Part One










May 2002





Alan Richardson B.Vet.Med., Ph.D., M.R.C.V.S.



“In 2001, the 3 km. cull seems to have been the idea of epidemiological mathematical modellers who could have no idea of the logistical effort needed to kill and dispose of the carcasses, nor of the economic losses and distress resulting from their prescription. Nor was this stratagem necessary, as all previous experience had shown. When the slaughter on suspicion policy became known, the distress was greatly increased when farmers realised that their livelihoods, and often their life's work, hung upon the competence of an unknown veterinarian, examining a neighbour's stock. The anxiety was increased when he reflected that this veterinarian was possibly young, from overseas and perhaps inexperienced and unfamiliar with the range of lesions to be found in British livestock. This cull was induced by panic and ignorance and born of the failure to be prepared.”







Elm Farm Research Centre September 2001


“Recent ministerial statements that this FMD outbreak has been handled successfully are profoundly depressing. It indicates that the worst of the old MAFF culture – narrowness of vision, arrogance and an unwillingness to learn – are prevalent in DEFRA. This culture has led to the to the slaughter of millions of unaffected animals, at times inhumanely, to destroy the heritage of hefted flocks, disrupt communities and individual lives, often far beyond the farmgate and all for the narrowest of economic goals. The handling of this outbreak has been uneconomic, inefficient and intolerable in a civilised society.”







Magnus Linklater  April 26th 2001

“So there you have it: the research, it seems, was wrong, the science was outdated, the slaughter unnecessary, the policy unethical, and the strategy ineffective. Apart from that, things seem to have been just fine!”







The 3km/Firebreak or Pre-Emptive cull conducted in Cumbria and elsewhere had no scientific basis, had never been used as a method of FMD control before and was illegal under UK law and also probably EU law.



'         Total confusion surrounded this policy at its outset and has continued to cause confusion to this day. It has caused Government Ministers to “mislead” Parliament and members of the public!


'         Who ordered the cull? On what scientific basis was this policy decision made?


'         In this short document I will examine the confusion, legality and reproduce some of the most bizarre comments made by government ministers concerning this subject.


'         There is no doubt this obscene policy resulted in the killing of millions of healthy animals causing much distress to the Cumbrian community as a whole. It was a complete PR disaster for Blair and resulted in Government Ministers lying in an attempt to save face.




1.           On 16 March 2001, the reproductive rate of the Foot and Mouth disease was “1”. (Reference: MAFF, Data assembled by Prof Mark Woolhouse of Edinburgh University). That is to say the disease was not out of control and the movement ban was working.

But had the Government ordered an immediate movement ban instead of the leisurely 4 day delay, how much more quickly “under control” would it have been and how long would the course of the epidemic have run?  Prof Woolhouse himself remarked, when giving evidence to the EFRA Select Committee (para 214) on 7 November 2001: “…we had 70 to 80 cases already by February 23;
with hindsight, if we had imposed a national movement ban on February 20, three days earlier, our estimation is the epidemic would have been between one third and one half smaller than it actually was.” An immediate movement ban would no doubt have prevented much of the uncontrolled spread and greatly reduced any need to implement the mass slaughter of healthy animals in the 3km cull.


2.           The 3km cull was ordered Thursday 15 March 2001 13:30 hrs. Nick Brown stated:

”All animals within 3km will be destroyed on a “precautionary” basis.”

Those affected by the
COMPULSORY 3km cull will receive full market value compensation for their animals, whether infected or HEALTHY, a MAFF spokesman said.


3.           Same day at 13:30. “Hundreds of cattle farmers left staring into the abyss as MAFF reveals mass slaughter zones for all animals 3km around FMD infected farms.


4.           Same day at 18:20. Astonishing u-turn on Border TV as Minister Nick Brown says policy only applies to pigs and sheep. Minister apologises for any hurt this has caused farmers:

 “We didn’t explain ourselves very well. Having re-read my statement it is accurate but I can see that it is ambiguous.”
[CORE 17, Pg 25]


5.           Local farmers tell the CVO, Jim Scudamore:  “To get  a grip!”
[CORE 17, Pg 30]


6.           Between 12-16th March 2001, the European Commission recommended to MAFF and Blair`s Government (DG(SANCO)/3318/2001 – MR FINAL).


9.1 To the competent Authorities of United Kingdom “It is recommended that the following actions be taken as a matter of urgency “consider preventitive slaughter in certain circumstances in an attempt to “get ahead” of the disease, and to reduce the weight of infection to which animals are being exposed.”


7.           The response from the CA (DG(SANCO)/3328/2001 – MR final):

 “As identified during the current mission: A widespread policy of slaughtering susceptible animals on neighbouring, and at risk premises had been introduced. It was noted that this had not been consistently applied in the areas visited, and that, during the mission, the CA announced changes to this particular requirement, which would allow an easing of previous practice.”



8.           More confusion:

 News & Star 17th March 2001:

“MAFF admitted tonight that the 3km. cull would not apply to all farms after all. A spokesman said cases would be judged individually, and that the policy would not simply be a matter of drawing an imaginary circle around all infected farms. Some within 3km. of confirmed cases may escape the cull, while in other places, animals may have to be killed if they are further from infected sites!”


9.           23 March 2001. Blair ordered the precautionary firebreak cull to be extended to all parts of Britain.


10.       News & Star 28 March 2001:

”Penrith Farmers & Kidd managing director, Richard Morris was told by MAFF that the cull became
COMPULSORY at 4pm yesterday.”
[CORE 17, Pg 48]

11.       27 March 2001. Article entitled “Firebreak slaughter in disarray” in The Daily Telegraph. Downing Street admitted it did not have powers to enforce the mass cull of healthy animals.

”Alistair Campbell, Blair’s spokesman, admitted that there were “practical difficulties” over the establishment of firebreaks around infected farms. He said: “We have to do that with the consent of farmers. The only situation where we can have the powers is where the CVO advises that the entirety of the stock there is liable to be infected.”
There were no plans to introduce emergency legislation to take compulsory slaughter powers, as the government hoped to “persuade” farmers to co-operate in the cull.


12.       28 March 2001. Live animals arrived today at Great Orton killing site for the first time. [CORE 17, Pg 48]


13.       19 April 2001. Cumbria Police have seized guns from five farmers following threats to MAFF officials who have been stepping up the cull of animals. The resistance to the 3km cull comes as MAFF vowed to get tough with people who did not co-operate. Previously farmers have been contacted and asked to surrender their animals voluntarily for slaughter. But after 240 out of 1,600 refused, MAFF say they will be taking tougher action. Farmers will be given one more chance to hand over sheep before the animals are classified as DC`s and killed on the farm. Penrith & Borders MP, David MacLean urges farmers to put down their guns before someone got killed.


14.       Pauline Scott, of Crooklands Farm, Dearham, accused MAFF of intimidating farmers. “The only voluntary aspect about this seems to be where we have the sheep killed,” she said.


15.       I spoke to many farmers during this period and since, who told me they had been bullied and intimidated by belligerent MAFF Officials. Some had been told that if they did not give up their sheep, they (MAFF) would come and kill their cattle or they would not be allowed to re-stock. Other remarks included “What would your friends think if you allowed FMD to get on their farms?” “MAFF will charge you for slaughter and disposal unless you volunteer.” The level of bullying reminded me of a Fascist state.


16.       Sadly, the undemocratic National Farmers Union, representing some 35% of Cumbrian farmers and around 30% of farmers nationally, also joined in the bullying. I was told several times that farmers who were attempting to resist the 3km cull legally, were telephoned by local NFU representatives and asked “why the hell they had not given up their sheep? They would help spread the disease. Give them up now!”


17.       A National news report at that time:

“John Sanders, who farms 200 sheep south of Penrith, has padlocked his gates and is refusing to co-operate with the Government after a series of ‘confusing and nonsensical messages.

He said: “The nearest outbreak to us was 32 days ago. The animals were killed and burned a couple of days later. My sheep were given a clean bill of health at the start of April by a vet who was working for MAFF, but then in a complete turnaround I got a letter saying that if I don’t put them into a voluntary cull they will be shot in front of me on my land. It makes no sense at all. More than a million sheep have been killed in Cumbria throughout the nine weeks of the epidemic. It’s as if the Government is caught in a killing frenzy and doesn’t know when to stop.

”Tom Lowther, 35, who farms 700 sheep on a hill farm near Penrith is also refusing to let MAFF on to his land and has had offers from villagers and neighbouring farmers of vehicles and ‘muscle-power’ to help defend. his property. ‘Everyone’s talking about what can be done,’ he said. ‘There is a lot of anger at what MAFF has done and the feeling that enough is enough.’

Two popular Cumbrian animal sanctuaries — the Animal Refuge and Hospital at Wetheral Shields near Carlisle and the Knoxwood Wildlife Trust, near Wigton — have joined the stand-off with George Scott of Knoxwood threatening to barricade his property.He said: ‘We will do whatever we have to do and have many friends who are willing to do a 24-hour stand at our gate. There is no law that says MAFF can come in here and just slaughter our animals.’

In Devon,’ where Hector Christie, 39, keeps nine Highland cattle and 12 Black Berkshire pigs on his holding and tourist attraction Tapeley Park, he and other farmers have grown increasingly defiant.

Mr Christie allowed a MAFF vet to visit and certify his livestock as clean earlier last week. But he refused to let them return every other day, for checks, on the grounds that this increased the risk of his animals catching the virus. ‘I have padlocked and chained the gates and have a huge sign outside which reads "Cull MAFF",’ he said. ‘I know it sounds extreme but like a lot of people around here I have had it. I really don’t care what they do to me, or threaten to do to me. ‘I’m ready for a fight. And I have plenty of people who’ll back me up. The only way they’ll get my livestock is if they take me out in chains and cart me off to prison.’ In the Forest of Dean an action group has been set up to defend 35 farms which have been served Section A notices to cull all livestock.

 Smallholder Pat Innocent, of Lydbrook, who has 11 sheep and eight lambs, is refusing to let MAFF in. Mrs Innocent said: ‘I have no confidence in MAFF. The decisions are being made by men who don’t understand the countryside.’


18.       23 April 2001. Biffa Press Release from their website (

 “Biffa Waste Services, working under the direction of MAFF to dispose of HEALTHY sheep and pigs as part of the pre-emptive cull. BIFFA has been assured by MAFF that all carcasses transported to its sites will be free of FMD and will pose no danger to the health of other livestock in those areas.”

 If these animals are healthy, was the cull legal and why kill them?


19.       26 April 2001. Agricultural Minister Nick Brown announces a major relaxation in the Government’s slaughter policy following the media outcry about the fate of Phoenix the calf. The revised policy will give vets greater discretion in whether to cull cattle on contiguous farms. Pigs and sheep will still be subject to the culls.


20.       In the Letters page of the Veterinary Record 19 May 2001, Mr Archie Hunter, a senior lecturer at the Centre for Tropical Veterinary Medicine, Edinburgh  writes:

 “The cull of sheep in the conjoined 3km zones surrounding infected premises in Cumbria has been switched from compulsory to voluntary to the present voluntary/compulsory scheme, in which farmers are invited to surrender their sheep for removal to a central place for slaughter.  Farmers can appeal, but if their appeal is turned down or if they fail to accept the invitation to surrender their livestock, then the cull will go ahead, possibly on the farm.” The voluntary aspect, therefore, has a strong compulsory veneer.”



21.       MAFF Invoices for compensation paid to farmers, have “VOLUNTARY DEPOPULATION SCHEME” printed as a header. Covering letter also states – VOLUNTARY DEPOPULATION SCHEME – DETAILS OF YOUR PAYMENT.

[APPENDIX  E – In Related  Submission Document “3km Cull, Did Defra Lie?” by Nick Green]


22.       29 April 2001. The Sunday Times:

“Dr Paul Kitching, ex Head of Exotic Diseases, IAH Pirbright, states that one in four of infected farms has been wrongly diagnosed as infected. About 550,000 of the 2.2million animals killed to date has been unnecessarily slaughtered. Some 400 of the 1,600 farms condemned as infected are now known never to have had the disease.
The policy of culling within 3km of an infected farm was based on the wrong model. And was introduced on the back of a fundamentally flawed prediction.”


23.       24 May 2001. 3km cull ceases.

375 holdings did not participate in Cumbria according to a later statement in the House of Commons by Elliot Morley on 29 October 2001.


24.       24 June 2001. Top government adviser speaks out on cull:

 “Common sense totally suspended. Ministers alerted to wrong policy in March.” Dr Paul Kitching speaks out again.


25.       17 October 2001. Margaret Beckett, DEFRA, states,

 “It is not clear to me that there was much of an alternative in treating the outbreak of a disease of this nature.”


26.       22 October 2001. Hansard Debates:

 “Mr Morley (holding answer 25 June 2001): As at 22 October a total of 7,294 Dangerous Contacts (DC) and 255 Slaughtered on Suspicion (SOS) cases, which have not been recognised as Infected Premises, had laboratory tests conducted. Of these,
FIVE yielded positive results and subsequently became I/P`s and were recorded as such. “

That is 7549 premises.
ONLY 5 of them showed evidence of active virus.


27.       November 7 2001. Government Chief Scientist tells the DEFRA Select Committee that “only 17.5% of 3km/Contiguous culls proved positive with 83.5% negative on average – but this was an acceptable loss to control the disease.”

However earlier statement by Morley (22 October 2001) is rather less than 17.5%. Proof complete that there is no laboratory evidence of disease on contiguous farms – full stop!



28.       From Warmwell website:

”ASTONISHING figures just extracted from Defra confirm that last year's "contiguous cull", the strategy promoted by the Imperial College computer to tackle the foot and mouth crisis, was one of the greatest criminal acts ever committed by a British Government. The only legal power Defra had to order the killing of some nine million animals, just because they were on farms within three kilometres of an infected farm, was provided by the Animal Health Act 1981. This permits the killing of animals only where there is evidence of infection or of direct exposure to infection.

The new figures show that not a single one of the 3,305 farms, which lost their animals under the cull, tested positive for the virus. Of 3,873 farms "slaughtered out" only one tested positive. Defra weakly pleads that, despite its own figures, other evidence indicates that 120 out of 2,960 cull farms were positive. But this is still less than 2 per cent of the total, meaning on its own admission that 98 per cent of the animals were killed illegally.
It is precisely because the Government knows that it was acting way outside its legal powers that it is pushing through its new Animal Health Bill, giving its officials power to kill any animal they wish, without having to produce justification and making it a criminal offence for anyone to object. “



29.       Alan Richardson. Veterinary Times Volume 32 Number 1, 14th Jan 2002:

Slaughter on Suspicion and the three km cull

”After a certain date in 2001, there was a change of policy and from demanding laboratory confirmation of all clinical cases; the veterinarians at HQ began to refuse them to uncertain cases, or to allow a period of observation. Instead they required the TVI to choose between declaring the animals FMD free, or advising slaughter "on suspicion". There is a significant difference between not being able to rule out the presence of the disease and suspecting that it is present. The option offered to the TVI did not admit of this difference and placed him in a dilemma. Because opting for the negative diagnosis carried the onerous responsibility for mis-diagnosing a positive case, with frightful consequences, a TVI usually opted for the "slaughter on suspicion." He thus did not arrive at a diagnosis by due process but made a guess. The correct diagnostic procedure (state of the art) was not implemented with the result that perfectly healthy animals committed to his care, were often slaughtered in very unsatisfactory conditions. In obliging his paymasters, he could not but fail in his duty to the animals committed to his care.”

”Killing all the susceptible livestock within three km of an infected place, irrespective of local circumstances, extended the notion of slaughtering on suspicion to the extent that animals were suspected of suffering FMD merely on account of their geographical location. Moreover, in these circumstances, the TVI "suspected" disease and served Form A because he was instructed to do so, not because he suspected it. This was a further departure from the state of the art diagnostic protocol, for the decision to kill took no account of local circumstances. It is arguable that the TVI signed the Form A in the absence of reasonable grounds for suspecting the presence of FMD on the farm in question. Such grounds as existed came from a computer model that took no account of the local situation.”

”The withholding of laboratory tests from animals that might have benefited from them was surely a breach of duty to animals committed to our care. If this were the CVO's decision, after considering the advice of academic modellers, it would seem he failed to follow the state of the art diagnostic practice. If, on the other hand, he acted upon the direction of ministers, non-clinical scientists and administrators, albeit reluctantly, he placed himself in the position of the veterinary surgeon who compromises good veterinary practice to please a client who insists on following a course prescribed by a layman. If he were completely over-ruled and required to do as he was told, it raises the question as to whether or not DEFRA veterinary surgeons are answerable for their conduct to the RCVS. “

”After slaughter, animals killed "on suspicion," having been refused the benefit of laboratory tests when alive, were then subjected to those very tests and the results given to the farmer. These often cast doubt on the diagnostic, or rather guessing, competence of the TVI. Nothing could be more calculated to bring the profession into disrepute, and if the CVO were responsible for this policy, arguably, he has a case to answer for.”

Motive for the SOS and 3 km cull

”There are grounds for believing that the changes to the diagnostic protocol were dictated by the government's electoral concerns. As early as April 26th 2001, Valerie Elliot wrote in The Times, "There will be no new FMD cases by the time of the election date of June 7th , the government's Chief Scientific Officer has predicted. David King told the Agriculture Select Committee that epidemiologists believed that the number of new cases would drop to zero in the days before June 7th." Clearly this date was significant to the modellers, presumably because they were asked about it. It had no significance from a disease control point of view. This provides the reason for suspecting that that the drastic culling was instituted to validate the model's prediction and to eradicate the disease in time for the election, even though it required debasing the diagnostic criteria and killing far more animals than was strictly necessary for disease control. “

Matters arising

”In carrying out a FMD diagnosis protocol (and 3 km cull) that was unduly influenced by, if not at the behest of, non-clinical scientists, administrators and politicians, and which fell short of the professional standard (state of the art), we arguably placed ourselves in the situation of a practitioner who co-operates with a layman and resorts to bad practice to please a client. It seems to me at least three issues arise.

Is the diagnosis of FMD an act of veterinary surgery and thereby restricted to members of the RCVS, or can anybody do it? May a lay employer, i.e., DEFRA, legally require a veterinary surgeon to act contrary to professional standards? Do those people who have had stock slaughtered "on suspicion" or in the 3km cull, without evidence of their being affected by FMD, have a case for negligence against the veterinary surgeons concerned (CVO and TVIs) in that the correct diagnostic procedures were not carried out?”

Legal opinion

”I have had two legal opinions on these matters. One lawyer thought that the wording of the relevant statutes seems to permit the civil service mandarins to control animal disease without any veterinary involvement all, if they so choose. Any remaining doubts will be swept away by the Bill now before Parliament, for this measure makes no mention of a veterinary in-put and will give officials carte blanche to do whatever they wish, with any disease. This, according to another lawyer, indicates the government knows it has acted illegally and seeks to avoid being caught out in future. This lawyer feels that the eradication of FMD is a veterinary practice and that DEFRA had no authority to require its vets to debase the state of the art for politico-administrative reasons. The justification for the contiguous cull was "suspicion"; but the suspicion was that of a remote academic computer modeller and not that of the veterinary surgeon in attendance. If this view is right, aggrieved animal owners could sue the TVI and the CVO. But, in that event, it appears the CVO might be fire-proof, being an employee of DEFRA, while the TVI would not, because he is fee-earning.”

”I suspect the mandarins know all this and the sooner they can get vets out of animal disease control, the better for them. Once the lab tests are thought reliable, technicians will be despatched to take the samples and the vet will be redundant. Thus the DEFRA mandarins will be able to practice veterinary surgery, something which, strangely, they have long itched to do. The public should be warned of the consequences.”

The profession and the public

”Whatever the legal situation, should not the RCVS make it plain to the public that DEFRA instructed veterinary surgeons to lower their normal ethical and professional standards so far as diagnosis was concerned?”

”Should not the RCVS declare that the SOS policy and the 3km cull, never having been used in the past and being based on the theoretical assumptions of academic models, were unnecessary and unethical?”

”Does the RCVS have any jurisdiction over the conduct of members employed by DEFRA?” If it does, should it not, in the public interest, review all DEFRA's veterinary practices along with the documentation that staff are required to sign in their capacity as veterinary surgeons?

”The answers to these questions may never be known because people who have lost stock might not find it financially worthwhile to risk a legal action, and the College might not wish to inquire into the matter. I suspect that when it comes to the crunch, DEFRA vets are immune from RCVS jurisdiction and that, in effect, we have two standards of professional conduct, one for when we work for DEFRA and another for the rest of the time. “


30.       19 February 2002. Dr David Shannon, Chief Scientist at the Ministry of Agriculture and Defra during the BSE and foot and mouth crises, said the committee that advised the Prime Minister made incorrect assumptions about the outbreak because it did not fully understand the disease, the food industry or farming practices. His attack on the contiguous cull policy, which brought medieval scenes of burning animal pyres to rural Britain and cost tourism billions of pounds, comes on the eve of tomorrow's anniversary of the epidemic's first recorded case.

31.       Alan Beat B.S.C.:

 “Even the Imperial College team, so remote from the reality of the situation on the ground, observed in their October report “Our analyses have demonstrated that . . . changes in culling policies explain less than 50% of observed past variation in transmission rates, indicating that effective movement restrictions and rigorously maintained biosecurity are equally vital.”  But the final condemnation of the computer modellers’ claims is simply this  - that their proposed policies have never actually been implemented.  Their targets of slaughter within 24 hours on infected premises, and within 48 hours on contiguous premises, have never come close to being met on a national basis.  

As the October report admits, “In no week of this epidemic have more than half of contiguous premises been culled within the specified target of 48 hours from report of a new case.”   In other words, the gruesome experiment has been so incomplete that no conclusions may reasonably be drawn from it.”

32.       See APPENDIX A.  Val Lusmore’s Submission to the Royal Society of Edinburgh Inquiry into FMD. Analysis of mathematical modelling.

33.       IAH, Pirbright. Extract from Submission to Lessons Learned Inquiry:

Serological testing during the UK FMD epidemic was based on state-of-the-art methods developed at Pirbright but DEFRA was reluctant to use any methods that were not fully validated under field conditions. Consequently considerable time and effort was expended in validating them during the epidemic. Several additional rapid on-site methods were also developed at IAH.  These techniques included a penside antigen-detection kit as well as a real-time RT-PCR.  These methods were tested and gave excellent results with samples from experimentally infected animals.  Around 300 of the on-site kits were distributed to veterinarians in Northumberland and Cumbria for testing under field conditions, but, disappointingly, very few kits were returned to the lab (less than 2%).  During the outbreak field samples were tested by the real-time RT-PCR methods in a research setting with good results, but were not used for final diagnosis.  Nevertheless, the results obtained are valuable and will support validation of RT-PCR methods for future use.

Para 4.2.5 "The full flexibility of modelling requires the close integration of modelling and disease/infection expertise. It is, therefore, of utmost importance that the predictions made by biomathematicians are scrutinised by experts in the veterinary or other scientific fields. We consider it essential that there is close collaboration between modellers and disease experts, especially those experts who have actually generated the biological/virological data for models." We discern well-disguised Pirbright fury at the inaccuracy of the mathematical modelling and its lack of reliance on proper science. With this we are in full agreement.

Para 4.3.1 ..." The control measures introduced during the 2001 epidemic, in particular the 24/48 hour cull can only be judged as being ethical or not when the data from culled farms has been analysed to determine whether the mathematical predictions for spread made by the modellers were actually accurate or not." But note also bullet point under 4.3.3: 7 "The 24/48 hour culling policy went against the available scientific evidence which showed that the virus was unlikely to spread over significant distances provided the control measures, in particular movement control, were enforced effectively. The fact that extensive local spread did occur indicates either that the predictions for airborne (uncontrollable) spread were too conservative or that there was widespread failure of biosecurity."

It is not clear whether Pirbright is accepting that there was extensive local spread, or saying that the data needs to be analysed. 4.3.1 seems to speculate there was extensive local spread, 4.3.3 that the data needs to be analysed. However, the law (as opposed to "ethics") works on available evidence, not speculation. The statement that the 24/48 culling policy went against the available scientific evidence is therefore of considerable significance.

34.       From The North Devon Journal 12 April 2002

”Quietly and with virtually no nation-wide publicity - which is just the way the Government likes it - more details about New Labour's handling of the foot and mouth crisis are emerging.“

”The inquiry under way in Brussels and Strasbourg - at which British officials, veterinary officers and, crucially, Ministers have been called to give evidence - is slowly teasing out the truth. But it is getting next to no national exposure and, quite clearly, the Government is getting off the hook.”

”Recent evidence has, quite understandably, been overshadowed by the Queen Mother's funeral. But the WMN reported on Tuesday the evidence of Lord Whitty, Parliamentary Under Secretary at the Department of the Environment, Food and Rural Affairs, and Elliot Morley, Animal Health Minister. Today we publish further evidence from vet Alan Richardson.” 

”The evidence of the two Ministers will have been of little comfort to the farmers who suffered such serious losses during the outbreak. The arrogance that characterised so much of the Government's approach to those affected was still apparent, as was Ministers' failure to understand that this was so much more than an economic crisis to those farmers who lost their stock.”

”Worst of all was Lord Whitty's cheap attack on Exmoor farmer Guy Thomas Everard, who was also giving evidence this week. The Minister said that if every farmer had acted like Mr Thomas Everard and refused the cull, the disease would have spread much more dramatically. That was an unwarranted charge to level at a hardworking farmer who successfully fought to save his animals from the slaughterman because they weren't infected with foot and mouth. “

Mr Thomas Everard told the hearing he and his family had been "bullied and intimidated" by MAFF over the cull and had only learned via a media press conference that their animals were due to be killed. When Neil Parrish, the Westcountry Euro MP cross-examining the Ministers, asked if those were the tactics that would be employed if the Animal Health Bill - which gives Ministry vets access to affected farms - were to fail, he got a chilling reply.”

”Elliot Morley told him that in those circumstances the Government would consider using "emergency powers" overriding the view of the House of Lords, which has stopped the Bill in its tracks because it has caused such widespread alarm across the countryside.”

”There was more alarming evidence from veterinary surgeon Mr Richardson, who had a role in both last year's outbreak and the one in 1967. He told the hearing that when he visited a Ministry of Agriculture office at the height of the foot and mouth outbreak last year he was appalled to witness overflowing in-trays yet staff going home at 5pm. "Everything was simply going too slowly," he said. “

”That was, at least, one thing everyone could agree on. Even Lord Whitty admitted that at the height of the outbreak the Government never came close to its target of culling infected animals within 24 hours of confirmation of the disease. He confessed that the contingency plan proved ineffective for an outbreak on this scale and that there was an urgent need to review the plan in case of another foot and mouth crisis. “

”Mr Richardson went further. In his evidence, reported in today's Western Morning News, he said: "The outbreak should have been run like a military operation. Instead it was handled by administrators who lacked the experience and knowledge." “

”All of what we have been hearing in Brussels and Strasbourg in recent weeks confirms the concerns of most people caught up in the foot and mouth crisis: that it was badly handled, that there was a lack of real control at the top and that - worst of all - lessons don't appear to have been learned. “

”But this inquiry, useful as it is, has still not got to the real heart of the matter, which is the part that political considerations, including the timing of the General Election, played in decisions that were taken over foot and mouth. “

”The suspicion remains that the controversial contiguous cull policy was massively stepped up, resulting in the needless deaths of hundreds of thousands of animals, to clear the decks for last June's election. That remains a question to be put to the Prime Minister in the full glare of an open, accountable and very public inquiry. So far there is little sign of that happening.”





Mathematical Models
 Valerie Lusmore

 Submission to
The Royal Society of Edinburgh Inquiry Into FMD



3.1 Pirbright scientists and modelling FMD


The scientists at Pirbright, world reference laboratory for FMD, had been working with mathematical models to study various aspects of foot and mouth disease, since the 1970s. The EUFMD research group discussed research papers on modelling at their annual conferences in both 1999 and 2000 as well as in earlier years. The group was led by Alex Donaldson and Paul Kitching who were world class specialists. Both had worked on the EUFMD research group for a number of years and knew most of the other international specialists on this subject.


The EUFMD group had a great deal of knowledge of the pan-Asian O strain of FMD and there had been increasingly serious discussions for at least two years of how to cope with this strain when it arrived in Europe. There had also been discussions of how to cope with the logistics of slaughter and disposal of large numbers of carcasses as it was felt that increasingly this would lead to a public outcry in many countries.


In Alex Donaldson's 1999 paper he wrote about the earliest model created through collaboration between IAH, Pirbright, and the UK Meteorological Office, a computer-based model was developed during the 1970s for assessing the risk of airborne spread of FMD. It was created by bringing together data on the aerobiology of FMD with data on the physical behaviour of particles in the atmosphere under different climatic conditions. The model was shown to be capable of giving a prediction within a few of hours of the confirmation of an outbreak of FMD of whether there was a risk of spread and, if so, which farms were in jeopardy. The model could predict accurately up to a distance of 10 km from the source. Any farms considered to be at risk could be placed under intensive surveillance so that suspected cases could be quickly identified and eliminated. The model was used successfully under operational conditions during the outbreaks of FMD on Jersey and the Isle of Wight in March 1981.


3.2 The mathematical modelling teams


MAFF invited 3 teams of mathematical modellers to assist with analysis and prediction of the outbreak - a fourth team from Imperial College independently created their own model


I will refer to them as:

THE VLA team - Professor Wilesmith from the State Veterinary Labs agency was backed up by colleagues from Massey University in New Zealand - they had worked together previously on the BSE problem.


The Cambridge team - Professor Grenfell from Cambridge and his colleagues - they were very experienced at analysing data from an epidemic against various factors to see if fresh insights could be obtained (eg measles, soay sheep, etc)


The Edinburgh team - Professor Woolhouse and colleagues - had the most expertise in Geographic Information systems and were called upon by the other groups in this area.


The Imperial team - Professor Anderson and his colleagues from Imperial College were well known to the Chief Scientist but were not among the groups originally asked to take part. They had experience of BSE modelling and various (mostly human) epidemic diseases. The team had recently moved (Nov 2000) from Oxford to a new department researching Human Health headed by Professor Anderson at Imperial College. Their only experience of FMD was that Ms Donnelly had co-authored a paper in July 2000 where the data from the FMD epidemics in UK 1967 and Taiwan in 1997 was run through epidemic simulations. The conclusions of that simulation exercise was that it was imperative that herds be slaughtered on the day that disease was confirmed and that resources should be available to implement this policy should an outbreak occur.




3.3 The computer modelling tools


Epiman database - developed at Massey University in the early 1990s and used to track and manage outbreaks. Had been adapted for EU conditions and tested by various European groups of FMD researchers. Purchased by MAFF some years previously to the 2001 UK outbreak but not set up with data. Needs time to be set up

Quote from a Dutch team of researchers in the mid-1990s 'The EpiMAN(EU) GIS application was user friendly and provided the user with good tools to facilitate certain tasks in the control of a FMD outbreak. The system could be used in the Netherlands, and has potential for other countries as well. However, digitized data has to be available in advance of an outbreak, which is not completely the case yet in the Netherlands. To fully use the possibilities of a DSS such as EpiMAN(EU), a permanent, updated database with farm full information, including farm locations, is necessary.'

This database provided the information for the associated Interspread model which was used for predictions and modelling .


Cambridge model - more complex model - contains more detail, in terms of describing transmission between individual farms, as a random process, allowing for more heterogeneity: differences between farms, in terms of numbers of animals, different species.


Imperial model - adapted by Neil Ferguson and Christl Donnelly from calculations that used the transmission of human sexually transmitted diseases to model spread together with knowledge gleaned from their work on BSE. Simple model - generalised animal species, and constant infectivity assumed.


Rimpuff Model together with GIS system - developed by University of Denmark in 1990s and adapted for use to predict plumes of virus and spread where predicted weather factors are included.


3.4 Papers written by the modelling teams - inconsistencies


There were a number of scientific papers written by the teams of modellers whose work was used by the government to determine their policies.


The paper published by the Imperial team in May describes the 'model' they used which led government policy to use the contiguous cull of all livestock within 3kms of an Infected Premise.


This model relies heavily on the 'contact tracing' carried out by MAFF in the first 3 weeks and discovered from this information that farms within 3 kms of an IP appeared to be at greater risk of infection. There was no differentiation between different species although information about the different infectivity of sheep, cattle and pigs to this particular strain of FMD was readily available. There was another generalised assumption that infectivity is constant from day 3 after infection to day 11.


Presumably the 3km spread was assumed to be via windborne transmission, although it was known by the Pirbright team that this strain of virus did not spread that way over more than 200 metres.


In the subsequent paper published by this team in October significant bias in the contact tracing was uncovered and it was suggested that 'local' spread may have been via personnel or vehicles; it was also discovered by analysing what had happened that there was significant differences in infectivity between different sizes of farm and types of animal.


In a paper by the Edinburgh and Cambridge teams analysing the epidemic data afterwards, it was again discussed that there was a bias in the contact tracing data towards 'local' contacts without discovering how the disease was spread. They also suggest that in reality there are epidemic dynamics within a farm which means that infectivity changes over time. These became more significant as delays in culling infected animals (as well as all the contiguous stock) built up. Analysis found significant differences in infectivity between species with cattle being more liable to infection and sheep being relatively little affected.


All these facts were known by the Pirbright team BEFORE this epidemic occurred - but were not fully taken account of by the modellers.


3.5 Major problems with modelling


The main problem with all the models was not the methodology or the assumptions, but the quality and integrity of the available data. This was not of a standard consistent with modern practice - there are comments in most of the papers by the modelling teams about the data. These range from the relatively mild comments from the Cambridge team about 'lacunae' in the data, to Anderson of Imperial's comments to the Parliamentary agriculture committee that several of the farms were, according to MAFF's figures, situated in the North Sea .


From my own experience of the data, checked and gathered every single day since I became involved in this epidemic, I know that the data which MAFF/ DEFRA published is extremely inaccurate. Any experienced data analyst would have realised that there was no point in continuing with the modelling unless significant effort was put into validating, verifying and correcting the available data. Until the data validity was improved only extremely simplistic models could be run.


4. Information Collection


4.1 Initial data setup


The information required for the models is in two sections:

            Firstly the general information of the overall picture of the locale

-        both for farming and geography of the areas


Secondly, the particular details of each IP in the FMD outbreak - by location and type of livestock involved


Ideally the general information should already have been available and fed into a Database (presumably that was why the Epiman database was purchased by the MAFF two years previously). This would be useful and appropriate under contingency procedures for ANY outbreak of disease.


Once the foot and mouth disease outbreak was identified in Britain, four New Zealand experts were sent immediately to work with British colleagues to get the system up and running urgently. Professor Morris of Massey University said that loading all the data and getting the program running was done in four days, by cutting corners to get available data into the system as quickly as possible, "warts and all", rather than methodically and calmly as intended.


In this case, the data had to be hurriedly gathered and converted from many different sources - not all of which were compatible. There was very little time for checking the accuracy or consistency of the available data on the 144000 holdings in the UK. Data was collected from:

            June 2000 agricultural census

            Local MAFF office databases (Vetnet)

            Database created for Swine fever outbreaks


From these sources a database of all farms was created to be used in conjunction with the data collected from the Infected Premises. Basic data from this database was then immediately available to be passed to the Epiman database of information about the IPs and used in conjunction with the Interspread model.


4.2 Commentary on data integrity



Unfortunately this data was flawed from the start:

The June census figures are not consistently collected and the numbers of animals on holdings change considerably during the year, especially in February where the number of sheep on each holding need to be maximised for the sheep premium.

Overall geographical mapping data loaded from current sources did not necessarily match the Vetnet data collected from a number of sources over a period of years. This data was often seriously out of data with regard to crucial factors such as map coordinates, addresses, postcodes, local authorities and counties.


Holding data had not been removed for farms that had stopped farming many years before. Holding numbers were not unique. I was told that there were no computer systems available in local MAFF offices at the start and inexperienced personnel were drafted in to copy all this data in from the Vetnet system, and that inadequate procedures were followed for checking the data for accuracy.


All of these items were crucial for accurate modelling. The data for the infected premises was not sufficiently accurate or consistent to model clearly -nor was it particularly accurate for the MAFF officials who needed to go round the local area to put on the D notices and movement restrictions. This was certainly observed at almost every stage throughout the epidemic and must have been even worse at the beginning.


Data on the outbreak was gathered by MAFF but, as they were not ready to deal with the outbreak, the accuracy and consistency of that data was also poor. This became very apparent as soon as data was published on the MAFF website daily for public viewing.


This data was widely published in the newspapers and on the BBC.


Almost as soon as the data was published the inconsistencies began to show.



4.3 Summarisation of Data


One of the main decisions to be made when setting up data of this type, is the levels to which the data may be aggregated for various purposes. There may be several different data fields that are stored merely so that data can be aggregated - for example, counties, type of holding, which office they report to, etc etc. The decision must be taken when setting up the data as to exactly which lists are to be used, otherwise all data previously loaded has to be changed whenever decisions are made to use a different categorisation.


In the case of the county lists on which the data was based this was never sorted out and even today some of the data is aggregated to one set of 'counties' (local authorities) and other information is aggregated to the 'counties' as they were in 1979. This may seem in itself a small point - but it ensures that it is impossible to completely reconcile the information in the two sets of tables!


This has been true throughout the running of the epidemic - the 'local authority' table used to tell the general public where the Infected Premises were located, has been amended constantly since last year, and has only just (Jan 18th 2002) been corrected.


Because the data has been changed so often, the total number of IPs (Infected premises) assigned to a particular county on the Totals page is often different from the number of Names and addresses on the actual Table; the total number of all these sub-totals is often different from the actual number of IPs at any point in time.


When producing large amounts of data in a computer it is common practice to produce 'control totals' which ensure that all the data is actually entered into the system. At any point, adding up details of the data gives a check as to whether all the data is included. This principle has been totally ignored throughout the course of this epidemic - the summary tables often did not add up to the number of cases in the database.