BSE Controls Review: Your response: letter from Dr Roger Dawson

Dear Sir

The Protection of the British Public from the Risks Associated with BSE

AHDA represents professional agricultural merchants qualified and registered to sell and supply animal medicines to farmers. Many AHDA members' businesses are dependent upon a viable UK sheep industry, and members were horrified to learn from press reports following FSA press briefings yesterday, that all UK sheep could be ordered to be slaughtered and destroyed. Although no evidence of any risk has been indentified, the damage this has done to the remaining confidence in the UK sheep industry cannot be underestimated.

The Phillips Report on BSE confirmed that after meat & bone meal was prohibited from being used in rations for ruminants, i.e. cattle and sheep, as some of us warned at the time, the inevitable leakage from its continued use in animal feed for pigs and poultry - from cross contamination and disposal of mis-manufactured pig & poultry feeds into cattle feeds at low levels - caused continued spread of BSE into the cattle population. It was not until March 1996 that this was recognised and stopped. Since then no meat & bone meal has been fed to British livestock. In addition to all the other measures taken to protect the British public from further exposure to BSE, this is one of the most important measures.

However, despite banning British beef the EU has consistently, even until the present day, refused to ban the feeding of meat and bone meal to pigs and poultry. This is despite clear evidence of some BSE in herds in many member states, and as is known from UK experience, if some cases are known, others will be present but undiagnosed. Therefore, meat and bone meal, including material from animals that probably have BSE or subclinical BSE, is at the present time being fed to pigs and poultry in many EU member states.

The Food Standards Agency's Review of BSE Controls (draft 27 October 2000) contains the following remarkable statement in paragraph 76:

There is concern among consumers and the industry that imported beef and other meat is likely to come from animals fed on material which is subject to less strict controls than is the case here. In the rest of the EU, although there is a prohibition on the feeding of ruminant material to ruminants, there is no bar to feeding it to non-ruminants. The problems of cross-contamination formerly found in the UK are therefore likely to be occurring elsewhere, possibly with similar results. We therefore urge the EU Commission to take action on problems of cross-contamination, especially in countries with a known risk of BSE.

For the moment one sentence from the above is worth repeating: The problems of cross-contamination formerly found in the UK are therefore likely to be occurring elsewhere, possibly with similar results.

This is part of paragraph 56:
The aim of the feed ban is to keep potentially infectious material out of feed for farmed livestock and so remove exposure to BSE. It is therefore the key control in eliminating BSE from cattle. Initially it took the form of a ban on the feeding of ruminant protein to ruminants. However, some cattle born after its introduction in 1988 continued to be affected by BSE. It was thought this was, at least in part, due to cross-contamination of ruminant feed by material from other livestock feeds which were not subject to the same controls.

Again one paragraph is worthy of repeating: It [the ban on feeding meat & bone meal] is therefore the key control in eliminating BSE from cattle.

Now we turn to imports of meat from outside the UK. Again the FSA‘s Review is quoted, first from paragraph 76 above: We therefore urge the EU Commission to take action on problems of cross-contamination, especially in countries with a known risk of BSE.

Then from the annexes to the Review:
Under the Single European Market, there are, and can be, no restrictions based on hygiene of production requirements on meat imported from other EU Member States. The only scope for any restriction would be on public health grounds, and a Member State would need a very powerful argument to sustain such a claim.

Again, one sentence bears repeating: The only scope for any restriction would be on public health grounds, and a Member State would need a very powerful argument to sustain such a claim.

What is the purpose of the Food Standards Agency (FSA)? One of its primary functions is to protect the British Public from food which has unacceptable risks associated with its consumption. Surely this is a cast iron case where the FSA must act to protect the British Public against the demonstrable risk of eating food from livestock which has eaten mammalian meat & bone meal? The FSA itself has stated that such a ban is "the key control", and is a vital part of UK controls. If it is right to protect the British public from this danger or risk in respect of meat and other livestock produce produced in the UK, surely it must be equally necessary to protect that same British public from similar dangers and risk associated with meat and other livestock produce produced outside the UK and imported into the UK?

All the FSA says it will do is to: urge the EU Commission to take action on problems of cross-contamination. The EU Commission has been "urged" to take action on this for many years, at least since the UK comprehensive ban in 1996, without success. It is clear that they are just not going to take this action. In any case why should the British public wait to be protected by the EU Commission, when their elected Government has established a Food Standards Agency to protect it from unacceptable risks from the consumption of food? Why will not the FSA provide that protection?

Perhaps the answer is this statement from the FSA: Under the Single European Market, there are, and can be, no restrictions based on hygiene of production requirements on meat imported from other EU Member States. Does this mean that the FSA is powerless to protect the British public against risks originating outside the UK? If so what a toothless and worthless body it is when so much the food sold in the UK is produced outside the UK. But, no, they go on to state: The only scope for any restriction would be on public health grounds, and a Member State would need a very powerful argument to sustain such a claim.

Well what are they waiting for? The FSA themselves have established that there is a very powerful argument to prohibit the feeding of mammalian meat & bone to livestock producing food, the FSA have stated that it is possible to introduce restrictions on imports from outside the UK, including the EU, when there is a powerful argument in favour of such a protective measure. Why then do they not immediately make such a recommendation?

British farmers are suffering hugely because they are bearing the cost of the necessary protective measures introduced to protect the public against any risk from BSE, but they see that same public is not protected against the risks of consuming food produced abroad in conditions of much greater risk to the public. It is a national disgrace that the UK government and the FSA are prepared to drive British farmers to the wall by their failure to protect the public from imports of unsafe food produced cheaply abroad under conditions that would not be accepted for UK produced food. No livestock produce should be allowed into the UK unless it can be proven that the livestock from which it was produced have never consumed any mammalian meat & bone meal. That would be a sustainable public health measure, which even if the government would not welcome, the FSA, as the protector of the public, must recommend if it is to build any credibility for itself.

I am considering this to be an open letter, and may copy it to others with an interest in this matter.

Yours sincerely
Dr Roger R Dawson
Secretary General