JULY 2001






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










The purpose of this submission is to set before the European Commission and Commissioner Byrne a limited vaccination plan to control and eradicate Foot & Mouth Disease in the hefted hill flocks (Cynefin) of the Brecon Beacons and the Welsh Uplands.


The hefted hill flocks of Wales present a special and unique case.


The landscape, bio-diversity and culture that this form of farming sustains; and its inter-reaction with tourism, the wider rural economy and the community, merits specific consideration and evaluation.


The impact of the Foot & Mouth epidemic on this area and the effects of the disease are appraised in Section 2 of this document. This includes the wide-ranging implications should sheep and sheep flocks have to be culled from this landscape. Particular reference is made to the damage that would ensue to the nature and character of this unique area and its ecology, bio-diversity and indigenous population.


The damage is assessed in terms of economic and socio-economic impact and on animal welfare grounds.


In Section 3 the current control methods for the eradication of FMD are evaluated and considered against a limited vaccination plan; to eradicate the disease. The report considers the current and emerging policies designed to respond to the special nature of the Brecon Beacons and the Welsh Uplands, and assesses whether there is sufficient provision within these policies to protect the unique nature and character of the area. Possible outcomes and the benefits afforded by a vaccination strategy are reviewed.


The timescale afforded by current policies, as compared to a vaccination strategy, with regard to disease free status and the resumption of export markets, is assessed and evaluated


Conformity with EU legislation is also addressed.


Section 4 details the recommendations and conclusions which we request the Commission and Commissioner to consider and to act in accordance with.


In the consideration of this submission and in the response of the Commission we would urge a swift and positive appraisal. The increasing number of outbreaks in the area is inflicting further damage by the day.



Dr Watkins paper on the vaccination programme and its implementation are presented in Appendix 5.













2.1 Environmental Considerations


2.2 Tourism and the Wider Rural Economy


2.3 Animal Welfare, Movement Restrictions and Autumn Sheep Sales


2.4 Socio-economic Impact


2.5 The Legal Framework


2.6 The Disposal, Sale and Marketing of Vaccinated Animals


2.7 Timescale






3.1 Current and Emerging Policy


3.2 Possible Outcomes


3.3 Vaccination as a Means of Controlling and Eradicating the Disease


3.4 The Benefits Afforded by a Vaccination Strategy


3.5 Marketing, Slaughter and Disposal


3.6 Vaccination and Disease Free Status
















The purpose of this submission is to consider the use of a limited vaccination plan to control and eradicate Foot & Mouth Disease (FMD) in the hefted hill flocks (Cynefin) of the Brecon Beacons and the Welsh Uplands


The submission will also evaluate the use of such a program compared to the effects of the continuance of the current control policies.


The submission will have particular regard to the unique nature of the environment of the Welsh Upland areas and the crucial role of the hefted flocks in the preservation and maintenance of such areas.






2.1 Environmental Considerations


2.1.1 The Brecon Beacons and the Welsh Upland areas comprise a landscape and environment which are unique. The geo-morphology and ecology of these areas, and their evolution over the last 2000 years, through grazing and land management, is the product of which we see today.


2.1.2 The landscape characteristics of open, unfenced hills, moorland and mountain, together with the nature of the vegetation; of close grazed grassland, have resulted in an area which is prized not only for its incomparable beauty, but also for the wide and diverse habitats it now provides.


2.1.3 The role of the hefted flocks in maintaining and preserving this unique and special landscape is crucial.


2.1.4 Any policy for the control and eradication of FMD must have fundamental regard to the inter-relation and inter-dependency of the hefted flocks and their upland environment.


2.1.5 It is paramount to recognise that each hefted flock is particular to:


I Its own specific geographic area


2 Its own ecology


3 Its own genetic strain.


2.1.6 If any hefted flock is lost through culling as a result of FMD infection it cannot be replaced.

2.1.7 To maintain the unique environment, ecology and bio-diversity of the Beacons and the Welsh uplands it is essential to preserve and maintain the individual hefts of each particular area.



2.2 Tourism and the Wider Rural Economy


2.1.1 Tourism and the wider rural economy are fundamentally related and dependent on the landscape and its management. If the landscape, its nature and characteristics, become degraded this will have a consequential impact on the wider economy.


2.1.2 Already the FMD epidemic has had a massive and disproportionate impact on the tourism industry and associated services and businesses.


2.1.3 Powys Rural Business Campaign in their report up to 27 April 2001 showed that the impact on 53 businesses based in Powys over the period of 1 March 2001 to 27 April 2001 caused a loss in turnover averaging 66% compared to the same period in the previous year. Appendix 1


2.1.4 The businesses surveyed included accommodation, conference, visitor attractions/outdoor centres, pubs, restaurants and retail.


2.1.5 It is understood that the survey is to be updated for the 19 July 2001 and a copy will be forwarded to accompany this submission in due course.


2.1.6 With footpaths remaining closed and the hills, mountains and moorlands not open for walking, there is no reason to assume the updated report will show any improvement in financial losses than those already evidenced.


2.3 Animal Welfare, Movement Restrictions and Autumn Sheep Sales


2.3.1 The current regime of movement restrictions is creating severe welfare problems :


1 The late movement of stock on to the hills and uplands is resulting in a shortage of animal grazing and feed now.


2 Farmers who have had little or no income in the preceding months cannot afford to buy supplementary feed.


3 The in-bye land and winter pasture will not have time to regenerate and therefore winter feeding areas will be significantly depleted.


4 Land normally used for sileage and hay production has had to be grazed which will further exacerbate winter fodder shortages.


5 Many farmers are over-stocked as they have been unable to trade and move animals to market.


6 If movement restrictions are still in place at the time of the autumn sheep sales, farmers will not be able to sell their animals, will be over-stocked for the winter and will have had no income to buy in feed.

7 It is critical that the autumn sheep sales will be able to proceed but at present there is no guarantee that the autumn sales will be feasible.



2.4 Socio-economic Impact


2.4.1 The effects of the FMD epidemic are not confined to the economics of agriculture, tourism and rural businesses. There is an additional degree of impact, not so easily quantifiable, upon the rural community as a whole.


2.4.2 Farmers unable to leave their premises, and those who have lost incomes and are now financially at risk, are experiencing strain and duress which, in extreme cases, has proved unbearable.


2.4.3 The uncertainty imposed by the open ended nature of the current control policies is compounding the extent of stress and anxiety which is being experienced across the breadth of rural communities. The lack of a clear, defined end date which can be regarded as the conclusion of this epidemic is creating a sense of desperation.


2.4.4 Those who still have stock are losing financially and have the worry and anxiety of how they will feed and market their animals. Increasingly, welfare culls are being sought as a means of bringing financial loss and uncertainty to an end.


2.4.5 Many farmers who have diversified, in accordance with Government recommendations, into tourism, accommodation or other rural businesses associated with their holdings are in severe financial difficulties. They cannot afford to feed and house stock and also have lost additional income from their diversification activities. They subsequently face financial ruin.


2.4.6 Those in the tourism industry and rural businesses are also faced with massive financial losses and no compensation. With no prospect of a return to normality predicted by a given date it is inevitable that many more businesses will not survive.


2.4.7 Markets lost both in the tourism and livestock sectors will be difficult to regain after FMD. This greatly concerns all businesses in Mid-Wales


2.4.8 In totality the longer the epidemic remains non-concluded the more difficult is the possibility of recovery for the economy and the wider rural community.


2.4.9 Rural communities as a whole are finding the unending restrictions on movement and the lack of normality increasingly stressful and onerous.


2.4.10 The fundamental requirement is a timescale which will indicate:


1 the end of the disease and the eradication of FMD virus from the UK.


2 a return to normal for activities and businesses


3 a clear exposition by Government of what tests and processes will need to be undertaken to re-establish disease free status and how long this will take


4 a realistic appraisal by Government of how long it will be before export markets can be expected to resume.



2.5 The Legal Framework


2.5.1 As a matter of policy the European Union prohibits vaccination against FMD. However, Article 13 of the Council Directive 85/511/EEC provides for limited recourse to emergency vaccination in areas nominated by the Member States competent authority and in accordance with plans which have to be authorised by the European Commission, working through the European Standing Veterinary Commission.


2.5.2 Vaccination may be permitted by a decision of the European Commission, and thereafter, by the grant of licences given by the member state.


2.5.3 Although strict controls would be required to allow the use of vaccination it is considered that these controls are already in place, or about to be put in place with regard to the hefted flocks of the Brecon Beacons.


2.5.4 In the letter of 5 July 2001 to Dr Watkins, Appendix 2, the Animals Health Directorate stipulate the controls would include:


1 individual identification of vaccinated animals


2 vaccination by authorised officers


3 a ban on all movement within and from the vaccination zone until 30 days has elapsed following completion of the campaign.


2.5.5 It should be noted that the Commission has already issued a decision which allowed the use of vaccination in Cumbria and Devon but that the policy was not implemented.


2.5.6 With regard to the vaccination programme in North Cumbria; the decision to vaccinate was on the basis that support was forthcoming from the farming, veterinary, consumer and food trade interests.


2.5.7 The contention should be, therefore, that if such support can be demonstrated with regard to the proposals for the vaccination in the hefted hill flocks, then serious consideration should be given to the introduction of such a program.


2.5.8 It is the intention of this submission to invite the Chief Scientific Advisor and the Chief Veterinary Officer to consider that the special case of the hefted hill flocks deserves further consideration and that the use of emergency vaccination to protect and preserve the flocks and their environment is sought.



2.6 The Disposal, Sale and Marketing of Vaccinated Animals


2.6.1 The Food Standards Agency has publicly stated that vaccinated meat and milk products do not have to be separately labelled and marketed. Appendix 3

2.6.2 Therefore there is no need for vaccinated animals to be dealt with any differently from unvaccinated animals. There is also no need for differentiation during marketing and selling.


2.6.3 The UK already imports FMD vaccinated meat and meat products(details to be added re volume and value of cattle, pig and sheep imports from country of despatch either vaccinating for FMD or where the disease is endemic. DEFRA is supplying this info for the last 5 years.) - attached as appendix Still awaited at time of submission.


2.6.4 The meat and animal products imported and marketed from both FMD endemic countries and those which use FMD vaccination are not labelled or differentiated at the point of sale.


2.6.5 The issue that must be put to the NFU and FUW is why they sought such differentiation with regard to UK vaccinated products for domestic consumption.


2.6.6 In compliance with EU Export considerations vaccinated animals and carcasses can be separately identified in accordance with EU requirements and can therefore be retained for domestic consumption and not exported.


2.6.7 Such a requirement will only pertain while vaccinated animals and carcasses are present. In any event this period of time is likely to be less than the time which will need to elapse before the export market resumes.


2.6.8 If it is envisaged that it will not be possible for vaccinated animals to enter the food chain, an alternative method of disposal based on compensation payments should be considered.


2.6.9 The preservation of both the genetic blood line of the specific hefts and the maintenance of the environment and ecology of the upland areas can be advanced as justification for welfare payments or compensation in such circumstances.



2.7 Time-scale


2.7.1 The uncertainty engendered by the current control and eradication policies is resulting in the following concerns:


1 no date and time-scale can be set for the last case of the disease


2 it is not yet known what tests and procedures the EU will require before disease free status is restored


3 it is not known how much time will need to elapse before export markets can resume, post the last case of the disease


4 there is no guarantee that there will not be further outbreaks in the autumn, further extending a return to disease free status and export markets


5 farmers do not know when movement restrictions will be lifted


6 no contingency plan has been demonstrated to exist should the autumn sheep sales not be able to proceed


7 as long as footpaths remain closed and the hills, moors and uplands remain inaccessible for walking, etc, tourism and other sectors of rural businesses continue to suffer massive and disproportionate loss


8 the longer the delay to normal movement and trading the costs to farmers continue to rise at a time when there is little or no income


9 it is not known what the policy will be if virus is found in the hefted hill flocks and how far a contiguous cull will extend.





3.1 Current and Emerging Policy


3.1.1 With regard to the hefted hill flocks of the Brecon Beacons, it has become apparent that there has been a significant refinement of policy with reference to the presence of antibody positive sheep in the hefted flocks.


3.1.2 It is our understanding that a proportionate response is to be applied to test results regarding antibody positive levels. Thus, depending on the number of sheep testing positive to antibodies and the antibody count within that flock, the response will be proportionate to the risk of onward infection.


3.1.3 The agreed levels of both criteria are as yet unpublished (as far as we are aware) and it may well be the assessment of risk will be based on a case by case basis.


3.1.4 Despite this lack of clarity the refinement of policy is to be welcomed as a significant contribution to preserving hefted sheep and flocks.


3.1.5 Notwithstanding this acknowledged improvement in response, three areas of concern remain paramount, namely:


1 It is not known what the response will be if live virus is detected in sheep and flocks.


2 The tests that are to be employed will not identify those animals that have recently been exposed to the disease.


The antigen ELISA test will only detect the presence of virus at peak of virus shedding and therefore animals that are antibody negative and virus negative by antigen ELISA  could already have been exposed and infected  but not register in testing.


The use of PCR testing at 0 and 5 days would need to be employed to detect such animals.


3 The activities of herding, penning, shearing and confinement could well give rise to ideal conditions for the disease, if present, to be passed on through many of the animals penned together.



3.2 Possible outcomes


3.2.1 Dr Watkins in her submission to the Chief Veterinary Officer, Tony Edwards, of 8 July 2001, (Appendix 4) has set out an operational approach to minimise the onward transmission of the disease through the penning, testing, shearing process.


3.2.2 This, together with Dr Watkins comments in the same document, regarding the interpretation of the testing results, will enable the limitation of the spread of the disease, should it be present.


3.2.3 However, unless two time-separated tests are carried out those animals which were infected, but not registering to the ELISA test, will be missed.


3.2.4 If the hefted flocks are released without secondary testing  but are already carrying the disease, then there is a strong possibility that there will be a chain of acute infections occurring through the hefts, on a 5 day cycle, throughout the time the flocks are on the common land.


This chain may also involve wild animals receptive to FMD as part of a chain of acute infections, which could play a role in sustaining and spreading the epidemic.


3.2.5 Such acute infections could still be present and occurring when the sheep are brought back down to the lowland farms in the autumn, or sent for sale to the autumn markets, if these have resumed.


3.2.6 The consequences could well be further outbreaks occurring in lowland farms in the autumn and again affecting cattle.


3.2.7 Such a scenario should not be treated as a reason for a more widespread cull of the hefted flocks now, but as part of a reasoned evaluation of the role of vaccination as a means of controlling and eradicating the disease.



3.3 Vaccination as means of Controlling and Eradicating the Disease


3.3.1 Given that the hefted flocks are crucial to the environment, ecology and bio-diversity of the Brecon Beacons and Welsh Uplands regard must be had to their preservation while eradicating FMD.


3.3.2 Furthermore, it is acknowledged and accepted that the culture of the Welsh upland farms is integral to the rural economy and tourism of the area.


3.3.3 It is therefore manifest that these hefted flocks should be preserved and maintained.


3.3.4 The current methods of control and eradication, as amended, do not ensure that these flocks will survive. It is still unclear what the policy will be should animals be found in the hefted flocks which are antigen positive.


3.3.5 The use of PCR at 0 and 5 day intervals has not been included as part of the test regime. Unless the testing methods being employed are time-separated it will not be possible to identify those animals which have been recently exposed to the disease and are incubating the virus, before they are released back onto the hills.


3.3.6 In order to prevent a chain of acute infections occurring throughout the flocks and passing from heft to heft through the summer it is suggested that vaccine is administered straight after testing. Testing should comprise taking a baseline sample for testing and the vaccine should be administered without waiting for the result.


3.3.7 The implementation plan which should be adopted is as set out in Dr Watkins submission Limited Vaccination Scheme  18 July 2001 (Appendix 5)

It is interesting to note that the procedures put in place by the CVO to test the hefted flocks mirror completely those suggested by Dr Watkins in every respect apart from the administration of vaccine.


3.3.8 If such prevention for the spread of the disease is not applied, then there is a realistic consequence of widespread and un-contained infection throughout all the hefted flocks.


3.3.9 The impact on the hefts, the environment and the economy if this was to result would create damage and loss which could not be repaired.


3.3.10 The current control policies appear to rely more on hope than science that the disease will not spread throughout the hefted flocks.


3.3.11 In addition there will always remain the risk that animals may contract the disease from wild carriers or dangerous contact while on the hills.


3.3.12 It appears no risk assessment has been carried out to determine the likelihood of infection passing through the hill flocks. Presumably this is why the penning, testing, etc has now been instigated. However, it appears that this strategy as yet has no contingency should antigen positive animals be found.


3.3.13 The fundamental concern must be that without scientific data to support this approach there is the greatest risk that the disease is already present and such actions will only serve to accelerate the spread of FMD.


3.3.14 There is much at stake with this scenario. It seems that the acceptability of these proposals is excellent if it is assumed no disease is present. However, it would unrealistic to rely on the hope that this is the case.


3.3.15 The responsible and rational response to the situation must be to sensibly consider a limited vaccination program to protect and preserve these unique flocks for the short period of time they remain at risk of infection. To do otherwise would be place in jeopardy the whole eco-system of the Welsh uplands and its dependent economy.


3.4 The Benefits Afforded by a Vaccination Strategy


3.4.1 If the hefted flocks are vaccinated as they are penned and tested, in accordance with Appendix 5, the following benefits are delivered:


1 Graziers can safely graze their flocks on the commons  and there will be no further spread of the disease within them.


2 Animals can be freely moved off the winter pasture to the common land allowing it to regenerate in time for the flocks return in the autumn.


3 FMD infection of flocks from wild animals cannot occur.


4 Movement and marketing of animals can be scheduled for the autumn, and sooner.


5 Recurrence of FMD in the autumn and winter will be avoided.


6 Recurrence from the rare instance of a carrier animal infecting another will also be avoided as carrier sheep will remain surrounded by vaccinated sheep until they no longer carry the virus.

7 Paths and bridleways can be re-opened.


8 The commons, hills and uplands can have accesses re-opened.


9 Normal tourism activities can re-start


10 Rural businesses which have been closed or have had restricted trading can return to normal.


11 Rural communities can regain their way of life that has been denied since the first outbreak in February.


12 The plan prevents the infection reaching the holdings around the commons.


13 The plan ensures the survival of the unique hefted flocks, their environment and eco-systems.


14 It ensures the continuance of the culture and nature of the landscape and its indigenous population of family run Welsh hill farms.



3.5 Marketing, Slaughter and Disposal


3.5.1 There is no reason for FMD vaccinated meat and animal products to be marketed any differently than any other meat and animal products.


3.5.2 In its Press Release of 21 February 2001 the Food Standards Agency stated


The Agency is satisfied that the use of the FMD vaccine doe 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.


3.5.3 The Press Release also allayed concerns about the sale and marketing issues, and that opposition from farmers would send a message to consumers that there is something to worry about. The Release replies:


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.


3.5.4 Thus there can be no justification that vaccinated meat and products should be differentiated and marketed any differently from other products which are also routinely vaccinated for other diseases which are endemic in the UK.


3.5.5 Furthermore vaccinated animals that were marketed would be unable to transmit the disease at market and the risk of onward infection would not occur.



3.6 Vaccination and Disease Free Status


3.6.1 The main argument against vaccination has been that it will delay a return to disease free status and the resumption of export markets.


3.6.2 For this view to be valid it is necessary to consider what the relevant timescales are for the current control methods, compared to the introduction of a limited vaccination plan.


3.6.3 Until the UK has had its last confirmed case the measures required by the EC cannot be put into place.


3.6.4 Given that it is not known how extensive the disease has already become through the sheep flocks of the UK it could be many months before the date of the last confirmed case.


3.6.5 In some areas the disease could already be endemic in a large proportion of the flocks. It may well be well into the autumn/winter of 2001, or even 2002, before the UK has its last outbreak.


3.6.6 After this outbreak it is still not clear what tests the EC will impose in order for the UK to regain Disease Free Status (DFS).


3.6.7 The Welsh Assembly has been asked to clarify what is the most realistic date by which exports are likely to be able to resume. To date there has been no statement clearly expressing what timescale the Assembly is working to, post the last confirmed case of the disease.


3.6.8 The 2001/295/EC Commission decision of 10 April 2001 laying down the measures to be carried out before releasing the restrictions applied in accordance with Article 9 of 85/511/EEC says in (4) The current epidemic involves to a great extent animals of susceptible species that express very mild clinical signs and therefore absence of disease must be substantiated by appropriate laboratory testing. Also in (6) The measures provided for in the Decision shall not apply to Great Britain in view of the different epidemiological situation which cannot be compared with other parts of the community. (ie, France, the Netherlands and Ireland) Appendix 6


3.6.9 As of today  19 July 2001, we are not aware of any update to the 10 April 2001 decision and therefore it is not clear what tests and procedures the EC will impose, post the last outbreak in the UK, and in relation to Para (6) of that decision.


3.6.10 It has been reported that Jim Scudamore, the Chief Vet, has expressed the view that export markets will not resume until 2004 at the earliest, this is a timescale of at least 30 months.


3.6.11 Even assuming that theoretically exports could resume two years after the last outbreak  the export market may still suffer pariah status and the markets may no longer be there or take many years to resume confidence.


3.6.12 The comparison with implementing a vaccination strategy require serious consideration. The OIE states that export markets could be resumed one year after the completion of a vaccination program, provided there were no further outbreaks; see OIE International Animal Health Code  2000 Article 2nd paragraph a). This would give a certain time point for resuming exports as soon as the vaccination program is complete.


3.6.13 The immediate time saving would be that the process starts virtually immediately and is not delayed while the tail of the epidemic continues.


3.6.14 At present there is no date at all for when the epidemic will be concluded.


3.6.15 Until we have had the last outbreak, at some unknown and unspecified time and date in the future, the timescale to the recovery of disease free status cannot even commence.


3.6.16 Furthermore, animals that are vaccinated now will have calves and lambs in 2002 that will be vaccination free and anitibody negative by the time they are ready for sale and possibly export. This can be certified before they go to market or to abattoir.


3.6.17 By testing these animals eradication of the disease can be conclusively determined. This would ascertain that they are not carrying the virus or antibodies. If all calves and lambs are negative from antibody at 6 months of age or later than FMD virus has been eradicated from the vaccination zone.


3.6.18 All these processes introduce certainty and science to the conclusion of the current FMD epidemic.


















4.1 This report has sought to demonstrate that a swift and finite end is needed to bring the UK 2001 FMD epidemic to a close.


The consideration of the use of a limited vaccination programme, in delivering this objective, is fundamental.


4.1.1 The uncertainty afforded by current control practices and the massive and disproportionate loss that is being exacted on tourism, the wider rural economy and the nature and infra-structure of rural communities urges a response that will inflict no more damage.


4.1.2 The report has set out in detail these concerns and impacts and attempted to demonstrate the extent and scale of the problems now faced by rural communities on the common lands of the Welsh Uplands.


4.1.3 The Group calls upon the EU Commissioner to have regard to all these considerations and in response assess the role of a limited vaccination programme to deliver a finite and defined conclusion to the epidemic.


4.1.4 The special nature of the landscape, its unique hefted flocks, the environment and eco-system that this form of farming supports and the reliance of tourism, the wider rural economy and the rural infrastructure which it sustains deserves specific consideration.


4.1.5 For all the foregoing reasons and considerations we urge that the Commissioner considers and grants a dispensation to allow the Welsh Upland Farmers permission to adopt a limited vaccination programme to control and eradicate FMD from the Welsh Uplands.





JULY 2001