Your response: from Adrian Holme
Do you represent a special interest group?
Spongiform Encephalopathy Research Campaign
Comment:
Paragraph 7 I understand that Maff had evidence that dogs can get BSE - is it not the case that TSE has been reported in hunting hounds fed on fallen cattle? I believe there was evidence to the BSE Inquiry to this effect (Iain McGill).
Paragraph 14 With Kuru all polymorphic variants were susceptible but with different incubation periods. Met/met at 129 had the shortest incubation period, followed by val/val, with the heterozygote having the longest incubation period. Kuru also showed an early peak age of onset followed by a later peak age of onset, i.e. the young were especially susceptible, but everyone was susceptible in the end. (Cervenakova et al, PNAS, Vol. 95, Issue 22, 13239-13241, October 27, 1998). It would not be at all surprising to find the same pattern in vCJD, and taking a precautionary approach we should take this possibility very seriously indeed.
Paragraph 15 As the draft points out, this figure of 136,000 maximum human cases is speculative, and included the assumption that only met/met people would be susceptible, see comments above. The cluster found at Queniborough gives grave cause for concern that the final figure could be higher.
Also Ghani et al assumed that the age distribution of the disease in the population would not change (in that it seems not to have changed so far). It is this that permits the calculation of 136,000. It seems too early to say this in that, by right, with humans becoming infected earlier in the century, we should see the age distribution rise as the people get older. I feel that the assumption is yet to be proved.
Paragraphs 16 to 20 I feel it is wrong for the FSA to concern itself with costs at all. Costs are a political question and should be dealt with by the government. The public needs a Food Standards Agency that can make recommendations to the government on what should be done to guarantee the safety of food. Let the politicians weigh up the balance between public safety and cost. After all it is only the politicians who are directly accountable to the public. For too long politicians have been able, in their decision making, to hide behind 'experts' who appear to have made their own unnaccountable judement of cost/benefit.
Paragraph 22 "Because of the significant decline in the UK BSE epidemic, we can say that even without the present controls, exposures to the BSE agent from the food-chain now will be considerably lower than when most of the present cases are likely to have arisen." Of course this is logical. However the OTM rule will also hide the epidemic if a proportion of animals is slaughtered at an earlier age than before, without having the time to develop symptoms.
paragraph 33 I understand from a former Maff employee that their studies showed chickens developing disease after BSE exposure, although they did not develop an encephalopathy as such.
paragraph 35 "The two principle controls to keep infected material out of the food chain are the Over Thirty Month Rule (OTM Rule) and the removal of parts of the body that could carry infection (Specified Risk Material (SRM))".
The SRM rule does not remove all parts of the body that 'could' carry infection, merely those parts with the highest demonstrable levels of infectivity. In fact muscle has been shown to carry TSE infection in a number of species. The fact that BSE infection in muscle has not been demonstrated could be due to the fact (as far as I am aware) that the most sensitive tests (cow to cow feeding or injection) have not been carried out. It should be noted (obviously perhaps) that we can eat rather a lot of it, and that peripheral nerves also penetrate the muscle.
These comments also apply to paragraph 38.
Paragraph 39 The statement that the FSA would expect to have to wait until the middle of next year before stating that cattle born after August 1996 are not a risk to humans, is extremely like that given out by the French last year and lambasted by the Government and the media. Could the FSA explain how they have reached this figure, who carried out the mathematics, and whether other members of the Government, and Maff are aware that the EC was misled?
paragraph 42 The notion that animals 'close to developing' clinical disease, or 'which would develop clinical disease within 12 months' are the only ones capable of transmitting BSE/vCJD is of course speculative. Clearly no such studies could be performed on humans!
I do not think it is for the FSA to speculate about the commercial implications of the rule. Leave that to the politicians.
paragraph 61 Tallow is still permitted for use in calf milk substitute - an inexplicable omission.
Conclusions The report has much to commend itself in terms of not relaxing the present BSE controls.
There are however areas omitted entirely which give cause for concern.
1. It has been reported in the Sunday Times (Sept 24, 2000) that 22,000 tons of cow material including blood, gelatin and tallow are fed to cows each year. Clearly this is of great concern and must end forthwith (as indeed Professor Collinge has said).
2. The report makes no mention of any risks from milk. Yet Maff has only recently commissioned a study in cattle to investigate the risks. (Guardian, August 7, 2000).
In talking about the risk to the public, it should not be assumed that everybody is in the same boat. People not previously exposed to BSE (young children and visitors to the country) merit special protection. The majority of the population has already taken the bulk of the risk.