30 April 2002
Subject: FMD Contingency planning
Given the vital role of contingency planning in the control of outbreaks of foot and mouth disease, there seems to be a strong case for evaluating role of the Commission and member states in the preparation, approval and adequacy of the plans actually produced - and the provisions made for their implementation.
In that context, having regard to the Temporary Committee's mandate, these aspects of the epidemic management seem clearly within its remit. Member States are, by virtue of Article 5 of Directive 90/423/EEC, required to submit to the Commission contingency plans for dealing with foot and mouth disease. Furthermore, the criteria for the contingency plans are set out in Commission Decision 91/42/EEC, which must be applied. Additionally, the Commission was empowered to adopt recommendations setting out explanatory notes on the criteria, which had to be published. Two documents appear to have been produced (although they do not appear to have been published):
VI/5211/95 - Contingency plans for epidemic diseases VI/6319/98 Rev 1 - Guidelines for FMD contingency plans in non-vaccinating countries
All fifteen member states submitted plans, which were approved on 23 July 1993 (Commission Decision 93/455/EEC). The Food and Veterinary Office (FVO) then undertook a programme of evaluating the adequacy of these plans, beginning with Belgium in 1999, covering Finland, Sweden, Portugal, Austria and Germany in 2000. One inspection was carried out in Spain, finishing on 16 February 2001. An inspection was planned for the United Kingdom in 2001 but the epidemic intervened. It is now planned for 28 October - 1 November 2002.
For the record, there were ten criteria specified by the Commission for contingency plans (Commission decision 91/42/EEC), as follows:
Issues which might be considered appropriate for evaluation by the Committee are as follows:
- the establishment of a crisis centre on a national level, which shall coordinate all control measures in the Member State concerned;
- the provision of a list of local disease control centres with adequate facilities to coordinate the disease control measures at a local level,
- the supply of detailed information about the staff involved in control measures, their skills and their responsibilities;
- each local disease control centre must be able to contact rapidly persons/organizations which are directly or indirectly involved in an outbreak;
- equipment and materials shall be available to carry out the disease control measures properly;
- detailed instructions shall be provided on action to be taken on suspicion and confirmation of infection or contamination, including proposed means of disposal of carcases;
- training programmes shall be established to maintain and develop skills in field and administrative procedures;
- diagnostic laboratories must have facilities for post-mortem examination, the necessary capacity for serology, histology, etc., and must maintain the skills for rapid diagnosis. Arrangements must be made for rapid transportation of samples;
- details shall be provided of the quantity of foot and mouth disease vaccine estimated to be required in the event of a reinstatement of emergency vaccination;
- provisions shall be made to ensure the legal powers, necessary for the implementation of the contingency plans.
- Were the criteria set by the Commission for FMD contingency plans adequate?
- Were the Commission's guidelines on the framing of contingency plans adequate?
- Should the plans have been approved by the Commission without their first having been checked by the FVO?
- Was the inspection programme by the FVO properly resourced, given that it was begun in 1999 (six years after Commission approval) and incomplete at the time the UK epidemic started?
- Was the UK contingency plan adequate?
- Did the UK have the resources and organisation to implement the contingency plan quickly and effectively?
As regards the detail of the UK contingency plan, this takes the form of what amounts to a detailed operations manual. Having regard to the above, it is germane to ask to what extent strategy is part of contingency planning. Presumably, any adequate plan should have at its heart different strategies to deal with the situations encountered, more or less along the lines of: "if A happens, we do B... if C happens, we do D". In other words, there should be a definition of the types of contingency that are being planned for, with an appropriate response detailed for each.
What seems to be missing from the UK contingency plan is precisely that. The preface to the "veterinary chapters" defines it as "instructions and guidance". It appears to have be standard, mechanistic instructions - with no variation to take account of differing circumstances.
Events indicate that the instructions were 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 does not appear to have been defined an alternative strategy devised to cope with what actually happened - late reporting/detection of the disease with widespread dispersion in multiple, unknown foci - to which effect, there appears to be no adequate instruction to deal with this contingency.
Therefore, as an additional issue, the Committee might consider the following:
7. What were the overall control strategies of the Commission and the UK in dealing with outbreaks of FMD? Were they clearly defined and so framed as to present practical options for reasonably predictable contingencies?