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Stakeholder Engagement on FMD Control Strategies

A process of stakeholder engagement commenced in May 2005 and has involved Defra and representatives from across the food chain working in partnership to achieve a shared understanding of the implications of FMD control strategies. Much progress has been made in defining the practical issues facing the milk, meat and meat processing industries so that the impact of an FMD outbreak can be properly managed and kept to a minimum.

Vaccination is now accepted as a vital part of the options available in fighting an FMD outbreak and its implications are now seen as practical ones regarding the treatments for products from vaccinated animals rather than ones of the acceptability of those products to retailers and consumer groups.

An important staging point in the engagement process was reached on 4 August when Defra’s Chief Veterinary Officer, Debby Reynolds, chaired a meeting of key stakeholders. A paper was produced for that meeting summarising progress to date and the movement restrictions and treatments required under the FMD Directive. An Action Plan was agreed setting out further work to be done. Details of progress made on the various actions will posted here over the coming weeks.

We hope the Action Plan will result in an industry that is well informed on the options available, in the event of an FMD outbreak, for dealing with vaccinated animals and animals from infected zones. This information will allow the industry to make its own contingency plans for coping with an FMD outbreak. These will include dealing with the impact of the immediate GB wide movement standstill which will be introduced on day one of the outbreak and recognising that Government policy on animal welfare provides for free collection, slaughter and disposal of animals but not the payment of welfare compensation.

This process is being carried out in parallel with the consultation period on the legislation that transposes the EU FMD Directive. The deadline for responses to this consultation is 1 September to enable the legislation to be brought into force by the end of the year.

In keeping with the partnership element of the Animal Health and Welfare Strategy, a process of stakeholder engagement has been undertaken through the period May – August 2005. This commenced with a briefing held immediately prior to publication of the Cost Benefit Analysis (CBA) of Foot and Mouth Disease Controls. The engagement process has three objectives:

  • As part of the on-going consultation process, to seek comments on the draft legislation which transposes the EU FMD Directive;
  • To collect and validate robust data on the impact and costs of the various controls required by the Directive, to inform the draft Regulatory Impact Assessment (RIA);
  • To build shared understanding and consensus on Defra’s FMD control strategy, including the possible use of “vaccination to live”, in preparation for any future disease outbreak. In particular to create an effective partnership with stakeholders on dealing with the ramifications of the treatment of animal products from both disease-affected areas i.e. Protection Zones (PZs) and Surveillance Zones (SZs) and livestock that had been vaccinated.

The engagement process has involved meetings with the following sectors:

  • Consumer Groups
  • British Retail Consortium
  • Livestock Producers
  • Meat Industry
  • Dairy Industry
  • Livestock Auctioneers Association
  • Veterinary Associations
  • Processors representatives
  • Meat and Livestock Commission
  • Meat Hygiene Service
  • State Veterinary Service

The outcomes achieved can be summarised as follows:

FMD Directive

There has been a general acceptance of the Directive and the fact that Defra has very limited discretion on how it is implemented. No major issues with the draft legislation were raised, although a number of very helpful drafting points were discussed which will enable us to improve the legislation and ensure its robustness. We are expecting full written comments by the end of the consultation period on 1 September, after which we will respond to those comments, finalise the legislation and present it to Parliament with a view to bringing the legislation into force by December, as planned.

Regulatory Impact

We have gathered some very useful data from this process. In parallel we have commissioned modelling work of this data in a range of disease scenarios from Risk Solutions, based on the FMD CBA. This work will significantly strengthen our RIA which we will then agree with the Cabinet Office.

FMD Control Strategies and animal product treatment

There was general acceptance of the need to work with industry to gain a shared understanding of controls on livestock and their products and the practical implications for the industry and the market. This work will need to take account of the fact that Government policy on addressing welfare issues is that free slaughter, collection and disposal will be provided but no compensation paid on the animals in question.

In particular, there has been a general understanding that Government can help to broker solutions but ultimately the onus lies on the industry to identify these solutions and share the costs. However, Government wants to actively help find solutions and, within the constraints of the disease control effort, to help the industry to function as normally as possibly and to minimise potential financial losses.

Effective dialogue, and particularly the publication of the CBA, has been successful in gaining understanding from stakeholders that vaccination is a viable option in certain disease scenarios.

Consumer/retailer view of vaccination

We have achieved an understanding and acceptance with consumer groups and retailers that consuming products from vaccinated animals has no implications for human health. This is consistent with twice issued advice from the Food Standards Agency and a recent statement from BEUC, the European Consumers Organisation. We have clarified, to general satisfaction, that products from vaccinated animals will not be labelled any differently from other products. Therefore there should be no price differentials at the point of sale for products from vaccinated and non-vaccinated animals as the differences will not be identified. However, due to the inevitable loss of export markets, even for animals and products not subject to specific controls, there will be an increased amount of product placed on the domestic market.

Treatment of animal products required by the EU FMD Directive

Vaccination is now seen as a practical issue regarding the treatments for products from vaccinated animals which is similar to those for animals from PZs and SZs (areas surrounding an Infected Premises by 3km and 10km respectively). This would consist effectively of heat treatment for products from all pigs and for products from sheep and cattle from PZs during the first phase of a vaccination programme. Heat treatment or de-boning and maturation for products from sheep and cattle would be an option for those from SZs and during the remaining two phases of the vaccination programme. A summary of movement controls for animals and treatments for their products is attached to this page - Movement Restrictions and treatments required under the FMD Directive. There is also the option of 9 month natural fermentation of products but this is of highly limited application in the UK.

Understanding and acceptance has emerged that heat treatments are in effect the use of existing procedures for cooking processed foods and do not constitute something new. Maturation under the new controls would only be required for a far lesser period than the usually accepted form of maturation (24 hours as opposed to 2/3 weeks) but may have the potential to be utilised in conjunction with existing procedures for producing a value-added product, depending largely on hanging capacity and the availability of a suitable market. The industry representatives identified risks in the use of terms that have either an emotive or different meaning outside of FMD controls and are keen to work with Defra to find more meaningful terms and to manage the message given to the wider stakeholder community. The treatments will require official supervision, the cost of which is likely to be Government funded. Work is to be undertaken to quantify these costs.

Sectoral issues

The impact of controls varies depending on species but can be summarised as follows:

  • For pig meat – the most valuable part of the animal (i.e. the loins) cannot readily be used to produce processed products. Economic analysis is required to establish the relative values of the parts of the animal for which treatment still provides a market and those for which there is currently no obvious market. The British Meat Processors Association (BMPA) and British Pig Executive (BPEX) have undertaken to assist with this and to examine possible markets for the cuts that would not normally be used by the processing industry.
  • For beef – the use of de-boning and maturation seems to provide an opportunity for a high degree of “business as usual”. There will be practical challenges if an abattoir is to process animals from zones with differing controls. The Meat Hygiene Service (MHS) have undertaken to work with Defra and abattoir operators to find ways of possibly addressing these challenges, particularly on the subject of separation of storage facilities.
  • For sheep meat – there is a possibility of de-boning and maturing part of each animal that can practically undergo such treatment (i.e. the shoulder and leg) whilst consigning the remainder for processing through heat treatment. This is a novel option which the Association of Independent Meat Suppliers (AIMS) and the National Sheep Association (NSA) have undertaken to work on together with Defra.
  • For the dairy industry – the issues are less fundamental than those for the meat industry due to the fact that the pasteurisation controls imposed in a disease outbreak would be similar to those in place normally, only having an impact on the relatively small raw milk industry. The concerns here are more practical around the need for an industry with a particularly high turnover rate to be able to continue to function through extra requirements of biosecurity for tankers, segregation of milk and the speed of licensing of processing plants (preferably in advance of an outbreak). These issues of detail are to be addressed.

Market implications

For all species there are questions of demand management and product displacement at a time when the overall market is likely to be contracting, due to loss of export markets. We acknowledged that new products, using meat from animals subject to FMD controls, would take a considerable time to introduce and are not therefore a realistic proposition. In practical terms, this means the challenge is to find ways of using the meat in existing products. This work must however be undertaken with a recognition that product specifications limit opportunities to substitute different cuts of meat. The “just in time” operating procedures of the retail industry and limited storage capacity also make it difficult to defer consumption of a hump in the supply of products. Furthermore there are issues of dedicated abattoirs serving big supermarkets and difficulty for people to change contracts with other parties in the UK, EU or 3rd countries. As described at para 12, the industry is however committed to working with Defra to focus on areas where scope for innovation appears to exist.

Next steps

Stakeholders have acknowledged that there is coherence in the controls which would need to be put in place in an FMD outbreak for products from vaccinated animals and for products from animals from PZs and SZs. They are also likely to be short-lived and regionally focussed. In addition, the CBA suggests, an outbreak on a smaller or, at least, less dispersed scale with the new controls now in place such as the six-day movement standstill and immediate national movement ban. Modelling work has been commissioned covering a number of disease scenarios to inform further discussions on the number of animals, and thus the quantity of meat, likely to be subject to controls and treatments. This work will consider the likely duration of the various measures and include large scale outbreaks as well as the smaller one the CBA suggests.

It has been acknowledged that regular and detailed dialogue between Government and the industry will need to be maintained. Work is required in “peacetime” to ensure that, in the event of a disease outbreak, producers and others in the supply chain fully understand the options available to them. This has definite advantages over the idea of leaving such work to be undertaken during a disease outbreak and reflects an acceptance of the concept of “prevention is better than cure” as reflected in the Animal Health and Welfare Strategy. In particular producers will be able to make informed decisions on the question of no return on their animals versus a possibly lesser return resulting from controls. Government will in turn help the industry maximise return through clarity on controls. This will be of added importance given that Government policy on addressing welfare issues is that free slaughter, collection and disposal will be provided but no compensation paid on the animals in question.

Attached to this page - Stakeholder engagement on FMD Control Strategies Action Plan - are details of the actions which we propose to take as next steps. These steps will ultimately enable the industry and Defra, working in partnership, to produce an Action Plan and decision tree, based on a variety of disease scenarios, to inform stakeholders of the choices available for the marketing of vaccinated animals and animals from infected zones in the event of an FMD outbreak. We are keen to have your confirmation that you share our understanding of the progress achieved to date and of the actions identified.
FMD Control Strategies - Stakeholder Engagement on FMD Control Strategies - Action Plan