Agency Chair delivers Wooldridge Lecture

Thank you for inviting me to give this year's Wooldridge Lecture, it is a great honour to be invited to follow in such distinguished footsteps of your previous lecturers.

I am also especially pleased because this lecture is an opportunity for me to acknowledge the central role of the veterinary profession in food safety in general and in the work of the FSA in particular.

This applies equally to the work of vets in relation to disease surveillance, in ensuring that regulations and good farm practices are followed, and in generally contributing to improved food standards.

In the early days of the Food Standards Agency I was asked during a radio interview whether I could absolutely guarantee, now that the FSA was in charge, that there would never be another food safety crisis like BSE.

No, I replied. There are bound to be new animal diseases, some of which will also affect humans, perhaps via the food chain.

That's the nature of Nature.

I then went on to say that next time the FSA will respond in a very different way, learning from the past mistakes of others.

• We won't bury the uncertainties.
• We will be open and transparent.
• We will continually reassess the risks in light of new evidence, listening to all points of view.
• And we will be prepared to change our response if the evidence requires it.

Two years later, the country was in the aftermath of the foot and mouth epidemic, which was not a food safety issue but nevertheless a huge crisis for farming and consumer confidence.

Experts will never know for certain how the virus got into Britain, nor, as the DEFRA risk assessment which was published earlier this year shows, are they able to quantify with any degree of certainty the magnitude of the future risk. There are simply too many unknowns for precise modelling.

Nevertheless a lot of people wanted to blame legally or illegally imported meat. So I was often asked whether or not the Food Standards Agency was going to ban imports of meat that could carry risk of causing a future epidemic.

I said that whilst more could be done to check on imports at point of entry and elsewhere, and more is now being done, the inspectors could never totally eliminate the risk of a new disease coming in.

But the Government as a whole could ensure that its response to any new outbreak of an introduced disease is as effective as possible. This will involve:

• Effective surveillance and horizon-scanning for new diseases. (I should at this point highlight the role of Craig Kirby, the Meat Hygiene Service vet who spotted the first confirmed case of foot and mouth disease in a sow at Cheale Meats abattoir in Essex. Craig is probably one of the few vets to have achieved National Hero Status in The Sun.)
• Understanding the factors causing the spread of any new disease.
• And rapid and effective responses in order to control a new outbreak.

The third animal disease I am going to refer to in detail today, is bovine tuberculosis. Like BSE and foot and mouth disease it is not a new problem, but it is one that has proved difficult to crack. My report on bovine TB and badgers in 1997 was the third in 17 years, following Zuckerman (1980) and Dunnett (1986).

The role of the badger is still much disputed not least on The Archers. Some think that it's beyond doubt that killing badgers helps to control TB, whilst others say the problem lies with modern farming practices.

The fact is that, whilst there is persuasive evidence that badgers contribute to the spread of bovine TB in cattle, we do not know their relative importance as a causal factor.

That is why my group recommended a proper trial to find out how effective different forms of badger culling would be as a control strategy. Whilst it was by no means comfortable to stick to the line 'we don't know, but here's a way of finding out', this was the only honest answer.

To briefly recap so far.

First, there will often be scientific uncertainties about risks from animal diseases. We should be honest and open about this.

Second, we can never guarantee that life is risk free and we should not falsely claim that we are aiming for this nirvana.

Third, minimising risk not only involves effective horizon scanning but also effective reaction when a potential problem is identified.

Before I move on to expand on these points in more detail, I want to briefly digress to say a few words about some recent developments that will have an influence on the veterinary profession in relation to animal disease and to food safety.

First, let me mention two reports. The outline animal health and welfare strategy for Great Britain was published by DEFRA in July, and the recent review of vets and veterinary services by the House of Commons Environment, Food and Rural Affairs (EFRA) select committee, is due out shortly. The former of these stresses the importance of the veterinary profession in relation to food safety, and I would guess that the second will do so as well.

Second, some developments that are taking place on the international stage.

In 2001 the OIE (the World Organisation on Animal Health) extended its scope on animal health to include food safety and animal welfare. This is a major change.

A large majority of the OIE's 140 or so Member countries support co-ordination and integration of the food safety activities of the OIE and the Codex Alimentarius Commission (the WHO body responsible for food safety), including co-operation on capacity building.

And furthermore, many Member countries are already strengthening the co-ordination of responsibilities for animal health and food safety at a national level.

Third, there are developments in training of vets.

Food safety and public health has traditionally not been a top career option for UK veterinary graduates. However, UK veterinary schools are now giving this area higher profile and this will hopefully lead to it becoming a more attractive option. This will be vital as the role of on-farm vets expands under the new 'farm to fork' EU hygiene legislation.

Finally, I want to mention the Working Group of the OIE on Animal Production Food Safety to develop the 'standard' on the role and functionality of veterinary services in meat hygiene throughout the food chain.

I am sure our own experience in the UK means that we have a great deal of relevant expertise to offer the OIE in its work.

Now, I return to my specific theme of animal disease and food safety, going into my three examples, BSE, FMD and bovine TB in more detail.

BSE
BSE has acquired an iconic significance in food safety circles. People talk of the 'post BSE world' with eroded trust in Government, in scientists and in modern methods of food production.

It is not so much the total number of people affected, mercifully still less than 150, but the dreadful nature of the disease, its irreversibility and its effect on young people that inspires dread.

Probably the Food Standards Agency's most difficult decisions have been those involving BSE.

In our first year of operation we were faced with the new finding of BSE in other European countries and had to give advice on whether or not to ban imports. Our risk assessment showed that a ban, whilst it might have been popular in some circles, could not be justified on public health grounds. Within the limits of estimation from epidemiological modelling, the risks from imported French beef and UK beef were comparable.

We had to communicate the uncertainty about BSE and sheep and deal with the aftermath of the collapse of the infamous 'sheep brain pool' experiment. I remember when I was just starting at the FSA, asking the then Minister with responsibility for food safety what kept her awake at night – she said 'sheep'.

Our straightforward and honest statement that BSE could have jumped into sheep through contaminated feed and that it could be there at a low level masked by scrapie, was radical at the time, but struck an emotional chord with the media and the public.

It did not, as some doom-merchants had forecast, cause a public panic or slump in lamb consumption. In fact surveys suggested that many members of the public had heard and understood the message and had not changed their eating habits as a result.

And, most recently, we have advised on the thorny issue of switching from the over thirty month rule to the European rule of testing OTM cattle before they are allowed into the food chain. The tests now have a proven track record (more than 20 million cattle have been tested in Europe), but because they probably do not detect pre-clinical BSE until the late stages, they probably entail an increase, albeit very slight, in risk.

As always, the first building block for the FSA has been to get the best scientific advice. We involved three groups of experts in the modelling, Imperial College, VLA and DNV consulting, and a raft of other experts in reviewing the work as it was developing.

Crucially, modelling the difference in risk between the OTM rule and testing involves making numerous assumptions. For several of these no more than educated guesses can be made.

So the modellers, guided by a joint SEAC/FSA expert risk assessment group, did two things. First they expressed the change in future risk relative to past risk. So, if past exposure has already committed 5000 people to die of vCJD (considered by almost all scientists in the field to be a very pessimistic view), how many extra deaths, using the same assumptions, would arise from the adoption of testing?

The answer is about 0.04 in 60 years. This number is not to be treated literally – it means 'a very, very tiny extra risk in comparison with the risk to which we have all been exposed so far'.

As a further check against the uncertainties in their assumptions, the modellers also recalculated the predicted extra risk taking the most pessimistic (rather than the most likely) assumptions that were considered at all plausible. This changed the figure from 0.04 to about 2.5 extra deaths in 60 years.

In short, the science says, not with absolute certainty, but with as a high a degree of confidence that we can get with imperfect knowledge, that the extra risk is minuscule.

The uncertainties in this estimate should not be hidden. BSE is still poorly understood and there may be surprises ahead. For instance, the genetics of human susceptibility are unknown, beyond the fact that all the confirmed cases so far belong to one genotype – homozygous for methione at codon 129 of the prion gene.

But, is it reasonable to change the rule, if it increases, even if by an incredibly small amount, the risk to public health? This is where science stops and judgement begins. Some people would simply say 'no extra risk, however small, is acceptable'. Not surprisingly, the Human BSE Foundation holds this view.

The Food Standards Agency based its recommendation to change to testing in a phased transition largely on the advice of a core stakeholder group made up of consumers, industry and others and partly on its judgement about balance.

Saving lives in any sphere of regulation does not come cost free, and the Agency's judgement is that the expenditure of an additional £300 million per year to maintain the current OTM scheme is not justifiable in terms of benefits to public health, even taking into account the uncertainties.

That is not, however, the end of the story. There are big practical problems to be solved before the switch to testing takes place. The infrastructure for testing must be in place, together with the mechanisms for matching test results with carcasses. The cohorts of BSE affected animals (which will have to be identified and probably culled to satisfy European rules) must be traced, and so on.

For farmers a change in the rule is good news and bad. Good because it signals the decline of the BSE epidemic to put us on a par with the rest of Europe. Bad because it could mean that the market is flooded with older beef and the price drops. And of course there is the challenge of exporting UK beef at about the same time as allowing OTM imports in.

Most of the task of implementing the testing rule falls to DEFRA and our advice to Health Ministers is that it should not be introduced until it is demonstrably robust and reliable.

The Meat Hygiene Service will have to undertake extra checks in the abattoir and the FSA has said that no change should be brought in until the money and training is provided to allow this to happen.

MHS vets are already central in the BSE controls and moving from the OTM rule to testing will introduce a number of additional key tasks.

Some people have said to us that a change to testing will undermine consumer confidence. Apart from the fact that the great majority of consumers have no idea what the OTM is, the important message for the consumer is that this is not about 'dropping our guard'.

It's about switching to a proven system, in which every single OTM animal is tested before it is allowed into the food chain, and in which more than 99% of any potential infectivity is removed in the specified risk material under MHS supervision.

It's also about recognising that whilst BSE has not gone away, the number of new cases has fallen to a trickle compared with the peak of the epidemic. Last year there were about 500 clinical cases compared with 37,000 in the peak year.

There have been about 65 cases in animals born since the complete feed ban in August 1996. Although these are still a mystery, the small number does show that cutting off the feed route has clearly dramatically cut down on new infections.

The risk modelling that underpinned the FSA's advice assumed that there would continue to be a trickle of new infections for the foreseeable future. If John Wilesmith's hypothesis is correct that the post August 1996 cases have resulted from contaminated feed coming into the country, then eventually the trickle should disappear.

For me, the biggest threat to consumer confidence would come from a major failure of the new testing rule, and from any attempts to cover up failures, large or small.

Given human error there are bound to be slip-ups, and it's vital that these are reported publicly. For the first six months of testing, the FSA will be commissioning an independent audit, the results of which will be published each month.

There will also be knock-effects of the change to testing. I will highlight one: the use of veterinary medicines. At the moment there is no need to test for residues in OTM animals because they are not eaten. But with the change to testing, there'll be a need for you in the veterinary profession to be sure that your prescriptions are compatible with older animals going into the food chain.

To check on the situation, VMD is going to propose to the Veterinary Residues Committee (VRC) that they increase surveillance for veterinary residues in OTM animals.

Foot and mouth disease
So much has been written and said about the FMD epidemic that you may feel that I could have nothing to add. And my remarks will be appropriately brief.

I just want to draw out two points.

The first is about my own involvement in setting up the modelling group that led to the contiguous cull policy.

In February 2001, my interest in the possible scale of the epidemic was not from the point of view of food safety, but in terms of its implications for the Meat Hygiene Service. I thought that their work in abattoirs would have been affected if there was to be a major disruption in movement of animals for slaughter.

So, with MAFF’s knowledge, I invited a group of the best UK experts in disease modelling to comment. As a result of a first meeting with the group, I asked MAFF to release all the data (by this time it was mid March 2001) and gave the modellers two weeks to come back with an assessment.

The meeting at which the Imperial and Edinburgh groups both reported that the doubling time for the disease was about nine days was the defining moment in the Government’s change of tack.

Meanwhile, vets on the farm were working flat out to help to control the spread of FMD, and the data supplied from this was key in informing the initial modelling work, as well as in its later evaluation.

To me this showed the importance of modelling alongside veterinary expertise, to understand the spread of the disease and potential efficacy of options for its control.

My second point is about vaccination. It is now generally agreed that reactive vaccination should be part of the control strategy for FMD in the future. This is the conclusion of both the Follett enquiry and the European Commission.

In Holland, where vaccination followed by slaughter was adopted, more animals were killed on a pro-rata basis than in the UK, so Follett recommended ‘vaccinate to live’.

But simply to say that ‘vaccination’ should be used is not to say how it should be deployed. Matt Keeling and colleagues have undertaken a detailed comparative analysis of vaccination strategies.

They conclude that the most effective vaccination strategy would be a ‘smart strategy’ vaccinating animals sufficiently far ahead of the spreading wave of the disease from the starting focal point, for them to acquire immunity before the disease arrives in new localities.

In April 2001, the Government was prepared to include vaccination as part of the response strategy, as was made clear at a meeting at Chequers. But this was firmly resisted by the farming and food industry, partly based on the assumption that consumers would not want to drink milk or eat meat from vaccinated animals.

The Food Standards Agency was unambiguous in its view that vaccination would not pose a food safety risk and that, since farm animals are regularly vaccinated against numerous diseases, there was no need to label products.

If the industry was correct in assuming that people would not want meat and milk from vaccinated animals, there does seem to me to be a bit of a paradox.

On the one hand most people want farm animals to be healthy, and if asked would probably acknowledge that this involves the prudent use of veterinary medicines both to treat and prevent disease.

On the other hand at least some consumers are uneasy about consuming food from animals that have been treated in this way to keep them healthy. I'll say a bit more on veterinary medicines in my concluding remarks.

Bovine TB
Bovine TB used to be big food risk. Before the days of pasteurisation and TB testing, 40% of cattle were infected and about 2,500 people a year died from bovine TB, some, perhaps many, as a result of drinking raw milk.

The rapid increase in the incidence of TB is illustrated by the fact that the rate of reported herd breakdowns in England and Wales has approximately doubled since the Krebs report.

The main concern for farmers is to reduce their risk of suffering a herd breakdown. In the 1997 report, the group I chaired made a series of recommendations for controlling the disease including work related to husbandry, badgers and vaccination.

But for the FSA, the question is whether or not bovine TB is a food risk.

Raw drinking milk and raw milk cheese can only come from Officially TB Free (OTF) herds. Milk from herds that no longer enjoy OTF status must be heat treated before it can be drunk or further processed for human consumption.

Our experts assessment is that these dairy controls adequately protect public health.

But what about raw milk cheese made before a herd loses its OTF status? The dairy hygiene regulations don't prevent the cheese from entering the food chain, but environmental health officers have to judge whether it could contain Mycobacterium bovis and therefore pose a risk to the consumer.

As far as I know there is no research on the survival of M. bovis during cheese production and maturation. With the increasing occurrence of bovine TB and the popularity of unpasteurised cheese amongst some consumers, this is something the Agency is considering.

Meat from TB affected carcasses may currently be sold for human consumption, provided that there is no more than one localised lesion.

When the FSA Board looked at our policy about 18 months ago, it asked for more research on the levels of M. bovis in animals salvaged for human consumption.

The preliminary results, which are still unpublished, show levels were higher than expected in reactor animals with no visible lesions.

So we have gone back to our Advisory Committee, ACMSF, for further advice on food safety. ACMSF's provisional view is that our results do not change the current risk assessment (which is based on human cases rather than affected cattle).

However, with the rise in bovine TB incidence, the risk in the future could increase, so the Agency will consider whether or not we need to do more to manage the risk. We also need to take into account what is happening in other countries, especially Ireland, where bovine TB is also a problem, and this in turn will be influenced by a report due out soon from the European Food Safety Authority.

Concluding remarks: looking to the future
First let me repeat my opening comments. I can say with some confidence that in the future animal diseases will continue to be a high priority for food safety. New diseases will come along, and both effective surveillance as well as horizon scanning will continue to be essential.

We will often have to make judgements about precautionary controls for a possible food risk when we do not have clear scientific evidence. I referred to BSE and sheep, where we have no direct evidence of a risk, but have taken a range of precautionary actions, including the removal of specified risk material and communicating with the public, against a possible risk.

Another example is Mycobacterium avium paratuberculosis (MAP). The evidence for a link between MAP and Crohn's disease is inconclusive. However, as a precaution the Agency is encouraging improved milking hygiene to reduce the risk of contamination.

We are also working, along with DEFRA, to look how it might be possible to reduce the number of cases of Johne's disease in cattle or even eliminate the disease completely.

And as MAP is a tough organism our strategy includes research, in collaboration with the dairy industry, into the processing conditions required to eliminate MAP, or at least to minimise the risk of it surviving the pasteurisation.

I've emphasised the importance of quantitative risk assessment and epidemiological modelling. I think in the future that vets and population modellers will need to work together to tackle animal diseases.

The current initiative being developed in Cambridge which will involve veterinary scientists and population modellers tackling campylobacter in chickens is an excellent example. The aim is to understand the dynamics of growth of the bacterium in chickens and how that relates to spread of campylobacter strains within flocks through a combination of using genetic markers and metapopulation modelling.

Campylobacter is a high priority for the Agency because, whilst salmonella in chickens is now down to about 5%, campylobacter is stubbornly high, with more than 50% of retail chicken contaminated.

The FSA and food industry strategy for reducing campylobacter will in the short term depend on better bio-security in production, but in the longer term will also involve a better understanding of the ecology, genetics and population dynamics of the disease. This mix of science and application is what I see as the way of the future.

Vets have a central role to play, not just for Campylobacter, but more generally in helping farmers to improve hygiene on farms.

What are consumer expectations for the future?

The FSA's consumer research shows that in food shopping, for many consumers price is still king. But people also want convenience (did you know that 63% of main meals eaten in this country every day are prepared in less than 10 minutes and a third in less than 5?), safety and quality.

The dominance of price has perhaps never been more vividly illustrated than by the TV images of people wheeling away supermarket trolleys of cut price beef on the day after Stephen Dorrell announced the link between BSE and variant CJD in March 1996!

But what about other consumer trends?

For an influential minority of consumers, standards of production, location of origin, and ethical concerns such as environment and welfare are a high and growing priority.

Sir Don Curry's report on the future of food and farming in England also suggested that perhaps one way in which English (and other UK) producers can differentiate themselves and compete with cheaper imports is by delivering better standards and a local supply chain.

One way for high production standards, beyond the minimum legal requirements, to be presented to consumers is through assurance schemes such as the Red Tractor.

Last year the FSA commissioned a review of 30 current schemes and concluded that, whilst in principle they are a force for good, at the moment they are confusing to consumers, not well understood, and not at all transparent. I wonder how many of you can say with confidence what difference having the Red Tractor logo on it makes to a piece of chicken you eat at home?

So change is needed if assurance schemes are to deliver for consumers. We have said what we think needs to be done. This includes more consumer involvement in setting up and running schemes as well as more transparency about the claims and rules of the schemes.

We have recently published guidance notes advising on best practice and we will check to see to what extent our recommendations have been implemented in a survey planned for 2005.

For animal production, two consumer concerns that we have identified are animal welfare and veterinary residues.

First, welfare. In the eyes of the public and the media, welfare of animals goes beyond simply being alive and productive, to embrace the 'five freedoms' recognised by the Farm Animal Welfare Council:

• Freedom from hunger and thirst.
• Freedom from discomfort.
• Freedom from pain, injury or disease.
• Freedom to express normal behaviour.
• And freedom from fear and distress.

The FSA does not have responsibility for welfare policy (this is DEFRA's responsibility), although it does have a role in welfare at slaughter through the MHS.

However, given consumer interest in welfare, it is of relevance to the FSA to know how, in the future, the welfare implications of different production systems will be assessed, so that consumer information can be based on reliable evidence.

For instance, a recent study of the welfare of dairy cattle has indicated that cattle welfare is not consistently better on Freedom Food farms compared with non-Freedom Food Farms.

The same study has also suggested that farm assurance schemes should focus more directly on welfare outcomes, as opposed to provision of resources and management procedures.

Now turning to veterinary medicines. Our food safety policy on both pesticide and veterinary medicine residues is based on risk.

There are those who argue that presence of any residue constitutes a danger to human health.

But we follow the advice of our independent experts that residues present at sufficiently low levels do not constitute any additional risk to health. The decision then becomes one of the acceptable level of safety.

One way in which we are proposing to strengthen our assessment of risk for both pesticides and veterinary medicines is to ask our expert advisers to consider the effect of exposure not just to one residue in one product but to look at aggregate exposure and cocktail effects.

However, for many consumers (including perhaps many of us?) this does not go far enough. Even where there is no risk, many of us, if offered a choice, would probably choose, all else being equal, to eat a piece of fruit or meat with no detectable residues. That is why the Agency's policy for the future is residue minimisation, going beyond safety and reflecting consumer preference.

This does not mean that we are in favour of prohibiting the use of veterinary medicines or pesticides. Veterinary medicines are, as I have said earlier, a key part of good animal welfare.

The surveys carried out by VMD shows that overall more than 99.5% of samples of meat for sale contain no detectable residues. But there are some black spots. For instance, amongst the chicken liver samples analysed for nicarbazin in 2000, 27.7% contained detectable residues and 15.6% of these were above the Maximum Permitted Level.

It is possible to produce meat without detectable nicarbazin residues by good husbandry and veterinary practice. We would see the 27% catching up with the 73%. Vets have in important job in helping farmers to do better.

A further important reason for prudent use of antimicrobials, is to prevent the spread of drug resistance. For this reason we support phasing out the remaining antibiotic growth promoters.

The experience in Denmark and Sweden, both of which have already phased them out, shows that it takes time for producers to adapt and that in the short term therapeutic use of antibiotics as well as mortality rates may increase.

Our general experience in the FSA, is that one way to bring pressure to bear on the industry, whether producers, retailers or manufacturers, is to carry out surveys and provide consumers with information. I am pleased to hear that the Veterinary Residues Committee is now about to do this.

In concluding, I hope I have been able to illustrate some of the many ways in which the veterinary profession is crucial in maintaining the safety and integrity of our food production and supply.

I am told that the Meat Hygiene Service is the biggest single user of vets in the country, and the role of the veterinary profession in protecting public health cannot be stressed too strongly.

This may be through disease surveillance and treatment on the farm, through checking animals and procedures in abattoirs, through providing support and guidance to producers in raising their standards and through research and policy development for Government.

You are also our eyes and ears out in the countryside for illegal and unacceptable practices, such as unfit meat scams, use of pesticides for sheep dips and unlicensed slaughtering.

In fact this is all put most succinctly in the opening sentence of Lord Selbourne's 1997 report for the Royal College of Veterinary Surgeons. 'Veterinary science is important to any society which is concerned about the health of farm and companion animals and the safety of food of animal origin.'