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FMD Review (Scotland) 2007

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Chapter 4
Disease Strategy and Movement Controls

KEY FINDINGS

4.1 Once the FMD outbreak was confirmed in August and again in September, the Scottish Government acted quickly and decisively to impose a national movement ban in line with their contingency plans. None of the UK administrations' contingency plans gave an indication of the timescale for removing the restrictions nor were the criteria clearly specified. Stakeholders considered that more detail on timescales would be invaluable and enable them to plan more effectively.

4.2 Stakeholders all agreed that such a ban should be imposed immediately no matter where disease first occurred in GB. Whilst all stakeholders supported the ban, the farming community wanted swift relaxations based on risk assessment to enable licensed movements to recommence as soon as possible without jeopardising FMD controls. A phased relaxation was considered crucial. The challenge was how to balance the prevention of FMD spread against the problems caused on a daily basis throughout the supply chain by the movement restrictions.

4.3 Improvements can be made which could help to reduce disruption either by reducing the impact of the movement restrictions or by informing stakeholders of the timescales and likely period so they can plan accordingly. These include:

  • the value and role of the routine movement standstills and associated separation agreements need to be reviewed to assess their value both in times of FMD freedom and during outbreaks;
  • improve the consistency of implementation both within Scotland and with the rest of GB;
  • the identification and evaluation of critical movements for industry and the risks they may pose;
  • defining risk areas to enable restrictions to be lifted faster in the lower risk and provisionally free areas;
  • preparation and updating of risk assessments for important categories of movements especially for welfare purposes and to slaughter;
  • availability of pre-prepared movement licences with clear unambiguous conditions.

Stakeholder involvement in all these activities is crucial for success as is liaison and coordination between all GB administrations.

INTRODUCTION

4.4 The main elements of the disease and movement control strategy are considered in this chapter and include:

  • routine movement standstills during periods of FMD freedom to prevent the silent spread of the virus before disease is identified;
  • imposition of a national movement ban on confirmation of disease to prevent further spread of FMD;
  • relaxation of the national movement ban to minimise disruption and return to normality;
  • other disease control strategy issues.

ROUTINE MOVEMENT CONTROLS

Routine movement standstills

4.5 During the 2001 outbreaks risk assessments indicated that a 20 day standstill of all susceptible livestock on farms following the movement of susceptible animals onto the premises would be an appropriate risk management measure. During FMD free periods a routine movement standstill provides an effective mechanism for slowing the potential spread and impact of FMD. As long as a standstill remains in force it prevents the disease being carried by infected animals to otherwise uninfected premises. If infection is present it will circulate amongst the animal population on the farm which will provide an opportunity for FMD to be recognised and investigated before any animals move off.

4.6 The 20 day standstill continued as a precautionary measure after GB was declared free of FMD in January 2002. The industry requested that the rule be changed as the restrictions interfered with normal trade and husbandry practices. The situation was reviewed to assess whether it would be possible to reduce the period but still maintain the additional safeguard to reduce the potential for FMD spread. In England computer models indicated that a 6 day standstill would provide adequate protection. As a result a 6 day standstill was introduced for cattle and sheep in England and Wales with the 20 day standstill remaining for pigs. Scotland adopted a different approach and decided on a 13 day standstill for cattle and sheep.

Separation Agreements in Scotland

4.7 As a concession to the 13 day standstill farmers who gave an undertaking to keep incoming and resident animals separate to avoid the spread of disease were given an exemption. The farmers would need to demonstrate separation between animals moving onto the farm from animals already on the farm. The separation agreements were approved by Scottish Government and currently involve around 1,800 farms. The agreements are monitored as part of routine animal inspections. The facilities and the operation of the separation agreements vary considerably from farm to farm. Some involve complete separation to the extent that FMD on one part of a premise would not be spread to another part. Others are not so effective and would not prevent the spread of FMD between different parts of the same premises.

4.8 It was accepted at the time of the initial concession that separation agreements would be invalid during an FMD outbreak due to the heightened risk of disease spread by animals. In these circumstances movements would only be permitted under licence and subject to the re-imposition of the 20 day standstill. When the restrictions were lifted on 23 rd August a 20 standstill remained in place as a precautionary measure. This created problems for farmers due to the short period in August/September in which to buy breeding stock while selling finished or store stock.

Issues in 2007

4.9 As a result of discussions with stakeholders and officials three issues arose:

  • the overall effectiveness of the separation agreements as a precautionary measure was queried;
  • the different requirements in England where there is a 6 day standstill with no separation agreements;
  • during the 2007 outbreak a 20 day standstill was reintroduced for all licensed movements and the separation agreements routinely observed in Scotland were suspended. Concern was expressed by stakeholders that all farms had to comply with the 20 day standstill and no account was taken of the separation agreements.

Lessons learned

4.10 It would be helpful if there was less confusion over the different standstill requirements in England and Scotland. While the separation agreements have limitations they encourage good practice and are useful for preventing the spread of some diseases with the adoption of good biosecurity and separating incoming and resident livestock. The benefits of this relate to a range of diseases other than FMD. Whilst separation agreements are of value in peacetime it is questionable whether they are of equal value when national movement controls are in place in order to halt the spread of FMD.

Recommendation 14: The Scottish Government should undertake a review of the effectiveness of movement standstills in periods of FMD freedom, and consider whether a 6 day or 13 day standstill with variable quality of separation agreements is the most appropriate precautionary measure. (Medium Priority)

Recommendation 15: The Scottish Government should conduct a full risk assessment on the effectiveness of separation agreements during periods when movement controls and licensing are in place and consider whether there is a potential for utilising separation agreements during an FMD outbreak to minimise disruption to producers. (Medium Priority)

IMPOSITION OF THE NATIONAL MOVEMENT BAN

Requirement for a national movement ban

4.11 Prior to 2001 national movement controls had not been imposed in GB following the confirmation of the first case of FMD. Following the 2001 FMD epidemic the Lessons Learned Inquiry, the Royal Society and the Royal Society of Edinburgh all recommended that a national movement ban should be imposed on confirmation of the first case of FMD in the UK. A national ban was considered to be a critical response to an outbreak of FMD. The rationale was to minimise potential spread of FMD when disease was known to be in the country and before full details of its extent and geographical distribution were known. This recommendation was accepted by UK Government and endorsed by all the stakeholders.

Objectives of the ban

4.12 The imposition of a national movement ban at the time of first confirmation of FMD serves a number of purposes:

  • it stops for a short period of time all movement of susceptible animals thereby preventing the spread of FMD by livestock and greatly reducing the risk of spread by people, vehicles or equipment;
  • it allows time for an epidemiological analysis to be undertaken to determine more appropriate risk areas;
  • it enables all movements which are gradually permitted on a risk basis to take place under strict controls to minimise the risk of spreading FMD via incubating or diseased animals;
  • it helps to alert livestock keepers and other interested parties to the presence of disease in the country. This leads to heightened awareness of the disease outbreak and the need for farmers and others to take precautions and to report suspicions of disease;
  • it demonstrates to the public, trade partners and EU Member States that the UK is taking steps to contain the outbreak and prevent spread out of areas which are already infected.

Issues in 2007

4.13 There was uncertainty about epidemiology and spread of FMD immediately following confirmation of disease on 3 rd August. There was one herd in Surrey with FMD, which might or might not have been the index case. The origin of the outbreak was unknown, and the reliability of preliminary information on movements on and off the holding was uncertain. In view of this, Defra wished to impose a national movement ban in England and requested Scotland and Wales to implement similar bans. There was unanimous agreement that a national GB-wide movement ban was necessary not least due to the lack of knowledge about disease and possible spread at that time. The national movement ban was introduced in all three countries using as the legal basis the imposition of restricted zones throughout GB.

4.14 Following confirmation of FMD on 12 th September a national movement ban was re-imposed but excluded the Scottish Islands. It is a matter of judgement whether a national movement ban throughout Scotland and Northern England was appropriate at that stage or whether a limited ban on the high risk counties around the FMD locus in Surrey was more appropriate. The disease appeared restricted to Surrey and the 20 day routine movement standstill remained although there had been movements to Scotland from Surrey on 10 th September. The routine 20 day movement standstills could have reduced the chances of uncontrolled FMD spread as a consequence of the continuing infection in Surrey. Little or no work has been undertaken to assess whether the routine 20 day standstill requirements could reduce the need for a national movement ban in some circumstances.

Lesson learned

4.15 The ease with which FMD can spread and the potential damage that came as a result of being slow to impose movement restrictions in 2001 justifies the immediate imposition of a national movement ban. There was no criticism from Scottish stakeholders about the introduction of the national movement ban in August. The majority of stakeholders also supported the imposition of the national movement ban following the outbreak on 12 th September.

4.16 From a risk perspective the need for such a ban with what appeared to be a continuing local outbreak in Surrey and the controls as a result of the 20 day movement standstill could be investigated further to provide information for decisions on the extent and timing of such a ban in future.

Recommendation 16: The Scottish Government may wish to review the need for the national movement ban in all circumstances taking into account the routine movement standstills on susceptible animals which are in force during periods of FMD freedom. (Low Priority)

MINIMISING THE DISRUPTION CAUSED BY A NATIONAL MOVEMENT BAN

Introduction

4.17 Discussion with stakeholders and officials identified six areas where improvements could be made to reduce the disruption resulting from the national movement ban. In each case the situation would vary depending on the strain of virus, the index case, the time between infection and confirmation and the time of year with potential spread of FMD through livestock movements. The six areas for consideration are:

  • duration of the ban;
  • consistency and co-ordination of implementation;
  • timescale and risk hierarchy for priority movements;
  • risk areas;
  • risk assessments;
  • licences and licence conditions.

Duration of the ban

4.18 A number of the enquiries after 2001 recommended that the ban should be speedily relaxed in consultation with stakeholders once the source and potential spread of the disease was understood. The report by the Royal Society of Edinburgh recommended that farmers in accordance with strict biosecurity should be able to move animals within farm units in such a way as to minimise the welfare problems and the risk of spreading disease. It was important to establish a mechanism whereby the animal welfare and commercial pressures which rapidly build up on farms when normal movements are restricted could be alleviated.

4.19 The Scottish Government's FMD Contingency Plan indicates that in principal the movement ban would be introduced as a precautionary measure for an initial period of 7 days. This would depend on the nature and scale of the virus spread. The ban would be kept under constant review to minimise disruption to industry. Limited movements would be permitted under licence to avoid animal welfare problems. Biosecurity and other requirements would be incorporated into the conditions of licences.

4.20 None of the UK administrations' contingency plans gave an indication of the timescale for removing the restrictions nor were the criteria clearly specified. This is understandable as each outbreak will vary considerably and policy will have to be developed in the light of the epidemiology and information on the disease and the industry activities at the time. However stakeholders considered that more detail on timescales would be invaluable and enable them to plan more effectively.

Consistency and co-ordination of implementation

4.21 Movement restrictions were relaxed at different speeds by the three GB administrations. In some cases Scotland relaxed restrictions and permitted licensed movements in advance of Defra. In other cases the reverse was true. Most licences were identical and the main difference was in timing. In other cases general licences were used in one country with specific licence for the same type of movement in another part of GB. All of this led to confusion amongst the industry and difficulties in enforcement especially if cross border movements were to take place.

4.22 The collection of fallen stock from farms etc and the uplift of animal by-products from slaughterhouses etc were included in the original movement ban. Initially there was a difference in policies in England from those in Scotland. On 5 th August, in response to pressure from stakeholders, on-farm burial of fallen stock was permitted throughout Scotland. The derogation to bury on-farm remained in place for 5 days until 10 th August when collection and movement of carcasses to an animal by-products approved disposal facility was permitted via a general licence and was subject to stringent biosecurity conditions, e.g. single collections only, collection at farm perimeter, full cleansing and disinfection of vehicles etc.

4.23. Although welcomed by stakeholders there was a view from officials that the decision in Scotland to allow on-farm carcass burial was unhelpful. Defra had come under early pressure from stakeholders to allow burial in England too, based on a perception that fallen stock was a significant issue. Close communication with the National Fallen Stock Company meant that Defra knew there was no backlog of fallen stock. In England the establishment of licences for dealing with fallen stock had gone smoothly.

4.24 Generally most functions in relation to the collection of fallen stock are undertaken by the same organisations in Scotland that deliver the same function elsewhere in GB. It is evident the organisations found it difficult to perform their role when the policy instructions coming forward from Defra, Scottish Government and Welsh Assembly Government were not consistent. This was particularly so when fallen stock for TSE surveillance were collected in England for disposal in Scotland.

4.25 Rapid movement of stock to slaughter is essential with even a 24 hour delay having potentially huge impacts on the supply chain. This is especially the case in the pig sector as there is less elasticity in the pork supply chain. There had been a debate around the timing of movements to slaughter. Defra had moved more slowly than Scotland because they were not sure of the extent of disease spread with confirmation of the second case on 6 th August. Scottish Government officials were working on the risk assessment and the conditions to allow animals to be moved to slaughter from day one of the outbreak. They were not dealing with an FMD outbreak at first hand, so were able to act quicker than Defra officials who were much more closely involved with the outbreak and its control. In order to permit animals to move to slaughter it was necessary to approve slaughterhouses, establish procedures, identify resources and finalise the round stamp policy. The policy for dealing with by-products was not clear.

4.26 Round stamps were not immediately available and there was some confusion about the requirements for marking products and packaged material where the EU oval stamp was printed on the packaging. This was a major issue for the retailers who moved product around the UK, especially with the lack of clarity in the early stages about the import rules imposed by the Department for Agriculture and Rural Development in Northern Ireland.

4.27 There were a number of other issues which arose in relation to the slaughterhouses. These included the disposal of slaughterhouse waste which caused delays and for which no detailed contingency planning in the event of a national movement ban had been made in any GB country. Dealing with animals which arrived unexpectedly at slaughterhouses needs additional guidance and the industry considered that the 24 hour rule for slaughter should be reviewed to see if the time frame could be extended so that animals could stand overnight for processing the next day.

4.28 Another area which could have been freed up earlier was a range of on-farm services such as milk recording and contract clippers and dippers. These types of activities could be licensed and monitored, and with satisfactory biosecurity the potential risks could be reduced to an acceptable level.

4.29 These are some of the examples of where there were either different policies in different administrations or where the implementation of those policies followed a different timescale. This is not surprising and it should be expected that based on the disease, epidemiology, distance from the outbreak, perceived risk and structure of agricultural industry that differences would be seen.

4.30 Good co-ordination between the Scottish Government, Defra and the Welsh Assembly Government is essential for handling the consequences of the national movement ban. Much of this can be achieved with improved preparation and contingency planning on a GB-wide basis.

Recommendation 17: The Scottish Government should provide greater clarity on the procedure for authorising slaughterhouses in the event of an FMD outbreak. This information should be available to stakeholders. (Low Priority)

Recommendation 18: The Scottish Government should work with the industry to review the procedures adopted at slaughterhouses and to develop solutions and protocols for dealing with issues such as unexpected arrivals, modifying the 24 hour rule and ensuring that vehicle wash facilities are adequate. (Low Priority)

Recommendation 19: The UK administrations should develop a clear policy for the use of the round stamp on carcasses and animal products in advance to ensure the availability of round stamps, and the resolution of the practical problems such as the costs of changing packaging for animal products at short notice. Round stamps should be held in reserve by the Meat Hygiene Service and not destroyed after an outbreak is over. (Medium Priority)

Timescales and risk hierarchy for priority movements

4.31 Defining welfare, husbandry and economic needs in advance, and then balancing these against the risks involved with movements would remove a lot of the pressure during a disease situation. In the first week welfare and movements to slaughter are considered by stakeholders to be the most important. The Scottish Government needs to be clearer and clarify the risks of different types of movements, brigading these into different levels of risk. This will aid industry's understanding of why restrictions are in place and the likely sequence for relaxation and licensing of movements.

4.32 Whilst licensing welfare movements helped to meet the practical realities, farmers faced the inconsistencies in the hierarchy of permitted movements which must be resolved. The ability to move a bull across a road, to put rams to the ewe, to move sheep to fresh pasture, to wean calves are all examples of normal husbandry practices within a business and need to find a suitable position in the risk hierarchy. Concern was expressed about the tight definition of welfare problems and the lack of flexibility given to Animal Health Divisional Office ( AHDO) staff to issue specific licences to resolve difficulties. Specific cases were quoted where farmers were not permitted to move animals short distances or across roads within their own premises for good husbandry reasons especially where grazing pressures developed. Some common sense and judgement should be used in these cases but further work is necessary to assess how local decisions based on risk can be made without jeopadising overall disease control.

4.33 A priority list of movements necessary to alleviate welfare, and husbandry problems linked to risk assessments would ensure that stakeholders were aware of the timescales and could plan accordingly. The option of using specific licences for the initial relaxation followed by general licences at a later stage when the level of risk is lower is a practical solution which was used in 2007.

4.34 Stakeholders need to be involved in producing a priority list of movements which could be based on the table below. The comparative risks are also indicated. This list was used by the Scottish Government during the second phase of the outbreak in September to determine the risks of different movement categories and to decide the timing for relaxing specific movement restrictions. This hierarchy of risk should be expanded to include the majority of movements. It must be recognised that the risk associated with the different types of movement is critically linked to the probability that FMD exists or does not exist in the area which in turn links to categorisation of the risk areas for disease control purposes.

Table 8
Priority movements and possible risk

No.

Movement type

Risk

1

Occupational movement for welfare reasons. Milking cow across the road.

Very low risk of spread reduced with cleaning and disinfection of the road

2

Movements direct from farm to slaughterhouse under a general licence

Minimal risk with C&D of vehicles and controls at the slaughterhouse

3

Local movements over a short distance between premises in the same control

Very little additional risk because same staff and vehicles involved. C&D reduces the risk.

4

Movement to collection centres for slaughter

Slight risk of spread a the collection centre but controlled by C&D before return home

5

Long distance movement within the same business for welfare or other reasons under a specific licence initially and later a general licence but in either event depending on distance

Risk of spread to a new area but slight additional risk as involves same farm staff and vehicle

6

Long distance movement within premises of different ownership or control for welfare or other reasons under a specific licence initially and later a general licence.

Risk of spread to a new area but additional risk as involves different farm staff and vehicle

7

Movement to slaughter with multiple pick ups

Risk of disease spread to at least one or all farms in the chain

8

Farm to Farm movements commencing as a specific licence

Risk of disease spread but only to one new farm but could seed FMD into a new area

9

Movement to slaughter markets

Slight risk of spread at the market centre but controlled by C&D before return home. More mixing of people and vehicles and longer on the premises.

10

Store sales

Intermediate risk

11

Markets

Major risk of spreading disease to all farms receiving animals out of the market. People and vehicles also pose a risk.

4.35 Consideration needs to be given to the possibility of issuing licences with appropriate safeguards for low risk movements soon after the national movement ban is imposed in order to minimise disruption. The feasibility of permitting movements at an early stage will be influenced by the speed with which biosecurity and other controls such as ability to clean and disinfect lorries can be implemented. This will depend on contingency planning by government and the relevant stakeholders.

4.36 On-farm services such as artificial insemination and milk recording are important. Milk recording is essential for dairy farmers especially the individual cow somatic cell counts which are vital to meet buyers' standards. Artificial insemination technicians were allowed back on-farm ahead of milk testing technicians which suggests a lack of parity in making relaxations when considering the level of risk involved in these two activities. Other contractor services involving livestock such as sheep dipping, sheep clipping and foot trimming are important and should be allowed to recommence as soon as practical although the gathering of animals could pose additional risks. This raises a series of issues especially around the levels of biosecurity observed by the contractor and the ability of the farmer to gather the stock safely.

4.37 There are many other potential movements but in general they fall into three categories; occupational, welfare and long distance. Taking practical steps to safely allow for these in a pre-agreed sequence which is seen as reasonable makes it more likely that farmers will accept the whole package of restrictions. It will be of benefit to develop a priority list of the key movements for each species at each main period throughout the year. It is important to identify movements and to ensure that the risks are assessed and licences prepared before an outbreak.

Recommendation 20: The Scottish Government should continue to develop a risk hierarchy for priority movements which maps out the sequence of events after FMD confirmation. Different scenarios with appropriate timetables to enable farmers and others to plan for movements and understand how the controls would progress should be prepared as part of the contingency planning process. (High Priority)

Recommendation 21: Milk recording needs to be recognised as a priority for dairy farmers and as soon as risk assessment allows, technicians should be allowed on farm under the conditions of licence. A code of practice should be developed and agreed between the milk recording organisations and the Scottish Government. (Low Priority)

Recommendation 22: The Scottish Government and Animal Health agency should consider whether instructions could be developed to enable Divisional Veterinary Managers to use their judgement pertaining to local circumstances in deciding which movements within a farm business could be permitted. Specific licences could be issued under certain circumstance e.g. where a single farm business is identified and the move presents a low risk. It will be essential to balance flexibility against the need to maintain consistency across Scotland. (Low Priority)

Risk areas for internal controls

4.38 The determination of risk areas and the level of permitted movement are interrelated. The speed with which parts of the country can be reclassified into lower risk areas determines the rate at which more routine husbandry management, commercial and longer distance movements can be authorised under licensed conditions. Details of risk areas and their classification are covered in Chapter 3 dealing with regionalisation.

Risk assessments

4.39 During the 2001 a central risk assessment unit was established by the Chief Veterinary Officer in London with four objectives:

  • to consider the risks posed by specific activities;
  • to identify ways in which these risks could be managed;
  • to make recommendations which could be used by policy makers in deciding actions;
  • to publicise the risk assessments to enable the stakeholders and public to comment on the assessments.

4.40 The risk assessments were mainly qualitative taking account of literature searches, on-going experimental work, advice from researchers working on FMD, expert opinion and OIE guidelines. Each of the assessments was reviewed by experts. At that time the risk assessments expert advice was obtained from the Risk Research Unit at the Veterinary Laboratories Agency and from the World Reference Laboratory at Pirbright. Over twenty detailed scientific risk assessments were prepared from which a practical version was made available for discussion with the industry and publication on the Defra website.

4.41 In 2007 there appears to have been a much more ad-hoc approach with each of the three administrations conducting their own risk assessments. In Scotland a series of risk assessments based on the practical versions produced in 2001 were prepared and peer reviewed at Glasgow University. They were not considered by a specialist risk unit nor was the expertise of the World Reference Laboratory at Pirbright involved.

4.42 The following table provides a list of the Scottish veterinary risk assessments which supported the decisions taken in lifting restrictions and permitting licensed movement to take place. The assessments 13 to 16 were undertaken following the FMD outbreak confirmed on 12 th September 2007.

Table 9
Risk assessments prepared in Scotland

No

Veterinary risk assessment

Date completed

1

Movement direct to slaughter

7.8.07

2

Fallen stock

9.8.07

3

Movement of weaned piglets, sows or cows to parturition

9.8.07

4

Scottish Islands-Removing the Restricted Zone measures form the Scottish Islands

10.8.07

5

Scottish Islands No2-movement from Scottish Islands to a single premises on the Scottish mainland

10.8.07

6

Routine farming operations

16.8.07

7

Welfare movements

16.8.07

8

Sheep shearers and dippers

20.8.07

9

Collection centres

20.8.07

10

Animal Gatherings

22.8.07

11

Livestock movement ban

22.8.07

12

20 day standstill

28.8.07

13

Artificial insemination

14.9.07

14

Movement from markets

14.9.07

15

Farm to farm/livestock services

23.9.07

16

Removing restricted zone controls in Scotland

9.10.07

4.43 A number of other risk assessments are required to cover the movements specified in the risk hierarchy. These would include movements such as moving hill lambs to lowland farms in Scotland or England. A pre-existing schedule of this kind would have been very helpful and probably would have enabled some relaxation of the movement ban to have progressed faster.

4.44 Veterinary risk assessments should be carried out during 'peace time' as part of contingency planning for an FMD outbreak. The risk assessments should be developed and finalised on a GB-wide basis covering the majority of movements identified in the risk hierarchy. The risk assessments should be agreed with stakeholders, not just between governments and should be prepared on the understanding that depending on the type and timing of an outbreak, a particular risk might be more or less significant. This means that there could be no automatic decisions on relaxing the ban. Each of the assessments would need to be peer reviewed and subject to scientific challenge. It would also be appropriate to engage Ministers in each country to agree the assessments.

4.45 A consistent risk assessment methodology should be available ahead of time which would provide a pre-arranged framework for use in different risk areas. This in turn would help to speed up the decision making process. Industry should be consulted when building a hierarchy of risk and essential movements although it will be important to ensure the correct balance between risk and economic concerns.

Recommendation 23: The Scottish Government, Defra and other Devolved Administrations should develop a full set of veterinary risk assessments for all priority movements listed in the risk hierarchy. The development and up-dating of risk assessments should be a routine component of contingency planning as should regular reviews to take account of changing patterns of trade and other factors. Ideally the three GB administrations should agree to use a single set of risk assessments for GB to ensure a consistent approach to their application. (High Priority)

Licences for permitted movements

4.46 Licences which allowed for certain movements were put in place fairly quickly. The vast majority of licences were general so no paperwork was required which was far preferable to the system in 2001 where all moves were completed under specific licence. Users could obtain copies of general licences from the Scottish Government website, AHDOs, LAs or markets. As restrictions continued, members of the AHW Panel of COSLA drafted a consignment note which had to be completed when moving under general licence. Some of the higher risk farm to farm movements were made under specific licence but these were issued by Animal Health agency who copied details to LAs.

4.47 Licences were often issued by the authorities on a staggered basis which created some delays and confusion over what was permitted. In some cases the definitions in the licences should be clearer to avoid inconsistencies e.g. farmers were required to carry a portable disinfection kit when going to markets but not when moving from farm to farm. The licensing system was better than in 2001 as the licences were easier to understand and to access although there were some doubts over the interpretation of the conditions by the AHDOs.

4.48 COSLA provided a daily update on enforcement issues to Chief Veterinary Officer ( CVO) Scotland and copied this to NFU Scotland which resulted in greater compliance on the ground. There was very little evidence of non-compliance throughout both phases of disease. Non-compliance was restricted to a small number of cases particularly at some markets. In general poor compliance was due to misunderstandings over what was required. Standardising conditions would assist users as would a simple list of do's and don'ts.

4.49 Following the relatively slow response after 3 rd August the speed with which licences were issued after 12 th September demonstrates the value of pre-prepared licences and the availability of risk assessments. The outbreak has provided a useful library of licences which can now be reviewed and consolidated. There is a need to have as far as possible ready-prepared off-the-shelf licences for any future outbreak, with variations to cover different levels of risk. Whilst this section deals primarily with movements of livestock it is equally important to have pre-prepared licences covering by-products and waste. Similarly the export conditions and licences for products which are eligible for export from day one of an outbreak should be pre-prepared with the systems established for immediate implementation.

4.50 It was apparent that farmers and others need greater clarity on the difference between specific and general licences and the implications and requirements of the licence conditions.

Recommendation 24: The Scottish Government should develop a full set of movement licences and export certificates, based on risk assessments, using a standard set of conditions with clearer definitions. The pre-prepared licences should be reviewed on a regular basis to take account of changes in trade or husbandry patterns. (Medium Priority)

OTHER DISEASE CONTROL ISSUES

Hobby farms

4.51 In the light of the outbreaks in Surrey, stakeholders expressed concern about hobby farmers in Scotland as well as in England. Disease control and prevention efforts are concentrated on large economic farms whereas the small hobby farms especially in the North and West of Scotland are neglected. Contact was essential with hobby farmers who should be made aware of their responsibilities. In the crofting areas there may be stock on crofts which are possibly not registered, with pigs probably the most likely to be kept without notification. The degree to which this creates a potential problem is unclear and when animals have come from surrounding crofts, knowledge about registering and best practice is generally passed on. In order to reduce risks the issue of policing farming practices must be considered to ensure hobby farmers were on record and subject to the usual checks.

Recommendation 25: Contacts should be developed and maintained with hobby farmers who should be registered in order to ensure they are included in the communications network if an FMD outbreak occurs. They need to be aware of their responsibilities for disease control and in order to achieve this, the Scottish Government should work with stakeholders to develop programmes to assist hobby farmers. (Low Priority)

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