The Scottish Government

REPORT ON THE CONSULTATION PAPER: ANIMAL HEALTH AND BIOSECURITY, PROTECTING SCOTLAND'S INTERESTS

Overview and Summary of Responses

Introduction

This report summarises the main points made in the responses to the consultation on the draft Code of Recommendations on Animal Health and Biosecurity.

Background

The draft Biosecurity Code was published for consultation on 18 March 2002. It comprised 3 parts: Part 1 for Farmers and Other Owners of Farm Animals; Part 2 for Recreational Users of Farmland; and Part 3 for Utility Workers. The official closing date of the consultation was 7 June 2002, though a number of responses were received after that date and were also taken into account.

The Code aims to stress the importance of biosecurity in that it is the responsibility of everybody who lives, works, visits and enjoys the countryside to reduce the risk of disease occurring and spreading among animals. Biosecurity is more than cleansing and disinfecting, it includes, for example, the prudent sourcing of stock, quarantine and testing and vaccination. Animal diseases affect animal welfare, cost time, money and effort to eradicate. The Code recommends measures that can be taken to reduce such risks in Scotland.

Consultation

Approximately 600 copies of the consultation paper were sent to representative organisations, professional bodies, local authorities and Scottish based Animal Health Offices. The consultation paper was also available on the Scottish Executive website. The covering letter to the consultation requested that, ideally, comments should be on the respective parts of the Code. Comments were also invited on the detailed aspects of biosecurity and on how best the Executive could ensure that the biosecurity message can be promoted over time.

In total, 58 responses were received on the Code: 34 from representative organisations, of which 19 were from organisations representing the farming industry; 4 from veterinary officers; 4 from veterinary surgeries; 2 from specialist veterinary practitioners and one from the British Veterinary Association. 5 responses were from Local Authorities, 2 from Recreational Groups and 5 from individuals. Only one respondent chose to remain anonymous.

Out of the 58 responses, 34 were of a general nature. The largest proportion (43 of the 58) were on Part 1 of the Code. There were 31 and 24 comments relating to Parts 2 and 3 of the Code respectively. Ten respondents chose to comment on each Part and also make general comments on the Code. Four representative organisations acknowledged receipt of the Code, but chose to return "no comment" on the paper. Some responses voiced opinions on issues beyond the scope of the consultation, for example, 20 day movement rule, illegal meat imports and Foot and Mouth Disease Inquiries.

Overview of Responses

In general, the proposed Code of Recommendations on Biosecurity was welcomed as a common sense approach towards reducing the spread of animal diseases. Three main themes were evident from the comments received. Firstly, there were those concerned that the Code had no legal status; was unenforceable; or who would welcome the Code having further legal power. Secondly, there were those who saw the Code as a form of "repressive legislation": too restrictive, unrealistic to achieve and, potentially, further "red tape" for farmers. Thirdly, there were some representative organisations that claim to be following stringent biosecurity procedures already and think that the advice could potentially be patronising to farmers who will feel they are being 'taught' advice that they already know.

Biosecurity Code Summary - General Comments

Within the general responses, some representative organisations consider that certain groups of people had been omitted, for example that deerstalkers and gamekeepers should be included in the Code. In addition, it was noted that horses had not been mentioned within the Code.

The best way of "getting the message across" was raised. One respondent said that the majority of countryside users were responsible, but suggested that there was a small sector that were irresponsible and, even if they read the advice, did not think it applied to them. Education was suggested as a useful mechanism for the transferring of information; improved education and training should be offered in the recognition and identification of notifiable diseases. The development of a website was a favoured idea, with further information (for example, clinical signs of animal diseases, lists of approved disinfectant, etc.) and links to related websites.

Comments were made on the format of the document. Some organisations argued that it was too long. The Code should be divided into 2 separate, stand-alone codes; one specifically related to farmers and the other encompassing advice for recreational users of the countryside and utility workers. Another representative organisation suggested 3 separate documents for Parts 1, 2 and 3.

Responses recognised that some elements of the Code were underpinned by law. Others stated that the Code lacked legal substance and was too "wishy-washy". Some representative organisations had no objection to the "stiffening" of the Code under the Agriculture (Miscellaneous Provisions) Act 1968. On the other hand, there were those who feared that the Code could develop into cumbersome legislation that would be difficult to control and would add further "red tape" to the farming industry.

A notable number of organisations believed there should be consistency and linkage between the Biosecurity Code and other Codes, for example the proposed Scottish Outdoor Access Code and the Prevention of Environmental Pollution From Agricultural Activity Code of Good Practice.

Biosecurity Code Summary - Part 1

General Comments on Part 1

There were suggestions for issues that could be included in the Code. Firstly, the danger of animal diseases spreading to humans (zoonotic disease). Secondly, the Code should highlight that animal diseases had the potential to affect environmental quality as a consequence of carcass disposal, disinfection procedures and the disposal of slurry, etc. Thirdly, there was concern that the Code did not include advice on the recommended best practice for the disposal of carcasses on agricultural land.

One respondent stated that if a farm immediately raised its standards to those suggested in the Code, the cost implications would be vast.

Comments on "Planning to Avoid Disease"

The importance of farmers having a 'farm specific' biosecurity plan was highlighted. There should be linkage of quality assurance schemes with the Code. Some such schemes followed (and had been for some time) biosecurity guidelines which were more stringent than those laid out in the Code.

The use of signposts was mentioned as a good idea to direct visitors to the farmhouse.

Concern was raised about the wording of "Discourage anyone coming onto your farm with dirty clothes or footwear". A couple of respondents thought this would cause recreational users of the countryside to feel unwelcome.

The provision of cleansing and disinfectant materials was strongly emphasised. Farm premises should have a place where water, pipes, brushes and chemicals, etc. were available, where it was easy to cleanse and disinfect yourself, equipment, vehicles, etc. The importance of cleansing and disinfecting footwear between farm visits was emphasised. If cleansing and disinfecting facilities were not readily available and easy to use, people would not bother with the appropriate procedures.

A respondent said that the advice regarding clothing / washing was more suited to an "intensive-care ward" than for animals living outdoors where wildlife roams.

The risk of dirty transport vehicles spreading animal disease was highlighted by many organisations. Although cleansing and disinfecting rules do vary for farmers and commercial vehicles, the ultimate aim was the same and the guidelines in the Code should be the minimum. In addition, several organisations commented on the importance of cleansing and disinfecting hired or borrowed equipment.

Quad bikes should be mentioned because they are a regular mode of transport for farmers. Farmers might often travel to nearby farms using quad bikes for ease. This could be a source of disease spread if such vehicles are muddy. In addition, it was stressed that quad bikes were hard to cleanse thoroughly and disinfect and this point needed to be stressed.

Several comments supported the advice to maintain stock proof boundaries. Avoiding nose to nose contact was a sensible precaution, but was hard to achieve in practice, for example, poor quality fencing on some rented land and farms.

Comments on "New Animals to Farm"

Buying from a single source (for example, tups) could restrict breeding programmes because of a limited gene pool. Rewording to "obtain stock replacements with as high a health status as possible" would be better. The Code should make it clear to purchasers of replacement stock that obtaining new animals from sources known to be free of diseases would greatly reduce the risks and the subsequent cost of controlling disease. Replacement animals should be bought from flocks with some degree of accreditation.

Advice on some "High Risk Activities" was thought to be unrealistic because, for example, it is believed to be common practice in remote crofting communities to share the use of bulls and rams. It was suggested that such animals should only be acquired if there was no realistic alternative. Another comment said that the use of hired animals should be discouraged.

The suggestion that foster animals and shared animals should be isolated and checked by a vet was deemed to be impractical and over cautious. A notable number said that foster animals should only be acquired if there was no realistic alternative. Such animals should be tested for specific diseases by a vet.

Farmers should belong to an approved livestock producers' health scheme. A call was made for the availability of animal health certificates, giving the health details of a recently acquired animal for those buying and selling animals.

Many highlighted the importance of worming animals on arrival to a farm. A good medication programme should be in place on farms to administer to new animals on arrival. The treatment of external parasites should be included.

Comments on "Feed and Water"

The advice was thought to identify the risk areas, but did not give advice on prevention, for example piped water and keeping feedstores vermin free. In addition, dogs and cats should not have access to main field bins and troughs.

Comments on "Slurry and Manure"

A number believed that the advice to store slurry and manure for at least 6 months would be hard to meet; but the results of the forthcoming Nitrate Vulnerable Zones Regulations were awaited. It was recognised by many that sharing equipment was common place and a potential source of disease spread. Suggestions included a contractor's code of good practice to clean equipment between farms.

Comments on "Records and Traceability"

Several organisations agreed that keeping accurate and up to date records of visitors and vehicles was a good form of register that could be useful in the event of disease surveillance and / or epidemiological investigations.

Comments on "Notifiable Disease"

Some respondents stated that farmers and stock keepers were already aware of the legal obligation to inform a local Animal Health Office (AHO) if a notifiable disease was suspected. Others suggested adding a supplementary list of notifiable diseases and, in an annex, a list of contact addresses and telephone numbers for Divisional AHOs.

Biosecurity Code Summary - Part 2

It was suggested that Part 2 should be omitted and readers referred to the proposed Scottish Outdoor Access Code. Recreational users of the countryside would be less likely to know about the Biosecurity Code, but there was a greater likelihood that they would be aware of the Access Code and would consult this for information.

A comment was received which suggested that Part 2 start with an explanation of how disease was spread. In addition, it should mention that stray young animals should be left alone. If stray animals were seen it would be best to report the matter to the nearest farm.

An addition of "respect signposting and ensure gates are left as they are found" was recommended. A notable number of comments emphasised that animals should never be fed and litter / left over food should never be dropped.

Biosecurity Code Summary - Part 3

There could be confusion over the meaning of the term "utility workers", referring just to those who work for the gas, power, water and telecom industries. This would exclude others who may visit farms such as agricultural representatives (who will move from farm to farm), agricultural contractors (who may not necessarily come into contact with livestock, so do not fall under Part 1), etc.

Contacting the farmer prior to a visit was a good idea, but not always possible, for example in the case of emergency visits.

The importance of signposting, at the end of a farm road / drive, was highlighted. The bullet point stressing the danger of feeding animals and discarding unwanted sandwiches and litter was commended.

Next Steps

Consultation responses have been considered and further discussion with stakeholders has occurred. The draft Code has now been revised and is currently before the Scottish Parliament.

Scottish Executive Environment and Rural Affairs Department, Animal Health and Welfare Division, October 2002.