Select Committee on Agriculture Memoranda



Memorandum submitted by the Royal Society for the Prevention of Cruelty to Animals (R 2)

  The RSPCA is grateful for the opportunity to comment on the scale and focus of the Ministry of Agriculture's research into:

    (a)  transmissible spongiform encephalopathies (TSEs); and

    (b)  the possible consequences for human and animal health of intensive farming methods,

  taking into account the issues highlighted and the conclusions drawn by the recent BSE inquiry.

  In relation to part (b) we will confine our response to that concerning animal health and welfare. However, as with any zoonosis both human and animal health are inextricably linked, for example, the total ban in March 1996 of incorporating mammalian meat and bone meal (MMBM) in any livestock feed (BSE (No 2) Order 1996), was a reaction to the discovery that BSE was probably transmissible to humans.

  The Society would like to emphasise that TSEs are serious animal welfare issues. It is of some concern that few, if any references are made in the literature.

 (a)   Transmissible Spongiform Encephalopathies (TSEs)

  There is a considerable corpus of knowledge about spongiform encephalopathies in animals, particularly Bovine Spongiform Encephalopathies (BSE) and Scrapie, which has enabled us to better understand these diseases. However, there are still some fundamental questions to be answered, for example, how BSE developed and why a cow or cows developed the disease.

  Although some schools of thought feel that we may never know the answers to such questions, the Ministry of Agriculture, Fisheries and Food's (MAFF) TSE research programmes have been developed in order to progress our knowledge related to these complex issues. To the end of the 1999-2000 financial year 195 projects have been commissioned thus far at the cost of £76 million.

  The programmes have been developed under the guidance of SEAC and its predecessors and have been subject to peer reviews.

  The research as it stands is split into four main categories:

    —  the epidemiology of TSEs;

    —  the pathogenesis of TSEs;

    —  the diagnosis of TSEs; and

    —  the transmission of TSEs.

  The RSPCA is largely supportive of the rationale underpinning this research strategy.

  As the incidence of BSE continues to decline in the United Kingdom, it bears testimony to the fact that the measures which have been established to date, to protect both human and animal health appear to have been reasonably successful in achieving this objective.

  One of the main issues which now needs serious consideration is that of diagnostic tests in order to be able to establish as far as possible, an ante-mortem test (other than clinical symptoms) for BSE, so that the risk of misdiagnosis of the disease is avoided.

  This will minimise the risk of the welfare of the animal being compromised, because there have been examples in the past of animals with BSE having been diagnosed as having hypomagnesaemia or even milk fever. The consequence of this is that the animal may have stayed on the farm for longer than it should have, in the hope that it would recover. This may entail considerable distress to the animal. A robust test, which could be applied on-farm, would avoid such confusion. This would also help to identify carrier animals, ie those animals which are clinically infected, but do not show any symptoms.

  Within this context, the Capillary immuno-electrophoresis (ICE) is a newer test which can be used on live animals (sheep), but needs further evaluation.

  Other diagnostic tests which may be of use are those associated with mass screening of material from slaughtered sheep for TSEs. Similarly, a test to distinguish BSE from Scrapie (as noted in Paragraph 90 of the Food Standards Agency review of BSE controls), although some scientists do not believe that BSE is present in the national sheep flock. It may also prove useful to explore the extent to which TSEs may be present in other species including monogastrics.

  The RSPCA would offer qualified support to the SEAC (Spongiform Encephalopathy Advisory Committee) Research and Surveillance strategy for TSEs in sheep. This strategy also gives serious consideration to the techniques associated with diagnostic tests noted above.

  However, much of the research requires the use of mice. Is it safe to assume that the procedures involved in this research are subject to a full ethical review process?

  The literature acknowledges that many mice are used in the research and are subjected to procedures such as intradermal inoculations under general anaesthetic, the effects of which will be with them for the whole of their life. The Society acknowledges that some of the information which is gained by some in vivo research is necessary in developing valid in vitro diagnostic tests.

  It cannot be over-emphasised that the research which is being conducted must be done on a united basis, avoiding the academic divisions which are often apparent amongst research agencies.

  The policy must be to reduce the number of animals used in the research; refine their quality of life by ensuring that their living conditions take due account of their basic needs and eventually replace the mice with in vitro techniques.

  One could question the validity of using mice for some of this work because of the species "barrier effect" which can influence the results of the research. Hence, in the mouse we can see the clinical symptoms of Scrapie and BSE which are different from those symptoms seen in sheep and cattle.

 (b)   The possible consequences for human and animal health of intensive farming methods

  This statement is to some extent a little simplistic, because it does not acknowledge the very important area of animal welfare, which differs from animal health. An animal can be physically healthy and yet experience poor levels of welfare, for example, through inconsistent stockmanship etc.

  The RSPCA is opposed to all forms of farming which cause, or have the potential to cause, distress or suffering.

  The key conclusions of the Executive Summary of the Report of the BSE Inquiry includes a statement that:

    "BSE developed into an epidemic as a consequence of an intensive farming practice—the recycling of animal protein in ruminant feed. This practice, unchallenged over decades, proved a recipe for disaster."

  This appears to be the only substantive reference to intensive farming practice in the Findings and Conclusions of Volume 1 of the BSE Inquiry Report. This statement is to some extent misleading, in that any conventional farmer who fed concentrates at any time of the year during the period in question would almost certainly have been feeding his animals recycled animal protein.

  An example of this would have been the extensive sheep or beef farmer who may have supplied supplementary feed in the form of concentrates for his animals. In other words, the practice was not intrinsically "intensive" (in terms of the generally accepted use of this word). It must be remembered that many farmers would have taken advice from their feed merchant etc, on which type of concentrate to feed.

  In order to answer this question in a meaningful way, we need to address MAFF's Research strategy for 2001-05 and I enclose the RSPCA's response made to MAFF on this strategy [not printed]. I also enclose the RSPCA booklet on Farm Animal Welfare.

  I hope that these comments are of some use and if you would like to discuss any of the points in greater detail, please do not hesitate to contact me.

22 January 2001

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