FAWC's
response,
of 21 May 2003 to a Defra consultation on Biosecurity Guidance
Thank you for the
opportunity to comment on biosecurity guidance for people coming into
contact with livestock.
FAWC welcomes advice
to farmers and others to remind them of the need for effective biosecurity.
We would like to stress that this strategy should be followed in good
times as well as bad; the biosecurity culture developed during Classical
Swine Fever and Foot and Mouth Disease should be maintained at an appropriate
level. We should be prepared for the next significant disease outbreak
but also use the strategy to reduce the effects of ongoing endemic diseases,
many of which have severe welfare consequences. Biosecurity is not just
for the major outbreaks.
Perhaps the guidance
could be presented and distributed in ways that are usable by each sector
when they need it. For example, leaflets sent to all farmers, agricultural
premises/contractors/suppliers, veterinarians and public servant liable
to go onto livestock units and available to the public at relevant outlets
(tourist offices, schools, etc.).
Turning to the detail:
On page 1, para 2
it should be added that, as well as prevention of disease entering or
leaving premises, it should also be aimed at limiting spread from shed
to shed and field to field within the same premises.
Page 2, para 6. Biosecurity
does come at a cost since disinfectants and other measures are not free.
While one might argue that farmers and others should have been doing such
things all along, this is extra to the status quo. One particular financial
consideration is the necessary "downtime" for vehicles being cleaned.
This may require an additional vehicle to be purchased and possibly lead
to poorer quality vehicles being used with welfare consequences for the
animals transported therein. Whilst we see no simple solution to this
dilemma, it should be borne in mind.
Page 4 of the main
guidance, para 5 (c) should "shows" also be listed?
Page 7. Para 2.1.1
add "spraying wheels"
Para 3.1.1 Add that
public should not deposit any waste or rubbish and should keep pets under
control.
Page 8, para 4.1 (a)
Include the footwell in the cleansing process as per Annex A, para 3.
Annex A, Para 1. Include
"especially if you have visited another livestock premises in the previous
48 to 72 hours"
Annex A, Para 3. Why
the "derogation" that vehicles may not be cleaned and disinfected before
moving to another premises. We feel it is an Achilles heel to allow this.
Products such as Virkon S can be carried safely in a cab in the dry powder
form and water obtained on site, so there should be no exceptions.
We welcome this guidance
as a positive step towards better disease control, and therefore towards
enhanced welfare protection for our livestock. To be effective, however,
it must be rigorously followed and not seen as a cosmetic exercise.