Index

• The One Thing Nobody Wanted to Happen; A Chronology of BSE in the UK
  • Early on: scientific curiosity on a novel cattle disease
  • A new cattle disease met other bugs
  • Period of transition - first doubts arose
  • Centralisation of power inside MAFF  monopoly of BSE cattle and infectious material and a database
  • Hypothesis of the cause of BSE  or why industry does not always know best
  • The first regulation  the protection of animal health
  • The appointment of the Working Party on BSE
  • The delay of publication of scientific advise as policy response
  • The critique started to shape up
  • Research needed and research carried out
  • Dissent views on BSE/CJD
  • Protecting public health
  • The difference between requirements and reality
  • The SBO ban as precautionary measure  "over the top"?
  • After implementing the ban the risk "disappeared", somehow
  • Mad Max and the pet food industry
  • Stalemate between 1990-1996
  • "The one thing that nobody wanted to happen"  the first cases of nvCJD

  • Summary: The UK BSE case

• 4The Role and Conduct of the Scientific Advisory Committees
  • 4.1 The UK Advisory Boards on TSE  Committees of the "Great and Good"
  • Summary of the UK advisory board system
  • 4.2 The German Advisory System on TSEs: a System of Ad Hoc Groups
  • Summary of the German advisory board system
  • 4.3Common Ground and Differences of the Advisory Systems in the UK and Germany
  • 4.4 Typical Problems for Scientists as Advisers
    • 4.4.1 The problem of "translation"
    • 4.4.2 The problem of "double bind-identity"
    • 4.4.3 The obligation to find a consensus
    • 4.4.4 The problem of time and resources
• Primary Sources
• References
1. "The One Thing Nobody Wanted to Happen"  a Chronology of BSE

In the introduction to this thesis, I gave a short account of existing work on the BSE/CJD case in the UK. In order to avoid redundancy, I shall focus in this chapter specifically on aspects of BSE/CJD that relate to questions of handling the issue within UK risk political culture and decision making on BSE/CJD in the context of uncertain scientific knowledge. The approach will be chronological, but it will contain phases of reflections upon the UKs risk political culture. The BSE/CJD case is enormously complex and my portrayal can only illuminate a few of the vital decisions that were taken. I shall therefore follow the case beginning with the emergence of BSE in 1985, when there was nothing but scientific ignorance about whether the disease might constitute a risk to humans, and ending, in 1996, with the acknowledgement of the first cases of Creutzfeldt-Jakob Disease in very young people when scientific ignorance was transformed into virtual scientific certainty. The approach that I will take will follow the logic of one of the UK scientists, with whom I conducted an interview: "I mean there are many, many questions you could always ask, but for policy purposes only a few are really important." In order to address the "really important" questions where science and decision making co me together, I shall focus in particular on questions that are relevant for policy purposes and where scientific knowledge and advise was essential (or at least should have been). It should, however, nevertheless be possible to show how those political actions were embedded within the deeper underlying risk political culture described earlier.

In 1985 a UK veterinary surgeon was asked to consult a farm in the South of England for a number of milking cattle showed unusual neurological conspicuous behaviour. The veterinarian had not seen anything like this before; he therefore asked the MAFF subordinated Central Veterinary Laboratory (CVL) in Weybridge for support. Scientists there examined the brain of these cattle and found under the microscope a spongiform encephalopathy (SE) like result, never recognised in cattle until then, but similar to the sheep disease, scrapie  a common and widespread SE disease of British sheep flock for more than two centuries. The question, whether it was indeed a SE was only answered in 1987, when the CVL scientists did confront the Neuropathogenesis Unit (NPU) in Edinburgh with this unusual bovine brain tissue and asked for their assessment. The response of the NPU scientists was clear and recalled later by those who conducted the study:

In the same month (October 1987) that the CVL received confirmation from the NPU that the new formerly unknown disease was a SE, it was given the name bovine scrapie and then 'bovine spongiform encephalopathy'  BSE  by the CVL pathologist in charge of the CVL, Gerald Wells in a 'Short Communication' account to the Veterinary Record. However, it has been suggested elsewhere that "most of the scientific research community did not learn about BSE until well into 1988". The incidence rate of the new disease, at the end of 1987, was already running at about 30-40 BSE cases per month.

At that very early stage, scientific ignorance about BSE was profound, and nothing appeared to be worrying about something of which simply nobody knew. There were still relatively few cases, and nobody could foresee the approaching epidemic. It was merely a scientific curiosity about an odd disease in a few British cattle. My study, therefore, does not support the view of van Zwanenberg/Millstone that MAFF officials acknowledged the possible human implications when the first cases of BSE appeared in 1986. Instead, my interpretation of the case, supported by evidence provided in interviews and documents is that: in those early days, BSE wasn't perceived as a problem for humans, and, in so far as it was perceived as a problem, then it was a problem for animals (and probably for trade in animals). Accordingly, scientists of MAFF's CVL were quite willing to talk about BSE rather frankly to others and to discuss the issue. For example, Gerald Wells, the pathologist of the CVL who classified the first cases of BSE as a SE, visited several US governmental and academic research institutes in spring 1989 to "provide information on BSE", and to "identify potential areas of collaborative studies between MAFF and USDA". Indeed "material was contributed for a slide seminar".

Clearly, it is not incidental, that the request for collaboration on BSE and the eagerness to provide information and to supply material was made to the USA and not to any EU member state. For this is one of the characteristics of the UK political culture: the traditional closeness and the feeling of solidarity with the United States of America, whereas the opposite is true for the other EU Member States.

To understand some of the initial official responses of UK public policy makers to BSE, it is vital to have a more thorough look on the pre-history of BSE, and in particular the food scandals of the 80s. Richard Lacey, a Professor of Microbiology at Leeds University, had discovered that listeria, which caused serious illness and even the death of several people in the UK in 1986, was caused by bacterial contamination of food. Although Lacey provided scientific evidence , the UK government denied any association between listeria and food. The same response occurred again, when Lacey, together with his then junior scientist Stephen Dealler, conducted scientific work in 1989 on salmonella and again discovered a connection between salmonella in eggs, the use of microwave ovens and the outbreak of the respective disease in humans. Although results were published in the prestigious scientific journal 'Nature', the links were again denied by the British government. When BSE emerged, it appeared to be the potential third food scandal in a row in the 80s, shattering public confidence, and fuelling mistrust of the respective scientists involved about the credibility and honesty of the government. Thus, anything conceivable was done by MAFF not to raise public concern about another food scare.

At the same time the government came under more and more under pressure and were required to explain their actions, at least internally: When the press took up the first food scandal (the listeria case), which had been thus far denied by the government, the press asked the public health department directly, about the cause of the outbreak. The press received confirmation that, contrary to the official announcement, listeria was associated with food contamination. The same thing happened with salmonella, but when BSE occurred, MAFF made sure that the DoH were not allowed to answer any questions relating to BSE and public health risks. Sir Donald Acheson, the Chief Medical Officer (1983-1991) recalled that in context of the BSE inquiry:

Instead, when the new cattle disease, BSE, loomed, MAFF did not inform the Department of Health about the outbreak of the disease, or about any "crucial scientific research that might have a bearing on its potential transmission to humans. And it was only with a delay of about six months after MAFF's awareness that BSE might have implications for public health, that the DoH was informed about BSE. The use of non-knowledge as a discursive tool is obvious here.

MAFFs relative openness about the new disease - at least in respect to scientific audiences  was already about to change at the time of Wells' visit to the United States. The first results of surveys conducted on BSE, the rapid increase in numbers of infected cattle in British herds, and the definitive confirmation of BSE as a SE led, subsequently, to a situation where scientific curiosity was accompanied by a growing awareness by policy regulators and scientists of the potential risks involved, not only for cattle and cattle trade, but in particular for humans by the consumption of just ordinary food. But as the epidemic was rather small yet, it was "quite difficult to persuade people (...) it is going to get bigger" because of the long incubation period of SE's. Consciousness of the new disease as a purely cattle disease and its potential implications as a cattle disease threatening British exports changed gradually, but inexorably towards awareness of the possibility that this cattle disease might have consequences for humans. For example, the Under Secretary of MAFF's Animal Health Group, said in early 1988 to colleagues:

MAFF appeared, however, to be neither ready for, nor willing to accept, another food crisis in the country, and therefore they did as much as possible to suppress the issue in public, but also inside the ministry itself. For example, ministers received advice from their civil servants and veterinarians, for example from the head of the Ministry's Animal Health Division, to

Any restrictions imposed on cattle herds appeared, in 1987 still to be "inappropriate and premature" as far as MAFF were concerned, and the then Central Veterinary Officer (CVO) warned the Permanent Secretary of MAFF that he was,

All these arguments were, of course, both enabled and supported by scientific non-knowledge of the disease. The only available evidence was by drawing analogies with sheep scrapie, but that was of course no proof. Acknowledgement of any association with scrapie, however, was avoided by MAFF in order not to jeopardise the export trade in cattle. The fact that it took a long time before BSE was acknowledged publicly in 1987 as a spongiform encephalopathy (SE) is explicable by the fact that scrapie was, at the time of the first putative BSE case, a "taboo disease" in the international veterinary arena. Any connection between the novel cattle disease and scrapie could therefore have made the export of UK live cattle difficult. Consequently, even the use of the name first considered to the new cattle disease, "scrapie in cows", was surpressed by the CVO in those early days. It was Gerald Wells' coining of the term bovine spongiform encephalopathy, "BSE" which eased this special association problem.

One might ask, how could the British government have supported such a standpoint, faced by enormous scientific ignorance, and increasingly uncertainty of knowledge (as we know at least something: it belongs to the group of TSEs) and especially regarding the growing suspicion that BSE might transmit to humans? Why did the government decide to adopt an obviously non-precautionary stance for UK public health for the sake of protecting the UK economy? What was the reasoning for MAFF to put pressure on DoH; and how should it be explained that civil servants advised the policy making people accordingly?

There were recurring replies in all of the interviews to those questions, all centred around the political personality and the leadership style of the prime minister, Margaret Thatcher. In any respect, the personality and the political leadership style of Mrs. Thatcher created a political atmosphere and risk political culture (of which Thatcher is of course a product herself), which enabled the emergence of the BSE story. Without the input of this specific "Thatcherite Culture" the BSE saga probably could have been told in a completely different way. Of course, for the most wide-ranging and long-standing decisions on the handling and mis-handling of BSE felt in her time being Prime Minister.

When Margaret Thatcher came into power in 1979, that year appeared to be "crucial". Whereas Thatcher's politics were most commonly described as: "'Free market, strong state, iron times': an authoritarian populism"; following Jessop et als more detailed analysis, Thatcher's leadership included:

All those cited attributes played a significant and vital role in the ways in which the BSE play was directed by Mrs Thatcher personally, but also by the culture she performed and she stood for, the so-called "Thatcherite Culture". For example, in order to protect the cattle industry BSE was for quite a while not officially recognised as a SE (as "scrapie in cow") in order to avoid any association with this "taboo disease".

Thatcherite Culture also provided support to the idea of a culture of discretion, in particular in strengthening the power of the civil service, which was one vital part of the whole BSE saga as it appeared. It is sometimes hard to escape the feeling that some senior civil servants played a quite significant role in the background, for example when the minister were told by a civil servant to "take a low key" on BSE issues in the public in order not to jeopardise the British economy. It is of course in a way quite understandable and almost natural given that whilst politicians might change after an election, the civil service (the administrators) are still there, and in addition the knowledge was there of whatever kind to support the minister. But as explained in the introduction to the chapter on risk political culture, Thatcher made the civil service even more powerful  in her sense of achievement which includes: stick to the line, her line, and be pragmatic on the policy needs she set. In that sense, it might well have been, as suggested by one interviewee, that the Chief Veterinary Scientist, Keith Meldrum, was told directly by Margaret Thatcher that she did not want any further problems with agriculture. It would fit very well in the political atmosphere Thatcher was spreading around her: an empowerment of the Civil Service to act according to her rules.

For example, Thatcher was very well known for her policy of reducing public spending. Additional spending should have been avoided by every conceivable means (considering the fact that Thatcher wanted to cut existing spending commitments). When BSE emerged, it was most likely that it would involve extra expenditure in the agricultural sector. Therefore, the civil servants briefed their ministers accordingly to "take a low key" approach. Hence, the least political attention thinkable was given to this disorder, in the hope that it will disappear as soon as possible without any further need for political action.

The response of the UK government to BSE during this period of transition (from the "cattle disease-only-hypothesis" towards acknowledging internally that BSE might spread to humans) reveals an attitude which can be described as conscious indeterminacy. Whereas scientific ignorance was of course. state of the art. when a new disease arises; the knowledge that it belongs to the group of transmissible spongiform encephalopathies should have been interpreted as rather worrying transformed basic ignorance at least in the state of uncertainty, where some facts are known, but plenty is still unknown. In fact, people in charge in the Ministry of Agriculture, Fisheries and Food must have been aware of this situation, for they not only detected and described the new disease, they knew also of the possible dangers for human health. An indication of this, in addition to the quotes already provided, is the fact that any relationship between the new cattle disease and TSE was underplayed until the end of 1987. For example, the director of CVL refused to publish an article on BSE in the Lancet or the British Medical Journal on the grounds that "it would over emphasise the possible risk of human health." The consciousness that BSE might be pathogenic to humans is also revealed by the rather strong reaction towards the Department of Health, which was deliberately excluded in discussions on BSE in favour of an enormous centralisation of power to decide and to define the disease within MAFF.

It appears that everything was done by MAFF to exclude as many actors as possible  even actors which should by definition be included on such matters, people who might have been in charge, like the DoH  to minimise the overall amount of people which knew about the case. This included indeed, the term excluded appears to be more appropriate in this case: scientists working on the agent. Furthermore, as almost no experiments were initially carried out or only a very few considered relevant, it wasn't really possible to make any justified assessment of the case. Even experiments, which potentially might have verified the official approved hypotheses that BSE did indeed arose from scrapie, which was considered as unproblematic for humans, were not conducted. So the status of indeterminacy might have been considered as quite useful and was in some parts deliberately kept, for if we don't know something we could not assume the worst either. It was therefore also the dimension of selective perception and mediation of knowledge involved in the case.

A situation came into being which putatively enabled the attempt by the UK government to "dissolve" the BSE problem by simply ignoring it  at least the government tried to undo the occurrence of a novel cattle disease, and any connection made to aspects of transmission, by a blanket of enforced silence (certainly in the public sphere). It appears as if ignoring BSE was considered as a way to make the issue go away. But the contrary was true: The more the government tried to ignore BSE, the more aggravated the situation became, for simply crucial time passed by during which precautionary measures could have been implemented (for example to ban infected feed from the animal feed chain or the risky material from human food chain already back in 1986), the general public told about BSE, and allowed to make up their own mind as to whether they will still take the risk of eating beef, and to ask the scientific community (beyond very narrow defined cadres) about their assessment of the situation. Conscious indeterminacy proved to be the wrong strategy. And the events took their course. This deliberate dealing with and use of scientific ignorance appears to have been fuelled by the hope that BSE would simply pass by without any bigger efforts on the part of science or policy. As if naming would make it happen, and would develop it's momentum. The contrary was true. Not the naming, but the ignorance of naming that there might be really a risk made it to the biggest food crisis ever happened to the EU:

MAFF not only prevented information from being shared, in a timely fashion, with DoH, but also with anybody else beyond the inner circle of MAFF (e.g. CVL). Some research into the human dimension of this cattle disease, started in the meantime by DoH, but had to stop immediately. Other researchers inside the UK and outside, including some laboratories in the U.S., were prevented from doing any work on BSE by effectively imposing a monopoly on every suspected or confirmed case of BSE in July 1988. That monopoly meant, if an animal was suspected of having BSE it was transferred automatically into the property of MAFF; they had legal control and ownership over all BSE material. Consequently, if researchers wanted to work with infectious material they needed the necessary facilities to carry out animal experiments, the permission of the ministry to work on this issue, and last but not least the ministry had to agree to provide the infectious material. Accordingly, any research carried out on BSE was intensely scrutinised and monitored by MAFF. Any publication on the matter required permission from MAFF for publication. Hence, most research (at least for the early experiments) was carried out in MAFF's own subordinated laboratories, in particular the CVL in Weybridge; or was at least MAFF funded. In fact, two thirds of all TSE research was funded by MAFF, although no extra funding was put forward by the government for agriculture as a result of BSE needing the research. All that happened until 1993 was that research funding for other aspects of agriculture were simply stopped and transferred to BSE research.

Another way of maintaining the power in one hand was the establishment of the BSE database in just one hand. Every single piece of data on each cow, suspected or confirmed of having BSE, went into that database. Any calculations on BSE cattle, on maternal transmission (the cohort study) was made on the basis of that data pool, based in the Central Veterinary Laboratory. On the one hand, centralisation of data is sensible means to keep up every single information at one place so that everyone knows where to ask for. On the other hand, it is of course an incredible powerful means to maintain control over the dates and the people who are allowed to get access to. Furthermore, the very same persons who had the power to control the data have, moreover, the power to define which calculations were in fact carried out and which were not; and which questions will be addressed in using the data and which will not.

Another striking example was given by an interviewee on how the system of political centralisation and control spread out and applied to the research domain - making a "closed job" of research funding: In a late evening meeting in 1990 in the House of Commons the agricultural minister announced that he would make additional money available for research on BSE and CJD. But when an independent researcher asked the very next day, in the early morning just when the offices at ministry were opened, about conditions for applications, he was told that:

"Outsiders"  no matter how close their work on the subject  were simply those researchers who were not funded by MAFF or DoH.

The introduction of the monopoly by MAFF appears not only as matter of centralisation of power in MAFF's hand. It was justified furthermore and interestingly by a senior civil servant of MAFF by two arguments: As it became obvious that this disease was not easy to handle, and with a very long duration of each experiment, demanding plenty of scientific practice and experience,

Correspondingly, only a very few highly selected scientific groups outside MAFF's own or subordinated scientific facilities were granted permission from the Chief Veterinary Officer (CVO), in whose responsibility the monopoly and hence the distribution and provision of material laid, to work on BSE. The second argument might have played a role during the length of the case, but was used in reference to the events of March 1996:

Several requests for material were refused by MAFF following that reasoning  perhaps present at time, but perhaps only formulated with hindsight. Yet, instead of taking that reasoning as an (admittedly effective) deliberate means of excluding particular scientists or scientific groups, that reasoning could also be read as part of UK risk political culture  here with emphasis laid on the patronising aspect, now not in respect of the general public, but in respect to the national and international scientific community. The tough controls over the, and the most likely refusal of supply of material to 'outside researchers' could be understand as a form of patronising science by the UK government. As government funded and subordinate scientific institutions such as the Central Veterinary Laboratory had by far the bulk of research on this cattle disease (which was of course one of the very, very few who were allowed to), so they were without any doubt by far the most experienced on it. Hence, they knew for sure about the details and how best to handle the disease. The dramatic fall in funding for research funding in UK agriculture during the 1980s and the closing of research stations meant that many of them that were still open were fighting for any funding they could get, and that included the CVL in Weybridge.

It was the pre-existence of a deeply rooted culture in the UK of deference, and institutional charisma (presumed public authority and respect) which allowed MAFF to imagine it could conceivably get away with the extreme hegemonistic control (where the introduction of the monopoly is just one, but influential example of the centralisation of power) which it exercised over information, research and interpretation of the unfolding BSE experiences. This situation was enabled by a pre-existing institutional culture which assumed officialdom (here in form of MAFF) to be more legitimate and more competent to judge than any other agent. What is more that one such agent, licensed ultimately by, and responsible to, the Monarch, as supreme UK State power, was assumed to be more competent at cultivating public truth on a matter of such complexity and uncertainty than a pluralistic melting-pot of open and equally legitimate and contending ideas. These commitments, the springboard for more specific interests, are of a more cultural kind. This is not to argue, deterministically, that a given cultural setting of this kind mechanically determines the supremacy of particular corresponding deliberate interests; but that it does (however imprecisely) set a selective field for the emergence and predominance of a bounded range of such interests.

It is obvious with a novel disease such as BSE that certain scientific knowledge could only be rather limited. Indeed, the detection of BSE was accompanied by huge areas of ignorance: starting with the origin of the disease, the nature of the agent, the route of transmission, the general transmissibility, etc. Thus, the (re)search on/of all these un-knowns started in 1987 on a rather limited and pre-defined scale.

As BSE became known as a SE, and given that the vast majority of TSE researchers (of the very few which they were in fact) had worked on the sheep disease scrapie, most available knowledge in the sea of scientific ignorance was without question related to scrapie. Therefore, initial conclusions were drawn from scrapie research and applied to the newly discovered cattle disorder. For example, the fundamental and long-lasting hypothesis that BSE is unlikely to be communicable to humans, was based on a scientific analogy with scrapie, which had been known for centuries in the British sheep flock without showing any signs of being a threat to humans. This hypothesis already existed long before the government even considered summoning a scientific advisory committee to provide advice on BSE.

For obvious reasons, the Neuropathogenesis Unit in Edinburgh and some of its scientists became rather important in evaluating and assessing the situation as a whole, and on specific questions relating to the science on scrapie. For this scientific institution was traditionally the world centre of TSE research (in particular, research on scrapie), which went back as far as 1936. For example, one of the ex-NPU directors became expert adviser of the British government and later the Southwood Committee, and a member of the Tyrrell and SEAC Committees. He even founded, in 1988, a consultancy entitled 'Scrapie and Related Diseases Advisory Service (SARDAS)'.

There was of course the search for the causal factor of BSE. A whole range of hypothesis were initially considered. Potential sources of BSE included: contaminated vaccines, imported animals, BSE as a toxic phenomenon, or as a genetic disease. As the result of surveys conducted by MAFF's Central Veterinary Laboratory in 1987 with farmers (those, on whose farms the first 200 case were detected) and by a process of elimination, two main hypothesis emerged: BSE as a genuine cattle disease; and BSE caused by feed of scrapie infected meat and bone-meal (MBM). The latter was, for the time, being more widespread and received much more attention than the former, in particular taking into account the considerable sheep population on the Island and the presence of scrapie for more than 200 years.

The reasoning was clear and based predominantly on assumptions relating to the time aspect: On the one hand, there was a major restructuring of the rendering process to produce MBM by the end of the 70s. This took place in large factories in specific parts of the UK from the beginning of the 1970s, ten years prior to the outbreak of BSE in cattle (the initial exposure occurred apparently at the beginning of the 80s). On the other hand, changes in animal feeding practices occurred while MBM (consisting of recycled sheep, later also recycled cattle and other species) became introduced and promoted as so-called 'high protein feed' stuff for high-yield varieties of cattle (in fact sometimes the trigger of so-called "cattle cannibalism"), and extolled heavily by MAFF. This view was supported by the fact that BSE appeared to be exclusively a British problem for several years. Simultaneously, the United Kingdom had been the only EU member state which had changed its rendering process to a less rigorous and less severe practice in which (at least) this particular bug wasn't destroyed (which is very hard to destroy anyway).

Although the modifications to the rendering process had already started in 1979 when the new Conservative government came to power, it was up to the new government, headed by Margaret Thatcher, to "impose regulations setting minimum standards" on the industry. But the proposal finally issued by the government, the "Protein Processing Order", was in accord with the Thatcherian policy on 'free market', 'industry knows best' and 'de-regulation' which had just started to be advocated by the new conservative government:

Interestingly hereby, when the evidence indicated that MBM appeared to be the most likely hypothesis, industry (here feed mills) refused to co-operate with MAFF, in terms of investigations into where things could have went wrong (e.g. what went into the cattle feed pellets). There is no evidence that even this behaviour was sanctioned by the government, although "that is probably the first and only time that we had not got co-operation and we did not get co-operation now", instead, it appeared that there was "a point of confidence all around the industry." Nevertheless, the industry was kept informed from the very beginning and onwards. Obviously, a few of the feed mills  though not co-operating  reflected upon the issue and did change some of their procedures up to 4 months before legislation (the later "ruminant feed ban") forced them eventually to do so.

But as early as 1979  which was right at the beginning of the modified rendering practices - some critics voiced concerns about recycling practices. For example, a member of the Royal Commission on Environmental Pollution, Hans Kornberg, suggested that this issue be given serious consideration:

The UK organic gardening lobby, the Soil Association, also argued at about the same time that cannibalistic recycling of remains in feed was wrong, even though no specific risk had been identified. These warnings appear not to have been widely acknowledged. But the worries of the Royal Commission, as with the concerns of the Soil Association, were only recalled after the events of March 1996.

The questions that came up within the scientific advisory committees concerning the practices of the rendering industry and slaughterhouse routines appeared to have been one of the most difficult, for a substantial lack of knowledge: Scientists in the committee simply did not know about the practices in abattoirs or in rendering plants. The situation became even worse, as the case has shown, for a lack of will of the industry to co-operate. Any recommendation given, and any legislation put in place, was therefore extraordinary problematic. For the fact that the industry emerged without any visible damage in its relations with the government is once again embedded in a background field of corresponding taken-for-granted cultural commitments. The identifiable - and costly - intimacy over BSE between UK governments concerns, policies and claims, and those of the UK feed industry, can be seen as a classic case of private interests tacitly at work inside government. This close industry-government relationship has been a distinct feature of UK policy since the 19th century. It is constituted not just by a succession of ad-hoc examples, but in addition, a host of rationalising beliefs, assumptions about trust and behaviour, normative expectations of industrial actors, and projected implicit models of others such as the public at large. These facets are woven into a historically evolved formal texture of consistent legislation and formal regulations, all part of a wider cultural pattern. Therefore, many of its most important features are not chosen but taken-for-granted and part of a certain identity on the part of UK policy and industrial actors. Thus, the close industry-government mutuality of interests which was evident in UK BSE risk management was politically feasible, or rather assumed to be feasible, just because it was cultural - it was performed without much, if any, reflection, as the 'natural' way of conducting affairs.

As a result of the surveys with farmers, that had been conducted by MAFF's Central Veterinary Laboratory, and the deepening concerns about the impact of meat and bone meal, at the begin of 1988 CVL scientists, together with "headquarter staff" (veterinary and policy advisers) at MAFF's Animal Health Group in Tolworth (and under consultation with some scientists), advised the minister that a "ruminant feed ban" should be imposed. The feed ban was accordingly accepted and announced by the Agricultural minister MacGregor only one day after the first meeting of the newly established governmental scientific advisory committee, the 'Working Party on BSE', in June 1988. This regulation was initially limited for 6 months, but became indefinite (as recommended by the scientific advisory committee) some months later. It was thought by MAFF and other people involved (scientists and administrators) that the introduction of the feed ban would effectively stop the source of infection, even if it would not "immediately be effective".

This was definitely not the case. Instead it took years before the ruminant feed ban worked well because, although the government introduced the feed ban, they did not withdraw the feed that had already been manufactured and sold to farmers. Hence, once produced or once bought, it was fed to cattle - at least it appeared to be most unlikely that it was put into the garbage without any compensation (neither by the industry, nor by farmers). Moreover, nor was a definite confirmation that the feed was in fact a risk for cattle in 1988 (until then the regulation was based only on epidemiological evidence conducted retrospectively, but no positive scientific proof was offered and this is still true; no infectivity has ever been demonstrated in feed). Though the rendering industry was not, in particular, willing to co-operate or to offer information requested by the government or by the scientific advisory committee's, one piece of information emerged that was especially worrying: Usually, the feed mills produce feed, not only for cattle, but also for pigs and poultry, for example. But, and that is the point, the processor is always the same, no matter if cattle feed or poultry feed was produced. Unless the processor was cleaned up very carefully (which one could not assume), cross-contamination with cattle remains (which were still allowed for pig and poultry feed) in cattle feed could not be ruled out. That was particularly problematic considering the fact that only a small amount of high-infectious material was sufficient to cause the disease.

One sign of the delay in the effectiveness of the feed ban, which couldn't be missed, were the new cases of BSE-infected cattle born after the feed ban (BAB's) in 1991. But the BAB's (at least presumably) did not appear as a consequence of having chosen the wrong means to stop BSE, but as a result of lack of proper implementation by the industry and especially the non-control of the implementation by the ministry in charge (see below).

On the farmers side, it appears still to be unclear whether farmers knew about the origin of this cheap high protein alternative (MBM) compared to the more expensive Soya bean feed. Moreover, it appears unlikely that farmers were aware that, by introducing this new feeding practice, they were actually transforming herbivores into carnivores, and indeed cannibals. They were only told that it would do good to their stock.

This was in accordance with what might be termed the sub-political culture of the UK Agricultural ministry, predominant until (at least) the middle of the 80s. This sub-political culture was characterised by a very patronising attitude towards farmers, which was partially due to the fact that MAFF was set up after the war explicitly as an institution "to help farmers". It is within this overall picture, that MAFF's research funding was allocated, in order to fulfil that purpose. It was MAFF-funded applied research that indicated, for example, that sheep or cattle remains can still be used and profitably processed as MBM by the rendering industry to become re-fed to farm animals. Those 'latest' outcomes of agricultural research were strongly recommended to the farmers as "this is a much better way of doing it as known in the past. Do it this way!". And supported of course by the authoritative reference to "sound science" evidence. There appears, furthermore, no reason, why farmers should not trust "their" institution. E.g. the National Farmers Union rarely argues with MAFF except over regulations and money.

When rendering practices changed, on the one hand, and the farmers were asked to use feed which included MBM containing sheep or cattle remains as a cheap way to increase production, on the other hand, both means were made on the basis of the virtual knowledge that it would do not any harm, but was just a better, or more efficient way to farm. But mistakes and errors are always endemic, and those two examples were certainly some of the more sad and consequential mistakes that have ever happened to the farming industry. There was, however, an element of basic trust on the side of the rendering industry in so far as they were advised properly (a social commitment towards their scientific advisers), according to the best knowledge available, that the modifications to the rendering process would do nothing except increase the efficiency of the process. The basis for the decision to introduce a ruminant feed ban was "only" epidemiological evidence - a causal relationship had not been proven that time. On the other hand, farmers could not have assumed that something was wrong with the feed, for no farmer in the world would be so stupid to feed a product to their animals knowing that it would jeopardise not only their health, but finally their living as well, with no compensation whatsoever. So neither the rendering industry or the farming industry, spread the agent (not known to be (still) there) deliberately, but only by mistake. Certainly, one could raise the question as to whether they should not be more conscious about the effects of their actions, for example the rendering industry might have questioned their taken for granted assumptions when suspicions arose about whether their process will efficiently remove all potential bugs in the feed; or the farmers might have insisted on the removal of all MBM in feed. Last but not least, it is not clear why farmers still used the feed for their animals or were not more cautious about the production of it when the feed ban was put in place. That habit is even less comprehensible when considering that the official discourse at that time was about an animal disease only, because the only two groups which were at that time really affected by that particular reading were of course the rendering industry and the farming industry. So, even in assuming that it was nothing but an animal health problem, there is no rational excuse to justify the violation of the law.

The only explanation I could think of is grounded in virtual knowledge and embodied knowledge and a basic trust grounded in culturally shaped understanding of how things are put in place and the relationship between the rendering and farming industry and the ministry of agriculture, who obviously did not put enough weight on the subject to make them change their way of doing things or to convince them that this is seen in deed as a serious problem. If MAFF would have done that, it would have broadcast the idea that there might be a risk, and one might reasonably believe that it would have been only a very, very few farmers breaking the law (the "black sheep" in business), and these, presumably, would not have been sufficient to cause the problem on the scale it appeared to be at the end.

What is more is that the case illuminates an intrinsic relationship between cognitive assumptions and epistemic principles, perhaps one time chosen and deliberate with maybe interests in mind, but which became gradually assimilated as part of routine practice in a particular area, and maybe also defining the identity of that area. When the rendering plants decided to change their practices (using less temperature, and losing the solvent extraction step) this was a deliberate decision in order to make their business more efficient. I am sure they received confirmation that those modifications would not alter any other conditions, for example that bacterial contamination is destroyed. So the modified process came to be part of what constitutes "proper rendering practice", culture and identity of its subjects. Thus one could say that the possibility that using sheep and cattle remains in UK animal feeds might cause unknown and unknowable effects for cattle, and for those who ultimately consumed their meat, was - albeit too briefly as it turned out - thought about at the time it was introduced, but went underground as an issue. (Thus for example the UK Soil Association criticised it at the time, but did not have specific damage pathways to point to, so their criticism did not raise public awareness and wider attention.) Hence the answer that this feed-cannibalism was safe for vegetarian cattle and their human consumers became an implied or virtual belief, tacitly enculturated into the particular routine taken-for-granted material culture of UK feed, farming, meat and meat-products industries.

As BSE developed rapidly into an epidemic throughout the whole country, the British government saw themselves as forced to allow something substantial to take place. In March 1988 MAFF informed the Chief Medical Officer (CMO) in the Department of Health (DoH) about BSE. The CMO suggested, faced by scientific non-knowledge and the lack of ideas about useful ways to combat the epidemic, which could not longer be denied, to appoint a scientific advisory committee to advice on the issue. Richard Southwood, a distinguished ecologist of Oxford University, was asked in early April 1988 to chair the first four member expert committee to advise the government on TSEs. When Southwood was asked he was told "of a new cattle disease which appeared to have some similarities to scrapie and the similar human condition of kuru" - an early, but admittedly rather limited acknowledgement by the government outside their very own organisation about the very nature of BSE as a transmissible spongiform encephalopathy (TSE) and thus the possibility of transmission to humans.

Only a few days before the Working Party met in June 1988, BSE was made a notifiable disease in the UK. And one day after the first meeting of the 'Working Party on TSEs', as the Southwood Committee was called, the first interim advice was given, suggesting major actions, which were implemented accordingly: (1) To impose the already prepared ban on MBM incorporating ruminant remains fed to ruminants. (2) To destroy the milk of cattle suspected of having BSE. (3) To destroy carcasses of cattle affected with BSE and that accordingly compensation of farmers would have been essential for the measure to be "effective".

The 'compulsory slaughter-with-compensation policy' evolved as a rather 'hot potato', because this particular regulation went straight to the heart of Thatcherite politics of reducing public spending. When the Working Party initially proposed to pay 100% compensation to farmers, MAFF rejected that proposal. One scientist remembered the discussion with MAFF:

So, against objections made by the scientific committee MAFF decided to pay 50% compensation for any confirmed BSE case (but 100% compensation when suspicions could not be confirmed after examination of the cows brain). And it was only in February 1990 that John Gummer, then Agricultural minister, announced that compensation "will be 100% of the market value of the animal or the average market price, whichever is the less." This change was a necessary consequence of the fact that 50% compensation did not convince every farmer to make a honest declaration of each cow showing symptoms of the disease, but was, instead, "a big incentive to cheat". In the end there was no evidence that the increase in funding from 50% to 100% made any difference, but it was expected to. This was thought to be because the symptoms of the disease were so strange that the farmers automatically called in the veterinary surgeons.

Another recommendation given by the Working Party (judged as an "urgent action") was (4) the establishment of an expert Consultative Committee on Research "to advise on the research which is in hand and that which is required to answer questions identified by this Working Party." And in the final Southwood Report of February 1989, the establishment of this committee was already announced and the members of the new expert committee, chaired by David Tyrrell, were welcomed. Moreover, the Southwood Committee made a recommendation (5) to monitor the human TSE, Creutzfeldt Jakob Disease (CJD) which was put in place in 1990 (see below).

A further cultural feature of UK science and policy which intersected with more interests-based commitments was the way in which MAFF were able not only to restrict access to supposedly open, universal scientific information and even basic research material (as described earlier), but also restrict the channels of official advisory expertise to very narrow cadres of recognised authority, severely reducing the richness of confusion of wider scientific debates, deliberations and uncertainties. Again one can plausibly account for this suffocatingly reductionist conferral of legitimacy to only a selected part of the full intellectual spectrum as a deliberate interests-driven commitment by MAFF officials and Ministers, those interests not being hard to identify. But it was a set of commitments, claims and initiatives which was only conceivable to its authors from within a culture where this general pattern of behaviour was already assumed to be legitimate, proper and even efficient, and where scientific advisory committees are an important element in the pragmatist-empiricist UK tradition. Political decisions on science-based matters draw heavily on the expertise of distinguished scientists. Policy action therefore on those issues always tries to gather support, and is promoted by, sound science arguments. But as we have seen in this case, the advice of the scientific committee was not always translated into policy action  or at least only at a later time when the view proposed by the committee was confirmed in real life (as in the case of the size of compensation).

What is of course significant in terms of sound science reasoning of public policy making is the time when the ruminant feed ban was announced: It was not before the Southwood Committee first met what would have been easily possible because the regulation was already formulated - and it was not separated from the recommendations of the committee when they were published, but, instead, made a part of the very same press release and hence public announcement of the scientific advice. So even if the regulation was put together and already agreed upon by others, but the newly established official governmental scientific advisory committee  without any input of the committee  it appeared as part of the recommendations from this very same institution. Accordingly, the ruminant feed ban (as with the specified offals ban later) was accompanied by a sound scientific justification of a policy decision made previously by policy makers. This scientific justification should not only to be seen as being a useful means to support a policy action, but should instead be interpreted as grounded and inherent in a deep UK cultural understanding of what is a legitimate basis for political decision making on those matters.

The distribution of the Southwood Report in early 1989 was already longed for by the media. The media had already started to become interested in this issue, not least because of a small, but significant article by the junior physician, Holt, and a dietician, Phillips, published in the British Medical Journal (BMJ) in June 1988. In that article, Holt and Phillips suggested the possibility of transmission of the cattle disease by dietary means to humans. This article subsequently became a key reference for critical voices wishing to emphasise the risks which might be connected to consumption of infected beef products. The Guardian food correspondent James Erlichman was the first journalist to take up this issue in 1988. He conducted an interview with Timothy Holt immediately after the article was published in the BMJ on the implications of what is stated there for UK public health. Erlichman was correspondingly the person who first made the connection between BSE and CJD in the public, non-scientific media.

After further investigations, Erlichman claimed that the publication of the Southwood Report was delayed by MAFF. The reasoning for that potential delay - though never confirmed neither by MAFF, nor by Southwood himself  might have been the fact that, according to an interview conducted with a scientist, the original report included the demand to ban bovine brains and various other tissues from cows immediately. But this request was firmly rejected by MAFF. And, as the information went further, Southwood's Committee were required to change the report and to exclude the paragraph on the ban of bovine brain and other tissues, whereas MAFF promised simultaneously towards the Southwood Committee that action would be taken on this matter, but without publicly announcing it (at least not in the report of the committee). Obviously, not that unusual as a senior civil servant admitted:

What is interesting here, is that  in positively assuming the delay of the Southwood Report  the very same happened with the interim report of the successor Tyrrell Committee, namely that it was postponed. According to a member of the Tyrrell Committee the report was received by MAFF and DoH about three quarters of a year prior to its publication. The question is, of course, why? Why did the government deliberately hold back the report of its advisory committee on the assessment of necessary research to be funded? The interviewee gave an interesting account on that, implying British political culture:

A view which was strongly supported by an interview conducted with a senior civil servant:

Of course, money certainly plays a role in that habit, as speculated by the interviewee himself. Furthermore, according to what has already been said about the Thatcher government, public expenditure should not be widened, but, on the contrary, cut. But is this explanation sufficient? For everybody, including the public, the cost argument was easy to access and certainly not hard to understand  at least in general. In this particular case, however, the circumstances might have been somewhat different, for it became more and more in the consciousness of people, how much money had already been spent on paying compensation to farmers. Moreover, Erlichman had begun to stress in several articles that the government had already imposed regulations on animal health matters (the ruminant feed ban), which was of course also a way to safeguard trade with UK cattle, but nothing comparable to public health had yet been announced. Thus, a clear step on the side of the government appeared to be necessary to avoid any impression in the public that government acts only on behalf of the industry, but does not invest into research for public health. Therefore, the distribution of the Tyrrell Report was postponed towards a time everything asked for in respect to research was already put in place or was definitely on its way. But the time the report was printed and published eventually in January 1990 the report was considered as "already out of date".

Otherwise it was equally known that not only the reports of the advisory committees were held up, but also other scientific papers on the matter. One interviewee described this as an "ethos of MAFF" which according to this scientist - changed after Gummer became minister, but prior to Gummer that ethos in MAFF apparently was:

This step shows one of the characteristics of the UKs political "culture of discretion", where political decision  in this case on money provided for research funding and on publication of research findings - are made in a rather opaque and inaccessible way inside the ministries. Obviously civil servants had a huge impact on the manner of performance, for example, whether a potentially significant scientific paper became dusty on a desk in the ministry or whether it was released relatively early for publication. It was not even comprehensible for the governments expert advisers, who were supposed to supply the material for the decisions, why their recommendations or scientific papers were dealt with in such a peculiar way. They were simply not told about it.

Although any decision made by political decision makers was avowedly based on "sound science" arguments, the way those decision-makers transformed it and, in this case, when, was at least far beyond anything approaching transparency. This delay tactic (of the publication of scientific recommendations and articles in order to implement regulation policy first on that very recommendation) provides, furthermore, an excellent insight into the characteristics of UK policy culture where decisions were often made in an ad hoc fashion, rather informally and pragmatically and often flexibly, allowing for the use of (non)knowledge as a discursive tool. Policy options are often constrained by policy needs or what in general appear to be as acceptable by closed "policy communities" (Rhodes, 1988).

The publication of the Southwood Report (with or without a factual delay) in February 1989 came along with the first longish debate in the media about the constantly increasing numbers of diseased cattle and their possible impact on humans. One of the first to react on the Guardian report was a consultant neuropathologist at Charing Cross hospital, Helen Grant, who knew, incidentally, a lot about the sheep disease, scrapie and was also aware of the Wells et al. paper, and therefore that a SE in the UK cattle herd had started to become a serious epidemic. Grant also read the article by Holt and Phillips and started immediately to be very worried about the potential link between human TSE and the disease in cattle. Only two days after the Guardian published the announcement of the delay of Southwood's report, Grant responded with her first involvement in a very long line of letters and other contributions to newspapers and other public media (including various TV and radio programs), titled "The hidden threat of BSE". In her letter to the editor, Grant described not only the serious scientific problems involved in this group of disease (such as the difficulty in destroying the agent; and the very long incubation periods), but she also accused the experts for knowing these "dismal facts" for nearly two years but not informing the public "to decide whether to go on consuming, for example, "meat products" which may contain beef brains."

Grant made some famous words the day the Southwood Report became released:

And she continued in saying: "Who knows, some of us may be incubating it already"

Although, at the very same time, the official standpoint was extraordinary reassuring about the disease, it was meanwhile baptised publicly as the more handy "Mad Cow Disease" as reference to the syndrome of trembling and staggering cows.

Grant was not only knowledgeable about the issue (for neuropathology was right on the subject), she was furthermore rather outspoken about the potential risks for humans inherent in BSE  an aspect, until only recently, absent from public debate. She received, accordingly, not only requests for taking part in talk shows and radio discussions, but also, for example, an inquiry by a senior abattoir worker in early 1989 for any safety instructions to avoid catching the disease of cattle. Grant recalls that phone call to the abattoir worker:

Again, this is a good example of Thatcherite Culture in 1989, namely assuming that, on the one hand, "industry knows best" on how to deal with those matters; on the other hand, still the habit of conscious indeterminacy towards the problem and thus no implementation of regulatory action such as explicit safety instructions for people confronted directly with the infection. Regulations of how to deal with BSE infected cattle in slaughterhouses were introduced later. It turned out that these directions were extremely non-specific, and gave no indication as to what to do if anything went wrong or the risks involved. But at that stage, where at least MAFF and its subordinated institutes were conscious of the possibility of transmission to humans, the food industry (here the abattoirs) were not asked to change their routines. Consequently, slaughterhouses hadn't yet changed any practices. That was, by the way, contrary to the experience of the animal feed industry, which were already forced to change practices as required by the ruminant feed ban.

Whereas Grant was for several months the only scientist who spoke out loud about the risks which might have been involved, others soon stepped in. It was not coincidental that the most prominent objectors to the official line (stating that BSE is purely a cattle disease with no impact whatsoever on human health) were the very same scientists who already had made their own experience with MAFF's dealing of food related diseases, namely Richard Lacey and Steve Dealler, who found out that the serious problems for human health were caused by listeria and salmonella bacteria in food - but which was publicly denied by the government. After those personal experience they were soon fairly suspicious about BSE in cattle as another source of food  and maybe as another potential food related disease for humans, too. But unlike Grant, who soon retired after her involvement in the BSE case and whose privacy was not significantly intruded on, others had suffered for the way they had challenged the official line, and their insistence on stressing that BSE might well constitute a problem for human health. For their knowledge wasn't anticipated as "authoritative", unlike the knowledge produced in MAFF and its subordinated institutes, where BSE was still seen and promoted as a cattle disease, but not as a risk for public health. Furthermore, all of the critics were (one tend to say 'of course') not animal health experts, but professionals in public health.

What Grant, Dealler and Lacey shared with the Southwood Committee (and with several other scientists inside and outside the UK) was the request for a lot more scientific experiments. What they were divided on were (1) the assessment of which research needed to be carried out, and which conclusions to be drawn out of existing data. Moreover, they did not agree on (2) the respective membership of the Southwood and it's successor the Tyrrell Committee, already in place at that time. Whereas the former (1) was of a quite fundamental nature. The latter (2) was more or less the denial of the government appointed advisory committee's expertise in the field of TSE and the demand to include "real experts" (whoever this might have been and defined by whom) by those who were more critical to the government's handling of the issue and who stepped into the breach advocating a more precautionary stance.

The fundamental necessity for certain scientific knowledge faced by extensive non-knowledge on almost every conceivable moulding of the disease was more than self-explanatory and beyond any debate. Solely, what kind of research was needed, and how to achieve what appears to be as knowledge-worthy, diverged substantially amongst the diverse actors. Contrary to the official announcements, the more critical (a term which is used here in reference to scientists critical towards the government) scientists claimed, the "most obvious research" wasn't carried out at all, such as looking for methods of diagnosis and treatment, or numbers of infected cows that went into the human food chain.

Or, as one scientist framed it retrospectively in an interview in 1997:

The government, in form of MAFF, may have served it internally, but not publicly. One scientist speculated:

Asked why this was the case, he responded:

And although TSE committee members made recommendations themselves on research priorities (in case of the Tyrrell Committee they'd introduced a modus of ranking research applications by a "star-system" to make it easier for the ministry to decide upon), the members of the scientific committee were by far not always happy with the way research was funded and, especially, that in general not enough money was provided for TSE research, in particular while considering the amount paid for compensation to farmers. One expert adviser gave an example:

It is clearly indicated in this clipping that the research situation was well beyond one of being sufficient at the begin of the 90s. Taking into account that since November 1986 more than 9000 cattle were already confirmed with BSE, and that MAFF officially constantly stressed "the Government's determination to deal with the disease", the situation of lack of mice and laboratories appears rather incomprehensible, and especially the prospect that the only one laboratory (namely the Neuropathogenesis Unit in Edinburgh), where particular experiments could be carried out, was faced by closure.

Whereas the steady increase of numbers of infected cattle can easily be explained as the outcome of the culture of conscious ignorance (hence, little was done); the desperate circumstances of research were, on the one hand, the continuation of this very culture, and on the other hand, another British tradition under the aegis of Margaret Thatcher: namely, to withhold successful researchers in further investigations on particular issues considered as 'hot potatoes' by the government. Institutes were closed, or at least re-structured it (as finally happened with the NPU) justified by the always notorious lack of money (similarly, the same fate suffered, for example, the Mordun Institute in Scotland, where "Dolly" was 'created' and when it was at the height of public and scientific attention). So the "Government's determination to deal with the disease" is rather doubtful when they even conceived to let one of the few existing independent research posts on TSE, traditionally THE institute in the field (world wide!), being closed down. This speaks, contrary to the published and emphatically repeated announcement of MAFF, a quite distinguished language. At least occasionally, it appeared that some scientists carried out research, deemed by themselves as really important but got no funding for it, with money meant to a complete other set of experiments. A governmental expert adviser respond to that 'abuse of research funding': "I am very glad they did!", for the results were quite significant.

At a time it was already deliberately stressed and reassured that the risk to humans is not zero, but really remote, it would have demanded particular explaining, why to put so much effort and money into the research of a transmissible disease which is only of minor interest for humans. So in order to be consistent, misleading messages should not be sent to the outside. This ministerial behaviour was naturally enabled and supported by the centralisation of power inside MAFF. And supported by the fact that there was a scientific advisory board in the background which did, at least officially but partially of course in fact, give blessing of decision making here on TSE research. But the fact that no more necessary research was carried out in the UK - though requested - was enabled basically through the fact of centralisation of political power in Whitehall and, in this case, by the introduction of a monopoly of any BSE suspected cattle or any infected material by and the transfer to the property of MAFF. In order to keep the overall control of the disease in the country, MAFF rarely agreed to supply the respective material asked for by TSE researchers from abroad. Consequently, the vast majority of research carried out on BSE in order to shade light on non-knowledge on that group of disease were national research on BSE, conducted by governmental funded and subordinated institutions, especially by the Central Veterinary Laboratory, or was at least supervised by MAFF. Although this appear to be a matter-of-fact in the BSE saga, as history has proven, it is nevertheless rather astonishing and should deserve more scrutiny considering that explicitly scientific advisory committees were there to recommend on "any additional work required" and "priorities for future relevant research". It may be revealed that the governmental funded institutes were the most appropriate institutes, therefore the decision to put most money into them was correct, but that stance might prove wrong too. So it was less about to get the most distinguished researchers world-wide to think of clues and to work on solutions of how to deal with scientific uncertain knowledge on that group of diseases and how to regulate them politically, but more to pretend to have everything perfectly well under control inside the own national borders and to avoid to much un-filtered information escaping from there. So this underlying element of the UK risk political culture of "we know how to run the world" applied to this putative cattle disease.

An alternative hypothesis on the cause of BSE was given by an organic farmer and self-taught chemist, Mark Purdey. According to Purdey, BSE had its origin in high doses of "chronic exposure to mutagenic organophosphate pesticides". The reasoning, why this disease did loom in the UK only, though other countries also apply the pesticide, was that it was not only compulsory in Britain, but it was moreover used at an extremely high dose: "4 times the dose rate of what was used in France and Switzerland, but in Germany they never licensed Phosmet, the chemical." And as it is known from the Gulf syndrome of soldiers who served in the Gulf war, the chemical lead to damage of the neurological system. The same principle applied, according to Purdey, to the British cattle stock when Phosmet was used compulsory to protect the cattle against warble fly infestation. BSE and it's human counterpart, new variant CJD, is thus not an infection, but due to exposure to specific environmental factors, with organophosphate as the most prominent (but also, for example unleaded petrol). Purdey's theory was only previously supported by some evidence of experiments carried out by Cambridge scientists. (Although, other evidence suggests the opposite, namely an infection; for example, the scientific fact shown in transmission studies, where minks were fed with homogenates of BSE infected cattle brain and developed in every case the disease.) Purdey did, furthermore, claim to have cured two BSE cattle on his farm (with an comparable therapy as applied on soldiers poisoned by the Gulf war), but never received attention, but disbelief by MAFF. What is more, he and his family got  as many other dissenters in this case  rather unpleasant responses to their involvement to BSE ranging from intimidation till victimisation.

When BSE emerged there appeared only a few researchers particularly knowledgeable on the human form of TSE: the Creutzfeldt Jakob Disease. One of them was Harash Narang, a virologist, who published his very first paper on spongiform encephalopathy in 1972, and the first article on CJD in 1975. Since then he had always been involved in TSE research, most of the time (1977-1994) for the Public Health Laboratory Service (PHLS). He was considered as a real authority in the field of TSE and was repeatedly invited and asked for common research projects by Carlton Gajdusek, the U.S. Nobel-prize winning researcher on human TSE, kuru. But Narang was never appointed to one of the TSE advisory committees in the UK. Why not? There are two very different reasoning on that: One supported by Narang himself and by a few others; the other stressed by officials, but also repeated by various others. (And I am not in the position to judge who is right, and who is wrong.) Therefore, I am trying to serve both sides.

Narang developed in 1985 a test system ("touch impression technique") on which, he claimed, infected meat can be distinguished from non-infected (the test was developed originally for scrapie, but was modified in the course of and towards BSE). He did offer this test 1988 to MAFF but was rejected. Following Narang, his test was put down because it would be too costly for the government, for once you apply the test and you find positives, you have to destroy the animals and prevent them for going into the human food chain. Therefore, it was "pretended" by the government that there is no such test. Following the government, the proposed test system of Narang did never work, thus any application was of course never considered. Narang, who worked for more than 20 years on CJD, presented work in January 1988 at the Neuropathological Society suggesting that he had seen "atypical cases of CJD" under the microscope. But as the CJD surveillance who started in the 60s, but was set out in 1985, it was hard to assess his finding. A few months later, Narang's work was  like many others too  stopped. According to Narang, this was because "this fear came that I am going to rock the boat." According to the government, this was because Narang was accused of not keeping official safety regulations, and of inadequately sterilising instruments, as well as some more indictments. After Narang gave evidence at the House of Commons Select Committee on Agriculture in 1990  already at that time temporarily suspended from work - he was supported by a Member of Parliament. With the support of this MP, Narang ensured that MAFF was eventually badgered in 1991 to supply specimen to prove the validity of his test, until then refused because of "lack of specimens" (as part of the monopoly policy). The "touch impression technique" was carried out by Narang on 10 supplied brains. According to Narang, "that was not an experiment at all", for MAFF had mixed up the specimen and any necessary identification was gone. Hence, any results produced with his test were without relevance, useless and unable to be validated. Following MAFF, Narang's test simply doesn't work, for the specimen delivered by them were OK and not mixed up. The story of two different versions continued on several other opportunities (and is probably still in place by writing up this chapter). In 1994 Narang was made redundant from PHLS, but he is still working on CJD, funded by a private businessman who has a personal interest in his work.

Purdey like Narang, but also others, were seen as 'rocking the boat', and as often happens to dissenters or "outsiders" written off as "irrational". Both had a distinguished view, which was opposite to what the government believed (for example, when Narang claimed to have developed a test on BSE or even worse when he suggested that he had seen "atypical cases of CJD"). It was easier with Purdey, who was just a self-taught chemist and "only" an organic farmer to put him down, for he was not at all seen as the presenter of any legitimate knowledge claim. In particular considering that some of Purdey's ideas were not supported by scientific evidence (for example a poisoning with OP' s could not explain maternal transmission, therefore not the BAB's). It was harder to discredit Narang, who had done already distinguished work in the field. But both had a hard time for their insistence of their own version of the BSE story. Centralisation of power, was again an element, which came into being in dealing with dissent views. In both cases the government was at certain points pushed to accept and to arrange that Purdey or Narang got support (e.g. material or someone who carried out or repeated experiments suggested or done by them). But the official line was a narrow fabric of hypothesis to follow according what was seen there as knowledge or examine-worthy scientific uncertainty, highly selected and defined by an intriguing political culture of discretion. And not all of that, what was accepted as knowledge, was rationally comprehensible for those who were not part of the cultural background framing within decisions were made.

One of the recommendations made in the final Southwood Report of 1989 was, according to the assessment from the sub-title above, the monitoring of the Creutzfeldt-Jacob Disease. Contrary to the publicly repeated reassurance by the government that BSE has nothing at all to do with CJD, the CJD Surveillance Unit at Edinburgh was re-established as a matter of interest in 1990. Though the justification for that step was different. According to Rob Will:

The unit was funded by the Department of Health. Rob Will who had already worked as a junior doctor (1979-82) on the English CJD surveillance (established in the 60s but discontinued in 1985) became the principal researcher on it. Whereas the work at the unit was formerly low key with only Rob Will and two others working part-time on it, the unit got gradually more scientists on it to monitor the disease, until the unit became well equipped in 1997. The scientists there were the one who found out at the end of 1995 that something unusual was occurring in CJD, which was significant in the UK only.

The re-implementation of CJD surveillance in Edinburgh could be explained as a part of a precautionary politics, to know as soon as something were happening on the incidence. It could be also read as a sort of acknowledgement that there might be a risk which is worthwhile to monitor. Most likely and supported by interviewees, however, is the view that it was basically done to reject and to refute any deliberation made by critics that the idea of a risk of BSE for humans might get real. The latter is backed by the information that even scientists saw the re-establishment of the unit more as a good opportunity to catch up on science on this extraordinary rare disease than because they really thought there is a risk for humans:

When the ruminant feed ban was implemented in June 88, it wasn't at all clear whether this step would be sufficient to safeguard human health too  at a time consciousness already rose that scientific non-knowledge did not allow to assume this is not a communicable disease to humans, but instead transmission could not be excluded. Contrary to the (scientific) advice the government got from elsewhere (not from SEAC!) to "leave it" by just implementing the ruminant feed ban (until the BSE epidemic shows it's decline), the policy makers decided otherwise: In November 1989, the government introduced the specified offals ban (SBO) as a "mere" precautionary mean for public health  15 months after they'd introduced the ruminant feed ban to safeguard animal health.

The evolution of the specified offals ban was recalled by one of the consulting scientists as "the most crucial and difficult single decision that had to been made". The idea for the SBO ban was worked out already back in 1988, but it was announced publicly only in June 1989. And it took another five months before it came into force in November the same year. The delay was due to "a consultation period which is normal practice in Britain". This consultation process involved of course the industry:

The idea to implement a SBO ban was definitely nothing which was based on recommendation given by any scientific advisory committee, neither Southwood's Working Party, nor Tyrrell's Committee: If it had been dealt with inside the Working Party (which was in place when it was worked out), it would have been found in the final report, which is not the case. Although, it must be said that severe concerns of the risk of BSE for baby food raised in the Southwood Committee seems to be at the bottom line where the SBO ban took up its course. But like in the Southwood Committee, it appeared also not to be a topic in the Tyrrell Committee, which was already established and in place at the time of the announcement of the ban to advise the government on BSE. But the Tyrrell Committee was obviously not involved at all in that decision; for it was described as a "consultancy" to advise on research only. And again, nothing relating to the SBO ban was in the Tyrrell Report of 1989 (but published only January 1990). Instead, the decision for the SBO ban was made solely by the government, assisted by the Chief Veterinary Officer, and supported by a very few scientists (some individuals were also member of the scientific advisory committees). The Department of Health was not involved in the discussions, but got the information, that the government was planning to introduce a ban on SBO's, only from The Guardian newspaper.

The decision to take up precautionary measures to protect public health was made partially on the basis of Southwood's concern of baby food; but mostly on the already existing scientific knowledge on transmissible spongiforme encephalopathies (including human SE's) which left no doubt on the dangerousness of these group of agents, the horror of the syndrome affecting the human brain (like with CJD) and, in particular, the knowledge that there is no cure! All that in combination with the fact that there was putatively no test to examine which animal is actually infected and which not led the government to the decision to ban "risky" deemed bovine material. A step which was supported and probably accelerated by the already ongoing public risk discussion in Britain (people like Helen Grant, Richard Lacey and Stephen Dealler), but also outside: Germany prohibited the import of British MBM in May; the European Union forbade the exports of live cattle from Britain in July; and again Germany (the federal government under pressure from its Länder governments) imposed a (temporarily) unilateral move within the EU to restrict trade with British beef in November  the month of introduction of the SBO ban. Apart from those more closely, maybe more obviously influencing circumstances, it should be noted that already back in 1984 a set of regulations on uncooked meat products was introduced by the government, which excluded already certain tissues from uncooked meat products. Affected by this regulation were, for example brain and spinal cord. So already at a time prior to the first detected cases of BSE there was a kind of atmosphere that led to the judgement that particular animal tissue or organs are not appropriate for human consumption (at least in its uncooked state).

Taking into account all of those considerations, two possible scenarios were theoretically conceivable in order to protect the public: (1) As infected animals can't be detected without the availability of a sensitive test, one way would have been to kill and to destroy all British cattle herd. A solution which was suggested (for example by Richard Lacey), but which appeared never to be a real option in the actual decision making process at any time for various reasons: Certainly for obvious economic reasons, but also grounded in scientific uncertainty. Nobody knew whether this disease will in fact be transmitted to humans, hence it could have well been that it will finally prove not at all to be a harm to humans, although a lot of money was spent on precautionary measures. One interviewee gave an impressive account on the problematic:

So the other option was (2) to exclude tissue which might contain infectivity. And that was the way chosen, which led finally to the specified offals ban. But it kept on being a matter of judgement on scientific non-knowledge and analogy towards related disease (especially Scrapie again) which tissue was excluded in practice. In fact, the risky deemed material was defined on the basis of risk assessment on the knowledge of pathogenesis; and backed up by "the other thing that influenced these decisions was, which tissues actually are eaten". The final SBO ban came up as a judgement on the balance of risk of infectivity and consumption, and it included: brain, spinal cord, spleen, thymus, and certain parts of the intestines of all cattle older than six months. And it was never concealed in the interviews that it was a matter of judgement which tissue was considered as being potentially infectious; where not only supposed scientific knowledge (for nothing but analogy, mostly based on scrapie, was the guiding principle for decisions taken by scientists), but also reasons grounding in routines and practices of production and consumption played an eminent role, for example the discussion on the intestines:

So it was pretty clear that moment, that at least one part of industry would disappear literally overnight: the tripe industry. And as tripe is also used to produce rennet for the cheese production, the cheese industry would be affected as well. Therefore, the expression of "balanced risk" applied strongly here, where regulations which would severely hit some food industry was balanced to the risk of exposure the public to the agent - at a time any regulation could not be based on scientific proof for a lack of knowledge. Similarly, the restriction that calves under six months were excluded from the final ban (note: brain of calves under six months are still on sale, whereas the intestines of the very same animal had to be removed) were only partially based on scientific evidence, but did also ground on reasons others, but scientific:

Another practical reason mentioned to justify the six month-rule ground in economic deliberations. In fact, Britain have had and still has a flourishing export trade on young calves under six months to Europe. And it is interesting therefore to know that I used to ask members from SEAC the question, why calves brain younger than six months were excluded from the ban. Their replies given were highly sophisticated scientific reasoning and justifications for this specific routine and recommendation and: by far not identical, and none of them referring to the above offered reasons of practicalities in abattoirs.

Even retrospectively the introduction of these two bans  the ruminant feed ban and the specified offals ban  were the two most important single policy regulations during the course of the case. Whereas the principle of prevention was applied by the regulation of the ruminant feed ban, for at least epidemiological studies supported the view that MBM was the supposed causal factor for the disease in cattle; the precautionary principle was in place the time the specified offals ban was brought in, for it was only a hypothetical probability that BSE will transmit to humans  it was even not clear, if it would transmit at all, and if so in which form (CJD was only one option). So nobody knew whether BSE would cause any harm to humans, the risk was considered as being "remote" and unlikely.

Interestingly however, the scientific advisory committees, summoned to make recommendations concerning BSE, were not included as an institution at the policy making process. Even so, a few single individuals who were also members of one of those committees were explicitly asked to contribute to it. But apart from those individuals, both decisions were made by a rather small intimate group of policy makers, including just politicians and (senior administrative) civil servants: "All key decisions were taken by a small group of ministers chaired by the Prime Minister with the CMO and the DoH fully involved". So note, emphasis was made on a "small group", which took decisions, but not on the Cabinet, as it was suggested elsewhere.

The two examples of the SBO ban (regulation of the intestines and the six months rule) appear to be excellent to visualize how uncertain scientific knowledge, cultural practices, economic deliberations and decision making are twisted together. As the example of the evolution of the SBO ban have shown, political decision on scientific matters are grounded in a whole variety of cultural, social or practical factors which were clearly influential, but by far not only scientific ones: considerations of/on the industry - will they be able to cope with? how much will it affects them?, what are the costs, etc.  thoughts on how much it will influence the food habits of the public; and what are the actual responses of other nations, importing UK bovine products, etc.

So it was only partially a rational example of cost-benefit- analysis combined with judgement on scientific issues which led to the formulation of the ban the way it was. It appears therefore as a sensible (though not sufficient) explanation, when the head of the pathology department of the CVL declared that the SBO ban "was a political decision, not a scientific one". At the end the government underpinned by a few scientists, found that only a very small number of tissues deserved to be deemed as 'risky', which were also (and maybe in particular) easily digestible for the industry and the consumer likewise. It was, as expressed by a scientist, "a middle ground". That made it relatively easy, once everybody agreed upon (including the industry for they were explicitly asked in the consultation process), to introduce that regulation to protect public health: "It was hard to get there, but it ended up extremely simple". The introduction of the two bans could be interpreted, following Brian Wynne, as "bureaucratic processing of uncertainty":

The whole problematic was that BSE first of all was only a theoretical risk with neither proof of factuality, nor the possibility to assume the opposite. The whole misery of this situation was expressed in (probably) the most frequently quoted, but immense important sentence, formulated in the Southwood Report in 1989:

The risk was thought to be "remote", although the "possibility that BSE could be transmitted orally cannot be entirely ruled out". A view shared not only by the majority of UK scientists, but also for example by the WHO, which reached the same conclusion in a meeting held in 1990. But of course, some scientists from Britain, and not least Germany, did emphatically oppose that attitude and asked for stricter protection of public health. But their point of view was declared as unreasonable and "scientifically unjustified". Therefore any action taken (no matter if taken by decision makers, by advising scientists, or by ordinary abattoir worker asked to remove the offals) needed an inner persuasion. Correspondingly, any action to protect public health was not due to the principle of prevention, but absolutely according to the precautionary principle (in its very sense; though of course one might argue whether this regulation went far enough). And no hard scientific facts were available to support this view  not an easy starting point for an empiricist political culture.

But it was apparent years later, that this persuasion did not work in particularly well. Although the SBO ban had been introduced and enforced by law since November 1989, the reality in daily practice of slaughterhouses were somewhat different. And it was not before 1995 that a tight and strict carrying out of that regulation took place and was enforced by frequent and rigorous controls by the newly empowered Meat and Hygiene Service. And it was only then that the members of SEAC got the information that the rules implemented on SBO's were not followed (at least not uniformly, and certainly in an insufficient way). Unfortunately that late, for it was the same year the first victims of a new variant of Creutzfeldt Jakob Disease occurred in Britain  and, decisive: in Britain only. And though it is said and emphasised that infection of humans could have occurred only until the implementation of the ban in 1989, it is quite likely that infection with the agent took place at least until 1995, for it was not before then that the SBO ban seems to be properly implemented.

Although the policy regulation on the SBO ban was clear and well defined at the end (specified tissue of all cattle over six months), the implementation in practice, in the slaughterhouses, was much more complex. The abattoir workers were only told to remove the SBO tissue, but not, for example, how?

Interestingly however, even when the specified offals ban came into force on 13 November 1989, the slaughterhouses got no guidance of how to deal with and safely remove the potentially infectious deemed material.

In a letter send to MAFF by the Institution of Environmental Health Officers three month after the ban should have been implemented overall the country, the institution complained that:

It is obvious, how difficult it is, "to restructure all of the abattoirs, all over the country", in particular considering the fact that the slaughterhouse workers and also the people in charge got no clear guidance how to apply the regulation properly, but it was again up to the industry who knows best, to interpret the law. Instead of getting guidance, which they explicitly asked for (which is obvious in the letter of the environmental health officers), the industry and the slaughterhouse workers received quite ambiguous messages from different sides: On the one hand, they were asked to remove specified bovine material because of the risk this may contain. While they got on the other hand, so called "no-risk messages" when watching TV, listening to radio programmes or reading their daily newspapers.

One of the UK scientists referred to the heart of the problem:

And also considering the fact that in between 1990-1995 there were only extra-ordinarily rare inspections of their careful removal of the SBO's, which did not underline in particular a sense of urgency and necessity to do so. Or as one interviewee referred to that general problem:

It is hard to say whether the government did deliberately not control the proper implementation of the bans, which might have been the case. Under that condition the government took action (by introducing the bans) only to restore public confidence in beef (in and outside Britain), and not because they were convinced there really was a risk. Accordingly, it would have been fully sufficient just to implement the regulation, but not to make the additional effort to control the very same. But it is also conceivable that this was again a matter of trust in industry assumed to follow regulations; maybe because of the fact that the industry was deliberately included in the process of creation of this legislation (during the consultation process), so it might have appeared to be not unjustified for the government to presume that the industry would follow at least the regulations they helped to formulate. So this might be interpreted again as a token for the predominant political culture of deep trust of the government in the attitude 'industry knows best', how to fulfil the orders; and furthermore in naively taking for granted that industry will for sure transform any legislation into proper implementation even if not controlled by governmental inspectors.

The scientific advisers of SEAC, however, never reflected on the issue of whether the ban were followed (which was of course not their task) until they were faced by the facts. They were simply convinced with never a doubt raised and took it for granted that everything was perfectly well in place and under control; they vested trust in the government's ability to enforce the regulations and in the industry's credibility of transforming law into practice. But this view changed in 1995:

Retrospectively, some of the scientists became rather disillusioned in respect to the policy making business; a kind of lost naïveté spread around the scientists who advised the government on BSE:

It appeared to be a situation that everyone obviously relied upon and trusted the credibility of the respective other, which did not show to be an especially justified assumption: Politicians selectively relied upon "the most optimistic conclusions" deriving from the scientific discussion, namely that the risk is most probably remote, which appeared to be almost as good as "zero" (of course, anybody knew and emphasised that there is nothing like a "zero risk", as evident for example by driving a car or smoking cigarettes). But to calm down other risk perceptions in Britain and elsewhere and to restore public confidence in British beef, the regulations were introduced. As this step appear to be nothing but pure precaution taken by the government, and not supported by sound science arguments, the industry relied upon that there is definitely not a risk, otherwise the government would have certainly enforced the regulations they'd introduced. Therefore any real changes in practices and daily routines of feed mills or slaughterhouses were neither reasonable, nor urgent, but instead annoying. The scientific advisers of the government in turn relied upon that industry would naturally implement their advise given to the government, which was based on the assumption that a risk cannot be excluded but instead could well develop to be a rather serious threat to humans. And furthermore, it was assumed by scientists that the government would enforce the following of a law. Finally, the public must have had trust in the government, science and industry that neither of them would do anything to jeopardise their health and that of the future generations. The term virtual knowledge was hence a strong one in the United Kingdom, as virtual knowledge is very much related to social commitments.

It was no surprise that the BSE crisis turned out to be (after the "most likely explanation" that BSE was in fact communicable to humans in 1996) the "biggest crisis British policy has suffered since the Suez crisis", certainly in respect to public confidence in government's handling. There was therefore no amazement when Grove-White and others stressed for genetically modified organisms in the aftermath of the experiences made in regard to BSE:

It was frequently stressed by politicians and civil servants alike that the SBO ban, where the precautionary principle was applied, was considered as "going over the top, going to be too restrictive", for a lack of scientific evidence to support that regulation. For example, the removing of the spinal cord was described by a MAFF civil servant as "overreacting", as one "occasion we were precise from going to take measures that were unjustified". The then Minister of Agriculture did respond similarly:

So according to the perception of political decision makers in charge they did not only the least, but "always (..) what the [scientific advisory] committee suggested as the best solution. I can't think of a single occasion that isn't the same." It is of course a quite peculiar perception, for as we've already seen that the enforcement of the ruminant feed ban and the specified offals ban was far from being properly implemented in real life. Furthermore, it was least the committee, but more a few individual scientists, which "suggested best solutions" apart from civil servants in the ministries.

What did also shine out was the notion that regulations were not put in place because they appeared to be necessary or justified to safeguard public health faced by scientific non-knowledge and by the unanswerable question at that time whether it will ever be a risk to humans, but because the "arguments were entirely driven by the European Community". In fact, the EU had already implemented regulations in July 1989 when the import of British live cattle (born before the ruminant feed ban) were prohibited on a EU-wide basis. The EU therefore put pressure on the UK to take a more precautionary stance on that "cattle disease". But admittedly this needs to be seen in the context of the already existing Euro-sceptic view endorsed by the British political culture and with Margaret Thatcher as one of it's most outspoken and intense promoters of this viewpoint. The discussion of the role the UK played in the EU and vice versa got further fuelled by requests and sanctions by the EU which appeared to be in the perspective of policy makers as unjustified and not based on evidence, but directed against the British farming industry, in favour of others. But the pressure of the EU was something which couldn't  unfortunately at that time for policy makers, but fortunately in retrospect for the British public as a whole - be escaped by the British government, as member of the European Union. Of course, the enforcement to implement precautionary means by the EU counteracted any UK endeavour to downplay the risk of BSE. Although the European Union and the European Commission wasn't in particular known to follow a very precautionary policy  as it was lamented for example by Germany, but especially obvious in the Report of the European Parliament on the "alleged contraventions or maladministration in the implementation of Community law in relation to BSE"  the EU did at least initiate on a low level precautionary measures on BSE in the UK. This input was occasionally followed by a furious reaction on side of some British politicians and administrators in the EU and increased euro-scepticism inside Britain. For example when inspectors of the EU visited UK slaughterhouses in 1990:

"When BSE was raised by the inspectors about the deficiencies, Mr Keith Meldrum, Chief UK Veterinary Officer, apparently reacted angrily, stating that the Commission inspectors had no authority to investigate BSE matters; that BSE was not a technical but a political problem; the UK provided the best certificates in the world and the Ministry of Agriculture was reluctant to install computers in abattoirs due to issues of cost and confidentiality"

Once the regulations were in place, an exciting turn in the way the government and other policy makers thought on the issue seemed to have taken place  at least as it was described in the interview conducted with an UK scientist: