Submission to DEFRA Consultation contingency plan exotic diseases May 2011 return to


Consultation on the 2011 Annual Review of Defra’s Contingency Plan for Exotic Notifiable Diseases of Animals


From Mrs Mary Critchley, editor of the website.: (address  xxxxxxxxxxx)


(My comments refer only to the section of the Consultation on Defra’s Contingency Plan
for Exotic Notifiable Diseases of Animals referring to Foot and Mouth disease)



The website was set up at the time of the 2001 FMD crisis and has been updated daily for the past decade on this and other relevant issues as a free and independent public information service.


Preliminary Remarks

New research has "significantly altered scientists' thinking about FMD - "what we thought we knew about foot and mouth disease is not entirely true."

The publication by Charleston, Woolhouse et al,  "Relationship Between Clinical Signs and Transmission of an Infectious Disease and the Implications for Control" - the new research paper published in Science May 2011 suggests that DEFRA's assumptions about the risks of Foot and Mouth  have not been entirely sound.

In particular, the conclusions of  Mark Woolhouse – one of the proponents of the 2001 mass cull policy that –

 “ there may be no need for pre-emptive culling in the immediate area of an infected farm”

suggests a re-think on what the March Consultation para. 8 (page 66/80) calls “pre-emptive culling”  (It is now widely known and deplored that in  the 2007 Surrey crisis, Defra engaged in a most disgraceful slaughter of healthy animals (that had been checked and tested day in and day out) as a firebreak to protect the Queen’s herd.


 "what is missing is the policies and strategies"


 It may be thought important too that, after DEFRA's Consultation Document was sent out, Scotland changed its stance on vaccination and culling. 


The Scottish  FMD Moredun Conference concluded that contiguous culling has no place in future policies.  Although there were differing opinions within and between groups, conclusions included such comments as :

"It was unanimously agreed by the group that the policy on vaccination (particularly whether
it was to be ‘vaccinate to live’ or ‘vaccinate to kill’) must be agreed between stakeholders
and Government in advance of an outbreak using meetings such as today’s as a stepping


 "there was a strong feeling that farmers should be allowed to complete vaccination of their own livestock.  The group felt
this was the best way to operate as farmers know their own animals and understand the facilities that vary farm to farm. "




In summing up what the speakers had emphasised,  Professor Julie Fitzpatrick, Director, Moredun Research Institute said  (

"... we have the tools and technologies to deal with FMDV if we wish to do so  – what is missing is the policies and strategies that we would require in order to employ this  – and perhaps today will help to stimulate that." 

Such a conference is urgently needed in England.


It is perfectly possible to vaccinate effectively in the face of an epidemic, but it is usually better to start emergency vaccination to live  as soon as is humanly possible.  Alick Simmons said at Moredun "Vaccine looks good in high density animal populations but less so in less dense areas, mostly due to cost"  - but delaying the start of vaccination, and allowing the virus to take hold and spread in the hope of saving money, is a desperate gamble.


1 Emergency Vaccination to Live ~  the timing of vaccination is crucial. The Royal Society in 2002 advocated its immediate deployment.  It should be accepted that it is going to be used as soon as humanly possible rather than endlessly ‘considered’
  "..... to move emergency vaccination from a measure of last resort to the forefront of disease control strategies and thus enhance the capacity to respond to an outbreak" 
a) The main arguments against vaccination during the 2001 FMD epidemic were:
  • "If you vaccinate you will have to live with the disease"
  • "You cannot distinguish between vaccinated and infected animals"
  • "Vaccination causes carriers"
  • "Carriers are a great risk!"
  • "Consumers will not buy meat or other products of vaccinated animals"
 In 2003, the experts below, concerned that the public were being misinformed, wrote a guideline for future prevention, control and eradication of FMD: The successful control and eradication of FMD in South America in 2001

"....We were struck by the fact that the measures used to prevent and control FMD were primarily based on agro-economic considerations and that authorities in charge were justifying their policies with doubtful scientific arguments. We heard veterinary authorities state 'To vaccinate means to live with the disease!' The public in general, including veterinary and agricultural communities, were misinformed by scientists and veterinary authorities and raised such basic questions as: 'Would meat from vaccinated animals be fit for consumption?'; 'Can sheep, goats and pigs be protected by vaccination?'; and, 'Does vaccination perpetuate FMD infection?'. We decided, therefore, that we should present the available scientific information as a guideline for future prevention, control and eradication of FMD..."

The successful control and eradication of FMD in South America in 2001

 (pdf) appeared in Virus Research 91 (2003) 101-/144
The authors were:

Paul Sutmoller Animal Health Consultant, former chief of Laboratories of the Panamerican Foot and Mouth Disease Center PAHO/WHO, Brazil
Simon S. Barteling - Consultant Veterinary Vaccines, former Head Department FMD Vaccine Development, and Production ID-Lelystad and former Head Community Co-ordinating Institute (for the EU), The Netherlands
Raul Casas Olascoaga - Direct Advisor of the Minister of Livestock, Agriculture and Fisheries, Uruguay, former Director of the Panamerican Foot and Mouth Disease Center PAHO/WHO, Brazil
Keith J. Sumption - Lecturer in International Animal Health, Centre for Tropical Veterinary Medicine, University of Edinburgh, Easter Bush, Roslin, Midlothian EH25 9RG, Scotland, UK


c) With modern robust vaccines, vaccination confers protection within 5 days.


d)  Dr Bernard Vallet, Director General of the OIE wrote earlier this year  in a letter to the European Livestock Association :


".. the OIE aspires to offer alternative recommendations to stamping out…. The use of vaccination is more and more relevant thanks to the scientific progress in vaccinology and diagnostic methods…trade standards are not mandatory and cannot be imposed by the OIE. It is up to the sovereign rights of each Member to determine which measure and how they will be applied." 


e) And as the expert virologist Ruth Watkins pointed out in 2007 

“ If FMD infection does occur post vaccination against the same serotype,  such animals have never been implicated in the spread of FMD in the many decades of use of vaccination to control and eliminate FMD outbreaks worldwide.”



f) Merial has a large bank of antigens of all strains of FMD.  Vaccines can therefore be made very quickly once the strain has been identified.  Delay can be kept to an absolute minimum and ring vaccination applied from the outside inwards to prevent spread.  And as DEFRA's  March Consultation says,


10.17 To ensure that emergency vaccination can be implemented without delay in

any future outbreak, Statutory Instruments have been created to allow non-veterinary

personnel to handle and administer FMD vaccine.  The Orders specifically permit

vaccine to be supplied to and administered by lay vaccinators who meet specified

eligibility criteria, thus reducing pressure on veterinary resources during an outbreak.


g)  The UK’s  position should now be immediate vaccination to live in a ring (outside towards inside)  combined with slaughter of infected animals and any animals, (formerly given the vague term “dangerous contacts”) shown to have been in close contact with animals during the infectious phase.


As the Charleston/Woolhouse research now shows,  contiguous culling is pointless where there is no risk of contiguous spread



2. "Carriers" 


"When disease does strike, Defra will act swiftly and decisively to.. Eradicate the disease and regain disease free status;"


The Directive's “Recovery of status following eradication of foot-and-mouth disease with vaccination” places an added burden of three months on countries that choose to protect their herds and flocks with emergency vaccination to live.


a) As everyone is aware, a very major stumbling block for emergency vaccination to live (a disease policy that is driven by considerations of trade rather than genuine science) can be largely traced back to  Article 61 of the EU 2003/85/EC  Directive with its assumptions that "vaccinated carriers" or FMD vaccinated products can pose a risk. These assumptions have allowed a trade barrier to exist against countries that use vaccination to protect their herds and flocks.

b) Unfortunately, and in spite of all the evidence to the contrary over the past ten years, the idea that FMD “carriers” represent a risk of transmission of the disease persists. 

c) This appears to "justify"  the basis for existing rules and regulations for international trade in animals and animal products and the extra three month wait for resumption of trade. 

d) Notes on Transmission and Vaccination (given to by Keith Sumption in 2002) shows that any suggestion that animals treated correctly with potent modern vaccine pose a risk from "chronic latent foot-and-mouth virus" stems either from ignorance or from mere political face-saving.


e) One suggestion received at, which perhaps deserves to be taken seriously (particularly in view of the recent recurrence in Bulgaria of FMD where no emergency vaccination has of course taken place), was this:


"If we modify our approach to parity by extending the Freedom WITHOUT
Vaccination period from 3 months to 6 months - rather than shortening the
Freedom WITH Vaccination from 6 months to 3 months - we may find more OIE
member states will support us since we can't escape the fact that however
much decision makers support welfare, trade is the driving force in their

f) We note that Mr James Paice said in a letter to an MP's consituent (in the past month)  that,

“..the timing of any vaccination programme to be adopted so as to minimise the effects of an outbreak can only be decided at the time taking into account all available epidemiological evidence and expert advice for the particular situation.”


g) By “minimising the effects of an outbreak” Mr Paice is here referring to economic effects – the costs solely in terms of money and profits from trade.  If there were no difference between the times set down for resumption of trade after the last case then a very high barrier to the use of the excellent available vaccines would be removed. 



3. Consumer concerns


"The FSA is responsible for providing advice to the public concerning implications for the food chain arising from an outbreak of exotic disease of animals."


a) FMD Vaccination leaves no residues (unlike some antibiotics/parasiticides/other chemicals etc etc) We are assured that it does not have to be labelled since there are no safety concerns.

      • If we eat meat, we eat products from vaccinated animals

      • If we consume dairy products, we are consuming products from vaccinated animals

      • It would appear to be simplicity itself to get these messages across to the public and the industry -



b) yet the Veterinary Record’s article on the Silver Birch Exercise mentioned that


“ ……..issues surrounding licensing of movements and vaccination, particularly whether abattoirs would be prepared to deal with vaccinated animals and whether retailers would be prepared to take them. As the exercise developed, it had become clear that this was a major issue, as no abattoir would take vaccinated animals because the retailers would not accept them. The problems could not be solved during the exercise and discussions would take place independently.


c) The public eats meat, milk, cheese, eggs from animals that have all been vaccinated - and meat from animals that have been vaccinated against FMD was on sale when the 2001 FMD epidemic started.  This issue needs to be transparent and it needs to be challenged.  It is frank dishonesty to imply that vaccinated products pose any kind of risk to the public



d) This issue of consumer confidence seems therefore to have simply been shelved instead of tackled as advocated by the various FMD Inquiries.  Below are references to the consumer confidence problem which date back ten years or so.


Innovative control strategies incorporating vaccination as a tool to reduce destruction
of animals to a minimum without compromising the trade in animals and products and
new surveillance methods, exploiting to the maximum new diagnostic tests, should be
developed and consensus should be sought at the international level within the OIE
Effective communication with consumers and retailers in relation to safety of
products derived from vaccinated animals should be implemented. 


(Brussels international FMD conference Dec 2001)

Food Safety and Foot-and-Mouth Disease Vaccination

The Food Standards Agency has considered the implications of both the foot-and-mouth
disease virus and vaccination against FMD. The FSA concluded that it is safe to consume
meat and milk from animals that have been vaccinated. The foot-and-mouth disease virus
does not present a risk to people and the vaccine uses a dead virus, so it isn’t active and
therefore cannot spread the disease.
The Agency is satisfied that the use of the FMD vaccine does not adversely affect the
quality or safety of animal products.


Meat and Livestock Commission, April 2001


Figures showing the Import of vaccinated meat at the time of the FMD crisis 2001:


Analysis of Meat import trade to the Uk

 The following is a list of all countries that exported to the Uk in the Fiscal year April 2000 through to April 2001. Beside each country is given the weight in Kilos traded, the type of meat, and the current status of Foot and Mouth in the country. A brief history is given for each country describing each outbreak.

Country Fresh Beef Frozen Beef Pork Lamb


Namibia 5254347 472702

18th July 2000 first diagnosed infection, 21st August 2000 began primary vaccination using Sat1,2 and 3 vaccine

25th October 2000 138,542 animals vaccinated 19th April 2001 no new reports of FMD for a period of 6 months ending 31st March 2001 so then a return to FMD free status.

- vaccinating since 21 August 2000 , now FMD free

- Virus type A24


South Africa 118348 14700


11th Sept 2000 virus escaped from a FMD test facility (Grietjie 6) attempting to breed FMD disease free animals.Virus defined as Serotype SAT 1, 3rd October stamping out policy started, 1st December 2000 zone vaccination began (48,720 pigs 14,308 cows vaccinated) , 3rd January 2001 cattle adjoining Kruger Park are normally FMD vaccinated twice a year,

6th Feb 2001 zone vaccinating near Kruger Park, 7th March 2001 48735 cattle vaccinated in Middelburg, no more reports available currently

- ring vaccinating since 1st December 2000

- Virus types 0 and Sat 1 found


Zimbabwe 5138322 297995


Outbreaks originally on the 16th July 1999 and 23rd July 1999 involved cattle areas which are at high risk and are all vaccinated against FMD, and both Mapanza Estate and Mkwasine Ranch fall within the FMD vaccination control zone, but the disease occurred in spite of vaccination. A total of 124,506 booster vaccinations were done from the 2nd February 2000 to control the outbreaks in Chiredzi district.

- blanket vaccinating historically

- virus type Sat 1 and 3


Swaziland 581671


23rd Nov 2000 import of 110 animals from a neighbouring country found animals with FMD, zone vaccinated 8386 cattle and 6857 small livestock 20th January ring vaccination 20th February branding performed of 4570 vaccinated catlle

- 23rd November 2000 ring vaccination

- virus type Sat 1


Uruguay 3104652 1486103 1010215


25th January 2001 recognised FMD disease free status without vaccination, 25th April 2001 new outbreak of FMD, 28th April 2001 stategic vaccination of 842,000 cattle in districts, 8th May 2001 mass primary vaccination bordering Brazil began, 24th May 2001 Primary vaccination coverage over the whole country reached 100% for dairy cattle and reached 100% for general bovine population on the 7th June 2001

- vaccinating since 28th Apr 2001

- close similarity to FMD virus subtype A24


Argentina 1710799 348339 258096


10th August 2000 outbreak found most animals testing negative as were vaccinated before 30th April 1999, movements resumed 7th September 2000, 21st February 2001 epedemiological situation points to the need to consider a new approach zone vaccination begun, 7th May 566 outbreaks reported since 21st February, 20th June Primary mass vaccination programme began.

- vaccinating historically

- Virus type A24


Paraguay 11434

- zone vaccinating


Eritrea 1465

- Outbreaks of Bovine FMD vaccinated


Canada 3615 3962 FMD free

Switzerland 33583 222504 FMD free

Chile 61842 FMD free

Dominica 45875 FMD free

Hungary 16982 FMD free

Iceland 165963 FMD free

Japan 711324 FMD free

Mozambique 10490 FMD free

New Zealand 239704 186876 85384022 FMD free

USA 18588 3371441 FMD free

Australia 5757069 46868 12066835 FMD free


Finally, here is a list of all of the countries with FMD declared in the last 18 months, some of them don't trade with the Uk and others who do might have FMD free status now (eg Japan)


August 2001 - email from the National Consumer Council


Kathryn Williams
Press Officer
National Consumer Council
Tel: 020 7881 3019
Fax: 020 7730 5851


Dear Mrs Critchley,


RE: Food labelling article in The Cumberland News


Thank you for your e-mail.


In most circumstances, we believe that comprehensive labelling of food is desirable. Consumer information is one of the basic principles on which we develop our policy. However, in this case, we take the view that food from vaccinated beasts does not need to be labelled. I have attached a link to our website which explains our position in full.


During the vaccination debate a few months ago, our Chairman Deirdre Hutton, had a number of private conversations with a variety of people including Ben Gill. Conversations like these contribute to our thinking when developing policy and Deirdre may well have emphasised the importance of consumer information. Since then we have fully developed our policy and, on 20th April, we issued the statement attached. (at the bottom of the e-mail)


We will, of course, write to The Cumberland News to clarify our position with them.


With thanks.


Kathryn Williams
Press Officer
National Consumer Council
Tel: 020 7881 3019
Fax: 020 7730 5851


Then, from 2004


From DEFRA's own Vaccination Protocol April 2004

" The Food Standards Agency have issued as statement which confirms that there are no risks to human health from consuming products from animals which have been vaccinated against FMD with an approved vaccine. "

e)  Arguments about the way to convince the public that FMD vaccinated animals and products are perfectly safe were summed up well by a group at the Moredun Conference in March (Scotland)


4. “Expert advice”?

"The SoS may be required to decide if emergency vaccination is to be
implemented for disease control purposes. The decision must be justified to
Parliament and will be based upon epidemiological and scientific advice provided by
Chief Veterinary Officer UK and SAGE (if active)"


4.25 "The National Experts Group is a permanently operational group which, in an outbreak of exotic disease of animals, provides specific technical and scientific advice and recommendations on the disease, its transmission and its control with a view to supporting Defra and GB policies via  the Animal Disease Policy Group, CVO and Deputy Chief Veterinary Officer (DCVO UK).  A Tactical Advisory Group may also be called to provide tactical advice for disease control purposes..."


b)  How far does such a group meet the requirements of the EU Directive?

Article 78

Expert Group

1. Member States shall create a permanently operational expert group, which is composed of epidemiologists, veterinary scientists and virologists in a balanced way, to maintain expertise in order to assist the competent authority in ensuring preparedness against an outbreak of foot-and-mouth disease.

Article 78

Expert Group

1.          Member States shall create a permanently operational expert group to maintain expertise in order to assist the competent authority in ensuring preparedness against an outbreak of foot-and-mouth disease.

2.           In case of a suspicion of an outbreak of foot-and-mouth disease the expert group shall at least:

(a) evaluate the clinical picture and the epidemiological situation;

(b) give advice regarding the sampling and analyses needed for diagnosing the foot-and-mouth disease together with the additional actions and measures to be taken.

3.           In case of an outbreak of foot-and-mouth the expert group shall at least:

(a) conduct at least in the index case and if necessary on the spot, an evaluation of the clinical picture and an analysis of the epidemiological inquiry in order to collect the necessary data for determining the following:

(i) the origin of the infection;

(ii) the date of introduction of the infectious agent;

(iii) the possible spread of the disease.

(b) report to the Chief Veterinary Officer and the national disease control centre;

(c) give advice on screening, sampling, test procedures, control and the other measures to be applied and on the strategy to be implemented;

(d) follow up and guide the epidemiological inquiry;

(e) amplify the epidemiological data with geographical, meteorological and other necessary information;

(f) analyse the epidemiological information and perform risk assessments at regular intervals;

(g) assist in ensuring that the disposal of animal carcasses and animal waste is done without causing any harm to the environment.


d)   "in retrospect we may have used the term 'experts' somewhat loosely"   

This quotation was reported to us as having followed questions during a stakeholder meeting about Defra's frequent references to their FMD expert group.  It came to light that  the group consisted of Defra officials and employees, not one of whom could remotely be termed an FMD expert. 





5.  Available rapid on-site RT-PCR Diagnostic Tests 


3.48 National Reference Laboratories are responsible for the provision and
interpretation of diagnostic and surveillance testing as well as disease-specific expert
knowledge in relation to the application of laboratory tests, epidemiology and control


that can determine on site whether an animal is infected or not - before clinical signs are apparent. 


a) How is it that for ten years the UK has avoided any mention on the Contingency plans of the rapid diagnostic tests when the same test that performed so successfully in Uruguay in 2001 had been offered to the UK (and unfortunately rejected)? 


b) At the most recent International FMD conference in Melbourne in April 2010 there was a presentation and demonstration of one of them  -  Carmelo Volpe's description of of the BioSeeq Portable Veterinary Diagnostics Laboratory.  It is a field deployable Rapid Testing and Instant Reporting system for on-site rapid diagnosis of FMD in the  field .  See pdf file    (More examples discussed on  



c) Dr Charleston is quoted as saying: 

"This result emphasizes the need for practical tools for pre-clinical diagnosis and at present we don't have an affordable, reliable test to use on farms.  We can identify infected cattle before they show signs of disease using tests in the laboratory. The next challenge is to do it in the field during an outbreak."

It is hard to understand why UK bodies such as BBSRC or  DEFRA are now being asked to fund the further development in the UK  of penside diagnostic RT-PCR tests when such equipment  is already available.   



6.  Are there not  higher principles in question here, questions of legality and human freedoms not to mention compassion?


3.24 A framework for decision making during outbreaks has been established
which is clear, transparent, timely and auditable and adheres to the principle of
subsidiarity (the organising principle that matters ought to be handled by the
smallest, lowest or least centralised authority).

Elliot Morley (he may wish to mull this over during his leisure time) admitted that there was no legal basis to the culling of uninfected animals when he told the EFRA Committee on 6 November 2001 that


 "At the present time we do not have powers for a firebreak cull..".


Yet of course such extensive and illegal  culling was widespread in the hotspots in 2001.


Now we have the amended Animal Health Act of 2002 which gives not only retrospective legality to the killing of animals who have not been in the vicinity of disease, but also gives power to a Minister compulsorily to remove property from any member of the public even when no public good can be proved  – something that would appear wholly contrary to our tradition of fairness and legality. 


Reading testimony from the ordinary people  to the European Inquiry – such as those who in 2001 suffered so badly at Knowstone , we see over and over again the feelings of astonishment at the callousness  shown by those “obeying orders” 


It is therefore cheering to see that policy is to be auditable and that  clarity, transparency and  timeliness are acknowledged as important - as is the principle that "matters ought to be handled by the smallest, lowest or least centralised authority".   



Sent  May 12th 2011