of 12 May 2001 on Relative resistance of pigs to infection by natural aerosols of FMD virus - A Donaldson & S Alexanderson

 

Appendix 14 Letters in Vet Record of 12 May from various Ministry Vets on FMD control strategies and the number of negative test results from confirmed cases and contiguous culls.

 

Appendix 15 Letter from Forest of Dean FMD Group to Secretary of State of 1 May 2001

 

Appendix 16 Letter from Forest of Dean FMD Group to Secretary of State of 14 May 2001

 

Appendix 17 NFMG Letter to Environment, Food and Rural Affairs Committee and other MPs re Amendments to Animal Health Bill - 6 November 2001

 

 

APPENDICES, contd

 

Appendix 18 Dr Shannons interview published in the February 2002 edition of

Science & Public Affairs, a magazine produced by the British Association for the Advancement of Science

 

Appendix 19 NFMG Letter to the NFU regarding FMD vaccination and safety of

vaccinated milk, meat, etc - 23 August 2001

 

Also documents referred to in the letter:

 

Food Standards Agency advice regarding safety of FMD vaccines and

vaccinated milk, meat and meat products

 

National Consumer Council views on the sale and consumption of

FMD vaccinated milk, meat and meat products

 

Appendix 20 Dr Sutmoller's presentation to the Royal Society of 15 January 2002 regarding Vaccination and its applications.

 

 

The following are papers and publications which we have had regard to, or prepared,

during the course of the last 12 months and which have informed this submission to

the Lessons Learned Inquiry. If the Inquiry would like copies of any of these papers

we would be pleased to provide them.

1 Papers from Alan Beat on Modelling of FMD as presented to the Royal Society Inquiry

 

2 NFMG & Vets for Vaccination letter to Royal Society Inquiry re Vaccination

Issues - 26 November 2001

 

3 EU Strategy for Emergency Vaccination against Foot & Mouth Disease - 10 March 1999

 

4 Resolution of European Parliament - 5 April 2001 - Calling on the

Commission to review immediately the basic non-vaccination policy for FMD

 

5 Resolution of European Parliament - 6 September 2001 - Regarding FMD,

its control in the UK 2001 outbreak and implications for Europe

 

6 NFMG Briefing Note on Vaccination

 

7 Vets for Vaccination Briefing Note on Vaccination

 

8 The two Decisions that have been taken by the EU to allow vaccination to

assist in controlling the current UK epidemic. (EC Decisions 2001/257/EC and 326/EC) Decision 257 (dated 30.03.01) relating to Cumbria and Devon. Decision 326 (dated 24.04.01) relating to Cumbria, Devon, Cornwall, Somerset and Dorset.