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.