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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
3e. MINIMISING IMPACT
Contingency Planning
101. Contingency Planning was a key theme of the Inquiries' reports. The Lessons to be Learned report acknowledged that there was considerable experience in Scotland at the local level of animal health contingency planning. Each Animal Health Divisional Office had its own plans which were regularly rehearsed. It was expected that on average in any 2 year period each Division would have undertaken its own rehearsal involving key local public sector organisations - e.g. police, local authorities, Scottish Environment Protection Agency (SEPA.)
102. Whilst those plans were broadly effective in assisting the Scottish response, the Executive's evidence to the Lessons Learned Inquiry also made clear that there was much more that could be done for the future - particularly in terms of developing a contingency plan and increasing stakeholder involvement. Work in these areas is ongoing. The Scottish Executive published a draft contingency plan in June 2002 and the responses to the 3 month consultation exercise are currently being taken on board - in parallel with a series of stakeholder discussions. Local plans are also being revised and these will be taken to stakeholder consultation in each of the Animal Health Divisions.
Overall Policy Direction
LL R81: We recommend that DEFRA develop further its Interim plan, published in March 2002, in full consultation with all interested parties. Its relevance should be maintained through agreed programmes of rehearsal, practice, review and reporting. This work should be given priority for funding. (p165) RS 9.4: The detailed strategies for controlling outbreaks of livestock diseases should be included in the published contingency plan, which should consist of an umbrella plan for matters that are common to all diseases, with specific modules for each disease. These plans should be rehearsed in an annual "fire drill" that must be realistic and involve DEFRA and all other relevant bodies including MoD. (p125) |
103. The Scottish Executive is continuing to develop its contingency plan, fulfilling its responsibility for emergency planning and preparedness. It is currently being revised in the light of stakeholder comments and the Inquiry Reports and a revised Plan will be published towards the end of the year. Whilst aiming to keep the plan focused and suitable to its purposes of guiding action in an emergency situation it will include as much information as possible to alert people as to what will happen in a disease situation - e.g. introduction of a movement ban.
Rehearsals
RSE 23: At least once a year a practice exercise should be undertaken at which there is a mock outbreak at a site not revealed until the start of the exercise. This would require all those involved to act as they would in a real outbreak as a means of testing their effectiveness and the suitability of the organisational structure. (para 216) RSE 26: The Scottish Executive should review the emergency plans of all Scottish Councils to ensure that they adequately cover the action required in the event of an FMD outbreak; and all Councils should up-date their plans if that has not already been done. Such plans should be reviewed annually in the light of developments in science and consequential changes in policy. (para 224) |
104. The Scottish Executive fully supports the view that regular rehearsals are important. This ensures a familiarity between key players which can be vital in any 'real' response. They are equally important in identifying practical problems and ensuring they are resolved.
105. Before the contingency plan is finalised, a programme of rehearsals at the national and local level will be developed, allowing stakeholder views to be fed into the national and local plans and allow organisations such as local authorities to revise their own plans. The first exercise will be conducted in 2003. These rehearsals will take place in the wider context of emergency preparedness exercises undertaken by local authorities, the Emergency Services and other operational partners such as the emergency services. Dr Anderson highlighted this background and awareness as a distinctive factor in supporting the effective Scottish response to the 2001 outbreak.
Blue Box
LL R62: We recommend that the use of Restricted Infected Area ('Blue Box' biosecurity arrangements) procedures be built into contingency plans. (p160) |
106. The Scottish Executive supports the adoption of a "Blue Box" approach in the event of a future disease outbreak. The Blue Box would introduce a heightened set of biosecurity conditions in an area around an infected premise. It would require increased levels of cleansing and disinfection on all movements on and off farm as well as through the area. It would also close the parts of footpaths that fall in the immediate area. An evaluation of the scheme showed that it was effective in reducing the risk of mechanical spread of the FMD virus. The Blue Box will be a core component of any future response and the Executive is currently discussing its implementation with stakeholders.
Training
LL R43: We recommend that training for those with responsibility for managing disease control include the relevant legal frameworks and the structure and responsibilities of local government. (p112) |
107. The Scottish Executive fully accepts that training is fundamental to an efficient disease response. In Scotland, regular two-way training with the SVS and local authority staff has been a longstanding practice and has ensured an effective joint approach to animal disease control. The Scottish Executive will also be developing a training programme for key non-veterinary disease control managers to allow them to fulfil their duties.
Reporting
RS 1.1: The UK Government should bring before Parliament for debate a framework for the Contingency Plans covering the principles involved in handling outbreaks of infectious exotic diseases and the resources required for their implementation. (p1) LL R11: We recommend that the government publish a biennial report to the nation on the level of preparedness to tackle animal disease emergencies. The first report should be published in 2003 and include measures of achievement against goals. (p39) RSE 27: To ensure that contingency planning at all levels is kept up-to-date and takes account of the latest developments, the Minister in the Scottish Executive with responsibility for animal health, should establish an independent standing committee to monitor this work and to assess the effectiveness of mock exercises. (para 225) |
108. The Scottish Executive accepts the principle of these recommendations and will ensure that the results of the disease surveillance programme are adequately disseminated to the industry. In particular, an annual report on the international and the GB disease position will be made to the Animal Health and Welfare stakeholder group.
109. It is imperative that the contingency plan is kept as a living document. In process terms the Animal Health Division will be responsible for regularly reviewing the finalised plan and ensuring that it is kept up to date in terms of key changes in the external environment - e.g. personnel changes; changes in legislation or environmental risk assessments as well as industry practice.
110. Any such changes will be reported to the Department's Animal Health and Welfare stakeholder group who will also review the plan at least once a year. The report will also be sent to the Scottish Parliament's Rural Development Committee and be placed on the Executive's website. In addition to reporting any key changes affecting the plan, the Scottish Executive will also report back on the conduct of regular contingency planning exercises.
Scenario Planning
LL R6: We recommend that contingency plans set out procedures to be followed in the event that an emergency expands beyond worst-case expectations. (p36) |
111. Work is being taken forward to identify possible disease scenarios. This will be informed by the analysis being undertaken on movement controls. The scenarios developed will be published.
Resources
LL 10: We recommend that Government Departments ensure that their own internal Departmental arrangements properly resource contingency planning work. This should be monitored by the National Audit Office. (p39) |
112. The Scottish Executive fully endorses the comments from Dr Anderson that a contingency plan must be capable of being delivered and will ensure that these principles are reflected in its development of emergency preparedness. The Scottish Executive is considering carefully the resources needed at all stages of the Plan. This will be influenced by the scenario planning work and especially the needs of the worst case scenario. The deliverability of the plan will also be regularly tested - at both national and local levels - by regular rehearsals. Resourcing issues will be considered on a regular basis to reflect organisational and other changes and will be included in the annual report to the Animal Health and Welfare Stakeholder Group.
COMMUNICATIONS
113. Communications is an area in which the Scottish Executive considers significant improvements could take place. Communicating in a disease situation is not straightforward, with a number of particular interest groups needing to be informed in what is often a rapidly changing environment.
A Strategy for Communications
RSE 25: A comprehensive review should be undertaken into the most effective means of communication to those concerned in the event of an outbreak and the appropriate mechanisms incorporated in the Scottish contingency plan. (para 221) LL R54: We recommend that a government-wide crisis communication strategy be developed by the Civil Contingencies Secretariat with specific plans being prepared at departmental level; for example by DEFRA and the devolved administrations in Scotland and Wales in the context of animal disease control. (p142) LL R57: We recommend that DEFRA commission research into the effectiveness of its direct communications during the FMD outbreak of 2001 so that all the lessons may be learned, acted upon and the results published. (p144) |
114. The Executive accepts that communication is a particular area where improvements can be made. Building on the experience of 2001 and the spirit of these recommendations, the Executive is commissioning a communications specialist to produce a communications strategy to assess the needs of individual stakeholders and the capabilities of resources. Stakeholders will be involved in the development of the Communications Strategy, which will be published alongside the Contingency Plan. It will be kept under review.
Communications Resource
LL R53: We recommend that the government build into contingency plans the capacity to scale up communications systems and resources rapidly at the onset of any future outbreak of animal disease. (p142) |
115. The importance of being able to scale up the communications resource at the earliest opportunity is acknowledged. The draft contingency plan identifies that members of the Scottish Executive's Press Office will be dedicated to supporting the disease control response at both headquarters and local level. This will be reviewed in the light of the externally developed communications strategy.
Website
LL R56: We recommend that DEFRA resource its website to ensure that it is state of the art operation. In any future outbreak, the website should be used extensively, and a central priority should be to ensure that it contains timely and up to date information at a national and local level. (p144) |
116. The Scottish Executive accepts the principle behind this recommendation and will be further developing its own systems. The corporate website used by the Scottish Executive (www.scotland.gov.uk) is a further point on which there is significant scope for improvement. This is being reviewed as part of the Executive's plans to improve access to information by overhauling the structure and content of its website. The communications strategy research will also consider how it could be most effectively be used in any future disease situation.
International Media
LL R59: We recommend that communications strategies during a crisis take special account of the needs of the International media. (p147) |
117. The international media paid considerable attention to the outbreak and this had a significant effect on influencing a number of potential visitors against coming to Great Britain. As such the Scottish Executive accepts this recommendation and will work alongside other Administrations and agencies - e.g. British Tourism Authority, visitscotland - to ensure that an accurate picture of events is received outside, as well as within, the country.
Keeping Stakeholders Informed
LL R37: We recommend that in order to build support steps always be taken to explain the rationale of policies on the ground, particularly where implementation is likely to be controversial. Wherever possible, local circumstances should be taken into account without undermining the overall strategy. (p98) LL R50: We recommend that government make explicit the extent to which the wider effects of disease control strategies have been identified, measured and taken into account in policy decisions. (p137) |
118. ,This recommendation is accepted and should be set alongside general issues relating to keeping stakeholders informed. The draft Contingency Plan explains that stakeholder groups will be set up to facilitate a two-way dialogue between the Scottish Executive and the industry. Such communication was vital in 2001 in delivering the effective partnership which characterised the Scottish response (and was highlighted by the Lessons to be Learned report).
INSTANT RESPONSE
119. The inquiries were unanimous in stressing the importance of an immediate response to the outbreak to prevent it turning into an epidemic. As such the Scottish Contingency Plan is designed to scale up resources sooner rather than later.
RS R9.1: The main objective in dealing with an outbreak must be to ensure that it does not develop into an epidemic. This requires the following basic measures: on suspicion of an outbreak: on confirmation by an OIE Reference laboratory of an outbreak: mobilisation of the full emergency arrangements including all the additional logistic resources and the interdepartmental co-ordination and scientific advisory structure; imposition of a total country-wide ban on animal movement with unambiguous and widely publicised advice on the fate of any animals in transit; rapid culling of all infected premises; identification and rapid culling of all premises where there is a high risk of the disease
Where these measures are insufficient to guarantee that the outbreak will be contained, we recommend in addition the early deployment of emergency vaccination. (p125) LL R16: We recommend that in all suspected cases of FMD, the response reflect the experience of the emergency services, where speed and urgency of action govern decision making. (p61) LL R33: We recommend that contingency plans provide for early appointment of regional Operations Directors or their equivalent to take on operational management of a crisis. There should be a cadre of senior managers - not all of whom need to come from central government - who can fulfil the role of the Regional Operations Director in an emergency and who should be trained in advance. (p87) |
120. The draft Scottish Contingency plan addresses the key issues identified by the Royal Society. As soon as samples from a suspect case are sent away for confirmation, the Disease Strategy Group will be created to advise the Minister for Environment and Rural Development on the Scottish Executive's response. In particular the DSG will ensure that appropriate legislation to introduce a movement ban and the Blue Box is ready to be used. In addition they will ensure that the Regional Operations Director is sent to the affected Animal Health Divisional Office to support the local Divisional Veterinary Manager. The Scottish Executive agrees that those who can fulfil the role of Regional Operations Director should be identified and trained in advance; and it has this in hand.
Mobilising Wider Resources
LL R39: We recommend that a mechanism be put in place at the centre of Government to assess potential domestic civil threats and emergencies and provide advice to the Prime Minister on when to trigger the wider response of Government. (p102) LL R8: We recommend that DEFRA develop its human resources plans for use in emergency. In particular they should focus on how staff numbers and expertise can be rapidly increased at a time of crisis. This should be developed in England in consultation with the Cabinet Office, the regional Co-ordination unit and the network of Government Offices. Similar arrangements should be developed in Scotland and Wales. (p36) LL 30: We recommend that, as part of its contingency planning, DEFRA, the Scottish Executive and the National Assembly for Wales, working with the Civil Contingencies Secretariat, examine the practicality of establishing a national volunteer reserve trained and informed to respond immediately to an outbreak of Infectious animal disease. (p82) |
121. The Executive's internal management review recommended that the Scottish Executive develop an emergency cadre of staff who could be deployed to an emergency situation to support existing staff in that area. The Management Group of the Scottish Executive strongly supports the development of such a cadre and this work is currently being taken forward. In doing so, the Executive will maintain close contact with the Cabinet Office Civil Contingency Secretariat, which is undertaking similar work for the UK government, to ensure the exchange of best practice.
LL R7: We recommend that provision be made in contingency plans for rapid prioritisation of a Department's work in the face of a crisis, and for speedy reassignment of resources. (p36) |
122. This recommendation is accepted. The ability of individual parts of the organisation to release staff will vary across the year. Reflecting this, in the eventuality of a requirement to initiate the emergency cadre of staff, the relevant head of department will discuss requirements with his Management Group colleagues who will identify staff who can be released from their area.
LL R17: We recommend that the State Veterinary Service consider forming a National network of 'flying squad' teams capable of responding to an alert. The continuing occurrence of false alarms can then be used constructively to maintain readiness and to practise routines. (p61) |
123. The national and local contingency plans set out a clear list of roles and responsibilities for those involved in responding to a suspect case. As Dr Anderson notes experience is a valuable learning tool and any learning opportunities from false alarms will be taken forward. This has already happened from a small number of scares in 2002 and as a consequence, for example, a new system of internal notifications has been developed.
Military Involvement
LL R29: We recommend that, as part of the mechanisms to trigger the wider Government response, the military be consulted at the earliest appropriate opportunity to provide advice and consider the nature of possible support. (p82) |
124. The army played an important role in the logistics of the disease control effort in 2001. The draft Contingency Plan, which has been discussed with the army, explains that the army will be notified as soon as a case is confirmed and will be kept in touch with the disease control position in case their input is required. However, no approach will be made to the UK Government to provide military assistance until there is a clear role for them to fulfil.
Local Volunteers
LL R24: We recommend contingency plans at a regional level include mechanisms for making effective use of local voluntary resources. (p74) |
125. Local voluntary groups played an important role in supporting the response to the 2001 outbreak, particularly in terms of non-disease control issues such as providing welfare support to those affected. Local contingency plans will outline the roles and responsibilities of posts in the local Disease Emergency Control Centre and the personnel officer will act as a contact point for organisations wishing to offer their services. If not relevant to the direct disease control activity the personnel officer will act as a signpost to where such resources could be used.
Diagnosis
126. During the 2001 outbreak, field vets were faced with a situation of rapidly moving disease. Clinical diagnosis was made more stressful by the knowledge that other conditions could cause similar symptoms, and that a positive diagnosis would trigger measures on contiguous premises and in Scotland, premises within the 3km radius. These pressures were exacerbated by the subclinical nature of symptoms in sheep. Laboratory diagnostic tests, even those based on the ELISA (Enzyme Linked Immunosorbent Assay) technique, took time.
127. The Scottish Executive recognises the pressures on field vets during the epidemic when rapid and accurate diagnosis was needed in order to bring in effective control measures. The Executive therefore welcomes the attention given by all three Inquiries to the issue of how progress in diagnostic techniques can assist the clinician in making a rapid and robust diagnosis and thereby limiting the spread of the disease
LL 36: We recommend that the State Veterinary Service be routinely equipped with the most up-to-date diagnostic tools for use in clinical practice, to contribute to speed and certainty of action at critical times. (p95) |
128. The Scottish Executive accepts the recommendation that up to date diagnostic tools should be made available to clinical practitioners. If more rapid and robust diagnostic methods had been available in the 2001 outbreak it would have significantly reduced the burden on vets.
RS 7.5: DEFRA should consider the benefits of bringing responsibility for all list A diseases under a single organisation. (p84) |
129. The Scottish Executive will liaise with DEFRA in creating the organisational structure suitable for all list A diseases.
International Co-operation
RS 7.1: DEFRA should consult with other member states to ensure that the OIE is appropriately constituted to validate new diagnostic techniques and reagents as rapidly as possible; and that OIE reference laboratories are supported politically and financially so they can better undertake their national and international obligations, including the development of diagnostic tests. (p84) |
130. The Scottish Executive supports the principle of properly resourcing designated national reference laboratories. In the UK this is IAH Pirbright which also acts as an OIE reference laboratory. In terms of ensuring that OIE is in a position to validate new techniques, the Executive would normally contribute to discussions which would form the UK agreed position. EU Member States are members of OIE, and therefore have a mechanism whereby they can contribute to OIE decisions.
New Tests
RS 7.2: DEFRA should ensure that sufficiently specific and sensitive pen-side antigen detection ELISAs are developed for FMD and other major diseases, are validated as quickly as possible, and are available on a large scale for use in the field, and that a similar ELISA is developed especially for detecting antibodies in sheep. (p84) RS 7.3: DEFRA should explore the potential for portable RT-PCR machines for use in the field or at regional laboratories. (p84) RS 7.4: DEFRA should develop advanced telecommunications between the field and central control. (p84) RSE 3: In view of the clear advantages they offer, SEERAD in consultation with DEFRA, Pirbright and interested commercial organisations should as a matter of the highest priority make resources available for the development of improved tests for the detection of FMD, especially RT-PCR; and that they should give similar priority to support the development and evaluation of on-farm tests for the detection of virus or viral components
. (para 62) |
131. The Scottish Executive agrees that a validated field FMD penside test, which was not available in 2001, would assist in diagnosis. Funding proposals for newer diagnostic techniques, including extended ELISA and RT-PCR, are currently being considered. The Scottish Executive supports this approach.
Scottish Testing Laboratory
RSE 2: SEERAD should identify a regional laboratory in Scotland to undertake diagnosis of FMD using tests where live virus is not required. The latter should remain the responsibility of Pirbright. (para 61) |
132. The Scottish Executive accepts that it is desirable to establish a serology laboratory in Scotland equipped to conduct tests on non-live virus samples in contained conditions. Work is already well advanced on this. A new building that will house the laboratory has been constructed at the SAC facility in Dumfries. Preparation of the fitting out of the laboratory and ancillary services, involving SAC and the State Veterinary Service, is under discussion with a view to establishing this laboratory in the current financial year.
VACCINATION
133. Vaccination is a complex subject, with a number of technical, trade, legal and consumer issues needing to be considered. Whilst not used in 2001 it was considered as part of the disease control strategy and is included in the draft Contingency Plan. Reflecting the complexities involved, the Scottish Executive is particularly grateful to the Royal Society for the clear way in which the issues were explained and for setting out a possible path for their resolution.
RS 1.3: The UK should continue to strive for "disease-free" status against highly infectious diseases such as those listed in the OIE's List A. (p5) RS 1.4: Providing the level of international threat does not increase; there are improved import controls; and there is a demonstrable improvement in the arrangements for handling disease outbreaks, the UK should not adopt a policy of routine vaccination, and should retain the internationally recognised status of "disease-free without vaccination". (p6) |
134. The Scottish Executive accepts these recommendations and notes that they formed the basis for the disease control strategies invoked in the 2001 outbreak. The Royal Society does, however, raise several important caveats and the need for international surveillance, import controls and contingency planning is discussed in more detail below.
Vaccination and Contingency Planning
RS 8.2: Emergency vaccination should be seen as a major tool of first resort, along with culling of infected premises and known dangerous contacts, for controlling FMD outbreaks. This policy should be vaccinate-to-live, which necessitates acceptance that meat and meat products from vaccinated animals enter the food chain normally. (p105) |
LL R48: We recommend that the Government ensure the option of vaccination forms part of any future strategy for the control of FMD. (p129) LL 49: We recommend that the State Veterinary Service maintain the capability to vaccinate in the event of a future epidemic, if the conditions are right. (p129) RSE 8.1: That UK contingency planning for future outbreaks of FMD incorporates emergency protective vaccination (ring or barrier) as an adjunct to slaughter of clinical cases and dangerous contacts. (para 122) |
135. The Scottish Executive accepts the unanimous recommendation of all three main Inquiries that emergency vaccination to live should play an important role in any future set of disease control options. These options will include, as in the 2001 outbreak and as required by EU rules, the culling of animals on infected premises and dangerous contacts. This work is being taken forward and a call off contract is currently in place to provide a vaccination resource should it be required. The Executive is however aware that there are significant downstream technical and trade issues which must be resolved before this can be implemented in the spirit intended by the Inquiry Reports. These issues are detailed in the following set of recommendations.
Issues to be resolved:
LL 47: We recommend that the Government establish a consensus on vaccination options for disease control in advance of an outbreak. (p129) |
136. The Scottish Executive accepts that a consensus on vaccination options would be valuable and is seeking to promote an informed debate among Scottish stakeholders. This will be achieved by engaging in discussions with industry, retailers, consumer groups and regulatory bodies and also by exercising and rehearsing the Contingency Plan with other agencies, under scenarios which involve vaccination. In these discussions, the Executive will highlight both those shorter term issues such as the design of vaccination strategies and the appropriate trigger points for implementing them and also the longer term barriers relating to trade and consumer acceptability which will need to be addressed on a wider basis.
RS 8.3: In determining the arrangements for deploying emergency vaccination, DEFRA should: take account of the urgent need to achieve validation for field use of the tests that discriminate infected from vaccinated animals; develop emergency vaccination strategies that integrate theoretical and empirical epidemiology and the logistics of delivery of vaccine cover; establish an exit strategy that takes account of the need for on-going surveillance, safeguards for those involved and agreement that products from vaccinated animals can enter the normal human food chain; (p105)
RSE 8.4: That the Government urges the OIE to validate tests that distinguish animals vaccinated against FMD from those that have been exposed to infection. (para 122
) RSE 4: SEERAD should, in consultation with DEFRA, press for early adoption of tests that can discriminate FMD vaccinated from FMD infected animals to facilitate emergency vaccination in dealing with future outbreaks of FMD. A regional laboratory in Scotland could carry out those tests that do not involve the use of live virus. (para 66) |
137. For vaccinated products to be acceptable it must be possible to differentiate vaccinated animals from those exposed to infection. This is agreed by the Scottish Executive to be a key area and we will be monitoring the research being undertaken on this subject in the UK, EU and the USA on validation of tests that will achieve this. The Executive will not demand that such tests be done in a Scottish laboratory as depending on circumstances the use of the GB scientific resource may be more appropriate.
138. The Scottish Executive agrees that a range of emergency vaccination strategies should be developed which are based on epidemiological analysis and are logistically credible, noting particularly that these must include decision or "trigger" points to establish when emergency vaccination becomes appropriate. This process is integrated into the Contingency Plan where a range of scenarios and plans will be tested on the ground in practical exercises and then reviewed and updated.
RSE 7 The Food Standards Agency should give public reassurance on the consumption of milk products and meat from vaccinated animals and should do so at a time, not of crisis, but when it is able to be dealt with as a routine issue in relation to imported meat already consumed in Europe. (para 109) |
139. During the outbreak, the Food Standards Agency issued clear advice to consumers that there are no public health issues associated with eating food derived from vaccinated animals. This is supported by the Royal Society's finding that concerns over the safety of products from vaccinated animals "have no foundation". If further consumer concerns are raised, the Agency will again ensure that authoritative advice on risk is issued. The Scottish Executive considers that wider consumer acceptability of food products from vaccinated animals is a key issue to be resolved and, in line with existing Agency advice, will work with stakeholders to develop greater public understanding.
RSE 8.2: The Government should ensure that vaccine manufacturers are involved in developing a national strategy for adequate production of emergency vaccine. (para 122) |
140. The Scottish Executive accepts the Royal Society of Edinburgh's recommendation for a national strategy for production of vaccine involving manufacturers. The Executive will be collaborating with other UK administrations in taking this work forward.
Other Diseases
RS 9.3: DEFRA should review its arrangements for other diseases, and in particular the developments required to enable emergency vaccination for CSF and bluetongue. (p125) |
141. The Scottish Executive agrees that control strategies, including vaccination, should be reviewed for other diseases and will ensure that the spirit of this recommendation is incorporated into its own plans. The FMD Contingency Plan is being developed to widen its applicability to other disease and this will include consideration of the appropriate circumstances for the use of vaccination.
Zoos and Rare Breeds
RS 9.2: As a matter of urgency, DEFRA should draw up arrangements for a process for the prior registration for vaccination of zoos and rare breed collections. (p125) |
142. The Scottish Executive accepts that zoos and rare breed collections should be registered for vaccination and will be contacting the relevant organisations to implement this.
Return to Disease free status
RS 8.4: DEFRA should explore with the EU and OIE what improvements to vaccines and surveillance tests are required to allow disease free status to be based entirely on surveillance results without the requirement for a minimum waiting period. (p105) RSE 8.3: We recommend that the Government presses the European Commission to clarify its policy on the tests and evidence required before exports of livestock and livestock products from a member state that has had the disease can be resumed to other member states. These rules should be no stricter than those applied to other countries. (para 122) |
143. The Scottish Executive accepts the desirability of a clearly defined exit strategy. (also see above, recommendation RS 8.3, last point). However the Executive does not at present support a surveillance only approach to regaining export status. One country's export is another's import, and given the disastrous consequences of disease introduction, the Executive believes that a combination of serosurveillance and a waiting period remains the safer balance between economic advantage and risk of disease introduction. The OIE decision to reduce the waiting period (after stamping out and serosurveillance using the non-structural protein test) from 12 to 6 months is welcomed as an appropriate first step.
Prophylactic vaccination
RS 8.1: The Government should take the lead in developing an international research programme aimed at an improved vaccine that would permit routine and global vaccination of livestock against FMD and other List A diseases. (p105) |
144. The Executive does not under present circumstances accept the priority given by the Royal Society to research on developing a routine and global vaccination against FMD. While prevention is proverbially better than cure, there are significant technical problems of creating a vaccine to be effective against the large number of known FMD serotypes. Equally significant and wide ranging are the EU and international trade policy issues which would have to be resolved. Realistically this recommendation would divert resources from shorter term and more realisable goals. The review mechanism of the GB Animal Health and Welfare Strategy will identify any major policy or scientific advances that would make this recommendation more viable and allow it to be reprioritised as appropriate within the strategy.
Slaughter
145. all the Inquiry reports have recommended that slaughter of animals on infected premises and dangerous contacts should remain at the heart of a response to stamping out a FMD outbreak.
LL 28: We recommend that DEFRA revise its guidance and instructions for slaughter. (p78) |
146. The Scottish Executive accepts this recommendation and in conjunction with DEFRA and the National assembly for Wales is reviewing slaughter guidelines.
Disposal
147. Disposal is a key step in any disease control process to ensure that any risks to animal or public health are minimised. As such it must be undertaken quickly which requires a considerable logistical exercise.
RSE 18: The following priorities should be followed for disposal of carcasses: Rendering plants should be considered as the first option but only where the transfer of carcasses can be guaranteed to be within sealed containers to minimise the risk of transferring infection to other premises and stringent disinfecting regimes applied to the transport used. Burial on site should be used where there is inadequate rendering capacity provided there are no risks to water resources.
Burning should be used only as a last resort. (para 170) RSE 20: The Scottish Executive, in consultation with relevant bodies, should give priority to identifying large burial sites throughout Scotland. (para 175) LL R42: We recommend that burning animals on mass pyres is not used again as a strategy for disposal. (p108) |
148. As part of the finalisation of the contingency plan the Executive will be working closely with disposal stakeholders to ensure that the disposal hierarchy:
rendering
incineration
landfill
burning
burial
is capable of being appropriately utilised.
149. The Scottish Executive has no desire to see mass pyres, but burning on infected premises will continue to be included in the disposal hierarchy given the importance of ensuring quick disposal of carcasses to avoid potential public health risks and recognising the remoteness of some Scottish locations. However, burning would be among the last of the disposal options.
LL R45: We recommend that local communities be consulted on mass disposal sites according to best practice guidelines, and that the question of compensation for communities accommodating emergency disposal sites be researched. We recognise that this is a complex legal area nationally and at EU level. (p114) |
150. Local contingency plans will be taken to consultation with local stakeholders and community interests. Disposal will be one of the issues that they consider as part of the emergency preparedness process. In addition in a disease outbreak should emergency disposal sites be required the Regional Operations Director will ensure that community and other local concerns are weighed against other factors in any decisions which are made and that health and safety and environmental requirements are met. Extensive publicity and information on any mass burial site would be distributed locally. The Scottish Executive does not believe that such consequential compensation should be paid as a matter of course. This is likely to be significantly bureaucratic and difficult to administer in determining who should be compensated and the level at which the payment should be set; and it is not clear that there is any general principle which would justify the payment of taxpayers' money in circumstances where an emergency has imposed a temporary - if unpleasant - inconvenience on a local area.
COMPENSATION
151. The loss of livestock is a financial as well as emotional blow to their keepers. Reflecting the rationale of the stamping out policy as being to prevent further spread of disease Government is obliged to compensate farmers for their losses of stock.
RSE 21: A clear strategy for dealing with the valuation process should be in place and a current list of competent valuers held by SEERAD. An annual review should also be considered to establish stock values and those values should be adhered to throughout any future outbreak. (para 191) |
152. Compensation payments have been reviewed in light of the 2001 outbreak. As part of this process we are moving to a list of valuers approved on the basis of their qualifications and experience in livestock valuation. Applications have been invited from known valuers and the resulting list will be published. In addition we are also moving into the process of appointing a panel of senior monitor valuers whose role will be to review the instructions and guidance to valuers and agree on additional ones which may be required during an outbreak. They will also review our valuations in any disease outbreak.
LL R80: We recommend that the joint DEFRA Industry Working Group for Animal Disease Insurance ensure that its scope and membership is set widely enough to address valuation and compensation issues highlighted by the 2001 outbreak. Clear deadlines should be set for reporting progress. (p165) |
153. It is important that the industry is fully involved in the development of any changes to the compensation position. The Scottish Executive is represented on the DEFRA led working group and supports their acceptance of the recommendation to widen membership. Scottish Ministers wil be responsible for future decisions regarding valuation and compensation in Scotland.
MANAGEMENT CONTROLS
154. Financial management was the main focus of the National Audit Office report and the Scottish Executive fully endorses the importance of sound financial management supporting the disease control response.
LL R25: We recommend that dedicated control systems be ready for use in a sustained emergency, and regularly tested as part of the contingency planning process. (p74) LL R26: We recommend that the processes for procuring and delivering the necessary goods and services from external sources during a crisis be reviewed. Systems should be tested to ensure they can cope with unexpected increased demands. (p74) LL R27: We recommend that priority be given to recruiting accounting and procurement professionals to operate in emergency control centres during a crisis. (p74) |
155. Reflecting the recommendation, procurement issues are being fully developed in instructions readily available to those involved in the responses. A dedicated procurement officer will also be appointed to the local DECC.
Records Management
LL R35: We recommend that from day one of an outbreak, provision be made to keep a record of all decisions made and any action to be taken. (p93) |
156. The Scottish Executive accepts this recommendation and the revised national contingency plan and local plans will include an officer tasked to records management. The Executive adopted this approach to recording the decisions of the Disease Strategy Group in the 2001 outbreak.
ANIMAL WELFARE
LL R46: We recommend that the Government consider the welfare implications of disease control policies, as part of contingency planning for FMD and other diseases, and seek to identify strategies that minimise the need for slaughter and disposal on welfare grounds. (p119) |
157. The Scottish Executive accepts this recommendation and will keep animal welfare under consideration when planning the implementation of slaughter polices and animal movement restrictions.
PUBLIC HEALTH
158. The FMD virus almost never affects humans and the disease does not therefore pose a threat per se to public health. The 2001 outbreak did however create concerns over the effect of the control measures on public health, particularly via environmental routes. (See Slaughter and Disposal section above.) In public health terms there were fears that paradoxically, the cure could be worse than the illness. The Scottish Executive, which has devolved responsibility for health, was aware of these concerns and welcomes Dr Anderson's conclusion that "the risks to the environment and public health associated with disposal have been shown to be minimal".
LL R44: We recommend that all agencies with responsibility for public health be actively involved in designing disease control strategies and in contingency planning and communications. (p112) RSE 24: SEERAD, in association with other stakeholders, such as local authorities, health boards and where appropriate the local enterprise companies, should establish a responsive system to assist members of the rural community to cope with stress during and following an FMD outbreak. (para 219) |
159. In preparing for a future FMD emergency, Dr Anderson recommends the active involvement of public health agencies. The Executive believes that local planning, led by NHS Boards, is the most appropriate way of tackling this. This issue will be raised at the next meeting of Directors of Public Health for an initial discussion and then the Directors could be invited to take the lead locally, with relevant partners, in drawing up local plans attuned to local circumstances. This is in line with the approach taken throughout the contingency planning process, of providing overarching strategic guidance within which local and specialist knowledge makes its unique contribution.
160. The Scottish Contingency Plan also proposes that during an outbreak, interests such as Scottish Executive Health Department, FSA, SEPA etc may be invited to meetings of the Disease Strategy Group as appropriate. It is expected that this will be the main mechanism for accessing strategic level advice on public health issues which arise during the course of an outbreak. At operational level, the Regional Operations Director (ROD) would normally establish a local team including Directors of Public and Environmental Health and this team would be responsible for activating the provisions of the local plan.
Environmental Issues
161. Environmental effects must be considered as a core element of the disease control process and the head of the Scottish Executive Environment and Rural Affairs Department will ensure that environmental issues are reflected in disease control decisions.
RSE 19: SEPA's role in protecting the environment should be properly incorporated into the contingency planning and the management of the emergency at the highest level. (para 173) |
162. SEPA will be invited to Disease Strategy Group meetings where they are able to offer input to specific discussions. However, they have a vital role to play on the ground working alongside the Regional Operations Director and Divisional Veterinary Manager in agreeing disposal solutions and also providing input into other issues such as the location of cleansing and disinfection sites. SEPA are core members of the DECC management team and their roles are explained in both national and local contingency plans.
Access
163. Access was a contentious issue in 2001 and the closure of footpaths in many areas created significant problems for other parts of the rural economy, particularly the tourism sector. Considerable work was undertaken to reopen the countryside based on risk assessments and explanation of dangers involved and the draft contingency plan aims to build on this experience.
RSE 22: In the event of an outbreak, unless its origins and spread are immediately apparent, the countryside should be closed for a limited period of three weeks at the same time as the animal movement ban is announced; but as soon as the extent of the disease is determined, the closure should be lifted in a non-affected areas. (para 198) |
164. The Scottish Executive is not able to accept this recommendation. Footpath closures for as long as three weeks would have a significant impact on the wider rural economy which cannot be justified in terms of the risks involved; and the suggestion that "the countryside" should be closed without regard to the specific veterinary assessment of risk would create unnecessary concern and loss for rural businesses. The draft contingency plan expects that as part of the creation of the Blue Box footpaths around the infected premise will be closed to minimise any risk of further disease spread. Outside the Blue Box the expectation is that the countryside will be kept open with closure only being permitted on the basis of a veterinary risk assessment. The assessment would take a presumption in favour of access as its starting point. The Scottish Executive will be discussing this issue in depth with the Access Forum at the end of November but the responses from the Contingency Plan consultation exercise have been generally favourable.
165. The finalised Contingency Plan will also include guidance to access users and utility workers on biosecurity steps they should take in a disease situation. This will complement the 'peacetime' advice included in the Biosecurity Code of Practice.
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