Memorandum

Foot and mouth disease - what went wrong?

Richard North
24 April 2002

The following is a preliminary list of issues which this author believes could be considered as constituting the major failures of the UK authorities/EU Commission in relation to the 2001 FMD epidemic.

  1. Inadequate contingency plan - the contingency plan was based on a model which presumed early detection/reporting of the disease, permitting early intervention at a stage when the epidemic was limited to known or immediately detectable foci and was thus amenable to containment. There was no alternative strategy devised to cope with what actually happened - late reporting/detection of the disease with widespread dispersion in multiple, unknown foci.
  2. Slow response to an unpredicted situation - the authorities were slow to appreciate that the scale and extent of the epidemic was different from that which had been previously experienced, demanding a different control strategy from that devised. For too long, it persisted with inappropriate measures.
  3. Resources inadequate - immediate manpower, materials and logistics were entirely inadequate for the scale of the epidemic. Furthermore, there was no efficient mechanism for scaling up the provisions and mobilising additional resources in an efficient manner.
  4. Wrong response - when the scale and nature of the epidemic were realised, the wrong control strategy was applied, viz the contiguous cull, which added to the logistic and management difficulties and alienated sections of the agricultural and rural communities.
  5. Wrong economic base - the strategy was based on the presumed economic needs of the livestock industry, with no recognition of the needs of and costs to the rural and wider economy, or the effects of the control strategy on it, resulting in unnecessary losses to that wider community.
  6. Complex legislative base - the combination of OIE rules, European Union and domestic law defied easy understanding and analysis and led to considerable confusion as to the options available, their legality.
  7. Failures of communication - with regards specifically to the above, and generally, there was a failure to communicate clearly with all affected parties crucial information which would have informed decision-making. This is particularly the case regarding the vaccination issue where the technical and legal aspects were often inaccurately reported by officials, ministers and interest groups.
  8. Vested interests - certain powerful groups, with their own agendas - particularly the farming interests - were able to dominate the public debate and prevail on policy issues.
  9. Inadequate epidemiology - there was a failure effectively to carry out detailed and adequate studies - and/or a failure to obtain data - which would assist in the investigation of the causation and spread dynamics of the epidemic, to the extent that no reliable, complete information can now be obtained.

Analysis

Of all the above, it seems to me that the initial failure to develop an adequate contingency plan could have been one of the most important failings. In my personal experience of investigating major episodes of infectious disease, the pre-planning element is absolutely essential. Without that planning, it is very difficult to assert control while also attempting to deal with the management of the crisis.

Nevertheless, with the benefit of hindsight, it is easy to claim that the plan was wrong. This might suggest that criticism should be tempered except that it is the duty of the authorities (individually and collectively) to predict that which could reasonably be perceived to be a possibility - having regard to the economic and social impacts of any such contingency arising.

In the case of FMD, it is arguable that, given the global spread of the pan Asian O topotype, an outbreak somewhere in Europe was inevitable. Given the progressive scaling down of state veterinary services (together with changing animal husbandary and movement practices) in the UK, it is arguable that there was a distinct possibility of delayed detection and/or uncontained spread prior to detection. If that is the view taken, then there is a good case for stating that the failure to develop an adequate plan for these contingencies represented a major failure on the part of the UK authorities, in the first instance, and also a failure of the Commission for approving in 1992 the plan submitted by the UK.

This notwithstanding, no contingency plan, however good, can take effect unless there are adequate resources to cope with an epidemic situation - with effective mechanisms to mobilise those resources speedily. If the view is taken that there were either inadequate resources and/or inadequate mechanisms to bring them on-line, then this represents yet another major failure on the part of the UK authorities. On the Community context, one also has to question whether the Commission had a role in at least determining whether resources and mobilisation strategies were adequate.

As to the matter of a possible slow response, a case can be made that there will always be situations which cannot be fully predicted, in which case there is always a risk that contingency planning will not be entirely adequate to deal with a situation as it arises. This is so much of a truism that, built into any epidemic response, must be a rapid review process to assess the nature and structure of the epidemic and to modify the response in accordance with the real situation as it develops. Then there must be in-built flexibility to enable appropriate, modified strategies to be developed and implemented. Necessarily, as part of this process, information gathering and communications must be adequate to ensure that the pattern of the epidemic and its individual characteristics are noted, and fully appreciated by decision-makers.

In this context, the questions must be asked as to whether the systems were sufficient and there was in-built flexibility.

As to the actual response in this epidemic - the contiguous cull - it is not enough to claim that, since the epidemic was ultimately brought to an end - that this strategy was necessarily successful. In the control of epidemic disease (and especially in an epidemic where there is no threat to public health from the infection), economic considerations are highly relevant. Thus, the test of success must include whether the strategy was implemented in the most cost-effective way. Any fool can, at great cost, destroy animals and, by that means, bring an epidemic to a halt but this cannot be used as a basis for claims.

An important consideration here, therefore, is the principle enshrined in Community law of proportionality. It has to be decided whether the responses by the member states were proportionate. Clearly, the issue here is whether vaccination rather than slaughter, could have been more appropriate.

Here, there is another important issue. The is already apparent considerable sentiment that vaccination may have been the most appropriate response but there is a risk here in then applying that sentiment to future outbreaks. However, given that any next outbreak may be different from the 2001 crisis, it could be the case that the dogmatic application of a vaccination strategy could be equally as wrong as was considered the slaughter policy in the recent epidemic. In other words, the response to every epidemic must be guaged according to its specific characteristics. What might be the right response in one epidemic might be entirely wrong in another, in which context, the important requirement is for there to be an element of flexibility in deciding which of the available options is the most appropriate.

Turning to the matter of the "wrong economic base", there can even now be little dispute that any policy which does not take into account the effect on the wider economy is flawed.

Then there is the matter of the "complex legislative base". There is a good argument for suggesting that there was (and remains) considerable confusion in government and amongst farmer groups (as well as others) as to what legal and other rules controlled and determined the epidemic response. It is valid to ask why that confusion arose, what steps were taken to counter that confusion and why they appear to have failed. This issue somewhat overlaps with the communication issue and here there may be substantial evidence of failure.

As to "vested interests" there is already some evidence that the interests of farmer groups held sway of the interests of others in the community, who perhaps had less access to government and officials. Decisions, therefore, favoured one group to the detriment of others. This issue needs to be explored, in particular, as to why some groups were favoured above others.

Finally, in respect of the above list, it can be stated that, in any epidemic, there is a dual responsibility for the authorities. Firstly, there is the necessary and urgent task of bring the epidemic to a speedy halt. But the other equally vital function is the study of that epidemic, in an attempt to understand how it started and how it progressed, the former to better inform prevention strategies and the latter to assist in developing and refining control strategies.

Thus, the study is by no means an academic issue - it is a vibrant and essential part of the policy-making process, to which extent it is vital that sufficient resources and skills are allocated to field epidemiology (and especially evidence gathering), even while the demand for control measures is at its most pressing. We need to know whether adequate provision was made.

As a concluding note, readers will observe that I have not identified "controls over imported meat" as a possible source of failure. My previous memorandum on causality applies here, to the effect that any findings and recommendations should be evidence-based. Since there is to my knowledge no good evidence that infected imported meat started this outbreak, there can be no utility in making a recommendation that controls should be improved.

This, however, raises a vitally important and highly relevant issue. Within the bounds of practicalities and the capabilities of science, decision-makers are entitled to be informed as to the causes of such major events as foot and mouth epidemics. As it stands, it is the case that we simply do not know what the cause was, and there is a possibility that we will never know. From this, further questions arise: (a) was there a thorough and effective investigation as to the cause of the 2001 FMD epidemic, using available scientific techniques; and (b) if there were any failures in that investigation, what were they, how and why did they arise?

In this context, there may come a situation where the issue becomes not so much a quest for the cause, as an inquiry as to why the authorities failed to take adequate measures to ascertain the cause. Such a line of inquiry would at least have the merit of helping to ensure that, in any future epidemic, better provision was made.

ends