Recent letter to Opposition parties: What the new Government
will find
(We have been asked to publish it but can only say that it seems
valid. The author feels that, should the Government change, the
arriving Government will find things to be much worse than they
were told beforehand)
I am worried that Labour may not be aware of what they will
find concerning BSE if they become elected.
I enclose a number of specific problems on separate sheets:
. Much greater cost of BSE than is currently
realised.
. Life Insurance industry realises that they may
not be able to pay.
. Herds cannot actually be claimed to BSE-free
despite any cull.
. Refusal of MAFF to release data on BSE
epidemiology and many other factors.
. Research budget lower than appears and most is
simply taken from other research.
. Public Health kept out from BSE but now let in
but knows inadequate amounts to act.
. BSE case numbers do not seem to be dropping
towards zero. i.e. it may become endemic.
. UK land contaminated with BSE: inadequate
research into significance; just fingers crossed.
. No money spent on looking for treatment.
. German determination to be free of BSE.
. Apparently low numbers of BSE in Europe. Is
there another factor involved?
. Vertical transmission of BSE. Unpublished
data, poor accuracy.
. Vertical transmission of BSE calculated by MAFF
using other methods. Again the
data kept unreleased.
. Computer systems demanded by EC to keep track
of UK beef produced invalid data.
. Predictions of BSE in the future have such high
confidence intervals that we cannot
expect bans to be lifted unless extreme actions are
taken.
. Data released is always in cow numbers with
BSE. MAFF have been able to calculate
the number of infected cattle eaten for many years but no
such data released.
. For some reason the incubation period of BSE is
still dropping. This does not fit with
other MAFF suggestions of what it happening.
. MAFF deliberately misinformed both the EC and
the House of Commons.
. MAFF credibility has crashed (for good reason!)
with many official bodies and not just
with the UK public.
. Environmental contamination quantification not
carried out.
. Now admitted unofficially that the mouse
inoculation test for tissue infectivity was a
million times too insensitive to show which bovine tissues
were safe enought to eat.
. Environmental contamination from smoke and ash.
MAFF have data indicating that
incineration is inadequate to destroy the agent chemistry.
Not released.
. MAFF not withdrawn its original guesses about
BSE e.g. feed manufacture methods.
Renderer compensation excess.
. Workers in abattoirs have not been told of the
risk that they may have taken.
. Pharmaceutical products may have contained
infected products before 1989. Hib vaccine.
. Human risks not discussed openly.
. Environmental contamination of water.
Inadequate research.
. Blood transfusion risks from BSE; these may be
serious and foreign countries may ban
UK blood.
The thing to remember about all TSEs is that by the time you
find out what is happening it is always too late to do anything
about it. In other words you have to take action before proof
is available; before scientific certainty. You have to take
pessimistic guesses. The reason for this is simply that this
sort of disease can affect a large proportion of a population
and so if you take optimistic guesses and are wrong, the effect
can be extremely damaging for the whole country.
What happened was that MAFF took optimistic guesses and kept
other groups out from the subject using many methods. What
Labour will find is that a lot of the optimistic guesses have
turned out to be wrong and so the effects we are now seeing
start to build up may be quite severe.
. BSE has a much larger cost than the 3.3
billion mentioned in the lecture of Mr. Hogg to the NFU meeting
last week. e.g.
Cost of the people dying of new variant CJD: in hospital 100
days, 100 per day,
85,000 people
(highest figure indicated by recent article in Nature from
group in
London School of Hygiene and Tropical Medicine, highest figure
from article in
British Food Journal was much higher and LSHTM group admit that
their results may turn out to be very low)
Cost of research into treatment
Cost of research into diagnosis
Cost of many things that took place in Europe (slaughter, etc)
Cost of all the side effects (loss of income from people dying
at age 20 after many
years of schooling, cost to all the various groups from
losses, etc)
The 3.3 million is the cost to the treasury but the actual cost
is much greater to the community.
. The Life Insurance industry is aware of
the potential risks to them and have taken on a Professor of
Statistics at the University of London to advise them. I know
that they are aware that, should things turn out to be bad then
the industry would be hit extremely badly and may not be able to
pay for the costs. The reason is simply that we cannot know who
is infected and life insurance virtually assumes that people
have a low likelihood of dying before the age of 60. With
humans dying young of nv-CJD the cost would be very high indeed.
i.e. I presume they are considering taking nv-CJD off the
conditions that they would permit the policy to be valid
following.
. Herds cannot actually be stated to be
BSE-free. This was made clear by the Royal Veterinary College
in a statement last week but has been quite clear to everyone in
the field for some time. i.e. you cannot declare that any herd,
or cow is not incubating the disease no matter how many culls
you do (unless all the cattle are slaughtered). Because of this
it is unlikely that any of the Europeans and many of the other
countries will accept any UK beef for many years, no matter how
many Florence agreements are fulfilled. Does Labour realise
this? It was made quite clear in Anderson's article in Nature
in August '96 and MAFF is probably perfectly aware.
. Data about the epidemiology of BSE (i.e.
the information about the cases of BSE) have not been allowed to
specific groups for academic study. e.g. Professor Kent in
Leeds has not been supplied with the data that he asked
for...but then again he was one of the authors that showed that
we were eating large numbers of infected cattle in 1995.
. The research budget for BSE is really
miserably low. Compared to the money spent on compensation to
various groups it is low, and much of it simply goes to
Government groups anyway. What is not apparent in these figures
is that much of the research money is simply being taken from
other research i.e. instead of being spent on chicken research
it has been diverted to BSE research. It is not being made
clear that the research budget to MAFF Labs as a whole in the UK
has been going down steadily and quite a large percentage of the
staff made redundant (for instance the major researcher into the
epidemiology of BSE is losing his job in about a month's time).
What added research budget has been put into BSE or nv-CJD and
not just taken from some other part of the research?
. For a long time the Government refused to
let the Public Health Laboratory Service carry out any work into
BSE, to calculate its risks to the human population, or to
investigate what action should be taken to avoid BSE as a public
health risk. This was stopped in about June 1996. As a result
there are very few people in the PHLS who actually understand
the subject very well: but they have been made important figures
to advise the DofH. The subject is far too complex for that and
the DofH will be inadequately advised. The PHLS has no budget
for research into the BSE public health risk even now and do not
seem to have asked external experts for their advice. When
Labour are in power they will find out just how little has been
done and just how many people involved are often self-proclaimed
experts. People that disagreed with the MAFF were denied
funding and their ideas derided (e.g. Prof Lacey, who seems to
have been largely correct).
. The number of cases of BSE do not seem to
be dropping towards zero. This work was published by MAFF
epidemiology group about 9 months ago as a graph in their 6
monthly document and was probably not noticed because of its
complexity.
. Everyone in the field is aware that a
large amount of infective material will have been fed to cattle
in the UK and simply passed through their gut to become cow pats
on the land. Despite the MAFF's attempt to indicate that prion
infection disappears in the land, the rate is extremely low
compared with other diseases and again, there is little evidence
about BSE as the experiments were done with scrapie. Scrapie
seems to remain endemic within the sheep population and it is
not clear how the agent remains associated with the land. Why
should this not be true with BSE? MAFF spent a lot of time
saying that BSE was just scrapie and hence it would not infect
humans (this was always scientific nonsense) but it really would
be true that we would expect UK land to be contaminated with
BSE.
. As far as I know no money is being
invested looking for methods of treatment for nv-CJD. There was
one person looking into this since 1992 and only now John
Collinge has taken up an idea. The problem with treatments is
that you have to start looking for one at least 10 years in
advance of the epidemic because it takes that long to develop
drugs. As it is we will have seen a lot of cases of nv-CJD with
no method of treatment.
. The cow that has died in Germany of BSE
is of unknown origin: many arguments have been put forward. The
Germans have decided to cull all cattle imported from UK or
Switzerland as a result. How can we expect Germany to take up
imports of possibly infected cattle from the UK again soon?
. Why has Europe not seen many cases of
CJD. We can calculate the number of infected cattle exported
and expected to live long enough to develop symptoms (about
1500) but less than 200 (inc Rep Ir) have appeared in official
documents from EC countries. Also, we have imported cattle from
EC and they have died of BSE within 18 months of entering the
UK. As we currently expect cattle to become infected when very
young this would suggest that they were already infected when
they entered. Also, at least one cow exported from Holland to
Portugal seems to have developed BSE. Are we being had? Is
there some other factor that is involved (e.g. organophosphate
insecticide phosmet) in the UK? At the moment the farmers think
that the French are denying cases.
. The vertical transmission rate of BSE
has now been declared as 7.8% in the last 6 months of the
incubation period of BSE in the mother. This data has been
submitted to SEAC but not published. No confidence intervals
appear to have been included in this sort of data as should be
present in statistical data. What are the findings? What are
the confidence intervals?
. Vertical transmission rates have been
calculated from MAFF data looking at the chance that the
offspring of a case of BSE will develop BSE itself. Complex
statistics have to be carried out to work out what is going on.
Remember that the figures have to be corrected for many factors
in order to make them valid and MAFF will do their best not to
admit the result. The finding was given to me in confidence and
so I cannot release it.
Vertical transmission would expect that there would be two
populations of cattle with BSE: one caught it from eating
infected feed and the other from their mother. No two
populations have been found from the statistics so far.
Europeans will simply not accept our declarations of 'BSE free
UK' unless this sort of finding is made.
. Computer systems were set up to work out
what was happening with the beef industry. They were a complete
flop. An example would be to ask the number of individual
cattle recorded on the computer as slaughtered in 1994 or
1995. Things may have improved but, it is not surprising that
the EC report is simply so damming of MAFF's action as the
computers were originally demanded by EC and MAFF agreed to run
them effectively.
. The prediction of case numbers in years
to come all depend on how number of cattle are slaughtered as
part of the cull and how effective the cull is. MAFF are aware
of the number of cases expected in 2001, 2002 etc of BSE after
the cull; and the confidence intervals. This simply
shows that the very optimistic calculations still expect cases
of BSE then.
. For every case of BSE seen we eat about
7 infected cattle (although this has changed a bit due to the
thirty month slaughter policy). How many infected cattle would
be being slaughtered, eaten, incinerated etc in the years to
2001 and the confidence intervals.
. The incubation period of any
transmissible spongiform encephalopathy depends on the dose of
infection present in the initial food that caused the disease.
The more infection eaten, the shorter the incubation period.
For some reason the incubation period (when other factors are
taken into account) of BSE in the UK seems to be dropping. How
could this be? After all, by rights the cattle dying now would
have eaten infection after the feed ban! It is as if the few
numbers are actually eating more BSE. One explanation is
underreporting by farmers (British Food Journal, 1995) but
there may be others. MAFF has not put forward any reasonable
explanations but some of them suggest that the disease may be
becoming endemic.
. MAFF information to the EC has been
deliberately misleading. The worry is that the information to
the House of Commons has been similarly misleading. The report
from the EP temporary committee of inquiry into BSE is to be
debated soon in the EP and will indicate that much of the data
was deliberately misleading. I have a copy of the report and it
is damming.
. MAFF information to the population
concerning listeria, cook-chill food, microwave ovens,
salmonella, E coli 157, and BSE have left them with minimal
credibility. The internal memo at the Meat and Livestock
Commission indicates that they can no longer rely on MAFF to
advise the population as the people simply would not believe
them. MAFF now has a large credibility problem in the UK but
the EC sees itself as having been taken for a ride also.
Remember that MAFF staff were on the veterinary committees that
were supposed to advise EC and are now indicated to have mislead
the EC. Two of these major advisors are now on SEAC. Labour
will have to look to see if various people on the SEAC have been
involved in the misleading that the EP claim.
. The environmental contamination with BSE
is actually very difficult to quantify. The reason is simply
that MAFF researchers failed to carry out the major research
into looking for it or even to look for methods of doing this
estimation. Quite inadequate funding was given to BSE
researchers both inside and outside MAFF (even though the
figures may look large) and various researchers were not
replaced when they retired.
. The major finding that mouse inoculation
was very insensitive method to test for BSE in tissue was
released at a lecture in Liverpool in June 1996 but has not been
released either in scientific literature or in Government data.
This must be admitted officially. The finding was that between
1000 and 10,000 infective units (one IU is the amount needed to
infect another cow) was needed to infect a mouse. This meant
that, as only 3mg of beef tissue could be injected into the
mouse, all we can say when we find that the mouse does NOT die
of BSE is that there is less than 3,000,000 IU per gram of that
tissue.
This was not made clear in information to the House of Commons
or to the EC. It was simply indicated that the mouse inoculated
with muscle (for instance) did not die. It was not indicated
just how little this meant as an indicator of the amount of
infection in the tissue.
The particularly irritating thing about this was that the German
Government seemed to realise immediately the poverty of
information that was available on BSE and how MAFF was trying to
pull the wool over eyes with misinformation, whereas the House
of Commons was not being informed with useful data.
. Environmental contamination from smoke
has not been assessed and the attempts by SEAC to assess it have
been poor and not fully published. I am aware that information
has now appeared suggesting that incinerated BSE remains at
least partly intact (this was extremely shocking to everyone
involved as the temperatures were very high). The regulations
concerning the incineration of bovine offal or infected
carcasses seem to be extremely lax and everyone knows that this
sort of incineration does not raise temperatures of some parts
of the material very high. The worry must be that MAFF and the
DofH are aware that incineration is not fully destroying the
chemistry of the agent...and yet they are not releasing this to
the House of Commons. The evidence from the USA that scrapie
is not destroyed fully by incineration (it is found still
infective in the ash after heating to over 300C) must suggest
that incineration may be inadequate for BSE. As far as I know
no adequate research is being carried out to assess the
effectively of incineration of BSE.
No research seems to be carried on into the risk of transmission
of a TSE from smoke or by the lungs.
. For a long time MAFF declared that it
was the change in the manufacturing process of bovine meal from
rendered cattle that caused the BSE epidemic. The evidence for
this has now become extremely thin. e.g. other countries with
the same methods do not have BSE, scrapie is present in other
countries and those sheep were also rendered, attempts to assess
rendering methods showed little effect of the methods used
before the changes in the late '70s, some rendering plants
changed in early 1970s (why did not the animal they fed get the
disease earlier?), there is now evidence that BSE is not scrapie
(some was available in 1990). The scientific groups are now
simply saying that BSE is probably a change in scrapie or a
sporadic change in the genetics of a single cow prion gene.
However MAFF still seems to be following the same ideas it had
earlier despite the scientific advice.
The renderers (including Prosper de Mulder that have done very
well out of BSE) have received a large amount of compensation
from MAFF. How much (I think it was going to be 53 million
pounds)? i.e. far more than money spent on research.
. The workers in the abattoirs were for a
long time kept unaffected by the documents from the Advisory
Committee of Dangerous Pathogens (organised by the DofH and the
Health and Safety Executive) on TSEs. i.e. in a lab we had to
handle samples that might be infected with BSE e.g. a liver of a
cow in a certain way (gloves etc) but in an abattoir no such
regulations were imposed. The reason for this was supposed to
be that the abattoirs had their own regulations from their own
voluntary body. As far as I know no adequate action was taken.
I remember going to a slaughterhouse and watching bovine heads
cut up with a saw with fragments of brain splattered around.
This happened to all the cattle heads as the brain was discarded
but the head meat was removed to be eaten with the eyes. MAFF
have not admitted that the keeping of the abattoir workers apart
from the ACDP directions may have put them at risk. Inadequate
information is available about the size of the risk that has
been taken.
. Pharmaceutical products, particularly
some vaccines may have been made using bovine products.
Recently the Italians have banned the use of the Hib vaccine
(given to all children in the UK) because of this. The
producers deny any cattle from the UK were involved but no
estimation of risk has been carried out and no attempt to look
into the contamination of pharmaceuticals from before 1989 (dont
forget that we will have eaten probably over 100,000 infected
cattle by that time).
. The human risk from before we knew BSE
even existed has not been even discussed openly outside
scientific groups. I have no evidence of MAFF or DofH having
looked into this or carrying out any attempts at such
calculation, even though some data would permit broad estimation.
. Environmental contamination in the soil
may well not pass through to the water. Myself, I would expect
it not to. However no adequate research is taking place into
this or apparently even being planned. Due to dilution I would
expect the risk from it to be low, but there are arguments
concerning this and these do not seem to have been either
published in the scientific literature or discussed openly in
parliamentary groups.
. For some reason the DofH seems to have
remained totally silent about the risks of blood transfusion.
The Nature article predicted a maximum of 85,000 cases of nv-CJD
currently incubating the disease (this may well be an
underestimate). It would be expected that their blood would be
currently infective and, as this group are just the ones that
donate blood it should be assumed (as it is in other countries)
that their blood is dangerous. This would suggest that one in
every 200 pints of blood donated currently comes from a person
infected with nv-CJD.
At the moment I am told that the US is likely to ban UK donors
of blood and the EU countries to ban the export of UK blood
products, specifically because of BSE.
There can be no proof at the current time of the number of blood
donors infected with nv-CJD and no proof that it is
transmitted*. However, because of the sheer numbers of people
involved it should be assumed to be infective, accelerated
research put into looking for methods to diagnose the condition
before symptoms appear (i.e. in donors) and the use of blood in
the UK (it is grossly over-used here) limited to when
necessary.
*Statistics from human studies of CJD are quite inadequate
currently and anecdotal evidence has appeared to indicate both
that it is a risk and that it is not.