FOR THE ATTENTION OF THE COMMITTEE ON THE ENVIRONMENT, PUBLIC HEALTH AND CONSUMER POLICY
I would be very grateful if the Committee could consider the following points:
Comments on the Short Justification, Draft Opinion
1. In the penultimate paragraph before the Conclusion Mr Whitehead states
“Suppressive vaccination in the Protection Zones would be introduced in densely populated areas of susceptible animals (especially pigs) if the disease cannot be stamped out by slaughter within 24 hours of confirmation, and by culling of animals at risk within 48 hours
i) Where is the authorisation for the above statement “would be introduced”? The current EU directive, and the Draft Directive do not automatically give carte blanche for suppressive vaccination in the above circumstances, as this statement implies. In Article 53 of the DD it states that
“Member States shall notify the Commission if they decide to introduce suppressive vaccination and shall provide details of the control measures to be taken …”
ii)From the disease control point of view and the risk of disease spread, there is no “automatic” justification for the vaccination in the 3 km surveillance zone to be suppressive vaccination, rather than protective. This is purely an economic argument.
iii) The EU Draft Directive does not authorise killing animals “at risk”. It refers to “animals likely to be infected or contaminated”. (Annex X. 1b). This is a very different proposition. There is no authorisation in the Draft Directive, nor in the current Directive, for blanket firebreak killing of healthy stock.
2. Mr Whitehead goes on to state :
“Member states will need to make a balanced judgement on the appropriate methods, including the use of “vaccination to live” in Surveillance Zones.”
This statement may give the impression, erroneously, that “vaccination to live” is only applicable in Surveillance Zones, which is not the case. With a protective vaccination strategy, killing would only take place on the Infected Premises, with vaccination in both the Protection and Surveillance Zones, and possibly beyond.
Comments on proposed amendments
Amendment 4 Article 50, paragraph 3
I disagree with the proposed amendment.
I feel it is imperative that the Commission reserves the right to exercise its “initiative” concerning the decision to introduce emergency vaccination, without collaboration with the Member State concerned:
1. The Commission must be seen to be independent of Member States’ internal politics, and to be acting swiftly to enforce the “rules”. The “collaboration” suggested with the Member State could take up valuable time in an emergency, and the procedure may be abused by parties who have vested interests against vaccination.. The disproportionate influence of individuals and organisations strongly opposed to vaccination on the disease control policy in the UK 2001 epidemic, and the associated propagation of outdated/incorrect information is well documented.
2. Also, the Commission is responsible for looking after the interests of the EU as a whole, and it should have the overriding power to impose decisions on that basis.
3. Evidence from the 2001 UK epidemic suggests that this power of the Commission is highly desirable to act as a check on Member States embarking on questionable disease control policies.
4. The Commission is much better “qualified” to reach decisions on FMD control as it has an enormous reservoir of FMD veterinary expertise to draw upon (particularly with regard to vaccination). Also, it seems that the Commission is willing to listen to this advice (e.g. it adopted the Emergency Strategy for Vaccination, recommended by the Scientific Advisory Committee in March 1999). This is in stark contrast to the UK, which ignored the advice of Dr Paul Kitching (leading expert on FMD in the UK), and his scathing criticism of the mathematical models being used to dictate disease control policy in the 2001 epidemic. Furthermore, there were no FMD vaccination experts in the Science Group headed by Prof Anderson, which meant that the various anti vaccination arguments went unchallenged, and that open and informed discussion of disease control policy never took place. If the Commission had this overriding power, then hopefully it would use it in any future outbreak of FMD to ensure that the best disease control policy was being employed.
Amendment 6, article 72, paragraph 10
I consider that the contingency plan should be updated yearly, in order to incorporate swiftly all the latest science, particularly with regard to the excellent diagnostic tests and vaccines available. It would be ridiculous for Member States to be operating on an outdated disease control plan simply because the Directive does not “allow for” these advances.
Amendment 9 Annex X, point 1, introductory phrase
I consider that the phrase “emergency vaccination shall be introduced” as opposed to “seriously considered” should stand.
The UK cannot have the situation where FMD gets out of control again. What is needed in an emergency is firm guidance from the Commission with no grey areas. It is essential that clear instructions are laid down, which are not open to different interpretations by the different lobbies. As John Ryan, veterinary consultant, EUFMD, FAO, states in “FMD, Risk and Europe”
“The uncertainty around such difficult decisions (e.g. whether, when, where to vaccinate) leaves gaps for political exploitation and sub-optimal decision-making. The only effective defence against such politicking is sound science, hard information, good communication and good emergency preparation where theses issues have already been discussed with key stakeholders.”
General points for consideration
There is an urgent need for clarity in the Draft Directive concerning the definition of Infected Premises and Contaminated Premises. There is scope within the Draft Directive for “abuse” of the system, either unintentional, through misunderstanding, or deliberate.
The animal and human costs in the UK 2001epidemic, through mass killing of uninfected premises, were enormous.
The financial costs were also huge, and potentially a “can of worms”. I refer to the Defra submission to the OIE for Disease Free Status, where it was apparently claimed by Defra that all Infected and Contiguous Premises had been tested for FMD (thus supporting claims for reimbursement from the EU for help towards compensation payments handed out to farmers). See extract below from Defra submission, where individuals can make their own judgements about whether I am correct in my interpretation.
I discuss these areas in my two recent “submissions” to the Agriculture and Rural Affairs Committee:
Part 1 concerns the very real fears that Defra could effect another mass killing of slaughter of healthy animals in the UK, within the framework of the Draft Directive.
Part 2 refers to the scope for incorrect/fraudulent claims for compensation from the EU by Member States within the Draft Directive, and also in 2001, under the current Directive.
A detailed case study of Wigtownshire (Dumfries and Galloway) is given, where
only 2 premises (with a total of 1129 animals) were shown to be infected, but 218 premises were slaughtered out, with obviously a large compensation claim to the EU relating to the total 90,000 animals killed. Should an EU Directive really be seen to be sanctioning this type of disease control policy?
I would be most grateful if the Committee could consider the above points with a view to introducing even more clarity into the Directive. One legacy of the UK experience should be the determination among EU decision makers to ensure that it can never be repeated. This requires tough wording in the Directive, and courage on the part of the Commission to implement this.
Anne Lambourn (Member of the public who submitted detailed material to all the FMD Inquiries).
Extract from Defra submission to OIE for DFS
While the first outbreak of disease was formally confirmed by the CVO on the basis of laboratory examination of samples from affected animals, local veterinary staff were subsequently authorised to diagnose disease on the basis of clinical signs alone and before receiving the results of the laboratory examinations, following consultation with a veterinarian at the NDCC who officially confirmed the presence of disease. (NB Defra states that lab tests done to confirm disease where vet has clinically diagnosed the disease, albeit after slaughter.)
Page 13 (this supports Page 11)
When the extent of disease became apparent, SVS veterinary officers were allowed to confirm disease on the basis of clinical signs. Where disease was confirmed on clinical grounds alone, fluid and tissue samples were still taken from clinically affected animals and examined at IAH Pirbright using prescribed OIE tests. Where laboratory examination of samples failed to detect the presence of virus, the case remained confirmed, as did the consequent arrangements for the establishment of 3 km and 10 km protection and surveillance zones and slaughter of animals on contiguous premises. (As I read this it again claims that samples were taken in all clinically diagnosed cases)
Pages 14 and 15
Preventive slaughter of animals on hodings at risk of FMD
FMD susceptible species on holdings identified as being at risk of disease (dangerous contacts) as a result of the epidemiological enquiry carried out in connection with each outbreak, were compulsorily destroyed as were FMD susceptible species on all holdings contiguous to an infected premises without waiting for the presence of disease to be confirmed. A target time of 48 hours was set for the animals on contiguous holdings to be destroyed, starting from the time suspect FMD was reported to the Local Disease Control Centre. Where there was clinical evidence of disease on such holdings the presence of disease was confirmed on clincal grounds and samples were sent to IAH for laboratory examination for virological and/or serological examination.
Where there was no clinical evidence of disease, blood samples were taken for serological examination and if FMD antibodies were detected, disease was confirmed on the holding...... (N.B. Samples were certainly not taken in all of these cases)