The Royal Society of Edinburgh (RSE) is pleased to respond to the UK consultation on contingency plans for the possible emergence of naturally occurring BSE in Sheep. This response has been compiled by Vice President, Professor Andy Walker and the Research Officer, Dr Marc Rands, with the assistance of a number of Fellows with considerable experience in this area.

Lessons have been learnt from the epidemic of bovine spongiform encephalopathy (BSE) and although there is no evidence that there is naturally occurring ‘BSE’ in the UK sheep flock, it is essential to have a contingency plan for responding, should it be detected.

The science of the present plan is derived from a combination of the facts as they are known for BSE and scrapie. This is based on the ‘best scientific analysis’ provided by the Government's advisory committee on transmissible spongiform encephalopathies (SEAC), the Food Standards Agency and others. However, one of the scientific ‘failures’ with BSE in cattle was that it based the safeguards and protection policies on what was known about scrapie, and BSE in cattle turned out to be different. Therefore, if BSE was ever discovered in sheep, it could be questioned whether sheep BSE would act in exactly the same way as cattle BSE. Experimental transmission of BSE to sheep has resulted in a more tissue-diverse prion manifestation than has been observed in cows, which is more akin to variant CJD in man. Whether BSE in sheep would represent a greater risk to human health (with more tissues affected in sheep than in cows) or a lower risk (due to filtering through a secondary host and further possible species barrier) is difficult to determine.

There is also a question over the purpose of the current plan and its target audience. On the basis of the past experience with BSE in cattle (and also the Foot and Mouth Disease outbreak), there is a need for a plan that sets out clearly and simply what will happen under a given set of circumstances, and aimed at the agricultural industry, the media and the general public. Judged against that need, the current document is too complicated and discursive and something much closer to an ‘action plan’ will be required. However, against this background the document is a fair summary of current understanding and the strategic steps set out are logical and defensible.

The specific questions in the consultation paper are now addressed below:

The EU Dimension

While policy should not be driven by likely public reaction, there is no consideration of the likely general impact of any UK plan which might be different (and seen as more relaxed) than a parallel EU plan. This seems unwise when the UK is the country which has had the highest prevalence of BSE, and based on previous experience with BSE, it is unlikely that Government statements will reassure in relation to the risk which BSE in sheep might pose to public health.

Age cut offs: differences between SEAC advice and EC guidelines

Potential problems if age cut-offs in the European Commission’s guidelines take precedence over those recommended by SEAC

Every effort should be made to bring the EU guidelines on age cut-off, for animals permitted into the food chain, into line with those developed by SEAC, as the SEAC figures are scientifically based. Current evidence indicates that both ARR heterozygous and ARR homozygous sheep are resistant to Transmissible Spongiform Encephalopathies (TSEs). Therefore they should not present a risk in the food chain and only reducing the age to 12 months for the former, as recommended by SEAC, should be a more than adequate precaution, as opposed to the EU proposal of 18 months for ARR homozygous and 6 months for ARR heterozygous sheep.

If the EC guidelines take precedence over those recommended by SEAC, the larger cull would be more expensive and might represent specific problems for Scotland where hill farming is more prevalent. However, in the event that this objective turns out to be unachievable, the UK will have little choice other than to follow the EU guidelines, although consideration could be given to a two-stage process, adopting more stringent EC guidelines immediately following detection of BSE in sheep. This could then be reconsidered once the true extent of the phenomenon in sheep is known. In addition, as a contingency, there may be a case for exploring with the UK supermarkets whether they would be prepared to develop the light lamb market.

The disease

What measures might be possible for the goat sector given that genotyping would not be an option

There could be a case for treating goats separately from sheep, as their methods of husbandry are different from those of sheep, with goats only to be brought under the legislation if a BSE-like condition is confirmed in them. In that eventuality all goats above the agreed cut-off age would have to be destroyed together with their products, including milk until the condition has been eradicated from the national herd. Importation of unaffected stock from a BSE free country would provide a basis for rapid restocking in the UK .

Communications

Which interests should be represented on the Defra core Stakeholder group

There should be a co-ordinating UK Stakeholder group, with representation from devolved administrations, and interested sectors, such as the sheep industry, goat breeders, the veterinary profession, the meat industry, consumers’ associations, the food industry, animal/veterinary scientists, and the CJD families' group. Such a group would also provide the focus for liaison with the EU. Drawing from this group, Defra and the devolved administrations should each communicate to their own industry and the FSA should take the lead in communication to consumers.

Disposal of animals

Whether the RPA or farmers themselves should be responsible for making arrangements with abattoirs for their animals to be collected and disposed of

To ensure the smooth running of the scheme and to reduce the possibility of abuse, the Rural Payments Agency (RPA) should co-ordinate the disposal of animals. However, the present plan places a substantial burden of organisation on the RPA, with a high risk of overload and of breakdown in the relatively complex administrative arrangements. A simpler approach, in which farmers make local arrangements following authorisation, would seem to have advantages. Consideration of pasture contamination could also be part of ongoing measures to monitor prion disorders in flocks following a cull.

Implementation issues

Age verification in sheep

Veterinarians will advise on age verification in sheep but the age of eruption of the permanent incisors can vary according to breed and feeding. It would be better in financial planning to allow for the date-based scenario, with only lambs slaughtered before a certain month each year being allowed into the food chain. However, 31 December would be too early for many hill breeds which make up most of the premium sheep killed in the first three months of the year (they are normally born from April onwards the previous year and are known as hoggets by this time).  A cut-off point of 31 March would be more appropriate for them.

Annexes

The draft partial Regulatory Impact Assessment

The impact assessment is appropriate, given the scenarios tested, and while the financial costs can be only very approximate, they are clearly considerable and highlight the scientific and economic importance of developing generic testing systems for TSEs. However, the psychological cost to the farming community is not mentioned and will also be considerable. A cull of sheep and goats, following the epidemics of BSE and foot and mouth disease, will be devastating for farming communities and a possibly a death knell for specialised breeding herds (particularly of goats).

Additional Information

In responding to this consultation the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: A contingency plan for the possibility of BSE in sheep (January 2002) and National Scrapie Plan: Scrapie Flocks Scheme (February 2003).

August 2004