See full response and accompanying letter
from the National Foot and Mouth Group re "CONSULTATION ON DEFRA’S FMD CONTINGENCY PLAN – Version 3.1 DECISION TREE & SLAUGHTER PROTOCOL"
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 EU Directive, 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 draw your attention to the recent paper by Dr P Kitching in the Vet Journal – Vol 167 Issue 2 addressing the role of modelling and the policy it directed in 2001.
Also we appended our assessment of the data we obtained regarding this to our response in February 2003 to UK FMD Contingency Plan version 2.5.
We again draw your attention to the very low number of positive cases of FMD that were confirmed when laboratory tested. Also, the figures we 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 were also included in Appendix 1 of our submission in February 2003.
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 and the results published.
In addition the revised EU Directive does not make provision for pre-emptive or firebreak 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.’
The Directive does not provide for the firebreak culling as detailed in the UK FMD Contingency Plan. See Page 92, Para 14, Page 93 Paras 20, 21, 22 and Page 106, Para 1 – 4.
“Legislation in England and Wales allows for slaughter of:
· Animals to prevent the spread of FMD, eg a ‘firebreak cull’.”
In addition we also question the interpretation of the EU Directive in Para 13 of Page 92 of the UK FMD Contingency Plan:
“The Directive requires slaughter of all susceptible animals on infected premises, and provides for culling of susceptible animals on epidemiologically linked holdings, as well as culling of susceptible animals on holdings where FMD is suspected.”
Our emphasis. From our reading of the Directive it does not allow for Slaughter on Suspicion unless it can be shown that animals are likely to be contaminated. Also such animals must have samples taken and be subject to clinical examination.