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Susan Ivory

1a Page Street

London

SW1P 4PQ                                                                                          21st January 2003

 

Dear Susan

 

Reference:        Consultation on FMD contingency plan

 

I would like to make a contribution to the consultation exercise announced by Ann Waters on the 8th January,  to ask for comments on the FMD contingency plan.

 

Page 8 paragraph 2

 

‘Pre-emptive or ‘firebreak’ culling not on infected premises’

 

My comment:

Being that the 3 kilometre cull was first carried out as a novel exercise in the UK 2001, the fact that the majority of the animals (84% according to the latest statistics) were indeed healthy, and that testing for virus was ignored for the majority of the animals culled under this category, there is no substantiated proof that the ‘firebreak’ cull was effective, apart from the obvious fact that by the animal being dead, it was no longer susceptible to the virus.  I am disappointed to see that a firebreak cull might still be suggested within your contingency plan, given the fact that vaccination is widely seen as a tool of first resort.                                                                               

 

Indeed, at this point in your plan, more detail should be given to the various scenarios that could be experienced as a result of a new outbreak, with the recommended options given. This, I understood, was work that was being undertaken by the Chief Scientific Officer in the Autumn of last year, according to a conversation I had with Elliot Morley after the Rural Conference (letter to Elliot Morley attached).

 

 

Page 8 paragraph 3

 

‘In order for a vaccinate to live strategy to work, a number of logistical, technical and trade problems need to be resolved in consultation with interested parties.’

 

My comment:

The above statement is too vague to be used as part of the contingency plan. I firmly believe that the ‘logistical, technical and trade problems’ statement should be broken down into detail, so that stakeholders might be able to see and contribute their thoughts to the problems for each category.

 

In terms of trade ‘problems’, the Government must take a lead in the debate over trade for meat that has been sourced from animals vaccinated against Foot and Mouth.  Consumers in the European Union have eaten meat in the above category for decades before vaccination was stopped at the beginning of the 1990’s and we yearly import vaccinated meat from Non Eu countries. The Food Standards Agency made a recommendation in April 2001 that they ‘were not advising the consumer against the eating of vaccinated meat’, and Deirdre Hutton, from the National Consumer Council has stated many times how there would be no need to label meat. As you might remind Margaret Beckett,  Dr Bernardo Cane (CVO, Argentina) spoke directly to her during his speech at the FMD Brussels Conference in November 2001 and said that ‘she has been eating vaccinated meat and probably has even had Argentinean FMD vaccinated beef at some point’.

 

I believe Page 8 paragraph 3 should be partly re-written to state that ‘The Government’s advice from the FSA and the National Consumer Council is that vaccinated meat does not require labelling, does not present a health risk, and should cost the same amount as meat not sourced from vaccinated animals.’ By a statement being given such as this, the Government will invite comment from the supermarkets and consumers which will then provide a debate.

 

 In much the same way as above, logistical and technical ‘problems’ such as export under OIE recommendations and maturation of meat should be spelt out by the Government so that interested parties may comment.

 

Without the above taking place, then we can only expect the kind of lack of co-ordination and leadership given by the Government as stated by Nick Brown to the EU temporary committee on FMD:

 

‘Some elements of the food industry were not prepared to put vaccinated produce into the food chain. Cadbury's issued a statement saying they would not take the milk from vaccinates," he said. "The majority of farmers and their leadership opposed vaccination because of uncertainties about the market response and because of the strict trade controls that would have to apply following vaccination’.

 

The EU Committee’s summary of the above statement describes exactly why such leadership from the Government must take place before the potential of a new outbreak:

 

What was startling was his frank admission that the government's policy on vaccination was determined not on sound scientific judgement as it should have been, but by the demands of British supermarkets and Cadbury's who maintained that they would not stock vaccinated products or take vaccinated milk, both of which are perfectly safe and legal under EU rules. It's an outrage that once again we find government policy being driven by big business’. (Robert Sturdy, March 25 2002)

 

Page 27, point 8.1 serology capacity

 

My comment:

No mention is made here of the rapid diagnostic tests that are available which would radically reduce the amount of testing time required, currently required by ELISA.

Is this because we still await validation to be performed for such tests? If so, when can the final results of the validation work be expected? My understanding, from a conference given early last year in Australia, is that validation results were shortly to be given.

 

Also, one of the more dreadful mistakes in the UK outbreak as recorded by Iain Anderson’s Lessons Learnt Enquiry was how serological samples were sent to Pirbright from Cheale’s abbatoir at the beginning of the UK 2001 outbreak, to finally have to wait overnight without being processed, as no one read an email that indicated that samples were on their way (Chapter 8 page 54). As part of the contingency plan I would think there should be a requirement to back up any email of such importance with a telephone call to ensure that communication had been made. Such a basic lack of communication lead to a 12 hour delay, which is substantial when it is considered that the first 3 days of the UK outbreak while animal movements were still allowed were known to have contributed to much of the size of the outbreak.

 

Page 31, paragraph 14.1

 

‘VIPER Chapter 32 Section G’

 

My comment:

I cannot find any publication in the public domain that relates to the VIPER document that is referred to in Section 14. Without details of the VIPER document, it is impossible to give an opinion on whether the procedures laid out within the document are sound.

 

Page 32 point 18 vaccination

 

‘Vaccination plans are currently being developed in discussion with a wide range of stakeholders’

 

My comment:

 Is there a list available of the stakeholders involved in contributing to these plans? If so , I would very much like to see it to check to see if the experts I know of are included as stakeholders, as without them, the contribution would be fruitless.

 

Page 91 Health and Safety teams

 

My comment:

No mention is made here of whether slaughter teams, or any other personnel contracted to work for DEFRA, must have their licences for the activity they expect to perform checked before admittance to a farm. There is documented evidence that in 2001 teams were allowed onto farms without licences being checked; some of these teams were found to be untrained (I can provide instances of occurrences such as this).

 

 

 

Page 93 Equipment for Biosecurity

 

My comment:

No mention is made here of whether the visitor to a farm might require or make use of:

 

Hepa filter face mask

Gloves

Head covering

 

Proven expert evidence is available to indicate that the FMD virus can be breathed by vets/farm personnel into the human pharynx after ‘mouthing’ (checking an animal for lesions in the mouth), which then in turn can exist and be transmitted from the same person for up to 96 hours.

 

No provision is made in the plan for recording who has been where, how long a ‘dirty vet’ should remain away from farms/animal contact/other contact, and what should happen once a farm is subsequently found to be infected after personnel have been known to have previously visited the same farm. For instance, wouldn’t it be wise to recall personnel away from further visits to farms for a given period should they be known to have been present on a farm found to be infected?

 

Also, during a recent ‘scare’ over a potential outbreak in Cornwall, DEFRA personnel were sent out in foot patrols to find neighbouring farms – surely this is a hazard in terms of biosecurity, and work which should be done by telephone using better and more uptodate records of where animals might be located. I think the contingency plan should make more indication of how contact with farms using vehicles and manpower should be avoided unless absolutely necessary.

 

In Summary

The contingency plan needs to be more specific in order to provoke better debate amongst stakeholders. As an example, supermarkets and farming unions need to be prompted to indicate their own policies regarding the sale and display of meat vaccinated, they will not voluntarily give their own standpoint without being told first what position the Government would require them to take. It would be a tragedy should an agreement on trade not be reached before another outbreak took place.

 

Thank you very much for inviting comments on the Contingency plan.

 

Yours Sincerely

 

Jon Dobson

Research Director

FMD Forum


Attached: Letter to Elliot Morley 21st July 2002


Elliot Morley

Parliamentary Secretary

DEFRA, Page Street

London                                                                                     21st July

 

Dear Elliot

 

Re:       FMD – discussion at the Rural Conference

 

I was so pleased to hear what you had to say when we met at the Rural Conference on Saturday. I know from previous media reports that you have always been a supporter of a ‘vaccinate to live’ policy, but it was good to hear how DEFRA now intend to include a ‘vaccinate to live’ policy into the new contingency plan.

 

There is still a huge worry that I have, which we discussed, to do with the threshold where after culling animals that are shown to be infected, a continued culling policy is replaced by a ring vaccination to live policy.  I know that you said that Jim Scudamore was considering that very point, but could I please request that this ‘switchover’ to vaccination in the contingency plan be made clear. I would like the decision point to be made more definite, so that vaccination is more than ‘a tool in the toolbox’, or an ‘option we have always considered’.  My fear, as founded from the experience in the Uk since 1967 of FMD vaccination, is that vaccination would remain as only an option. 

 

We also briefly talked about labelling. I have enclosed a video of Kevin Hawkins, Head of Marketing at Safeway on News at 10 17th July 2002. He states ‘Clearly, all vaccinated meat would have to be labelled as such and that would mean that many of our customers I think would perhaps be doubtful that it was safe’. As we both know, labelling has been discounted for vaccinated meat/milk by  the National Consumer Council and the Food Standards Agency early last year. Actually, the most telling point is that we routinely vaccinated for FMD until 1991, so all meat and milk would have been vaccinated anway.

 

We agreed that issues such as labelling will only be resolved by the Government taking the lead by using the advice from the FSA and implementing that with the retailers. Is there a stakeholder group on labelling that my organisation could contribute to?

 

It was a pleasure to meet you,

 

 

Jon Dobson, Research Director

I would like the attached statement from the FSA to be added to my submission on comments for the FMD contingency plan. Thank you