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

 

  For the attention of:

 

Susan Ivory

DEFRA

1a Page Street

London  SW1P 3PQ

 

                                                                                                         27 February 2003

 

Dear Ms Ivory

 

CONSULATION ON DEFRA’S FMD CONTINGENCY PLAN, DECISION TREE & SLAUGHTER PROTOCOL

 Please find attached our response to Defra’s consultation on the above and the relevant supporting papers.

We also append our Draft Programme for the Containment, Control and Eradication of FMD incorporating Emergency Protective Vaccination and would be grateful if this could also be taken as part of our submission.

We would be grateful to receive a copy of the revised Contingency Plan in due course.

If you have any queries regarding the attached papers please do not hesitate to contact us.

Yours sincerely

 

Janet Bayley

NFMG Co-ordinator

 

        

   

 

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

 

 

 

DEFRA FOOT & MOUTH CONTINGENCY PLAN, DECISION TREE & SLAUGHTER PROTOCOL

 

NFMG RESPONSE TO CONSULTATION:

 

 

1          INTRODUCTION

 

The NFMG welcome the publication and consultation on the Government’s intended Contingency Plans for use in the event of a future outbreak of Foot and Mouth (FMD).  We are also pleased to note that many of the issues we have raised and advanced in our various submissions to the FMD Inquiries have now been incorporated into the Plan.

 

However, we have two over-riding concerns:

 

a          that the key issue of Emergency Vaccination, as a means of controlling FMD, does not appear, as yet, to have been sufficiently developed and taken forward, and

 

b          the inclusion in the Contingency plan of the use of pre-emptive and ‘firebreak’ culling of animals not exposed to disease, as a means of FMD control.

 

We wish to first address these concerns and then respond to the particulars within the Contingency Plan, the Decision Tree and the Slaughter Protocol.

 

 

2          EMERGENCY VACCINATION

 

2.1       Requirement for Emergency Vaccination Protocol

 

The revised Animal Health Act which has recently been adopted has placed upon the Secretary of State a “Duty to consider vaccination”  in relation to any occurrence of FMD, and whether “treating animals with serum or vaccine is more appropriate than any other means of preventing the spread of disease.”      See Section 14B.

 

In addition, the Draft EU Directive for the Control of FMD also states in Annex XVII – Criteria and Requirements for Contingency Plans, that:

 

“Member states shall ensure that contingency plans meet at least the following requirements:

 

Para 10           Detailed plans shall be available for emergency vaccination”

 

See EU Draft Directive, Page 106

 

While a detailed Contingency Plan, Decision Tree and Slaughter Protocol has been prepared and submitted for consideration and consultation, thus far, the Contingency Plan contains little in relation in emergency vaccination and no equivalent Vaccination Protocol has been drawn up for consultation and to be used in the event of a future outbreak.

 

Given that both the UK Animal Health Act and the proposed revised EU Directive now provide for the use of Emergency Vaccination as a means of FMD control it is imperative that such a Vaccination Protocol should now be drawn up to form part of the UK FMD Contingency  Plan.

 

We submit that this is a major deficiency within the Contingency Plan and should be addressed with urgency.

 

 

2.2       Scope and Extent of Vaccination Protocol

 

As part of our submission to the Royal Society Inquiry we developed a Draft Programme for the Containment, Control and Eradication of FMD incorporating Emergency Vaccination.  We attach the Programme and its supporting papers at the end of this submission and hope that this may be of assistance.                                                      

 

The document was not intended to be prescriptive – but to illustrate how such a process could be applied and to stimulate debate and discussion.  However there are several factors which we submit should be included within the Government’s own Emergency Vaccination Protocol, namely:

 

 

1          Criteria and Thresholds for determining use of vaccination

 

2          Provision and availability of appropriate NSP free vaccines and relevant differential tests for different sero-types of FMD

 

3          Procedures determining when, what, where and how vaccination will be     applied and how this will be recorded

 

4          Bio-security and other measures to be employed in the vaccination zone;

 

i           during vaccination,

 

ii           post vaccination and prior to the commencement of sampling, and

 

iii          during sampling and awaiting results.

 

 

5          Post vaccination surveillance – measures and application

 

6          A sampling and sero-surveillance programme to determine which flocks and herds have been exposed to infection and to define what additional screening may be needed.

 

            Note:   Such a sampling programme should be agreed in advance with the OIE to define what data and information will need to be submitted in order to determine Disease free status in accordance with Article 2.1.1.7 of the Animal Health Code, Chapter 2 relating to FMD and as per Item 6   

 

7          Similarly there is need for agreement within the EU to determine that intra-community trade will be determined in accordance with the  OIE  declaration of Disease free status.

 

8          To disseminate the relevant information and instigate appropriate training prior to a future outbreak with veterinarians, farmers, and all others likely to be involved in delivery of a vaccination protocol.

 

9          To establish a clear timetable setting out the necessary time scales that each process would require and the implications for all those involved in the rural economy – including the time frame for the re-opening the countryside post vaccination.

 

As set out in the Draft EU Directive, principally but not exclusively in Section 8

dealing with Vaccination, some of these elements have been developed.  Articles

49 – 58 provide the initial framework as to how vaccination will be utilised to control

an outbreak.

 

However there would appear to still be substantial areas which need clear and full detail and articulation if Emergency Vaccination is to be meaningfully applied.

                       

We submit that until the UK Government has prepared and submitted such a Protocol for Emergency Vaccination for consultation, and it has been adopted, it will  not be possible for Emergency Vaccination to be duly considered in accordance with the revised Animal Health Act.

 

Furthermore, it may be very difficult to implement such a control if the relevant ‘Stakeholders’ have not had an opportunity to consider and understand how such a process would operate. 

 

We note from your covering letter on consultation that a revised Contingency Plan is due to be laid before Parliament at the end of March 2003.  We consider that the revised Contingency Plan must make detailed provision for emergency vaccination and how it would be utilised.

 

 

3          PRE-EMPTIVE AND FIREBREAK CULLING

 

3.1       FMD CONTINGENCY PLAN – Version 2.5, Decision Tree and Slaughter Protocol

 

At Page 8 of the Contingency Plan in the continuation of Para 7 – Outline of Policies and Initial Procedures – “If FMD is confirmed” it states that other additional strategies and options are available including:

 

“pre-emptive or ‘firebreak’ culling of animals not on infected premises not dangerous contacts or not necessarily exposed to disease, in order to prevent the wider spread of the disease out with the area”.

 

The Decision Tree sets out the factors which are to be taken into account in deciding which strategy to adopt to control the disease, while the Slaughter Protocol outlines the processes and actions that may be taken to slaughter animals in order to control and eradicate the disease.

 

3.2       Validity of Pre-emptive and ‘Firebreak’ Culling to Control FMD

 

We submit that until the full epidemiological data relating to the UK 2001 FMD epidemic has been independently and scientifically analysed and assessed the legitimacy for the use of pre-emptive and firebreak culling, as a means FMD control, has not been determined.

 

We contend that all the other measures, as detailed within the Contingency Plan and supporting papers, provide the necessary controls to bring an outbreak under control and eradicate the disease.

 

Furthermore, the information relating to incidence of disease in 2001 that has been made available, indicates that the use of pre-emptive culling as a control method resulted in massive numbers of healthy animals being slaughtered, with the attendant logistical problems of disposal and compensation payable – and many other socio-economic impacts.

 

We append our most recent assessment of the data we have obtained regarding this – Appendix 1.  We draw your attention to the very low number of positive cases of FMD that were confirmed when laboratory tested.  Also, the figures we have obtained for the Great Orton burial site provide compelling evidence that such measures are neither a proportionate nor rational response to control the disease.   These are also included in Appendix 1.

 

We urge that pre-emptive culling should not form any part of the disease control process, or at the very least be deferred until the analysis referred to above has been undertaken.

 

We also note that the EU Draft Directive does not make provision for pre-emptive culling of animals which are considered not to have been exposed to the disease.  See Article 8 ‘Preventive Eradication Programme’ – which only refers to animals ‘likely to be contaminated and, if considered necessary, of epidemiological linked production units or adjoining holdings.’

 

Therefore the draft Directive does not provide for the firebreak culling as detailed in the UK FMD Contingency Plan.

 

 

4          RESPONSE TO PARTICULARS IN CONTINGENCY PLAN

 

Firstly we welcome the clarity and detail that has been provided in the Contingency Plan, that the document is now freely available in the public domain and is to be subject to widespread consultation and revision.

 

Our response refers to the relevant pages and paragraphs within the document:

 

Page 8                        Para 7 – Re Pre-emptive culling  - see above

 

Page 8                        Para 7   Issues still requiring resolution.

 

Para 7 also states “For a vaccinate-to-live strategy to work, a number of logistical, technical and trade problems need to be resolved in consultation with interested parties.

 

Response:   May we suggest that a fully detailed Vaccination Protocol should be drawn up as soon as possible to deal with the logistical issues.  As regards technical and trade problems – these are addressed to some degree in the Draft EU Directive.

 

The issues relating to the treatment of un-vaccinated and vaccinated meat and milk, etc are dealt with in detail in the draft Directive.  We urge that DEFRA, in its discussions with Europe, query whether such treatments are necessary and are based on science-based risk assessment.  It is our understanding that meat, milk and meat products sourced from Protection Zones and Surveillance Zones during the 2001 epidemic were not subject to such treatments.  It is therefore questionable whether such treatments should be applied in vaccination zones – where it could well be argued there is even less likelihood of virus circulation.

 

The issue of whether vaccinated products need to be labelled is also covered in the EU Draft Directive.   Here again the EU is suggesting some parity between meat and milk sourced from non-vaccinating protection and surveillance zones and that sourced from vaccinating areas.

 

There needs to be a clear distinction drawn between those measures which are designed and put in place to prevent any onward transmission of FMD to susceptible animals, and those measures which relate to human health.

 

Regard must be had to both the Food Standards Agency Press Release of 20 April 2001 and the respective views of the National Consumer Council – both of which agree there is no need for FMD vaccinated animal products to be labelled – or any risk posed from the consumption by humans of FMD vaccinated animal products.

 

It is better to prepare statements now – and resolve these issues with the food industry and public education – rather than they be raised mid-epidemic with confusing and contradictory advice being provided for the consumer.

 

 

Page 25          Para 7 – Disposal        7.1  Disposal Hierarchy

 

We note that policy developments and environmental constraints have now determined that commercial incineration, followed by rendering are the preferred disposal methods.  However at para 7.2.2. it states that “Incineration capacity is limited and will only be able to deal with small isolated outbreaks or the first few days of a new outbreak or disease recrudescence.”

 

Thus, recourse to rendering would soon have to be taken up.  Here again disposal capacity is limited.

 

Response:    Given the additional constraints on the disposal of carcasses that would be imposed in the event of a future outbreak we consider that this limitation should be given greater weight in determining the control method, and inter alia, the number of animals thus requiring slaughter, ie whether to use culling or vaccination for disease control.  The full constraints on disposal must be properly factored in to the decision making process and the decision tree.

 

 

Page 27          Para 8 – Serology capacity

 

Response:   We understand that several types of real time RT-PCR tests are under development by various commercial companies world-wide and at the IAH, Pirbright.

 

Given the importance of fast and accurate diagnosis in determining presence and extent of infection we submit it would be very helpful for DEFRA to publish a position statement (similar to the references in the Decision Tree relating to what vaccine is being obtained and from where) to make clear what the current  and emerging situation is.

 

If the situation is that such tests require validation in order for recognition by the OIE in its Manual of Standards for Diagnostic Tests and Vaccines, and for licensing for use in the UK and the EU, then it would be very helpful to know what time scales are likely to apply.

 

If Government funding is needed to bring this work forward may we suggest that this would be a worthwhile investment.   Rapid diagnosis is a key tool in control and eradication.

 

Page 85          Annex I – Veterinary Risk Assessment, etc

 

Response:     We welcome the publication of the factors to be considered in this exercise – although it appears the provisions of this Annex were drawn up to respond to a re-occurrence of the 2001 outbreak.

 

In the event of a future outbreak we assume such risk assessment would be used to determine rights of way closure.   We submit that, properly modified, this paper forms a very good basis for such assessment.

 

Page 93          Annex L – Biosecurity Advice and Guidance

 

Response:     While welcoming an explicit and detailed list of recommended precautions we consider a major possible vector has not been addressed.  Namely the transmission of the disease by persons having had contact with infected animals and subsequently carrying the virus in the throat or nasal passages. 

 

Such persons may be unaware that they have been in contact with the disease – particularly in the early stages of infection.  We suggest that the use of appropriate face masks for personnel visiting the premises must also be included. 

 

Also disposable gloves should be used.

 

Additional Bio-security Advice

 

May we suggest that the Bio-security Section should also provide a protocol for:

 

Effective farm quarantine – explicitly detailing how farms and holdings can isolate stock from possible infection,  via:

 

1          safe animal separation distances from neighbouring stock and possible housing to minimise risk of infection from airborne transmission.  

 

2          the measures to be used for all personnel and visiting service vehicles, eg, feed and milk tankers, etc.   The issue of milk is particularly important given the possibility of early virus circulation –  during the last outbreak detailed plans addressing this and the requisite air filter maintenance of milk tankers were issued.

 

3          Such measures should also detail how a vaccination plan would be delivered – and how vaccination would be applied without compromising the farm’s quarantine and bio-security.

 

In addition each farm/holding should have a bio-security/farm quarantine plan pre-agreed with DEFRA – via the local DVM – which should be put into place as soon as disease is confirmed in the country.

 

Such plans could be based on the effective and thorough approach which was implemented with the Blue Box protocols.

 

 

5          RESPONSE TO FMD DECISION TREE

 

Firstly, may we re-iterate our concern regarding the inclusion of pre-emptive culling as a means of FMD control- see above.

 

We cite the relevant Section – and then our Response.

 

Para 7             Vaccination Policy   

 

Response:     This paragraph now appears out of date.  Please note there is now a draft EU legislative framework to provide for Emergency Vaccination – as detailed in the draft Directive 92/46/EC of 13 December 2003.  Articles 49 – 58 specifically deal with this approach.

 

Para 9             Vaccination Policy   

 

Response:     While accepting that there are still unresolved issues relating to Emergency Vaccination, given that the draft EU Directive has progressed and advanced this means of control, and that Defra itself is also undertaking significant discussions with Stakeholders to address these issues, it is sincerely hoped, and anticipated,  that an early resolution of outstanding matters will be achievable.

 

Para 12           Suppressive Vaccination  (Vaccinate to kill)       

 

Response:     We note that this Para states “It (suppressive vaccination) could also be used where there is an urgent need to reduce the amount of virus circulating in an areas and reduce the risk of spread beyond that area.”

 

However this rationale is not applied to the section on Protective Vaccination (Vaccinate to live) Paras 10 and 11.   We submit that this outcome would apply equally whether used for a ‘vaccinate to live’ or a ‘vaccinate to kill’ regime – as vaccination would substantially reduce the amount of virus circulation in both circumstances.  We therefore consider the same paragraph should be added to the Protective Vaccination section.

 

Para 17           Animals which are believed to have been exposed to infection

 

Response:     We welcome the inclusion of the caveat that where animals are believed to have been exposed to the disease these will be “subject to a veterinary inquiry to determine if, in the opinion of the Veterinary Inspector, they have been exposed to disease.” to determine if they are to be slaughtered.

 

A major concern in the 2001 outbreak was that little veterinary risk assessment was undertaken to determine the likelihood of infection – with the obvious trauma and distress when farmers and owners truly held that there animals had not been exposed to infection – and no risk assessment was undertaken prior to slaughter.

 

Para 18           Same section as above

 

Response:     Again we welcome the inclusion of the sentence “A decision to slaughter will be taken by the veterinary inspector based on information gathered during the inquiry and account will be taken of levels of bio-security.  The action that we take will depend on risk assessment.”

 

However we urge that for all farmers and livestock holders should be fully briefed and kept updated on farm bio-security and effective farm quarantine – perhaps on a bi-ennial basis – so that should a future outbreak of FMD occur they know immediately how to isolate themselves, their farm, their animals and put in place all necessary measures to protect against infection.

 

Para 20           To prevent the spread of disease

 

Response:     Pre-emptive culling etc.   Please also have regard to our earlier statements regarding this.  See Section 3

 

Our main concern is that a decision to impose a blanket cull will again result in many healthy animals being needlessly killed, create major logistical problems, rule out proper veterinary risk assessment, generate distress and despair amongst farmers and livestock owners and adversely impact on the wider rural economy and society.

 

We cannot stress enough how little evidence has been advanced to substantiate this approach post the 2001 epidemic.

 

We submit that once nation wide movement restrictions are imposed, effective farm quarantine established and the requisite bio-security enforced – via the ‘Blue Box’ approach if necessary, transmission of the disease will be halted.

 

If some form of firebreak is needed – then a recourse to fire-break vaccination, on a vaccinate to live approach, would reduce virus amplification and transmission to a far greater extent than ‘firebreak’ or pre-emptive culling.

 

We urge that pre-emptive culling should be removed from the Contingency Plan and Decision tree as a means of controlling disease – we note that it does not feature in the draft EU Directive.

 

 

5.1       The Decision Tree Flow Chart

 

Response:     It is our understanding that vaccination is now to be considered ‘as a tool of first resort’ in line with the Royal Society recommendations and the EU FMD Report.  Therefore we question why its consideration (Box 2) is linked with an ‘And’ to Box 4 ‘Are there additional culling strategies?’

 

There should also be a link from the box asking ‘Are resources and disposal capacity available for additional cull strategies’ back to the vaccination line if there is ‘No’ disposal capacity available.  It should not result solely in endemic FMD as the Decision Tree shows or to the box ‘Stamping out and additional cull strategies’.

 

5.3       FMD Decision Tree – Factors to be considered

 

5.3.1    Decision Box 2 – Is vaccination permissible and possible?

 

Response 1:              We note that it is suggested that ‘A 2-dose strategy (followed by a booster at 6 months) would be necessary for a vaccinate-to-live strategy’.

 

It is our understanding that the EU Directive appears to advance only a 1 dose strategy in the Articles relating to Vaccination 49-58.

 

Please could DEFRA clarify with the EU and others if a 2 dose strategy is necessary.  We submit that the NSP free vaccines, of high potency and delivered at suitable payload rate would enable a 1 dose strategy to be used with all the attendant benefits.

 

Response 2:  With reference to the validation of differential tests to be used for post vaccination surveillance.  We understand that proposals are currently under consideration with the OIE to design the appropriate sampling and surveillance regime to determine which herds and flocks have been exposed to disease and those which have solely responded to vaccination.

 

This regime may enable submission of appropriate data to the OIE to recover DFS before the validation of the specific differential tests is completed.  No doubt DEFRA is aware of this situation – and will be able to utilise this approach should a further outbreak of FMD occur.

 

 

5.3.2    Decision Box 3: Is the exit strategy “vaccinate to live”?

 

Response 1:  With reference to the controls on products from vaccinated animals. 

 

We urge that the UK Government question whether all such controls are necessary when evaluated in terms of science based risk assessment.

 

The purpose of the treatments is to prevent any onward transmission of FMD to further susceptible animals.  In the 2001 epidemic many animal products from Protection and Surveillance zone where allowed to enter the human food supply chain without the need for such treatments.   On the condition that certain provisions and caveats for movement of animals to slaughter and milk for consumption were followed.

 

It would therefore seem reasonable to question whether such treatments are needed for animal products destined for human consumption from Vaccination Zones, where, if anything, there is likely to be an even lower possibility of virus circulation than in the un-vaccinated Protection and Surveillance Zones.   The provisions which were applied in the Protection and Surveillance in 2001 would be sufficient to prevent any onward transmission of disease.

 

Furthermore with the banning of all swill feeding the possibility of FMD contaminated food being fed to susceptible animals should now be non-existent.

 

We also note that the various time scales that have been applied for the application of these treatments have now been superseded by the draft EU FMD Directive.  Please see Articles 49-48.

 

Also ditto for the movement of vaccinated animals.

 

 

Response 2:  With reference to food labelling.

 

During the 2001 epidemic we became very  concerned at the confusing and contradictory statements which were being repeated by many involved in the discussions on vaccination.  Eventually we wrote to the NFU in response to this situation and attach the letter and supporting papers as our position statement on the issue of the labelling and sale of vaccinated animal products.       Appendix 2

 

We understand from the Food Standards Agency and the National Consumer Council that FMD vaccinated products do not require labelling at point of sale, nor do they pose any risk to human health.

 

We urge that DEFRA seeks to resolve these issues with the FSA, NCC, food producers and retailers as soon as possible.  The confusing and often erroneous statements that were made during the 2001 epidemic appeared to result in widespread opposition to FMD vaccination that was not founded on fact or reality.

 

 

6          DISEASE CONTROL (SLAUGHTER) PROTOCOL

 

Response:     While welcoming the explicit nature of the document in identifying which animals are to be slaughtered, and the provision of explanations thereto, we consider that an equivalent document relating to a Vaccination Protocol is also required.  Furthermore, our main concern is the legitimacy of the use of slaughter to prevent the spread of disease, ie ‘firebreak’ and preventative culls.

 

In particular:

 

Animals exposed to infection:

 

a)         Direct contact with infected animals

 

Response:     As stated earlier, a clear and detailed farm quarantine and bio-security plan, which includes pre-determined safe animal separation distances, should be put in place as soon as FMD is confirmed.  This would reduce the likelihood of infected animals having direct contact with susceptible animals – and thus reduce onward transmission.  Such plans should be agreed in advance of an outbreak – and adherence to them taken into account in assessing these criteria of the Slaughter Protocol.

 

b)         Airborne Spread

 

Response:     In the 2001 epidemic the issue of airborne transmission gave rise to grave concern.  We are mindful of the papers subsequently published in the Vet Record regarding the relative risks of uncontrollable (airborne) spread and the relative resistance of pigs to infection by natural aerosols of FMD. *

 

We urge that in assessing this possible transmission route DEFRA will consult widely with FMD scientists to ascertain the true level of risk which airborne spread may pose so that it is correctly ascertained and not over-stated.

 

In general:     We submit that all the criteria detailed in this section on Animals exposed to infection would benefit from inclusion in a detailed Farm Quarantine and Bio-security protocol, explaining what precautions need to be taken.

 

Such a protocol should show what measures should be put in place to limit possible transmission of the disease in each section, a – j, as soon as the first case is confirmed.

 

To prevent the spread of disease – new slaughter powers for pre-emptive culling

 

Response:     As detailed earlier in Section 3 and in response to Para 20 of the Decision Tree we remain extremely concerned as to the inclusion of this approach within the control measures.

 

Once movement restrictions have been imposed and all other farm quarantine and bio-security measures implemented, including the effective enforcement of the ‘Blue Box’ schemes, the likelihood of being unable to control the disease are effectively nil.  Should preventative measures be needed then it would be far more effective to confer immunity by vaccination, rather than through the logistically difficult and far more risky approach of pre-emptive culling, with all its attendant socio-economic impact.

 

However, what needs to be made clear is that there will almost inevitably be a time delay from the imposition of these measures to the reduction in the number of FMD cases continuing to occur on a daily basis.   This is not because the disease is spreading, but because clinical symptoms will continue to appear on farms and holdings which had become infected before the standstill and other measures were imposed.  

 

This is exactly what happened in 2001.  Indeed by the time the Contiguous Cull was introduced on the 28 March 2001, the disease had already peaked and the number of new cases per day had begun to fall.   

 

We respectfully ask DEFRA and the Secretary of State to repeal this provision from the Animal Health Act, and from the FMD contingency plan.  Much trust and good will has been lost between the Department and the farming and rural communities through the 2001 FMD outbreak.

 

Such a gesture, coupled with clear and sound bio-security guidance and a workable vaccination protocol could go a long way to restoring the much needed trust and co-operation that must be re-established if we are to have a secure and workable future for UK farmers and the associated rural economy and society.

 

NFMG  -  February 2003

 

 

 

 

 

 

     APPENDIX 1

 

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

LAB TEST RESULTS FOR FMD WHICH DEMONSTRATE VERY LOW NUMBER OF PREMISES WERE ACTUALLY INFECTED

Source of Data:  Parliamentary Question 2164 & DEFRA  Website

 As of 20 February 2003, the total number of a AFFECTED PREMISES on the DEFRA website now stands at  10,472

This is the total number of premises where animals have been slaughtered.

According to Parliamentary Question and Answer PQ 2164:

 

The total number of premises that were sampled  is    2,372

 Of those that were sampled only   1,328  returned positive results demonstrating that they were either infected or had been infected and animals now carried antibodies.

 

Therefore, although  10,472  farms and premises were slaughtered only  1,328  were definitely confirmed to have had the disease when lab tested. 

We know from the papers and letter of Dr Paul Kitching and Dr Alex Donaldson in the Vet Record of the 19 May 2001 that if samples were sent to Pirbright for testing, from animals that were either exhibiting clinical signs or had been exposed to the disease, the tests would provide positive results.

(Note:  If DEFRA now has further epidemiological data which does not support the above it would be timely for such information to be published).

Furthermore,  the level of incidence of disease that was confirmed in the lab, county by county, shows that some counties had hardly any infection confirmed, yet massive numbers of farms and premises were slaughtered.

For  example, Gloucestershire, Hereford & Worcestershire, Shropshire, Wigtownshire.    At Great Orton burial pit – where approximately = a million animals were slaughtered, only 1 farm was definitely confirmed to have antibody positive sheep.

SEE FOLLOWING INFORMATION

 

INFECTED PREMISES CONFIRMED BY LAB TESTS - RATIO TO NUMBER OF FARMS CULLED -  IN GLOUCESTERSHIRE, HEREFORD/WORCESTERSHIRE & SHROPSHIRE, WALES, AND WIGTOWNSHIRE

 

Source of data:  Answer to Parliamentary Question   2164

 

 

County            No of IPs*       No tested       No +ve          Total Farms       Ratio Culled

                                                                                                

 

Glos                           72                   46                   13                    346               1:26

 

Here/Worc                  66                    49                     15                   394               1:26

 

Shrops                       12                     8                     5                     131               1:26

  

Wales                       115                   102                  60                  806                1:13

 

Wigtownshire          15                     13                   2                   218               1:109

 

 

*An IP was a premise declared as infected by DEFRA either on the basis of clinical signs or if testing positive.  It is important to note that the reliance on clinical signs to confirm the presence of the disease, particularly for sheep, was considered unreliable.  The total number of farms slaughtered includes all Infected Premises, Dangerous Contacts, Contiguous Culls and Slaughter on Suspicion cases.

 

Note:

 

We understand that if samples from animals showing clinical signs were submitted for laboratory testing then the lab test results would have provided positive results if the animals were infected with FMD.

 

This view of Dr Paul Kitching and Dr Alex Donaldson of IAH Pirbright – is expressed in the Vet Record of 19 May 2001, p640.  They also write:

 

“We believe that laboratory support for a diagnosis of FMD in sheep, in particular, is essential.”

 

ANGLESEY

 

We understand that there were 13 IPs on Anglesey

 

Of these:         5 tested +ve

                       

5 tested –ve

 

3 were not tested.

 

Of approx. 244 farms culled as a firebreak, only 7 were tested - all were negative.

 

We also understand that the 1st outbreak was in Gaerwaen abattoir.

 

Apparently there was some delay in the slaughter at the abattoir of a matter of days which allowed the virus to spread, possibly by the movement of vehicles and personnel, or by other vectors and thus infect other premises.  As shown above it appears only 5 became infected and have been confirmed on laboratory testing.

 

We draw your attention to the number of farms culled on the basis of only 5 positive IP’s identified in laboratory test results.

 

The ratio is 244 divided by 5.    This is 1:49.

 

The Anglesey figures were supplied to NFMG and submitted to the Anderson Inquiry.

 

 

GREAT ORTON

 

These figures were supplied by DEFRA Carlisle and submitted to the Cumbria Inquiry by Will Cockbain – NFU County Chairman – NFMG also then submitted them to the Anderson Inquiry. 

 

Will Cockbain – NFU County Chairman – Giving evidence to Cumbria Inquiry

 

“Reference to the 3km cull was also made by county NFU chairman Will Cockbain

of Rakefoot Farm, Keswick, who told the inquiry that chief vet Jim Scudamore

had justified the slaughter by claiming the sheep flock was "heavily

infected", although MAFF had failed to produce any evidence at the time to

support this.

 

According to Mr Cockbain, the results of blood tests carried out at Gt Orton

had only been revealed to him a short time before the inquiry and these had

shown that sheep from 115 farms had been tested. Sheep from only one farm

had tested positive, with one additional "mild positive" and three

"inconclusive". "This shows that Jim Scudamore's initial reason for the 3km

cull was wrong," he said.”

 

Will Cockbain’s data as supplied to NFMG:

 

Great Orton

 

There were sheep from 115 farms tested, 5786 animals in total, between the 7th and

23rd of April 2001.

 

One farm had a positive test on 9 sheep.

 

One farm had what Andrew Hayward (DVM Cumbria) termed "mild" positive with 2 sheep testing positive.

 

Three farms were inconclusive and the rest, 110 farms had negative tests.

 

No farms were culled as a result of finding clinical signs of FMD, I asked if any clinical signs had been found and he said no. To the best of my knowledge 451,000 sheep were slaughtered at Gt Orton.

 

NFMG -  20 February 2003

 

                                                                                                                   APPENDIX 2

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

 

 

23 August 2001

 

 

For the attention of Mr Martin Haworth

 

NFU Headquarters

Agriculture House

164 Shaftesbury Avenue

London  WC2H 8HL

 

 

Dear Martin Haworth 

 

RE: NFU VIEWS ON VACCINATION, FOOD LABELLING, FSA & NCC

 

Thank you for our conversation yesterday.

 

Our concern is that the NFU's recently expressed views at a public meeting in Carlisle last week, regarding vaccination and food labelling, do not concur with statements from the FSA or NCC.  I have attached files of the FSA press release and NCC statements for you to consider.

 

In addition, the opinions expressed about the need to slaughter vaccinated animals, and how vaccination would affect the return to disease free status do not appear to reflect the EU decisions, or the provisions of the OIE on FMD and vaccination - as contained within the International Animal Health Code - 2001, concerning FMD - Chapter 2.1.1

 

As regards the provisions of the EU legislation regarding vaccination, it appears that the NFU are still of the opinion that all vaccinated animals have to be slaughtered.  However, the EU Decisions sought and obtained by the UK Government to vaccinate cattle in Devon and Cumbria, and later in Somerset, Cornwall and Dorset, 30 March and 24 April, respectively, were for protective vaccination, not suppressive vaccination, which meant that it was not necessary to slaughter such animals, under EU legislation.

 

As regards comments, at the same meeting,  that under EU regulations it did not say that vaccinated animals could live, the NF&MG have searched through the legislation and can find no reference to this.  What the EU decision of 30 March does say is how vaccinated animals and milk products are to be prepared to enter the food chain. See Annex V and VI of the Decision - 2001/257/EC - 30 March 2001.

 

The view expressed by Mr Gill, based on a letter from a friend in Argentina, that FMD can be transmitted between vaccinated animals and their progeny, is also worrying.  The view of many leading world scientists in FMD is that this is not the case.

 

Regarding the view that FMD vaccinated meat and meat products would have to be labelled - it is the opinion of the Food Standards Agency and the National Consumer Council that this is not the case.  FMD vaccinated meat and milk products imported into the EU and UK are not labelled so there should be no necessity for home produced meat and products be to disadvantaged and treated differently.   May we take this opportunity to say that it has always appeared odd that the NFU has sought to have more onerous restrictions placed on the domestic market as opposed to the import market.

 

We feel the expression of such views may give rise to foundless consumer resistance to vaccination.

 

One of the most worrying aspects regarding FMD vaccinated imports is that despite lengthy research and communication, mostly with DEFRA, the NF&MG have still not been able to ascertain the amount of FMD vaccinated meat and meat products entering the UK from countries where FMD is endemic or vaccination takes place.  Ultimately DEFRA referred us to the OIE website.  The assumption we have been forced to make is that it is not known by  DEFRA, or Customs and Excise, or anyone, how much vaccinated meat is actually being imported into the UK.

 

One of the key difficulties is that once the meat and meat products enter the EU, which they can do through many Border Inspection Posts across the EU,  there are no further controls as they pass from Country to Country.  Therefore it is extremely difficult to determine where the country of origin actually was, the only reference is the country of despatch.  Source DEFRA.

 

As we discussed in our conversation, the Group has submitted a report on the Control and Eradication of FMD in the Hefted Flocks to both the Welsh Assembly and DEFRA.  Copies have also been sent to Peter Rudman and Keith Baker and to NFU Cymru.  We have already had a meeting with Huw Richards and Mary James of NFU Cymru and would be very grateful to have the opportunity to discuss the above and the submitted report with yourself, Peter and hopefully Ben Gill.

 

If you have any queries, or would like a further copy of the report please do not hesitate to contact me.

 

Yours sincerely

 

Janet Bayley

National Foot & Mouth Group

CC to Mary James – NFU Cymru

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Press releases

 

FOOT AND MOUTH DISEASE

 

What does it mean for the consumers?

 

The Food Standards Agency advised on 21 February that foot and mouth disease does not pose a threat to food safety. This remains the case. The Agency has continued to monitor the outbreak and today issued further advice on the public health implications of the measures being taken to control foot and mouth.

 

 

USE OF A FOOT AND MOUTH VACCINE

 

The Food Standards Agency is satisfied that the use of such a vaccine would not have any implications for food safety.

 

All vaccines for food animals have to be given a licence before they can be used. As part of the licensing process, the Government’s independent expert committee, the Veterinary Products Committee, thoroughly assesses the safety of the vaccine to ensure that its use will not pose any threat to human health. This was done for the Foot and Mouth vaccine in 1992 and again when the licence was renewed in 1997, and on both occasions the Committee was satisfied that there would be no safety problems for anyone eating products from animals that have been treated in this way.

 

SALE OF MEAT FROM FOOT AND MOUTH SURVEILLANCE ZONES

 

The European Commission and the Government have agreed arrangements for the slaughter of animals from FMD surveillance zones for human consumption, providing the animals are certified as not showing clinical signs of disease. For disease control reasons a special round GB health mark will be stamped on export-standard meat produced in Great Britain to show that the meat can not be exported. This mark will be used on all meat processed in Great Britain. It is not an indication as to the origin of the meat, as it applies equally to imported meat that has been processed in Great Britain. The round health mark will replace the oval EU health mark. These arrangements are expected to come into force on 23 April.

 

The Food Standards Agency is satisfied that the meat from animals slaughtered under these arrangements would have no implications for food safety.

 

FOOD SAFETY AND FOOT AND MOUTH VACCINATION

 

How safe is it to consume meat and milk from animals that have been vaccinated against FMD?

 

7         The vaccine uses a dead virus, so it isn’t active and therefore cannot spread the disease.

7         The vaccine has been through rigorous safety assessment by independent experts (the Veterinary Products Committee) before being given a licence.

7         Millions of doses of FMD vaccine have been given world-wide with no adverse effects on human health. Foot and mouth disease vaccines are widely used throughout the developing world in parts of Africa, South America and Central America.

7         If people go abroad on holiday to countries where the FMD vaccine is routinely used and eat meat, that meat has probably been vaccinated and has never been shown to cause any human health problems. In mainland Europe (including The Netherlands, France, West Germany, Belgium, Italy, Spain and Switzerland, people were drinking milk and eating meat from animals vaccinated against FMD up until 1991.

7         In the Netherlands, meat from vaccinated animals does not enter the human food chain. This is as a result of concern about animal safety (vaccination may mask the presence of infection) rather than any risk to human consumers. Milk from vaccinated animals is being used for human consumption within the Netherlands.

 

Why is the FSA not proposing to label food products derived from animals that have been vaccinated against FMD? Doesn’t this deny consumers choice?

 

7         Animals are vaccinated against a number of diseases, about 33 in total, none of these vaccinations are known to pose any threat to human health. This is the case with FMD. Therefore, the FSA sees no reason to treat animal products from FMD vaccinated animals differently to products from animals vaccinated against other diseases.

7         The Agency is satisfied that the use of the FMD vaccine does not adversely affect the quality or safety of animal products. There is therefore no difference, from a human health point of view, between products from vaccinated and non-vaccinated animals. The FSA thinks it would be inappropriate if FMD vaccinated meat was labelled while other vaccinated meat was not.

 

If meat and milk from animals vaccinated against FMD is safe to eat, why is the Government talking about additional measures for these products, such as heat treatment for milk and de-boning of meat?

 

7         These are not food safety measures. They are disease control measures drawn up by Maff. The disease is highly contagious for animals and these extra controls are aimed at preventing the disease from spreading to non-infected animals.

 

It has been reported that shops say they will only stock milk and meat from FMD vaccinated animals if consumers want to buy them. Surely there is a danger that consumers will simply stop buying all British meat and milk if they are not confident of what they are buying?

 

7         We understand the supermarkets concern about consumer confidence. But, we are dealing with a situation that is very well understood. The disease is well known, it has been around for a long time. It has been studied very extensively and we are confident that there is no human health risk from vaccinated milk or meat from vaccinated animals.

 

What about the farmers’ opposition? Surely this sends a message to consumers that there is something to worry about?

 

7         Not at all. We have to be clear about different concerns here. Farmers are quite rightly concerned about their animals’ welfare and controlling the spread of the disease. These concerns are not prompted by food safety issues.

 

Vaccinations are used regularly for cattle in the UK. Which ones and on what scale? Do they result in antibodies or virus in the milk or meat?

 

7         There are currently 33 vaccines for cattle in the UK. Most of these are inactivated vaccines for calves and cattle against a range of diseases endemic to the UK. There are also a number of live vaccines, such as those against respiratory disease caused by bovine rhinotracheitis (IBR) virus and parainfluenza virus (PI3) and a vaccine against lungworm. There is a zero withdrawal period for these vaccines, as they do not present a risk to human health. Both live and inactivated vaccines do result in serum antibodies being excreted in the milk. Sales of some of the vaccines are very extensive; for instance tens of millions of doses of inactivated clostridial vaccine for sheep and cattle and of live parainfluenza virus vaccine are sold each year.

 

 

 

 

 

 

NATIONAL CONSUMER COUNCIL

 

Statement from Deirdre Hutton,  Chairman of National Consumer Council on Vaccination and Foot-and-Mouth Disease

 

20 Apr 2001

 

Food from vaccinated beasts can go into the food chain and need not be

labelled. But we must review our agricultural policy thoroughly and quickly

too.

 

Consumers have made the link between animal feeding practices, health and

welfare and food safety and they are inevitably worried. In our recent

research 23 per cent said that they have changed, or are thinking of

changing, their eating habits in the light of foot and mouth. Consumers are

right. Animal health and welfare is closely linked with human health and

food safety. But consumers are wrong if they think that foot and mouth

carries the same risks as BSE or genetic modification (GM).

 

It is our view that consumers need to be reassured of this before they will

accept meat or other food from livestock that has been vaccinated. Our

research showed that 71 per cent believe they are not getting enough

information about the way in which agricultural practices affect the meat we

eat.

 

To overcome these difficulties, foot and mouth must be treated as more than

an animal problem. The Food Standards Agency (FSA ) is a trusted public

health agency and needs to give out information about the whole range of

potential concerns. The Chairman of the FSA, Sir John Krebs, has begun this

task by saying quite plainly that there is no health risk from eating meat

and dairy products from animals that have been vaccinated. Indeed animals

are already vaccinated against a variety of things, all of which we accept

without question and some of the beef we import is undoubtedly from animals

that have been vaccinated. As one of those bodies that called for an

independent agency like the FSA, we accept the agency's view.

 

Nor do we believe that such food needs to be labelled to distinguish it from

other produce. The National Consumer Council, and other consumer

organisations, have of course argued that labelling should be applied in the

case of GM, so why the difference? Simply that in the case of genetic

modification we are dealing with a new technology where there is inevitably

some uncertainty. We do not know what, if any, the problems might be,

because we simply haven't got enough experience or all the science. The same remains true for BSE. In the case of foot and mouth there are several

hundred years of experience in the UK and abroad, which tell us that there

will not be a problem for human health.

 

 

But the public should demand more than information about the effects of foot

and mouth. There are some much bigger questions that need to be addressed.

For example:

 

? to what extent has this outbreak of foot and mouth been made worse by

modern practices in the food chain?

 

? what is the best way of farming sustainably in this country?

 

? why do we continue with a Common Agricultural Policy that has let down all

consumers?

 

Questions like this will only be addressed if the next government commits

itself to a thoroughgoing review of UK agricultural policy and the food

chain. That's why I wrote to the Prime Minister on 14 March calling for a

Food and Agriculture Commission to be established which would explore

options for more sustainable farm policies in the interests of farmers and

consumers alike. It is also vital that such a debate embraces the interests

of low income consumers. The EU's CAP has let down all consumers -

especially disadvantaged consumers - badly. It overcharges them for food,

reduces choice, undermines food quality and disregards the nutritional

consequences of its policies.

 

We have a unique opportunity to reform our agriculture for the benefit of

society as a whole. The next government must seize that opportunity.

END