Friday 3 July 2009

FSA Board to consider replacing OTM rule with BSE testing of cattle

Monday 7 July 2003

Ref: R726 - 39

The Food Standards Agency (FSA) board will consider recommendations to replace the over thirty months (OTM) rule with BSE testing at its meeting on Thursday (10 July 2003). The OTM rule, one of the three main BSE control measures, does not allow cattle over 30 months to enter the food chain. BSE testing has been evaluated and is used throughout the European Union.

Changes are being considered because of the continual and steep decline of BSE in the UK over the last 10 years and the effectiveness of other BSE controls. The main BSE control measures are the Specified Risk Material (SRM) controls, which remove over 99% of BSE infectivity that may be present in cattle. The third measure is the ban on feeding meat and bone meal to farm animals.

The FSA began a review of the OTM rule in July 2002 by setting up a stakeholder group whose recommendations were considered at a public meeting in March 2003 and whose final report has been subject to a three-month consultation throughout the UK.

The difference in risk to public health between the OTM rule and the testing of all cattle was recognised by the stakeholder group as very small, but the costs of the OTM scheme are very large. Based on the most realistic estimates, any of the possible changes could mean less than one additional vCJD case over the next sixty years. The worst case could be about two and a half additional cases over the next sixty years. The OTM costs £360m a year, compared to around £60m a year for the proposed replacement.

The risk assessments, directed and peer-reviewed by a joint FSA and SEAC (Spongiform Encephalopathy Advisory Committee) group, are available on the Agency website.

The stakeholder group recommended two options to take effect from January 2004:

complete replacement of the OTM rule by BSE testing of OTM animals entering the food chain; or
allowing all cattle born after 1 August 1996 into the food supply, with BSE testing required for OTM animals

The Agency Board will consider proposals that take into account practical issues raised during the consultation and that recommend replacing the OTM rule with testing in two stages.

Under the proposals OTM cattle born after 1996 would be allowed into the food chain, after being tested for BSE, from January 2004 but complete replacement of the rule would not take place until July 2005.

The risk assessments have taken a pessimistic assumption that human exposure to BSE to date could result in 5000 cases of variant CJD in the UK over the next 60 years. Based on this, the most realistic estimate was that the changes could mean 0.04 additional variant CJD cases in the UK over 60 years. Because of the assumptions made in the modelling, there is a 40-fold range of uncertainty. Therefore the estimate range would be between 0.002 to a worst case of 2.5 additional cases. This modelling includes casualty animals entering the food chain after being tested for BSE. Using the most realistic estimates, excluding casualty animals from the food supply would make a very marginal difference to vCJD risk, but add in the region of £300 million to costs over the next six years.

The core stakeholder group said that, whatever option is adopted, there should not be an unacceptable difference in risk between imported and home-produced beef. A risk assessment for Irish beef has now been carried out, which shows that, if the OTM rule were removed, there would be no greater risk from imported beef than from UK beef.

Sir John Krebs, Chair of the Food Standards Agency, said:

'Variant CJD is a terrible disease and in reviewing the controls the Agency has to ensure that public health is effectively protected. With the continual and steep decline of BSE in the UK the Agency has undertaken a major public review of replacing the over thirty month rule with BSE testing, underpinned by a thorough, science-based risk assessment. The Board will discuss what are the most appropriate measures to recommend to Ministers to protect public health based on the current and estimated future risks.'

' I would like to thank the members of the stakeholder group for their contributions over many months and those that have contributed during the public consultation.'

Notes to editors

This most up to date estimate is based on the recent risk assessment by DNV Consulting, in 'Exposure of the human population to BSE infectivity...' Philip J Comer and Paul J Huntly, DNV consulting; Journal of Risk Research Volume 7 (not yet published), available to see on the Food Standards Agency website www.food.gov.uk.

From a peak of over 37,000 clinical cases in 1992, UK BSE cases are currently declining by some 40% year on year. Last year 445 clinical cases were found and 594 cases were detected by tests.

There have been 137 vCJD cases in the UK to date.

The Rebublic of Ireland (ROI) is by far the largest exporter of beef into the UK (over 80,000 tonnes each year in recent years).

Attached below is Annex 3 to the July board paper on the OTM rule, which gives a comparison of costs of the different options of replacing the OTM rule with BSE testing, and the relative risk of deaths from vCJD.

Comparison of the financial costs, and risks of deaths from vCJD, for options to replace the OTM rule
NOTE: All figures are cumulative totals for the 6- year period 2004-2009 and are based on the latest knowledge and estimates available in June 2003. Except where indicated, all values are totals for the UK.

OPTION
A1
A2
B
C
Complete replacement from Jan-04
Complete replacement from Jul-05; animals born after 1-Aug-96 allowed from Jan-04 to Jul-05
Born after 1-Aug-96 from Jan-04
Born after 1-Oct-98 from Jan-04
1
Healthy and casualty cattle allowed into the food supply

risk as additional vCJD cases

1.1
most realistic estimate
0.05
0.04
0.04
0.03
1.2
range*
0.003-3.4
0.002-2.5
0.002-2.4
0.002-2.2

1.3
total costs (£million)
170
352
449
727

1.4
cost per additional life saved - most realistic vCJD estimate (£million)
-
13,309
21,496
28,274

Excluding casualties from the food supply results in an additional cost, but decreases the overall vCJD risk

A1
A2
B
C
2
Excluding casualty cattle from the food supply

risk as additional vCJD cases

2.1
most realistic estimate
0.04
0.03
0.03
0.03
2.2
range*
0.003-1.7
0.002-1.2
0.002-1.1
0.002-1.1

costs (£million)

2.3
total when casualties allowed (line 1.3)
170
352
449
727
2.4
plus casualty cull costs
358
326
304
256
2.5
total including casualty cull (£million)
528
678
753
983

2.6
cost per additional life saved - most realistic vCJD estimate (£million)
46,537
27,178
26,619
34,000

Notes

Casualties: vCJD estimates are based on the assumption that 50% of on farm OTM deaths are casualties

vCJD: estimates represent the number of deaths resulting from exposure to BSE infectivity during the period 2004-2009. Date of birth limits are assumed to be effective from July of that year. Range gives the extreme lower and upper limits of the estimate

* the range given shows the lower limit for GB only and the upper limit for the UK

Calculation details

Total costs (line 1.3) are the sum of:

(i)
A scheme similar to the OTMS for those animals excluded from the food supply, based on a cost of £426/animal

A1
A2
B
C

number of animals

450,000
765,000
1,440,000

(ii)
A cohort cull (see paragraph 27) in GB (NI costs would be additional, but significantly less than GB), based on a cull of 45 animals for each post 1/8/96 case at £1,500 and 6 for pre 1/8/96 at £750 per animal + testing at £27/animal and incidental costs.

A1
A2
B
C

number of animals
55,254
55,254
11,100
4,800

(iii)
Additional testing over that now required for surveillance purposes (which includes all casualty animals), based on £27/animal. This would include all healthy animals aged 30-42 months or born before 1/8/96 (excluding 10,000 pa included in current surveillance)

A1
A2
B
C

number of animals - one off
627,500
262,500

number of animals - ongoing
576,000
576,000
576,000
576,000

(iv)
MHS enforcement costs at £15million pa for GB

Casualty cull costs (line 2.4):

These are those casualty animals that would otherwise be eligible to enter the food supply, based on £426/animal, including admin costs.

A1
A2
B
C

number of animals
840,000
765,000
712,500
600,000

Cost per additional life saved is calculated by:

(a) Taking the additional cost for an option over that for A1-1 (complete replacement from 1/1/04 including both healthy and casualty animals in the food supply) which equals £169million

(b) Calculating the decrease in vCJD deaths compared to A1-1

(c) Dividing (a) by (b) then gives the cost per additional life saved

This is calculated separately for the vCJD most realistic estimates (lines 1.5 and 2.6) and the upper limit within the range (1.8 and 2.10 below). NB when the number of lived saves is a fraction of 1 the value of a life saved will be greater than the tota

A1
A2
B
C
1
Healthy and casualty cattle allowed into the food supply

risk as additional vCJD cases

1.5
upper limit for GB
2.8
2.0
1.9
1.7
1.6
upper limit for NI
0.61
0.50
0.46
0.43
1.7
upper limit total (as in line 1.2)
3.4
2.5
2.4
2.2
1.8
cost per additional life saved - upper limit vCJD estimate (£million)
-
203
279
464

2
Excluding casualty cattle from the food supply

risk as additional vCJD cases

2.7
upper limit for GB
1.6
1.1
1.0
1.0
2.8
upper limit for NI
0.12
0.08
0.08
0.08
2.9
upper limit total (as in line 2.2)
1.7
1.2
1.1
1.1
2.10
cost per additional life saved - upper limit vCJD estimate (£million)
211
231
253
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FSA Board to consider replacing OTM rule with BSE testing of cattle

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