Materiale fra Fødevareministeriet vedrørende forekomst af BSE hos får
Modtaget via elektronisk post. Der tages forbehold for evt. fejl
Europaudvalget
(Alm. del - bilag 1751)
landbrugsministerråd
(Offentligt)
|
Medlemmerne af Folketingets Europaudvalg og deres stedfortrædere |
|||
|
Bilag |
Journalnummer |
Kontor |
|
|
|
|
|
|
Til underretning for Folketingets Europaudvalg vedlægges Fødevareministeriets skrivelse, pressemeddelelse, Contingency Plan samt notits fra veterinærdirektør P. Willeberg vedrørende muligheden af forekomst af BSE hos får.
Materialet er samtidig hermed oversendt til Folketingets Udvalg for Fødevarer, Landbrug og Fiskeri.
|
Folketingets Europaudvalg |
./. . Til orientering vedlægger jeg pressemeddelelse samt Contingency Plan, som d. 28. september 2001 er udsendt af de britiske myndigheder.
./. I vedlagte notits af 28. september 2001 fra veterinærdirektør P. Willeberg redegøres for drøftelsen i veterinærchef mødet d. 26.-28. september om muligheden af forekomst af BSE hos får.
Materialet er samtidig oversendt til Folketingets Udvalg for Fødevarer, Landbrug og Fiskeri.
Pressemeddelelse
EU's videnskabelige komité har siden slutningen af 1990’ erne beskæftiget sig med spørgsmålet om forekomst af BSE i får.
Arbejdet er endnu ikke afsluttet, men den britiske regering offentliggør i dag et udkast til en beredskabsplan, som skal anvendes i tilfælde af forekomst af BSE i får.
I introduktionen til beredskabsplanen står følgende:
This consultation document seeks views on the actions to be taken should BSE be found to be present in the United Kingdom sheep flock. The document has been prepared purely on a contingency basis. The present situation is that no BSE has been found to occur naturally in sheep. The contingency plan is part of the Government´s precautionary strategy for risk management and the protection of public health. It will also serve towards meeting an obligation placed by European Union legislat ion on the United Kingdom and all other Member States of the European Unison to draw up such plans.
Offentliggørelsen af det engelske udkast skal ses i sammenhæng med en videnskabelig undersøgelse af BSE hos får, som har været drøftet på et møde med EU’s veterinærchefer den 26.- 28. september 2001. Undersøgelserne er endnu ikke afsluttet, og forventes fortsat drøftet i EU’s videnskabelige komité.
EU’s veterinærchefer finder ikke, at der er grundlag for at træffe konkrete foranstaltninger på nuværende tidspunkt.
BSE og den beslægtede sygdom scrapie er hverken konstateret hos får i Danmark eller hos får fra New Zealand, men Fødevareministeriet vil følge sagen nøje.
For yderligere oplysninger: Ring til Henrik G. Jensen, Fødevaredirektoratet tlf. 2180 4496 eller Rikke Hoff-Jørgensen, Statens Veterinære Serumlaboratorium tlf. 4871 2714
Contingency Plan
For the emergence of naturally occurring BSE in Sheep in the United Kingdom National Flock
Contents
Why have a contingency plan? *
If evidence arose that BSE might be a problem in sheep, would it not be possible simply to repeat the measures taken for cattle? Why is a new contingency plan needed? *
Contingency planning in the context of the Government’s overall risk management strategy *
1 Action and Decisions Following Emergence of Test Results *
2 Immediate Action Following the Onset of a BSE Crisis in Sheep *
2.1 Introduction *
2.2 Section A: Protection of human and animal health *
2.3 A full audit of the use of sheep- and goat derived products outside the human food chain? *
2.4 Section B: Communications strategy *
2.5 Section C: European Union dimensions, and import and export controls in the event of a crisis *
3 Slaughter and Disposal Programme *
if it becomes necessary to slaughter at least part of the United Kingdom flock *
3.1 Introduction *
3.2 Intermediate steps *
3.3 The worst case scenario *
3.4 Would it really be as bad as that? *
3.5 Managing the disposal programme *
3.6 Slaughtering arrangements *
3.7 Direct incineration of the whole carcase after slaughter *
3.8 The rendering route *
3.9 Incineration of the products of rendering *
3.10 Storage of meat and bone meal *
3.11 Transport *
3.12 Staffing costs *
3.13 Northern Ireland aspects *
4 implications For The Farming Industry and the Rural Economy *
4.1 Immediate aid to producers *
4.2 Aid at slaughter *
4.3 Retention aid *
4.4 Timing of payments under the retention aid scheme *
4.5 Making payments direct to producers *
4.6 Casualty animals *
4.7 implications for related areas of the rural economy *
5 Screening for ‘Safe’ Sheep and Segregation of Their Meat from Potentially Infected Sheepmeat *
5.1 Introduction *
5.2 Screening methods *
5.3 Allowing only offspring of resistant rams into the food chain *
5.4 Allowing only resistant or semi-resistant lambs into the food chain *
5.5 Allowing into the food chain only animals that have been tested for a TSE *
5.6 Identification *
5.7 Would there be a sufficient commercial incentive to persuade the industry to market "safe" sheep? *
5.8 The cost of testing and identification *
6 Rebuilding the Industry *
6.1 A post-crisis structure for the sheep industry *
6.2 How to achieve post-crisis objectives *
7 Summary of Issues for Consultation *
7.1 Chapter 1 *
7.2 Chapter 2 *
7.3 Chapter 3 *
7.4 Chapter 4 *
7.5 Chapter 5 *
7.6 Chapter 6 *
1. This consultation document seeks views on the actions to be taken should BSE be found to be present in the United Kingdom sheep flock. The document has been prepared purely on a contingency basis. The present situation is that no BSE has been found to occur naturally in sheep. The contingency plan is part of the Government’s precautionary strategy for risk management and the protection of public health. It will also serve towards meeting ligation placed by European Union legislation on the United Kingdom and all other Member States of the European Union to draw up such plans.
2. The report of the BSE Inquiry published in October 2000 noted that the Government had been taken by surprise and wrong-footed by the announcement in March 1996 that a new variant of CJD had been identified which was probably linked to BSE. The announcement was made by the Spongiform Encephalopathy Advisory Committee (SEAC) which is an independent committee of leading experts set up to provide the Government with the best p ossible scientific advice on BSE and the safety of British meat. The report went on to say that the Government should have appreciated the possibility of this outcome. The report noted that there had been no consideration of any contingency plans and no interdepartmental discussions. It drew the lesson that contingency planning was a vital part of Government.
4. The need for contingency planning is also recognised at European Union level, and a recently adopted European Regulation (999/2001, article 14 and recital 14) requires Member States to draw up contingency plans specifying the measures they would implement where cases of Transmissible Spongiform Encephalopathy (TSE) diseases (that include BSE and scrapie) are confirmed, including in sheep.
- There are some fundamental differences between foot and mouth disease and BSE. Amongst those is that foot and mouth is a virus that is highly contagious and serious amongst animals but which as far as is known does not have a significant, if any, impact on human health. It is generally accepted that BSE is not a virus but rather a slowly progressive and ultimately fatal neurological disorder of adult cattle. Its transmission patterns appear to be totally diff erent from those of foot and mouth disease. Unlike foot and mouth BSE has potentially severe implications in terms of human health.
- One of the precautions taken with foot and mouth disease was restrictions on the use of rights of way and access to land in certain areas. This was because of the risk that the virus could be spread by humans to previously uninfected animals. Because of the differences between foot and mouth disease and BSE there is no evidence, on current knowledge, that BSE could be passed on in the same way. Therefore there would appear to be no grounds for similar c oncerns arising regarding the closure of the countryside should BSE be found in sheep. (The separate question of whether sheep could pick up BSE infectivity from the environment is touched on in chapter 6.2.4).
8. Chapter 3 covers the arrangements for the disposal of sheep. What is proposed is a managed disposal programme spread over several years if necessary. The phased approach would be in contrast to the disposal of carcases because of foot and mouth disease where slaughter had to occur without undue delay. The phased approach reflects the differences between foot and mouth disease and BSE and itwould benefit the en vironment, at least in the short to medium term, since it would allow land to continue to be grazed by sheep.
Contingency planning in the context of the Government’s overall risk management strategy
- Measures to protect public health;
- Measures to protect animal health;
- An on-going programme of research;
- A national scrapie plan designed to increase resistance to TSEs in, and eventually to eliminate scrapie from, the sheep flock.
Measures to protect public health
- Controls on SRM prohibit the use of certain specified animal tissues, including those from sheep and goats, which might theoretically harbour BSE infectivity. SRM controls are in place for imported sheepmeat and imported goatmeat as well as for imported beef and other products of animal origin. There are also controls on the use of vertebral columns from sheep and goats, as well as from cattle.
- Guidelines on minimising the risk of contracting Transmissible Spongiform Encephalopathy (TSE) are in force for both human and veterinary medicinal products, including vaccines (see chapter 2). The guidelines have the force of law – from 1 March 2001 in the case of human medicines, and from 1 June 2001 in the case of veterinary medicines.
13. Under the Medical Devices Directive (93/42/EEC) the device manufacturer can demonstrate compliance with the Essential Requirements of the Directive by the application of the relevant European Standard. The assessment of conformity with the requirements for safety and quality is performed by third party organisations (Notified Bodies) and the Standard (BS EN 12442) on animal tissues utilised in medicinal devices addresses risk management, sourcin g controls and validated methods of elimination or inactivation. Additional measures to further strengthen the existing regulatory controls are soon expected with the draft Commission Decision on medicinal devices. This document is relevant to the utilisation of material of bovine, ovine or caprine origin and its mandatory nature is more comprehensive than the Standard. These medicinal device manufacturers will be required to demonstrate compliance with the updated requirements next year.
14. The Government have put in place measures to reduce the theoretical risk of variant CJD being transmitted between humans. These include leucodepletion of all blood for transfusion, the use of imported plasma to manufacture blood products, single–use instruments for tonsillectomy, and a decontamination action plan for all National Health Service Trusts.
Measures to protect animal health
An on-going programme of research
17. Parts of the programme have particular relevance to contingency planning. Sheep of different genotypes with known differences in susceptibility to TSEs have been fed with brain material from cattle infected with BSE. The time course of any development of disease in the tissues of these animals is being monitored. This will provide information on the age at which infectivity can be detected in tissues and whether genotypes thought to be resistant to diseas e carry infectivity in their tissues, even though they do not go on to develop clinical signs of disease. Information from these experiments will be of great importance if BSE is found in sheep. It will permit the safety of allowing sheep of resistant genotypes to enter the food chain to be fully assessed.
18. Food safety could also be protected if a diagnostic test were available which would allow sheep with a TSE to be identified and excluded from the food chain. In theory the test could be performed on the live animal or it could be used to screen carcases in abattoirs.
19. Diagnostic tests used to screen carcases and which detect the abnormal form of the prion protein have been approved by the European Commission for use in Member States’ surveillance programmes. In the case of sheep these do not distinguish between the different TSEs. One of the high priority areas in the research programme is the development of a sensitive diagnostic test for detecting TSE infection in live animals.
20. In sheep BSE appears to behave like scrapie and therefore there is a theoretical possibility that it can be transmitted from sheep to sheep in the same way that scrapie can. Understanding the conditions under which scrapie can be transmitted and what the risk factors are would be important if it proved necessary to re-establish a disease-free flock in the United Kingdom. This work includes investigation of whether and to what extent infectivity can persist in the soil.
21. A programme of surveillance is also underway, one of the aims of which is to look for BSE in the national sheep flock. It has not so far been possible to sample large numbers of sheep. This is because of the probable under-reporting of scrapie, not all reported cases are suitable for testing and that the rapid biochemical methods of differentiating between BSE and scrapie have not been sufficiently well developed confidently to distinguish between BSE and some strains of scrapie. It has been necessary to use bioassay in mice to characterise the strain of TSE. This is a lengthy and expensive process which limits the number of brains that can be tested. To date about 180 scrapie brains have been inoculated into mice as part of an ongoing programme. So far none of the assays have led to a conclusion that BSE has been present. In parallel, work is progressing on the further development of biochemical methods of differentiating between BSE and scrapie. of the probable under-reporting of scrapie, not all reported cases are suitable for testing and that the rapid biochemical methods of differentiating between BSE and scrapie
22. One of the scenarios discussed in this paper envisages the possible slaughter of large numbers of sheep if BSE were found to be present in sheep. Safe disposal of infected material would be a major issue. The research programme includes studies on the inactivation of the TSE agent in different conditions.
A national scrapie plan designed eventually to eliminate scrapie from the sheep flock
23. DEFRA and the Agriculture Departments of the devolved administrations in Scotland and Wales have been actively developing a national scrapie plan for Great Britain. The plan will implement a recommendation from SEAC that there should be a long-term control and eradication programme for scrapie. The first phase of the plan is to be a breeding programme selecting for genetic resistance to TSEs in the pedigree part of the nat ional flock. A public consultation on proposals for this first phase concluded on 31 October 2000. Various options were identified and these were discussed with both SEAC and the Food Standards Agency. The ram genotyping scheme, the first phase of the National Scrapie Plan, was launched on 19 July 2001. Work is also underway on developing proposals for the other phases of the scrapie plan. Priority is being given to how the national scrapie plan might be accelerated. The objec tives should not only be to build up a TSE-resistant flock for the future but also to find a way of allowing some sheep to pass into the human food chain should evidence emerge from the research that BSE may have been present in sheep.
24. A somewhat similar scrapie control and eradication initiative is proposed for Northern Ireland. This will feature liaison and co-operation with the authorities in the Republic of Ireland, with the objective of controlling and eventually eliminating the disease on the island of Ireland.
How was the contingency plan drawn up?
"In agreement with all interested bodies within Government, and taking into account the European Union dimension, to produce an integrated contingency plan of the actions to be taken should the presence of BSE in sheep be confirmed and should that lead to a total or partial ban on the consumption and export of sheepmeat produced in the United Kingdom."
How is the consultation exercise to be conducted?
When would the plan be implemented?
27. The plan would come into action only if research produced results which suggested the presence of BSE in sheep. Such results would first have to be scrutinised and carefully evaluated by SEAC so as to determine their significance. Chapter 1 of the plan outlines the processes to be used by the Food Standards Agency in the lead up to their decision on the advice that they should offer to the public in the light of the re search results.
28. Should the evaluation lead to the conclusion that there was BSE in the United Kingdom sheep flock, a number of immediate actions would be needed. A communications strategy would need to be activated. The European Commission and other European Union Member States would need to be involved. These matters are covered by chapter 2 of the plan. If BSE arose in sheep it is likely that there would need to be a ban on the consumptio n of at least some of the sheepmeat produced in the United Kingdom. It might, however, be possible to identify animals which could be consumed ‘safely’*. A crucial factor for this would be the availability of genotyping and/or BSE testing facilities. These issues are covered in chapter 5 of the plan.
29. A ban on the consumption of at least some United Kingdom sheepmeat would require the controlled disposal of sheep from the national flock, and that is covered by chapter 3 of the plan. To ensure that a disposal programme operated effectively an aid package would be needed (chapter 4 of the plan). Chapter 6 of the plan deals with the measures that might be put in place to re-build the sheep industry following a BSE crisis.
30. This plan should be regarded as a dynamic and living document. It will need to be kept up to date in the light of developments, for example in genotyping and testing capacity. The plan identifies a number of areas where further work is needed. The present version will be refined to reflect both the results of that further work and of the proposed consultation exercise.
31. It is not possible to predict with precision the implications of any finding related to BSE in sheep. The intention is that the contingency plan should provide a menu of actions which would allow the Government to respond flexibly and quickly to the wide variety of scenarios that might apply in the event of a crisis. Not all the actions set out in the plan would be appropriate to every scenario. Action would also need to be taken in a European Union context.
32. Market difficulties might occur as a result of concerns about public health which arise as a result of unfounded scare stories not based on any sound scientific information. That would be a different scenario to those considered in this contingency plan which assume that market difficulties would flow from advice from the FSA not to eat certain types of sheepmeat and/or a formal ban on its sale. Some aspects of the plan might nevertheless be relevant in such circumstances.
Action and Decisions Following Emergence of Test Results
This chapter sets out the steps the Food Standards Agency would employ, following the emergence of new research results, in the process of deciding whether the Agency’s existing advice to consumers and Ministers concerning the safety of sheepmeat needs to be changed.
The hypothesis on which this contingency plan is based is that at any time new research results could appear which might have significant implications for the Agency’s current advice on sheepmeat. Such results could come from a variety of sources and might or might not lead to an immediate decision that BSE had been found in sheep.
If the results were to come from a known experiment, for which the criteria for a positive result for BSE had been pre-determined, it might be possible to state on receipt of a result which met those criteria that it was a finding of BSE in sheep. In those particular circumstances there would be no need to seek further scientific advice in order to confirm the positive result. The Agency would then advise Ministers as to its new advice to consumers on the safety of sheepmeat, what furth er measures to protect consumers should be taken and whether any further testing or research was needed in order to provide a more reliable basis on which to take decisions. In formulating its advice, the Agency would take into account the current scientific knowledge and all other relevant factors, which might at that time affect the safety of sheepmeat.
In all other circumstances, that is, where test results could give rise to increased concern about the possibility of BSE in sheep but could not be considered immediately definitive, SEAC advice would first be required on the significance of the results in relation to the question of whether or not BSE may be present in sheep. If the presence of BSE in sheep were confirmed or, if not, SEAC considered that the results would nevertheless make the presence of BSE in UK sheep more likely, the Agency would at the same time seek SEAC’s advice on the implications for consumer safety. The Agency would then, on the basis of the SEAC advice, advise Ministers as set out in paragraph 1.1.3 above.
The Agency would welcome comments on the steps it proposes to employ, as set out above, in deciding whether its existing advice needs to be changed.
Immediate Action Following the Onset of a BSE Crisis in Sheep
- If BSE is found to occur in sheep, immediate action will be needed to protect human and animal health. This will include action to ensure that no "unsafe" sheepmeat enters the human food chain, and to recall sheepmeat, sheep products and sheep-derived products which are deemed to pose a threat and which are already in the system at the date a crisis emerges. The recall arrangements might need to include a buy-back scheme and a stocks d isposal scheme of the kind that were put in place for cattle. Further work is needed on the detail of such schemes, including who should run them.
This chapter of the plan considers these issues. It also deals with the communications strategy that would need to be activated immediately if a crisis arises. Finally, the chapter deals with the European Union dimension and import and export controls.
Section A: Protection of human and animal health
The Human Food Chain
Research on experimentally infected sheep indicates that the BSE agent is more widely distributed in the bodies of genetically susceptible sheep than it is in BSE-affected cattle and that it would be virtually impossible to separate all potentially infected tissue from the meat. For that reason, it would not be possible, as in cattle, to remove the large majority of any potentially infective tissue by SRM-type controls. Therefore, at the present state of kno wledge, if BSE were shown to be present in the national flock, the Food Standards Agency would have little option but to advise that only sheep which could be clearly demonstrated to be free of BSE could be allowed to remain in the food chain. It is also likely that the Agency would have to advise against consumption of goat meat (as goats are susceptible to BSE) and sheep and goat milk and dairy products.
In the event of finding BSE it might also be possible to allow some sheepmeat into the food chain based on its genotype. This would depend on progress in areas such as breeding for genetic resistance to TSEs and traceability. Another, longer term possibility would be to screen sheep using a diagnostic test. All such factors would be taken into account if and when a decision in relation to a finding of BSE in sheep had to be taken.
In the event that a ban on consumption of at least some United Kingdom sheepmeat became necessary, then potentially unsafe products already in the human food chain would presumably need to be traced and withdrawn. The information currently available would suggest that sheep or goat material is not used in nearly such a wide range of food products as that in which beef derivatives may be used. In relation to sheep meat usage, from figures provided by the Meat and Livestock Commission, ab out 75 per cent is sold as fresh or frozen meat (of which two thirds - or 50 per cent of total sheep meat usage - is sold retail and one third – 25 per cent of the total - for catering). The remaining 25 per cent is sold processed (20 per cent retail plus 5 per cent for catering), in products such as curries, meat pies and shepherd’s pies. In addition, sheep intestines are used to produce sausage casings. A limited amount of sheep meat also goes into pet food.
The Food Standards Agency has commissioned two research projects to assess the risk to humans were BSE present in sheep. One is a short-term project of an expected duration of 6-9 months. One of the objectives of the project is to identify how the carcases of lambs and ewes slaughtered for human consumption are utilised. The results of this work will assist in defining the categories of food product which may contain sheep material and may need to be withdrawn in the event that the Agen cy advises that at least some United Kingdom sheepmeat may no longer safely be consumed.
The Agency would welcome views on the actions proposed for the human food chain and suggestions about further action that might be taken.
Human and Veterinary Medicinal Products
There is no known alternative to the use of some substances of animal origin in the manufacture of medicinal products. A single, unified, set of guidelines on minimising the risk of transmitting TSEs are in force for both human and veterinary medicinal products. The guidelines apply at European Union level. Under European Union Directives all new applications for marketing authorisations, in the case of human medicinal products from 1 July 2000 and in the case of veterinary medicinal products from 1 October 2000, must be demonstrated to comply with the guidelines. All existing medicinal products must comply in the case of human medicinal products by 1 March 2001 and in the case of veterinary medicinal products by 1 June 2001. Guidelines to industry on sourcing and processing of materials derived from ruminants such as cattle, sheep and goats used in the manufacture of medicinal products for human use have been in place in the United Kingdom for some years.
The guidelines cover matters relating to the source of animals, the nature of animal tissue used in the manufacture of medicinal products and the production processes. A key feature of both sets of guidelines is that ovine or caprine material specified in the guidelines and intended for use in medicinal products should not be sourced from countries where there is a high incidence of BSE. It is highly unlikely that any human or veterinary medicinal product currently available, or about to become available, in the United Kingdom would contain products specified in the guidelines that had been sourced from United Kingdom sheep or goats. Where, for example, ovine material that falls within the scope of the guidelines is still used in veterinary products in the United Kingdom it is almost always sourced from New Zealand. From the relevant dates the Government will have information on the source of ruminant materials used in the manufacture of medicines that are covered by the guidelines. It is of course possible that, in the event of BSE being found in sheep, countries currently regarded as "safe" sources might no longer be so regarded.
Not all ovine and caprine products come within the scope of the guidelines. Under the unified set of guidelines milk and milk derivatives, and derivatives of hair and wool, are excluded although there are special provisions which effectively include milk in certain circumstances in the case of human and veterinary medicinal products. Where products outside the scope are used to make a starting material for the subsequent production of medicinal products, information about the use of the p roducts could only be obtained by contacting holders of marketing authorisations.
In the event of BSE being found in sheep, the information available to the Government from 1 March and 1 June 2001 should be sufficient to identify which human and veterinary medicinal products containing the sheep or goat products specified in the guidelines needed to be recalled in the light of the new information that gave rise to the crisis. There could be a problem, however, if the crisis called into question the safety of products not covered by the guidelines. Information about the ir use would not always be available to the Government. It would be possible, in advance of any crisis and on a contingency basis, to ask marketing authorisation holders and applicants voluntarily to disclose to the Government – or as an alternative to keep a readily accessible register of – information about any sheep and goat products not covered by the guidelines which are being used in medicinal products. This could be done as part of the compliance exercise under the European Union Directiv graph 2.2.6 above).
The Government would welcome views on this and on any other actions that might be taken on a contingency basis. The Government intends to seek the views of SEAC on whether they consider it possible that a future development on the BSE front might lead to a conclusion that one or more of the products currently excluded from the guidelines could pose a threat to human or animal health by being included in medicinal products.
Other Uses of Sheep- and Goat- Derived Products
Experience of BSE in cattle suggests that there will be a number of fairly obscure uses of ovine/caprine material which could only be uncovered by a thorough audit, starting at the bottom of the supply chain. With the help of the Department of Industry, the list below has been put together. It does not claim to be exhaustive as it was compiled without consultation of those outside Government. The list indicates that a full audit would be a fairly extensive exe rcise. As a starting point, it would be reasonable to assume that the full range of uses is likely to be as extensive as for cattle, and in the case of cattle the BSE Inquiry report criticised MAFF for not having undertaken an audit of the uses of bovine material when BSE first emerged.
A preliminary examination suggests that, if a BSE problem arose for sheep, the main issue as far as the safety of fertilisers is concerned would relate to organic fertilisers containing only one major nutrient. Fertilisers containing only one major nutrient fall outside the scope of the relevant regulations, and as a result information is not always available on what they contain. Some fertilisers are known to contain sheep-derived products. There is currently an explosion of organic fer tilisers on the market, for use for example in domestic gardens, and they are not subject to approval or registration procedures.
There are estimated to be about 265 cosmetics manufacturers in the United Kingdom. There is currently relatively little information within Government about the source of the ovine or caprine products they use. However, there is some information which suggests that, apart from tallow, little use is now made in the United Kingdom of animal material in the manufacture of cosmetics. Cosmetic products are regulated by the Cosmetic Products (Safety) Regulations 199 6. Directive 98/16/EC prohibited the use in cosmetic products of certain materials from bovine, ovine and caprine animals. It also included new controls on the manufacture of tallow derivatives. The Directive was implemented by SI 1998 No. 1727 on 16 July 1998. The Regulations are enforced by Local Authority Trading Standards Departments or District Councils.
All the following are classified as industrial raw materials, with the exception of chamois leather, which is a retail product. The upstream supply chain usage of these products is extensive:
- Nappa (grain) leather (mainly clothing)
- Suede leather
- Chamois leather
- Wool-on sheepskins (clothing, gloving, rugskins, seat covers etc)
- "Pickled" pelts (the raw material after wool has been removed from sheepskins by chemical processes)
- "Slink skins" (produced from stillborn and perinatal lambs, for gloving footwear and clothing use)
- Pickled grains/finished skins (desk tops, leather goods)
- Leather for leather goods and footwear derived from goat carcasses.
Figures from the British Leather Confederation suggest that there are 50 tanneries altogether in the United Kingdom. Only one or two are thought to deal in caprine leather. It is likely that tanneries deal either in cattle hides or sheepskins, although information is not available on the split between them.
Sheep carcases are used in veterinary schools for dissection and teaching purposes. It is possible that sheep carcases may also be used in other educational institutions for teaching or research purposes. Live sheep can be used for antibody production, and proteins for medical purposes are derived from the milk of transgenic sheep, goats and cattle.
It is likely that ovine material is used for many of the purposes which were identified for bovine material such as glues, greases and lubricants.
A full audit of the use of sheep- and goat derived products outside the human food chain?
As stated above, it would take a full audit to uncover all the uses of sheep- and goat- derived products and such an audit would be labour intensive. It would be important that it be adequately resourced. The Government intends to undertake such an audit. The Government also intends to ask SEAC whether they have any views on the relative risks that would be posed to human and animal health by the different types of products in which sheep and goat material is used, should there be a BSE crisis involving sheep. That would allow particular attention to be paid to any products that SEAC thought might pose risks should a crisis arise.
The Government would welcome views on any other actions that might be taken on a contingency basis in relation to these sheep- and goat- derived products outside the human food chain.
Section B: Communications strategy
One of the important actions following the emergence of a BSE crisis would be the activation of a communications strategy. An important principle underlying the strategy would be that it should operate on a United Kingdom basis, and should involve all interested parties both inside and outside Government.
The Government has drawn up plans for internal communications within Government should a BSE crisis arise in sheep. It has also drawn up plans for involving the European Commission and partners in other Member States. The Government would also wish urgently to brief consumer, industry, and trade groups together with representatives of the health sector, when a Ministerial announcement is made about BSE and sheep, should such an announcement prove necessary.
The Government would welcome any suggestions for additions or amendments to the following lists of bodies it would propose to brief:
- Association of British Abattoir Operators
- Association of British Pharmaceutical Industry
- Association for Science Education
- British Association of Sheep Exporters
- British Generic Manufacturers Association
- British Goat Society
- British Leather Confederation
- British Meat Federation
- British Meat Manufacturers Association
- British Organic Farmers
- British Retail Consortium
- British Wool Marketing Board
- Chartered Institute of Environmental Health
- Consumers Association
- Consumers in the European Union Group
- Country Landowners Association
- Farm Animal Welfare Council
- Farm Livestock Advisory Group
- Freight Transport Association
- Goat Advisory Bureau
- Goat Producers Association
- Livestock Auctioneers Association
- Local Authority Co-ordination Body on Food and Trading Standards
- Local Government Association
- Meat Hygiene Service
- Meat and Livestock Commission
- Minerals and Waste Topic Group of the Planning Officers Society
- National Consumer Council
- National Federation of Consumer Groups
- National Federation of Meat and Food Traders
- National Farmers Union
- National Office of Animal Health
- National Sheep Association
- Proprietary Association of Great Britain
- Royal Agricultural Society of England
- Royal Society
- Scrapie Information Group
- Skin, Hide and Leather Traders Association
- Small Abattoir Federation
- Tenant Farmers Association
- United Kingdom Renderers Association
- Womens Farming Union
- National Sheep Association (Scottish Branch)
- Shetland Flock Book Society
- Royal Veterinary College
- Scottish Agricultural College
- British Veterinary Association (Scottish Branch)
- Convention of Scottish Local Authorities
- Crofters Commission
- Scottish Crofters Union
- Shetland Agricultural Association
- Highlands & Islands Livestock Ltd
- National Farmer’s Union of Scotland
- Scottish Society for the Prevention of Cruelty to Animals
- Institute of Auctioneers and Appraisers In Scotland
- The Rowett Research Institute
- Institute of Animal Physiology & Genetic Research
- Scottish Federation of Meat Traders Association
- Scottish Association of Meat Wholesalers
- Scottish Quality Beef & Lamb Association
- Scottish Landowners Federation
- The Royal Environmental Health Institute of Scotland
- Health and Safety Executive
- Scotch Halfbred Sheep Breeders Association
- Scottish Consumer Council
- Scottish Food & Drink Federation
- Sheep Veterinary Society
- Shetland Sheep Society
- The Society of Border Leicester Sheep Breeders
- Scottish Greyface
- Scotch Mule Association
- Shetland-Cheviot Marketing Society
- Highlands & Islands Sheep Strategy
- Scottish Environment Protection Agency
- Scottish Retail Consortium
- The Royal Society of Edinburgh
- Shetland Fish Products Ltd
- McIntosh Donald Ltd
- United Fish Products Ltd
- William Forrest & Sons
- Dundas Chemical Co Ltd
- Dundas Brothers Ltd
- R McCulloch Ltd
- S & C Murphy
- Grayshill Knackery
- S B & Co
- Sacone Industries Ltd
- Hamilton (Irvine) Ltd
- Road Haulage Association (Scotland)
- Quality Meat Scotland
- Western Isles Council
- University of Glasgow Veterinary School
- British Society of Animal Protection
- Women’s Farming Union
- The Rural Centre
- Moredun Research Centre
- Aberdeen Consumers Group
- Food Industry Forum
- Scottish Consumers Association For Natural Food
- Scottish Borders Enterprise
- Sheep Veterinary Association
- Scottish Agricultural Organisation Society
- Shetland Animal Health Trust
- Directors of Public Health
- Chief Executives Health Boards
- Royal Colleges
- Directors of Environmental Health
- Department of Public Health, University of Aberdeen
- Department of Public Health, University of Dundee
- Department of Public Health, University of Edinburgh
- Department of Public Health, University of Glasgow
- Scottish Centre for Infection and Environmental Health
- Public Health Institute for Scotland
- Institute for Animal Health Neuropathogenesis Unit
- CJD Surveillance Unit
- Country Landowners Association
- Countryside Council for Wales
- Farmers’ Union of Wales
- Guild of Welsh lamb and beef
- National Farmers’ Union
- National Sheep Association
- Royal Welsh Agricultural Society
- Welsh Consumer Council
- Welsh Local Government Association
- Welsh sheep breed societies
- Young Farmers’ Clubs
- [Further public health contacts may be added]
- DAFRD Dublin – agree line on exports/imports.
- General Consumer Council (NI).
- LMC.
- NI Livestock Auctioneers Association.
- NI Meat Exporters’ Association.
- Relevant industry bodies. (See Below.)
- Ulster Farmers’ Union.
- NI Bleu du Maine Club
- Ulster Ram Breeders’ Association
- NI Bluefaced Leicester Sheep Breeders’ Association
- Ulster Vendeen Sheep Breeders’ Club
- British Charollais Sheep Society Ltd (Northern Region)
- NI Dorset Sheep Breeders’ Club
- Hampshire Down Sheep Breeders’ Association of Ireland
- NI Ile de France Club
- NI Cheviot Sheep Breeders’ Club
- NI Rouge De L’Ouest Club
- Suffolk Sheep Society (NI Branch)
- NI Texel Sheep Breeders’ Club
- Irish Beltex Sheep Breeders’ Society
- Irish Vendeen Sheep Breeders’ Club
- NI Goat Club
- National Sheep Association (NI)
Section C: European Union dimensions, and import and export controls in the event of a crisis
The European Commission is aware of the contingency planning exercise, and discussions have taken place with them about the details of the plan. The Commission is itself giving thought to contingency planning, and Member States are obliged under a Council and European Parliament Regulation to draw up contingency plans for new TSE outbreaks specifying the national measures to be implemented and indicating competences and responsibilities. Many aspects of the plan (notably the aid package) would be capable of implementation only with the agreement of the Commission. Moreover, developments since the start of the contingency planning exercise have made it look ever more likely that, if a BSE crisis arose, the United Kingdom would not be the only Member State affected. Union-wide measures are therefore likely in the event of a crisis, and the United Kingdom would not have total control on the form those would take. The proposals in this plan could however serve as an input to the Commission’s and broader European Union thinking. It has to be recognised that what may emerge at Union level may not be the same as what is set out here. Much would depend on how far the Commission are prepared to go in preparing a Union-wide plan.
The United Kingdom has opened bilateral contacts with some other Member States about the plan, and with the Republic of Ireland on land border issues. It is possible that a BSE crisis in sheep might be activated by developments in another Member State rather than in the United Kingdom. This plan could remain relevant in such a situation.
The Government would welcome suggestions on any further action that might be taken on a European level, or on any other aspects of the European dimension that should be taken into account in the planning exercise
- Experience with cattle indicates that increased checks would be required to ensure that any ban imposed, following a crisis, on the export of United Kingdom sheep was watertight. (At the moment, as a result of foot and mouth disease, an export ban is in place in Great Britain with effect from 21 February 2001). Increased checks would also be needed to ensure that any exports that were allowed to continue complied with the requirements that allowed sheepmeat to be deemed "safe ". As far as imports are concerned, the controls would depend on the nature of the crisis. If a crisis was confined to the United Kingdom, it would probably not be appropriate or possible to introduce import controls. A difficult situation could arise if in the United Kingdom’s view the evidence suggested that the likelihood of BSE in sheep was not confined to us, but if that view was not shared by the Commission and other Member States. That possibility perhaps increasingly unlikely. If the crisis were Union-wide there would need to be checks to ensure that imports (whether from other Member States or from third countries) met whatever requirements were in place to determine the safety of sheep.
The Government would welcome comments on aspects relating to imports and exports, particularly on the practicalities of operating controls.
if it becomes necessary to slaughter at least part of the United Kingdom flock
- The possibility of using diagnostic testing for BSE and/or genotyping to identify sheep that could continue to be allowed into the human food chain;
- The possibility of extending SRM controls;
- The possibility of limiting the problem to particular areas or particular flocks within the United Kingdom or within the European Union, for example by imposing controls on movement and by slaughter of flocks identified as infected or as having been in contact with infected animals;
- Strict controls over the disposal of potentially infected sheep.
Would it really be as bad as that?
Managing the disposal programme
This leads to the conclusion that the Government will need powers to manage the disposal programme in a way which allows it to direct individual farmers about when they should dispose of their sheep, and in what order. The legislation would need to be on a consistent basis throughout the United Kingdom, but separate legislation would be needed in each of the devolved administrations.
The Government thinks it would be right to draft the necessary legislation on a contingency basis.
The Government would welcome comments on these proposals.
- Government powers to direct when a producer presented animals for slaughter, and in what order;
- any Government aid to take account of need for orderly disposal and need to encourage maintenance of welfare standards in the case of animals on farm awaiting disposal;
- increase in inspections under animal welfare regulations of farms with animals awaiting disposal.
- the speed of the disposal programme.
Spreading the cull over several years could have some positive, although possibly short-term, environmental impact since it would allow land to continue to be grazed by sheep. There would still be a need to at least start work considering the future of the countryside in environmental terms with a reduced national flock.
The Government would welcome comments on the proposal to discuss tenders on a contingency basis.
The Government would welcome comments on this proposal.
Direct incineration of the whole carcase after slaughter
To deal with foot and mouth disease, about nine mobile incinerators were brought into the United Kingdom. These mobile incinerators would be unlikely to have any significant impact on the direct incineration capacity available for whole sheep carcases should BSE be found in sheep. There is in any case some doubt as to whether environmental approvals and licenses would be issued for the use of these incinerators in such circumstances. Mobile plant intended for ‘temporary’ use requires normal planning permission if it is to be used for more than 28 days in any 12 month period at the same location and, hence, also requires consideration of the need for an Environmental Statement.
The Government would welcome comments on the analysis.
Incineration of the products of rendering
The Government would, however, be grateful for the views of the rendering industry on these matters.
In addition to the above, Ministry of Defence sites might be available. Land under the ownership of or otherwise held and controlled by the Crown would be subject to the Crown Development procedures. While this removes the formal requirement for planning permission, the procedure requires the proposer of the development to give notice of their intentions to the local planning authority. It follows that the views of the authority must be taken into account in reaching a decision. In view of this, authorities have a legitimate expectation of meaningful consultation.
It is possible that, with an ordered slaughter programme, abattoirs will arrange for collection of animals from the farm without any need for the use of collection centres. As part of further work on the planning process, the Government will, however, keep under review the possibility of a need for collection centres. That will include keeping under review the implications for livestock markets. Renderers might be expected to collec t raw material from the abattoirs and deliver meat and bone meal to store. This would only leave transport of the meal from store to incinerator to be arranged by the Intervention Board, using a tendering arrangement. Restrictions in place for foot and mouth disease might impact on transport from farms to slaughterhouses.
The Government invites comments on these transport issues.
Under the disposal arrangements set out in the previous chapter, sheep producers would have no commercial outlets for animals slaughtered under the disposal programme and would in many cases be required to retain animals on-farm for longer than they would under normal market conditions. The Government would have legal powers to direct the disposal programme but it is questionable whether those of themselves would be sufficient to c ounteract what would be an understandable desire on the part of producers to dispose as quickly as possible of an asset with no value. It would be essential, for reasons of environmental protection and on the grounds of public and animal health, to ensure as high a compliance rate as possible with any disposal programme and to minimise the unauthorised disposal of animals. In addition to the legal sanctions, there would need to be economic incentives to farmers to comply with the disposal programme. H owever, any financial resources that might be applied to deal with BSE in sheep would not necessarily be unlimited and, indeed, might have to be re-directed from other activities.
The immediate aid package available to producers in the event of a crisis might have two elements:
aid at slaughter;
Views are also invited on how the retention aid might be calculated.
Timing of payments under the retention aid scheme
Making payments direct to producers
Implications for related areas of the rural economy
The Government is interested in having views on possible means of helping the rural economy to adapt.
Screening for ‘Safe’ Sheep and Segregation of Their Meat from Potentially Infected Sheepmeat
- Allowing into the food chain only the offspring of rams or ewes whose genotype makes them resistant to TSEs (that is, ARR/ARR rams); such offspring will be at least semi-resistant to TSEs (that is, they will carry at least one ARR allele);
- Allowing lambs into the food chain only if they have been genotyped and have been shown to be resistant or semi-resistant to TSEs;
- Allowing animals into the food chain only if they have been tested, either live or after slaughter, for the presence of a TSE and no TSE has been detected.
Allowing only offspring of resistant rams into the food chain
- At its meeting on 28 February 2001 SEAC advised that some degree of assurance could be provided for public health, if BSE were to be found in a small number of sheep, by a strategy which:
- Permitted only animals which were resistant or semi-resistant to TSEs (that is, which carried at least one ARR allele) to enter the food chain;
- Coupled this to an age cut-off, perhaps of one year; and
- Amended current SRM controls to remove intestine from the food chain.
Allowing only resistant or semi-resistant lambs into the food chain
- This second option would allow lambs into the food chain only if they have been genotyped and have been shown to be resistant or semi-resistant to TSEs. Many of the considerations set out above for the first option apply here too. But the scale of the genotyping requirement would be very significantly higher since about 20 million lambs would need to be genotyped annually at a cost of some hundreds of millions of pounds. That is well in excess of the genotyping capacity that will be available under the national scrapie plan. Genotype testing might possibly be viable on a limited scale. However, the scale and the practicalities of the level of testing mentioned above would appear to rule genotype testing out as a viable proposition for large scale lamb production for consumption. It might be used on a limited scale to maintain a smaller home market for lamb while rebuilding a ‘safe’ national flock.
- This third option would allow animals into the food chain only if they have been tested, either live or after slaughter, for the presence of a TSE and no TSE has been found.
- The sheep industry that would emerge from a major BSE crisis would be likely, at least in the short term, to be different from the existing one.
Allowing into the food chain only animals that have been tested for a TSE
The Government would welcome views on the identification issues outlined above.
Would there be a sufficient commercial incentive to persuade the industry to market "safe" sheep?
This raises a question about the viability of aiming, in the initial stages following any BSE crisis in sheep, at immediately putting a limited number of "safe" sheep into the human food chain. An alternative approach would be to aim in the first instance solely at building up, through genotyping, a breeding nucleus of "safe" sheep which would eventually increase the flock to a level that would again be commercially viable. The NSP aims to increase the levels of resistance in the national flock over time.
The Government would welcome views on this issue.
The cost of testing and identification
The Government would welcome views on these issues.
A post-crisis structure for the sheep industry
How to achieve post-crisis objectives
6.2.5 The Government will be undertaking further analysis in this area and would welcome any views on the rebuilding of the industry.
Summary of Issues for Consultation
Action and decisions following emergence of test results
|
|
|
|
|
|
Immediate action following onset of a BSE crisis in sheep
|
|
|
|
|
2.2.5 |
|
2.2.10 | |
|
2.3.2 | |
|
2.4.3 | |
|
2.5.3 | |
|
2.5.5 |
Implications for the farming industry and the rural economy
|
|
|
|
4.2.2 | |
|
4.2.3
4.2.3 | |
|
|
4.2.4 |
|
4.3.2
| |
|
4.3.3 | |
|
4.5.2
4.5.2 | |
|
4.6.1 | |
|
4.7.3 |
Screening for ‘safe’ sheep and segregation of their meat from potentially infected sheepmeat
|
|
|
|
5.5.6 | |
|
5.6.2 | |
|
|
5.7.3 |
|
Views on how the cost of testing and identification might affect uptake. |
5.8.3 |
|
|
|
|
Comments on the structure that should be aimed for after a BSE crisis. |
6.1.2 |
|
Views on the best means of achieving post-crisis objectives. |
6.2.1 |
|
6.2.5 |
Notits 28. september 2001
Ved CVO-mødet den 26.-28. september blev der, på anmodning fra den tyske delegation, fra UK delegationen fremsat en udtalelse med efterfølgende uddelte bilag, som vedrører forlydende om muligheden af, at det kan påvises, at der optræder BSE hos får smittet i UK under produktionsforhold.
Følgende referat af UK’s fremlæggelse den 26. september forventes at ville fremgå af referatet fra mødet (endelig tekst foreligger endnu ikke, men dette afsnit er en oversættelse af UK delegationens egne forslag til formuleringer til referatet, udformet den 28. september):
"På anmodning fra den tyske delegation informerede UK delegationen CVO-gruppen om følgende:
- UK’s myndigheder er i færd med at offentliggøre med henblik på høring et udkast til beredskabsplan for BSE i får i overensstemmelse med TSE forordningen;
- UK’s videnskabelige komité forventes i oktober (i forbindelse med et møde den 19. oktober) at overveje den nuværende opfattelse af den forskning, som er igangsat med henblik på den mulige forekomst af BSE hos får;
- Et af de igangværende projekter undersøger for tegn på BSE hos får, som i begyndelsen af 1990*erne blev diagnosticeret med scrapie. I denne undersøgelse bliver en "pool" af 3000 fårehjerner med scrapie indsamlet mellem 1990 og 1992 typebestemt. Vanskeligheden i denne undersøgelse er at skelne BSE fra de mange kilder til scrapie. Hvis BSE påvises, skal forskerne også forsikre sig om, at det kan udelukkes, at der er tale om krydskontamination af prøverne fra BSE-inficerede ko-hjerner. Yderligere undersøgelser af mulig krydskontamination er igangsat. UK’s egne eksperter mener, at det endnu ikke er muligt at drage nogen konklusioner af denne forskning;
- Siden den tilgængelige information ikke tyder på, at situationen har ændret sig, vil UK myndighederne ikke foreslå nogen ændringer på nuværende tidspunkt;
- UK myndighederne vil nøje følge forskningens resultater og det kan tænkes at de senere vil revidere rådgivningen i lyset af eventuelle nye resultater eller anbefalinger."
UK delegationen udelte den 28. september kopi af det nævnte udkast til TSE-beredskabsplan for får, samt kopi af UK regeringens reaktion på Phillips-rapporten om "UK BSE-inquiry".
I førstnævnte udkasts afsnit 2.2.1 skitseres hvorledes et dokumenteret fund af BSE hos får formentlig ville udløse forskellige stramninger i reglerne for anvendelse af produkter fra får og ged i den humane fødekæde, bl.a. overvejelser om forbud mod kød og mælk fra dyr, som ikke kan dokumenteres at være fri for BSE. I afsnit 2.5 redegøres der kort for, hvorledes situationen forventes at påvirke EU-Kommissionen og medlemsstaterne.
Ved direkte kontakt til UK og ansatte i Kommissionen kom det frem, at Kommissionen overvejer mange forskellige scenarier, og at der er bestilt en rapport fra den videnskabelige styrekomité om dette emne. Det menes, at TSE-BSE-ad-hoc-gruppen p.t. arbejder med et oplæg til denne rapport, som muligvis kan behandles på SSC-mødet den 18.-19. oktober.
Disse udmeldinger har ikke affødt nogen særlig umiddelbar reaktion hernede, hverken fra Kommissionen eller fra noget andet medlemsland.
Rådssekretariatet meddelte, at sagen formentlig vil blive diskuteret på rådsmødet i oktober (den 22.?).
I øvrigt henvises til, at UK’s Food Safety Agency har haft en dækkende omtale af sagen på deres hjemmeside siden 2. august 2001:
(www.foodstandards.gov.uk/press_releases/statements /st010802.htm).
I relation til fårehold i Danmark kan det bemærkes, at vi ikke har diagnosticeret scrapie i Danmark, at der er planlagt en intensiv overvågning fra 1. januar 2002 som anført i TSE-forordningen, at der er importeret får, formentlig også fra lande med scrapie, samt at det bør søges afdækket hvor udbredt brugen af kød- og benmel har været til danske får op til i dag.
Preben Willeberg