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Scottish Executive Response to: Lessons to be Learned; Royal Society; and Royal Society of Edinburgh Inquiries into Foot and Mouth Disease
3d. REDUCING VULNERABILITY
LEGISLATION
59. The Scottish Executive has both primary and secondary legislative powers to support its animal health and welfare objectives. Much of this is heavily influenced by EU legislation which it is incumbent upon the Scottish Executive to implement. In terms of FMD the current rules set out in Council Directive 85/511 require a stamping out policy. The European Commission will shortly publish its proposals to revise the existing FMD Directive and the Scottish Executive will be contributing to its drafting via a Council Working Group.
60. Reflecting such commitments the Animal Health Act 1981 and related secondary legislation gives Scottish Ministers the broad powers to deal with the FMD outbreak. These powers were used to implement the disease control strategy of culling animals on infected premises and dangerous contacts (i.e. animals suspected of being infected, animals which had been in contact with infected animals or those believed to have been exposed to the FMD virus).
LL R77: We recommend that the powers available in the Animal Health Act 1981 be
re-examined, possibly in the context of a wider review of animal health legislation, to remove any ambiguity over the legal basis for future disease control strategies. (p163) LL R38: We recommend that provision be made for the possible application of pre-emptive culling policies, if justified by well informed veterinary and scientific advice, and judged to be appropriate to the circumstances. (p99) |
61. Dr Anderson considers that there are ambiguities with regard to the current legislation. The existing legislation is being reviewed with the aim of clarifying the legal interpretation of some powers, for example the right to enter premises. The opportunity is also being taken to examine existing legislation in the context of increased awareness of disease risks. The Scottish Executive hopes to consult shortly on proposed new animal health legislation.
Movement Controls
62. A key aspect of the Royal Society report is the recommendation that animal movements should be reduced to a minimum. This recommendation is founded on the observation that animal movements were an important vector in transmitting the FMD virus in 2001. The Scottish Executive endorses the position that movements must be reduced and is working with the industry to address the issue. The current position is reflected by a ban on market to market movements and a 20-day movement standstill.
63. The current interim movement regime has the aim of reducing the spread of disease. Should an infected animal move onto a farm, the 20-day period allows time for detection to occur before the animal, or others it may have affected, moves off the farm. It thus increases the probability of detection and reduces the potential for disease spread.
RS 5.3: DEFRA should investigate all the issues connected with reducing animal movements and come forward with practicable solutions that strike the right balance between the legitimate interests of livestock owners, market systems and long-term disease control. (p54) LL R78: We recommend that the Government retain the 20 day movement restrictions pending a detailed risk assessment and wide ranging cost-benefit analysis. (p164) |
64. The movement regime does impact on livestock farming systems by limiting the flexibility of herd/flock management. This is particularly true in Scotland given that the highly stratified nature of the livestock sector requires a significant number of movements at certain times of the year, particularly Autumn and Spring. Reflecting the importance of a movement regime in minimising disease risks and equally maintaining the commercial livestock sector, research has been commissioned to assess the veterinary risks and associated costs and benefits of different options that achieve a balance between effective control and the continuation of reasonable movements by commercial livestock farmers.
65. This research has been commissioned on a GB basis but will consider the distinctive Scottish livestock sector and the system of separation within the current 20-day regime which is able to provide - subject to specific biosecurity conditions - exemption from the whole farm standstill. Once completed the research will be used as the basis for stakeholder discussions and the development of a permanent movement regime. Whilst research has been commissioned on a GB basis, the future regime will be determined by Scottish Ministers and will reflect Scottish circumstances.
At Time of Disease Outbreak
RSE 5: A complete ban on movement of susceptible animals throughout the country must be imposed immediately an FMD case is confirmed. This may be speedily relaxed in consultation with the relevant stakeholders, including rural businesses, once the source of the disease is traced. (para 74) |
66. The draft contingency plan states that in the eventuality of a future disease outbreak a national movement ban on susceptible animals will be introduced immediately on confirmation of disease. This will be relaxed as soon as possible on the basis of veterinary advice. As the RSE suggests, the identification of the source case will be a key factor in this decision.
INDUSTRY PRACTICE
67. The industry has an important role to play in minimising future outbreaks. Whilst they have played a leading role so far, it will be important that standards continue to be raised and do not slip as the memory of 2001 fades.
Pigswill
LL R15: We recommend that the UK prohibition of swill feeding of catering waste containing meat products continue. The UK should continue to support a ban at EU level. (p49) |
68. The Scottish Executive supports this recommendation and notes that it has already been implemented in the UK. An EU Regulation banning swill feeding in the EU has been approved.
Animal Identification
LL R79: We recommend that Government develop a comprehensive livestock tracing system using electronic tags to cover cattle, sheep and pigs taking account of developments at EU level. The Government should seek to lead the debate in Europe on this issue. (p164) |
69. The importance of a reliable means of identifying and tracing animals was recognised during the 2001 outbreak. The Scottish Executive agrees with the principle of traceability and that fully electronic identification and traceability systems are the way forward and has undertaken significant work in this area. A joint SEERAD/Industry project was established in March 2000 to look at the introduction of electronic identification (EID) and use of electronic data transfer (EDT) to enhance the existing cattle traceability system. Key EDT elements have already been introduced to speed up the reporting of births, movements and deaths of cattle with built in pre-validation to reduce the opportunity for error. The next stage of the project is now underway to encourage widespread use of EDT. The project has also been assessing the performance of current EID technology against industry and legislative requirements and it is clear that technological advancements are required before implementation across the whole production chain is possible. Work is on-going with EID manufacturers to encourage further development. The views of the EU are also important as indications are that there will be EU-wide standards for EID technology used for animal ID and traceability. This will ensure compatibility of systems to encourage international trade.
70. The Scottish Executive made the decision that traceability was of such importance to the Scottish sheep industry that rather than wait for the development of suitable technology, interim measures were necessary to improve the tracing of sheep, pigs and goats. The sheep and goat system introduced in February 2002 includes the baseline tagging or tattooing of all animals, standard movement documents, the insertion of movement tags to cover specific moves, and reporting of batch movements to the Scottish Animal Movement Unit (SAMU). A similar system operates for pigs with the exception of the tagging and tattooing requirements.
BIOSECURITY
71. Biosecurity is about taking action to reduce the risk of disease occurring or spreading to other animals. It is an activity that is principally the responsibility of the livestock keepers, but attention is also required from others who come into contact with livestock. There is also an important role for the Scottish Executive in helping to disseminate good practice and help the livestock industry to enhance their practice of biosecurity measures. As such the Executive is very supportive of the key inquiry recommendations and has been working on this issue with the industry.
LL R61: We recommend that the livestock industry and government jointly develop codes of practice on biosecurity. They should explore ways to communicate effectively with all practitioners and how incentives might be used to raise standards. (p150) |
72. In March 2002 a draft Biosecurity Code of Practice was issued for wide stakeholder consultation. Over 600 representative organisations were targeted to ensure that the Code was being developed in a way that was user friendly and would ensure that the advice - driven heavily by veterinary input - would be capable of exerting a positive influence on biosecurity practice. On the basis of responses and ongoing dialogue with stakeholders the Code was revised and is in the process of receiving Scottish Parliamentary approval as a statutory Code of Practice.
73. The publication of the Code and Parliamentary approval will not be the end of the story. It is important that the biosecurity message does not fade with the memory of the 2001 outbreak and a number of pieces of work are underway to keep the agenda moving. In particular:
SAC has been commissioned to promote biosecurity advice
a biosecurity website has been developed
SEERAD is working with SAC and others to develop a biosecurity training module for use in agricultural related higher and further education courses as well as in Continuing Professional Development.
Biosecurity in Disease Situation
RSE 13: SEERAD should prepare and keep in readiness up-to-date factsheets on biosecurity to be issued to all concerned at the start of an outbreak. Every effort should also be made to ensure that standards of biosecurity, even in normal times, are raised so as to minimise the risk of any infection spreading. (para 143) |
74. The Biosecurity Code is designed for use in normal times and gives advice on reducing disease risks. However, as the RSE recognises, heightened levels of biosecurity will be required in times of disease outbreaks and the draft Scottish FMD Contingency Plan includes further biosecurity advice during a disease situation. This will be available on the Scottish Executive's Biosecurity Website and this guidance will also be posted to Scottish livestock keepers in the event of a future outbreak.
75. Recognising that biosecurity is not only the responsibility of the livestock keeper the Biosecurity Code also includes guidance to other users of farm land - e.g. walkers - and SEERAD will be working with Scottish Natural Heritage and the Access Forum to ensure that biosecurity issues will be fully reflected in the forthcoming development of the Scottish Outdoor Access Code.
Quality Assurance
LL R76: We recommend that the livestock industry work with Government to undertake a thorough review of the assurance and licensing options to identify those arrangements most likely to reward good practice and take-up of training, and how such a new system might be implemented. (p162) LL R75: We recommend that farm assurance schemes take account of animal health and welfare, biosecurity, food safety and environmental issues. (p162) |
76. In taking forward the Biosecurity Code of Practice, the Scottish Executive has been working closely with those responsible for the main livestock Quality Assurance Schemes. This has ensured that consistent messages have been sent to the industry and that as many linkages are being exploited as possible. Whilst Quality Assurance schemes are an industry responsibility, the Executive has worked with Quality Meat Scotland to include biosecurity aspects in the annual inspection. Quality Meat Scotland has also contracted its certification body, Scottish Food Quality Certification Ltd., to undertake a fundamental review (part funded by SEERAD) of the standards and procedures for all Specially Selected Scotch assurance schemes. This will include animal health, welfare and farm biosecurity issues.
RS 5.4: DEFRA should ensure that all keepers of livestock (including that not kept for food production) are properly registered and submit to DEFRA each year the name of their nominated private veterinary surgeon and a health plan approved by the same veterinary surgeon. (p54) |
77. The Scottish Executive recognises that any individual animal of a susceptible species, even one kept as a pet, is vulnerable to epidemic disease. It prefers, however, a less prescriptive approach from that indicated in this recommendation and believes that the highest priority in biosecurity is for all livestock keepers to consult regularly with their veterinary surgeon and develop, with him/her, a health plan appropriate to the individual circumstances. Such good practice is recommended in the Biosecurity Code.
TRAINING
78. Training is an important issue to help both minimise the risk of disease outbreaks and to assist preparedness. It is also good practice and the Scottish Executive is currently undertaking a review of training and education for the farming industry.
LL R60: We recommend that farmers, vets and others involved in the livestock industry have access to training in biosecurity measures. Such training should form an integral part of courses at agricultural colleges. (p148) LL R72: We recommend that colleges, universities and training organisations provide courses to equip those working in the food and livestock industries, and those owning susceptible animals, with the skills and knowledge to enable them to recognise the signs of animal disease early and take appropriate action to prevent its spread. (p161) RS R10.5: DEFRA should take rapid action to investigate and improve: the continuous professional development of farmers and stock keepers; postgraduate training in livestock health and welfare; the attractiveness of careers within the SVS the training of TVIs and LVIs by DEFRA, with the RCVS, the BVA and its species divisions, investigating the feasibility of the BCVA proposals. (p138)
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79. To complement the publication of the Biosecurity Code of Practice the Scottish Executive is developing a training module which could be used by further and higher education courses as well as continuing professional development courses. In addition to this work with the industry the Scottish Executive has also included biosecurity as a core element for the induction training of Agricultural Officers. The role of private veterinary surgeons in an emergency is being re-evaluated. Improved training for Local Veterinary Inspectors in emergency situations will be part of this process.
LL R73: We recommend that DEFRA commission a handbook for farmers on identifying and responding to animal disease, drawing on the experience of 2001. (p162) |
80. As part of the programme of biosecurity advice to farmers the Scottish Executive has developed a website which includes practical advice on identifying clinical signs of disease. It also provides contact details for reporting notifiable diseases and generally recommends a regular dialogue with their veterinary surgeon.
Veterinary Education
LL R68: We recommend that DEFRA and the Department for Education and Skills jointly explore with the veterinary professional bodies and higher education institutions the scope for increasing the capacity of undergraduate and postgraduate veterinary provision. Equivalent work should be done in Scotland. (p160) |
81. There is currently no significant shortage in the number of veterinary graduates. However, there is an issue with regard to their post-university career path, particularly in terms of numbers willing to work in large animal practices and research. The Scottish Executive, Scottish Higher Education Funding Council, DEFRA and the Higher Education Funding Council for England are currently working with the RCVS and the Wellcome Trust to develop a Strategic Alliance to enhance the numbers of researchers actively engaged in clinical veterinary education. This will have further benefits by exposing veterinary undergraduates to a research rich environment.
LL R71: We recommend that Government support a national action group charged with the responsibility of producing a plan to tackle the gaps in practitioners' knowledge of preventing and managing infectious diseases of livestock. To be effective this will need a timetable, milestones for achievement and incentives. (p161) LL R74: We recommend that training for Local Veterinary Inspectors in exotic diseases be intensified, and consolidated into ongoing training strategies. (p162) |
82. The SVS is seeking to improve the training of Local Veterinary Inspectors and their use in emergency situations. In addition the SVS is actively looking at ways of involving veterinary surgeons from other areas of employment (e.g. veterinary colleges, industry, and other parts of Government) with its work, with the aim of having joint training initiatives which, as well as developing expertise on both sides, would provide a nucleus of reserve veterinary surgeons during an emergency. SVS staff in Scotland will continue to provide training in State Veterinary Medicine for undergraduates in the Edinburgh and Glasgow veterinary schools. This covers notifiable diseases and animal welfare.
Scientific Advice
LL R34: We recommend that DEFRA's Chief Scientist maintain a properly constituted committee ready to advise in an emergency on scientific aspects of disease control. The role of this group should include advising on horizon scanning and emerging risks. Particular attention should be given to the recommendations on the use of scientific advisory committees in the BSE inquiry report of 2000. (p91) |
83. Scientific advice during an emergency is central to the decision making process for determining disease control options. In terms of infectious diseases, GB is a single epidemiological unit, and therefore the underlying science will be consistent across GB. However, animal health and welfare are the responsibility of Scottish Ministers, and the Executive will ensure that this constitutional position and the unique aspects of Scottish farming and geography are thoroughly accounted for when advice is sought. The Executive will therefore establish sound lines of communication with the Scientific Advisory Council proposed by DEFRA to provide scientific advice. This will be an advisory NDPB made up of senior and external scientists to guide DEFRA's Chief Scientific Adviser on the scope, balance and direction of the scientific effort in animal health and welfare. The Scottish Executive will take account of this advice in conjunction with advice from its professional scientific advisers and will work with, and seek advice from, relevant scientific communities in Scotland when it is appropriate to do so.
RESEARCH
84. The major part of funding for research on exotic pathogens in the UK comes from DEFRA and the BBSRC. Most of this funding is directed to the centralised specialist containment facilities at the Institute for Animal Health's Pirbright Laboratory. This is appropriate given that it minimises the risk to UK livestock and concentrates valuable expertise in one location. SEERAD's own research funding is guided by its Strategy for Agricultural, Biological and Related Research 1999-2003. Development of a new strategy will commence shortly and during this there will be considerable opportunity for other funders of animal health research to comment on the direction and co-ordination of research.
RS R10.1: The Government should undertake a thorough overhaul of research into animal disease, and in particular develop a national strategy for research in animal disease and surveillance. (p136) RS R10.3: The Government should create a virtual National Centre for Animal Disease Research and Surveillance, the Board of which would be responsible for delivering the National Strategy. (p136) LL R65: We recommend that the Pirbright Laboratory resources, and research programmes, be integrated into the national strategy for animal disease control, and budget provisions be made accordingly. (p159) |
85. The Animal Health and Welfare Strategy will identify high level/strategic research priorities for exotic and endemic diseases and will engage with a wide variety of interests in its development. The Scottish Executive is engaging in discussions with other administrations and with funding bodies to ensure that the model for delivery of this research is appropriate in form for the research needs identified by the Strategy, and efficient in its use of expensive facilities.
RSE 10: SEERAD should foster and co-ordinate the available expertise in prevention and control of animal disease in Scotland in conjunction with SHEFC and the NHS. A good starting point would be an audit of available high containment facilities where FMD research could safely be undertaken. (para 128) |
86. The Scottish Executive already has good links with the Scottish schools of veterinary medicine, with the Moredun Research Institute and the SAC, the latter two being the main SEERAD-funded organisations carrying out animal health research, and will continue to use this intellectual resource as appropriate in the future. An audit of containment facilities in Scotland was undertaken during the 2001 outbreak, building on the provisions of the Specified Animal Pathogens Order 1990 which licenses laboratories to hold pathogens.
87. Staff from the SVS in Scotland maintain close liaison with UK-wide bodies which monitor the effects of animal and human health: the UK Zoonosis Group, the Surveillance Group for Diseases and Infection of Animals and the UK Advisory Committee for Microbiological Safety of Food. These bodies are UK-wide, reflecting the relevance of their work to all parts of the United Kingdom and their membership covers a wide range of disciplines.
Funding
RS 10.4: The Government should increase investment in animal disease research and development by the order of 250M over the next 10 years. (p136) RS 10.2: The Government should draw together the current research funding in infectious diseases of animals (both endemic and exotic) within England into a single joint arrangement, the funds being made available to implement the national strategy; (p136). |
88. The Scottish Executive component of GB animal health research funding amounts to 5.4M in 2002/03. This represents around 12% of research spend by SEERAD's Agricultural and Biological Research Group. The majority of this is provided as core, grant-in-aid funding to the Moredun Research Institute and the SAC. DEFRA manages the majority of funding for Animal Health research on a GB-wide basis, of the order of 37.6m in 2001/02 rising to 38.4m in 2003/04.m pa). Any increase in funding for Animal Health Research is likely to come from this source via the outcome of SR2002.
89. The Executive will consider carefully, in consultation with DEFRA and BBSRC, the implications for animal health research in Scotland, of a single joint funding arrangement for endemic and exotic diseases. There are important consequences in this for Scottish Institutes that have a strong track record in research on endemic diseases but limited access to funding from sources other than SEERAD.
Research into Livestock Sector
RS 5.5: DEFRA should establish an Applied Research Unit on Livestock Management Practices that will undertake or commission research leading to (i) the design of effective biosecurity measures against infectious animal diseases, and (ii) the design of livestock management structures and practices that improve animal health in terms of infectious diseases. (p55) |
90. The Scottish Executive acknowledges the role that husbandry, management and farming systems can play in the prevention and control of endemic and exotic diseases. The development of SEERAD's Biosecurity Code of Practice can be seen as a symbol of the Executive's commitment to enhancing the level of attention given to biosecurity practices. Research may be commissioned as part of the programme of work to support the development of better biosecurity.
91. The Scottish Executive continues to fund research into livestock management practices through its Agricultural and Biological Research Funding Programme. This includes research into and promotion of biosecurity, veterinary surveillance and advisory services, and decision support tools. An important element is the effect of management practices on disease status.
Specific research areas: modelling
RS R6.3: DEFRA should undertake a major research programme into the potential of mathematical modelling for understanding the quantitative aspects of animal disease. Mathematical models can be used both in preparing for outbreaks (including evaluating alternative strategies) and during the course of controlling an epidemic. (p72) |
92. The Scottish Executive accepts that quantitative modelling is a valuable tool. Both its power and its acceptance would be increased if existing models were to be refined and the methodology demonstrated to the wider scientific community and public. Scottish Executive officials attended the DEFRA workshop on mathematical modelling in June 2002. This also involved representatives from Government funded Institutes, Universities and the SVS. SEERAD will be involved in developing research requirements for mathematical modelling although funding for a major research programme in this area would rest with DEFRA.
RS R3.3: DEFRA should carry out urgent research into local transmission of FMD that will improve biosecurity in the field. (p35) RSE 9: Further analysis of the role of sheep, cattle and pigs in the 2001 outbreak should be undertaken and the results published. Further studies on factors influencing the spread and survival of FMD virus strains are also required. (para 125) |
93. Biosecurity is a vital component in reducing the vulnerability of the livestock sector to disease incursion and GB-wide studies are currently being undertaken concerning the methods of local spread and the susceptible stock involved. A comprehensive epidemiological analysis of the outbreak is well advanced and will address the role of species and behaviour of the virus. The Scottish Executive is involved in taking this work forward and will ensure that the results are used to inform policy.
RS R6.2: DEFRA should commission research to improve the methodology used to identify dangerous contacts. (p72) |
94. As noted in paragraph 82 above, a major review will shortly be undertaken of animal health and welfare research needed to support the development of the Animal Health and Welfare strategy. This recommendation will be taken forward in this context.
INFORMATION
95. The Scottish Executive acknowledges that IT was not used in a seamless fashion during the FMD outbreak although the Lessons Learned Inquiry indicated that effective use of our computer systems and links was a factor in our relative success. There was, however, incompatibility between the main systems used by the SVS and SEERAD, and some databases and spreadsheets which had been designed for non-emergency situations proved unequal to the demands placed on them. These problems were identified in the internal management review undertaken for the Scottish Executive and work is in hand to rectify them. The improvement of management information systems for veterinary matters and disease control will be overseen by the SVS Management Board.
LL R20: We recommend that DEFRA lay out milestones for investment and achievement for improved management information systems. (p73) LL R21: We recommend that data capture and management information systems be kept up to date and reflect the best practice.(p73) LL R23: We recommend that standard definitions of all important parameters of information be agreed in advance. (p73) |
96. The overall approach taken by the Scottish Executive will be to link databases as far as possible so that any applications can have access to a seamless integrated set of data. Standard definitions of all types of input information will be vital to this process. It is also important that data quality is maintained; information relevant to agricultural matters, such as holdings data and animal census information, can change rapidly. The Executive accepts Dr Anderson's recommendation on data capture and is currently working to ensure that there are effective links between its main databases and the SVS system, Vetnet.
RS 3.2: DEFRA should undertake a comprehensive review of the available information on FMD and develop a consistent and coherent database of the basic information that would be required during an outbreak. (p35) LL R5: We recommend that the Government build an up to date database of livestock, farming and marketing practices. This should include research to examine the evolution of regional livestock stocking densities and implications for disease risk control. (p30) |
97. The Scottish Executive fully accepts that a coherent central database, including not only disease control data but also livestock, farm business and geographical data would be of great value in supporting a wide range of functions. Work is going on in Scotland to harmonise different sources of data and create linkages to existing databases.
LL R18: We recommend that use be made of alternative sources of information and intelligence during crises. (p71) |
98. The Scottish Executive accepts that a wide range of sources of information would be of value in a disease emergency. The Contingency Plan provides for stakeholder input across the board and envisages that detailed local information would be channelled to the disease control effort via links with local stakeholders.
LL R19: We recommend that DEFRA's Geographical Information System and the Integrated Administration and Control System (IACS) be designed so that they can be used more effectively for disease control purposes. (p72) RSE 6: An appropriate GIS system should be established detailing land use, livestock numbers and other information relevant to disease control. Furthermore uniform standards in database design and data handling protocols should be established. (para 94) |
99. Experience during the outbreak has confirmed the Scottish Executive's view that a Geographical Information System and its associated mapping capabilities is an invaluable tool for all levels of decision making. Work on developing and accessing an effective GIS for disease control purposes across GB is ongoing and the Scottish Executive is closely involved with this In parallel, the Executive recognises that locational data is intrinsic to many of its functions and is progressing a Scotland-wide GIS strategy to support work across areas of devolved responsibility.
RS R6.4: DEFRA should ensure that the data from the 2001 epidemic are checked and then made widely available, while ensuring that any data protection issues are resolved. (p72) |
100. The Executive therefore accepts these recommendations and will be playing its part in implementing them. However, data protection issues arising from the EU IACS regulation and from the Data Protection Act (DPA) are a barrier to rapid implementation. IACS data has been collected for subsidy purposes, and not for disease control reasons. During the outbreak these issues were overcome because the wording of the EU legislation allowed that to happen, but there are concerns that to use IACS data during non-disease periods would not respect the data protection conditions. This issue is currently being taken forward.
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