DEFRA CONSULTATION ON THE CONTINGENCY PLAN FOR THE EMERGENCE OF NATURALLY OCCURING BSE IN SHEEP

Thank you for the opportunity for FAWC to comment on the contingency plan for the emergence of naturally occurring BSE in sheep. This forward planning document is to be welcomed and seems to cover many of the salient points.

The main areas of welfare concern seem to be covered, i.e. stopping the build-up of animals when there may be insufficient feed, and whilst restricting their movement. Welfare during transport and at slaughter are other areas for concern, and it will be important for all those involved with the animals to maintain high standards of welfare as the animals may be seen to be of lower worth and financial value as they are not going into the food chain.

Members read the plan with interest, particularly in its construction bearing in mind the nature of any outbreak as compared to contagious notifiable diseases. We appreciate that the document is in its early stages and much has yet to be decided both within the UK (Defra, FSA, etc.) and in Europe. It is apparent that Europe needs to agree some major issues, e.g. SRM’s, age and tests (laboratory/inspection (dentition)) at which sheep would be included or excluded from the human food chain.

Members suspect that there may be an underlying assumption that having an ARR allele in the genotype will confer resistance to BSE as well as to Scrapie. This assumption must be supported by scientific data.

The major welfare issue in any natural occurrence of BSE in sheep will be in relation to managing any cull. It is noted that an on-farm cull appears to be excluded – yet all other matters in arranging any cull, from the time of restrictions on any holding will be of paramount importance otherwise sheep will potentially suffer unless all welfare considerations are exercised by the keeper and appreciated by the RPA and its agents in administering the cull scheme. It is noted that slaughterhouses will be specifically approved for any cull, no doubt removing them from conventional slaughter for human consumption. There must be sufficient slaughterhouse cull capacity for the numbers of sheep envisaged. Sheep subject to any cull may be transported over long distances if the slaughterhouses participating in the scheme are sparsely spread?

A few points to consider in the order that they occur in the document:

Paragraph 20 highlights that there is risk of infectivity in dairy products and yet there is no mention of how this is to be dealt with. Milk production cannot be put on “hold” or delayed until the result of blood tests come through and there are animal welfare implications in not milking stock as well as environmental concerns about disposal of milk. Defra should perhaps be encouraging the small number of milk sheep producers to genotype flocks now, perhaps matching the costs of testing.

Paragraph 60 - In the weeks post lambing there is perhaps less of a welfare issue as grass growth is increasing and lambs are not ready anyway. It is later in the year when problems might arise as farmers are trying to get stock away before winter. If this is a contingency plan Defra should be aware of the change in risk on a month by month basis. Where the priority is is going to change through the cycle.

Paragraph 74 - Need to ensure the capacity is there and the locations are suitable. Premises will be making commercial decisions as to whether they want to “assist” Defra or not.

Paragraph 75 – By rough calculation the incidence of group 1 and 2 animals is likely to be between 50-75% in the “slaughter” population. This plan implies that the first course of action will be to kill everything rather than blood test and allow group 1 and 2 into the food chain. There are stand-by plans for producing vaccine and vaccination teams for FMD but no mention of having blood sampling teams and lab capacity ready to deal with this scenario. Getting animals into the food chain, reducing the number of animals needing to be killed and then incinerated and reducing compensation to farmers must be the better option. What resources would be needed to test and tag 300,000 sheep a week?

There are concerns that rams of the susceptible genotype might be castrated rather than slaughtered. These rams cannot be used for breeding and castration of adult animals should not be considered, better they are disposed of with all necessary care.

Comments on specific issues raised:

Age cut offs

Without individual ID from birth it will be difficult to accurately age animals. Date cut off coupled with dentition checks might be the best compromise. Priority should be to get the lambs genotyped and into the food chain. The cull animals, as they carry greatest risk, should go straight for disposal, however welfare provisions must be ensured.

Options for goats

Is Defra aware of any case of scrapie type disease affecting goats? Reading para 19 it seems that if BSE was clinically found in sheep that controls would automatically extend to goats. The vets may have other views but unless there is some sort of proven transmission link such as contaminated feed then there is no justification for this.

Interests on the stakeholders group

Animal welfare should be represented, perhaps by a member of FAWC.

Arrangements for disposal

Can only be efficiently controlled through some form of central operation. Would agree RPA are probably best placed to do this.

Impact assessment

The value of ARR/ARR animals is likely to rise if there is not a complete collapse in the market for lamb. It might be economically viable for farmers to test sheep in order to place them on the market. Could this be facilitated, i.e. is the testing procedure in the public domain, and how might labs be accredited by Defra to provide this service?