In a message dated 31/07/01 10:18:46 GMT Daylight Time,
M.J.Bennett@vfs.defra.gsi.gov.uk writes:
 
 Dear Mr Wright
 
 My apologies for giving you the wrong information. The directive is in fact
85/511/EC. I can only blame a slip of the keyboard!
 
 As for Commission Decision 2001/295/EC, I am informed that we are basing our
activities on its requirements as this is the EU standard for demonstrating
that all appropriate measures have been taken to identify and deal with any
"hidden" disease in the country. Measures taken under this established
protocol will be necessary to satisfy the EU and ourselves that we have taken
all the steps required to demonstrate freedom from FMD and hence regain our
former status.
 
 Yours sincerely
 
 M J Bennett
 

My reply:

Dear Mr Bennett,

You originally told me that the serological surveillance is being carried out
as a requirement of an EU Directive (85/511/EEC and Commission Decision
2001/295/EC) to enable lifting of restrictions on farms in the protection
zones, the zones of 3km radius, around infected premises 

DEFRA Information Sheet 14, 27 July 2001 states (p4): "The testing is
required by EU regulations (Council Directive 85/211/EEC and Commission
Decision 2001/295/EC).  It is to see if antibodies to Foot and Mouth Disease
are present in the blood of sheep and goats which may not have shown signs of
disease....etc."

You now tell me that the serological surveillance is not in fact required by
these instruments, but that you are basing your activities on the
requirements of Decision 2001/295/EC.  I object to the misleading advice,
given to me and to the recipients of  DEFRA Information Sheet 14.  Please
would you correct the Information Sheet and explain what enables your actions
in the serological surveillance, what instrument defines the requirement and
requires the procedure you are following?

I have now read Directive 85/511/EEC and Commission Decision 2001/295/EC.

The former lays down requirements for the diagnosis of FMD, the control of
movements of animals on a holding where FMD is suspected or diagnosed, the
killing of infected animals and the control of movements of animals in
protection and surveillance zones.  I note that it does not require the
killing of susceptible animals on the infected holding, if they are in a unit
separate from those infected. [Article 6 (1)].  I note also that Article 9. 3
(b) merely requires that "the measures in the surveillance zone shall be kept
in force for at least 30 days after the elimination of all the animals
referred to in Article 5 from the holding and the carrying out on that
holding of preliminary cleaning and disinfection operations in accordance
with Article 10."  The measures being applied here are well in excess of
these requirements.

The latter describes the measures to be carried out prior to the lifting of
the protection zones and surveillance zones defined in the former document,
in countries other than the UK.  In the protection zones (3 km), at least 15
days after the killing of the infected animals and after the completion of
preliminary disinfection and cleaning, it requires clinical examination of
all animals of susceptible species for signs and symptoms of FMD; and in some
circumstances, serological sampling of some of the animals (at least 21 days
after the killing of infected animals and completion of preliminary
disinfection and cleaning).  In the surveillance zones, at least 30 days
after the killing of the infected animals and after the completion of
preliminary disinfection and cleaning, it requires clinical examination of
all animals of susceptible species for signs and symptoms of FMD, and in some
circumstances serological sampling to be carried out.  Its specific
requirements for serological sampling exclude holdings where sheep or goats
have been in contact with bovine animals within 21 days.

Your activities do not follow these requirements.

I should be grateful for your advice.

Yours sincerely, 

Lawrence Wright
Middle Campscott Farm
Lee
Ilfracombe
Devon EX34 8LS
Tel 01271 864621