We are fully in support of Option 3 regarding the powers for
controlling future outbreaks of Foot and Mouth Disease as outlined in the document
Regulatory Appraisal of The Foot and Mouth Disease (
Responses to specific questions asked in the consultation document are outlined below.
11. Do you think we should retain the
following elements of the existing legislation (not required by the directive)
in controlling a future disease outbreak?
As long as the costs of retaining and implementing this existing
legislation are not greater than the benefits derived from implementing them
(in terms of controlling the disease spread and minimising
the wide ranging negative impacts on sectors that might be affected by a
breakout), then this existing legislation should be retained. The elements outlined are considered to be
logical precautions that should be undertaken to reduce disease spread in the
event of an outbreak of FMD.
12a. We intend to substantially repeat the cleansing and
disinfection requirements in place during the 2001 outbreak. How should these requirements be retained?
A more flexible approach is favoured as this means that conditions and risks on individual farms/slaughter houses etc. can be dealt with appropriately. Written instructions from the veterinary inspector should be given to those required to carry out cleansing and disinfection to make absolutely clear what is required of them and therefore reduce the risk of disease spread. A veterinary inspector is probably the best person to write the directions as they will have visited the premises and will have identified particular risks. Generic bio-security information needs to be provided to all livestock handlers and other relevant sectors during the event of an outbreak.
12b. We do not intend to impost additional controls on domestic
trade in vaccinated animals when the country is FMD free.
Agree that is makes sense to restore normal trading conditions (or
close to) as soon as practically possible.
12c. We intend to retain substantially controls on common and
unenclosed land used in the 2001 FMD outbreak.
Agree that this level of control on common and unenclosed land should
be retained.
12d. Will
there be additions costs or income, and thus industry price differentials,
arising from specified treatments, including heat treatment, required for
products from FMD vaccinated animals until we regain FMD-free status, before
placing them on the market? If so what
would be their scale?
Additional direct costs of production will be incurred if livestock
products are required to be heat treated before being placed on the
market. An estimation of the magnitude
of these costs cannot be made; however, they would be similar to the costs
incurred per equivalent unit in the conventional livestock sector. Small processors (the category which most
organic processors fall into) may be disadvantaged by having to outsource
specified treatments to larger processors that possess the necessary equipment
to carry out the treatment.
12e. What practical issues are there in the livestock and meat
processing industry arising from the requirement to apply specified treatments
to products from FMD vaccinated animals?
Organic meat is required to be processed at a certified meat processing
plant, and any plant that also processes conventional meat, must ensure product
separation at all times. Therefore, any
specified treatments must be carried out so that this product separation is
maintained. The need to heat treat meat,
for example, may also be extremely problematic for small processors as they are
unlikely to possess the equipment necessary to carry out such treatments and
would therefore have to outsource the process.
12f.
What would be the demand, here and abroad, for meat and animal products treated
as required by the directive.
There may be decreased consumption of organic products treated as
required under the directive if livestock products can be sourced from abroad
that have not been vaccinated and have not undergone any of the necessary
treatments. Having
said that, national consumption of meat and animal products may remain
unchanged if consumers are aware of the animal welfare implications of mass
culling instead of vaccination and product treatment as the major control
method for FMD.
Compiled by Dr Pip Nicholas
On behalf of Organic Centre Wales