We have received responses to DEFRA's contingency plan: From Mary Marshall - member of DEFRAs FMD Stakeholders Group representing the Smallholders Forum (also a member of the Foreign and Emerging Diseases Committee of the US Animal Health Association)
Version 3 of DEFRA's Contingency Plan is now available (opens in new window)
From the Countryside Alliance Campaign for Independent Food
From Anne Lambourn - Individual with veterinary and farming connections, who has submitted material to all the Inquiries.
The National Foot and Mouth Group - "An affiliation of organisations affected by 2001 UK epidemic"
From Captain Bryn Wayt - "The EU proposals for fighting FMD are reasonably fair, but the UK makes it clear they are willing to go beyond what is proportionate by invoking the AHB..."
March 11 ~" this work is underway."
From the NFMG's response to the DEFRA Contingency Plan, kindly forwarded to us today: "The outstanding issues which remain are also due in part to the EU Directive - which specifies the various treatments for animal products - both from vaccinated and non-vaccinated areas, and the sampling and sero-surveillance that would have to take place after vaccination - with differential tests that are some way from full validation.
This does not mean that this approach/process cannot be used - but that a sampling/surveillance regime which incorporates these tests will have to meet OIE and EU requirements - this work is underway. "
March 3 ~ Comments on Defra's Foot and Mouth Disease Contingency Plan, Version 2.5
" "Defra should not be re-fighting the last war, but planning and training for the next."
While welcoming the consultation process on the contingency plan, I find the current document woefully inadequate and hope that significant changes in strategy based on recent developments in diagnostics and surveillance will be implemented, and further relevant research and trials will be supported and funded. Through my contacts with scientists in the UK, EU and North America, I am in possession of a considerable amount of information, some of which I have been asked to share only with government agencies. In all cases, I have shared information which is not in the public domain with Defra. In the comments that follow, I may refer to some of this information without providing full references, but all of this information is in the hands of Defra. ..." Mary Marshall, Member of Defra's FMD Stakeholders Group, representing the Smallholders Forum. and member of the Foreign and Emerging Diseases Committee of the US Animal Health Association has submitted an astonishingly knowledgeable response to DEFRA's Contingency Plan. It is of great importance - and we quote at some length from it in the paragraphs below. The entire paper may be read here.
March 3 ~ "Absent from this document are the crucial topics on improving diagnosis and record/data acquisition and analysis."
(Marshall Comments for DEFRA on their FMD Contingency Plan) There are major sections in the Contingency Plan on the press and internal press activities, and a curious phrase "Stakeholder Handling" (are we dangerous animals to be kept firmly under control?). Absent from this document are the crucial topics on improving diagnosis and record/data acquisition and analysis. Professor Martin Hugh-Jones' comments sum it up perfectly: "Some aspects which I hold are vital:
- Animal side tests of reliable sensitivity and high specificity. Nobody should or need wait for reference-quality laboratory confirmation.
- Wireless data acquisition from the farm at the time of examination and preliminary diagnosis by laptop or other suitable electronic device. Ditto updated data as the herd is processed. If "wireless" is difficult, it should be through a website or other access system that is available at all times. This should, if possible, include digital graphics acquisition and transmission -- if Page Street doesn't believe the VO, he can, for example, send a photograph of the lesions he has seen or of anything else.
- That data should be immediately omni-available, at least throughout Defra.
- The data loggers should have GPS chips installed so that there are no errors in accurately locating diseased, suspect, or healthy herds.
- Data should be GIS linked so that situations on individual farms can be queried remotely -- e.g., klik on a farm icon on a quasi-3-D map display, as well as to either constantly updated frequent analyses or by idiot-able custom analyses. Martin Hugh-Jones is a UK (Cambridge)-trained vet, currently Professor of Epidemiology, Dept. of Pathobiological Sciences, School of Veterinary Medicine, Louisiana State University, and Moderator of ProMED-mail. His other posts include:
Director, World Health Organisation Collaborating Center for Reference & Training in Remote Sensing and Geographical Information Systems for Veterinary Public Health
World Health Organisation/Veterinary Public Health,
Chairman, Working Group "Anthrax: Epidemiology & Information";
Coordinator, of Supervising Committee, "Anthrax Control & Research".
March 3 ~ Diagnostics.... portable real-time RT-PCR tests.....The US Congress has just been told that these tests are ready for use in an emergency....
(Marshall Comments for DEFRA on their FMD Contingency Plan) "....Objections to the use of the portable real-time RT-PCR tests (e.g. the test developed by the USDA/Tetracore) are still being raised. ...
Fred Landeg..: "Steve Edwards, Vice President of the OIE Standards Committee, is one of Defra's chief advisors. We are not behind on this!" (where is this then to be seen in the Contingency Plan?), and he went on to say that Defra relies on Pirbright which has full up-to-date expertise and knowledge.
Would that this were true!
Pirbright's own portable PCR test is still in development, and Pirbright is under-staffed and under-funded. But according to Landeg, "This is a small island. we have no trouble getting samples into the laborarory. Pirbright is the World Reference Library for FMD, and we use it in the laboratory, PCR that is. We are fully up to date".
This is surely open to international expert discussion and peer review. Defra may have no trouble getting samples to Pirbright, but in so doing, days will be lost and the disease likely to be out of control.
Suggestion: In order to reduce time to detection, use should be made of portable real-time PCR tests that can identify all 7 serotypes of the FMDv within 2 hours, using samples taken by non-invasive procedures. An immediate standstill of all animal movements should be declared. The results of tests on samples sent for laboratory identification of the serotype, which would be available within 3 hours, should immediately trigger production and distribution of vaccine. ........"
March 3 ~ GIS surveillance ... " it can eliminate the need for bulky double tags on sheep and goats and reduce the amount of paper work .."
( Comments for DEFRA on their FMD Contingency Plan) "....nowhere is there mention in this document of a comprehensive computerised GIS database and tracing capability linked to field diagnostics which would provide real-time disease management. The capability for this exists. There are at least two such systems: both are available through private US companies working independently but in cooperation with the US government. I have provided an outline of these and contact details to Defra.
When I asked about UK GIS capability at the stakeholders meeting on 25 February 2003, Fred Landeg replied that "we have GIS capability now and that it is exactly the same system that was in place in 2001".......
.....from one of the US companies:
"In summary, we can identify an animal or product at the farm, trace it through the supply chain, provide third party certification, use our newly developed biosensors to determine contamination , utilize new RFID technology for ear tags and container tracing, all with web based seamless technology. We can detect diseases with our sensors, provide immediate first responder information with contaminated area pictures, local supplier information, built in GIS/GPS analytical tools (water tables etc.), and provide check print outs for immediate producer payment. Our biosensors can detect any foreign-borne pathogen by contact or air. The new technology allows for rapid growth of the media cutting current standards in half. Most important we can do all of this economically ......"The Polish government has requested a demonstration of the system developed by the other private company.
Contrast this with Roy Hathaway's statement on 25 February 2003 that "we need a few days to type the strain and trace the movements and dangerous contacts.there would be a standstill on day 1 [when is day one according to these plans?], then tracing vaccination would not start before 7 days".
March 3 ~ Real-time alert (table top) exercises
( Comments for DEFRA on their FMD Contingency Plan) These are a requirement of the draft EU FMD Directive, but I could find no reference to them in the Contingency Plan. I have passed on to Defra information about the recent US exercises.
A comment from someone who was involved in one of these exercises:
"If DEFRA is relying on a seven day time table..."Good Luck". Twenty four hours is really stretching it in the states. In all our exercises FMD was out of control within that time frame. In the UK you have greater animal population densities, in smaller confined areas, and closer proximities than we do in the states. Disease transmission is much faster. Technology is the only key to detection and mitigation." The exercises in the US have shown that stakeholder participation is essential, and has the added benefit of demonstrating to the livestock industry which regulations are important (and which are not important) in mitigating the effects of an outbreak (Roger Breeze, private communication).
March 3 ~ "We need balanced, focused leadership which can.. rise above.... narrow vested interest groups, researchers seeking funds .... political pressures. "
( Comments for DEFRA on their FMD Contingency Plan) We need balanced, focused leadership which can evaluate, but also rise above, the quite legitimate demands of narrow vested interest groups, researchers seeking funds which may not be strictly relevant, and political pressures. This leadership should be centred on a strong CVO, advised by a group of government and independent scientists with a demonstrable predominance of veterinary expertise and experience.
The draft EU FMD Directive requires just such a permanent "expert group" (Article 78). Is it possible that such a group can be found amongst the numerous groups and committees outlined in the Defra's Contingency Plan? An explanation from Defra would be appreciated. This expert group must be more open and accountable than the group which was formed in 2001...."
March 3 ~"Please, can we fundamentally review the contingency plan and open it up to international consultation?"
" This is not a trivial matter. The stakeholders were told by Roy Hathaway on 25 February 2003 that the EU FMD Directive, which is legally binding in all EU countries, is a vague and loosely worded document, and consequently Defra will have broad powers of interpretation, including the full powers given in the Animal Health Act 2002. Some of these powers should never be exercised: with the sensible use of new diagnostic technologies that can rapidly and accurately identify infected animals and herds, there is no justification now or in the future for a contiguous or "firebreak" cull. The use of this technology would allow for the rapid implementation of targeted vaccination, thereby reducing the numbers of animals needing to be slaughtered and needing to be vaccinated. The procedures (locally, regionally and at HQ) to implement this suggested strategy should constitute a substantial part of the Contingency Plan..."
March 3 ~ Will Defra have the courage to accept this new approach to animal disease control?
Will the government provide the necessary funding?( Comments for DEFRA on their FMD Contingency Plan)
If the answer to these questions is "no", then one contributor's comments should be noted:
"Business is going to be directly behind the change. Class action litigation, demands from banks and financing agencies, lack of insurance coverage without exclusions, are having a global impact on the need for preventative measures. Lending agencies and insurance companies are extremely concerned about the assets they are investing in or protecting. Animal health and food safety issues are at the top of the list. Earlier this year, in the state of Kansas we had a false FMD rumor surface. Within one hour, the commodity markets dropped the max, and every corporation that depended on beef did the same, many losing over a $1 share value. Fast food chains, steak house chains, feed companies etc. It took one hour to accomplish this, luckily the markets were closing, or it would have been worse. Bureaucrats need to understand the consequences; they need to be shown they must invest in the protection of the economic future of their country. All it takes is one incident. Unfortunately, FMD will be back in the UK, they must know how to immediately isolate and control the problem; every member of the EU needs to as well."
March 1-2 ~"It seems that Defra is still woefully ill prepared..."
"... to implement emergency vaccination, and yet it obviously has detailed slaughter plans. The science is way ahead of Defra: there are the vaccines and tests available. What has been lacking has been the political will to use the available scientific knowledge to combat FMD in a 21st Century manner. It would appear that there are still individuals in Defra who have an outdated mindset, and that there have been too close links with individuals with economic interests. I feel strongly that Defra needs to open up and to modernise, and to be seen to do this by members of the public and the rural community. Otherwise, there will be continue to be little trust placed in the Department." Extract from Anne Lambourn's submission to DEFRA over its contingency plan, kindly sent to us by its author.
Feb 28 ~ "It would be catastrophic if another outbreak occurred while leisurely preparations were being carried out...".
We have received the submission of the Countryside Alliance and Honest Food to the latest Contingency Plan. (The deadline for submissions is today)
Extract: "While we welcome the publication of the contingency plans, we find it a little disappointing that, despite assurances, these do not seem to be much of an advance on the previous plans that did not, on the whole, prove to be very effective during the epidemic.
We also find it disappointing that inadequate attention has been paid to recent scientific developments around the world.....
...In particular, we would like to know whether there are any plans to develop on-farm testing for confirmation of FMD. Containment of a rapidly spreading disease and targeted vaccination or slaughter depend largely on ability to diagnose disease as rapidly as possible. While on-farm diagnosis will have to be confirmed by laboratory testing, it ought to be considered as an important part of the procedure. We understand that various methods of on-farm testing are being validated at the moment but would like some assurance that the validation process is going ahead as rapidly as possible; work done outside the United Kingdom and the European Union is being taken into account seriously; and that the possibility of validation being done by highly regarded private laboratories in parallel to DEFRA tests is being explored. None of this has been made clear either by the published contingency plans or by ongoing discussions of the stakeholders' group.