LAID BEFORE THE AGRICULTURE COMMITTEE
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
(a) transmissible spongiform encephalopathies
(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
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
The research as it stands is split into four
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
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
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 practicethe 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
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