FSA Consultation Letter, 9 December 2004
Comments are sought on proposed possible changes to EC Regulation 999/2001 following an announcement by the European Commission of a possible finding of Bovine Spongiform Encephalopathy (BSE) in a French goat. It is proposed that these changes will only be implemented if BSE is confirmed in the suspect animal. Responses are requested by: 6 March 2005
Consultation details
The proposals extend the list of tissues that are designated as specified risk material (SRM) in goats, and increase the level of TSE monitoring in goats. The Agency is consulting only on the proposed changes to goat SRM.
Responses are required by 6 March 2005 . However, it would be very helpful to receive your responses, even if these are only preliminary, by 7 January 2005 . This will enable your views to be fed into early discussions of the proposal at the meeting of the EU Standing Committee on the Food Chain and Animal Health (SCoFCAH), which is likely to be held in mid January.
However, if you are unable to respond by mid January we would still like to have your comments as it still may be possible to feed these into the decision making process.
Background
EC Regulation 999/2001 (as amended) lays down Community-wide rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies (TSEs). These rules are amended as necessary in light of new findings and emerging scientific evidence.
On 28 October 2004 , the European Commission announced a possible finding of BSE in a French goat. In accordance with EU procedures, the finding was submitted to the Community Reference Laboratory (CRL) in Weybridge for evaluation by an expert panel. The Commission issued a subsequent announcement on 26 November stating that the expert panel had met and concluded that currently available results were incomplete and a further two months were required before all the results could be properly interpreted. The results of the CRL evaluation are therefore expected in the New Year.
Although BSE had never before been found naturally occurring in goats, there has for some time been acknowledgement of the possibility that it could exist, masked by scrapie. This is because it is likely that some goats ate the same feed that spread BSE in cattle and laboratory experiments have shown that BSE can be transmitted to sheep and goats. As a result, precautionary measures, such as SRM controls, have been in place for some time to minimise any potential risk to public health.
In its opinion of April 2002, the EC Scientific Steering Committee (SSC) recommended additional measures to protect public health in the event that BSE should become likely in small ruminants. In view of the possible finding of BSE in a French goat, the Commission is proposing that the additional measures recommended in the SSC opinion should be implemented, if the finding of BSE is confirmed.
The draft EC proposal was discussed at an EU TSE Working Group meeting on 30 November and will be subject to further discussions at SCoFCAH in December and January. It is unlikely that SCoFCAH will vote on the proposal until the views of the CRL expert panel are known. These are expected at the end of January 2005.
One effect of the proposal will be a change to the list of tissues that are designated as Specified Risk Material (SRM) in goats. As the proposal currently stands, the list of tissues designated SRM in goats will be extended to include:
These tissues would be designated SRM in goats of all ages. Spinal cord will remain SRM in goats over 12 months of age.
At present, only the spleen and ileum are designated SRM in goats of all ages, while the skull (including the brain and eyes), tonsils and spinal cord are designated SRM in goats aged over 12 months of age.
At this stage, the FSA is inclined to support the extension of the tissues to be classified as SRM. The EC proposals would remove most of the tissues that are associated with BSE infectivity in an infected animal. Unlike in cattle, the lymph nodes in sheep and goats have been shown to carry TSE infectivity in infected animals. However, removal of all lymph nodes, would not be practicable.
We would welcome your views on any benefits or drawbacks likely to result from the changes set out above and in the Regulatory Impact Assessment (RIA) [available from the FSA web site], in particular, on the potential cost of the proposals and practical aspects of removing the additional SRM. Your views will help to formulate the UK negotiating position on this issue. I must emphasise how much we need you to contribute to this process. It will not be possible to accurately assess the impact of the measures without your assistance.
We apologise for the short interim deadline but this is driven by the EU timetable. If you are unable to meet the interim deadline, your comments are still important to us and can be fed into the process at a later stage. Even if you were able to make preliminary comments, it would still be possible to send more detailed comments later.
If the proposals do become European law then domestic legislation, in this case the TSE ( England ) Regulations 2002 (and equivalent legislation in Scotland , Wales , and Northern Ireland ), will require amendment to take account of the new European Regulation. In addition to informing you of the Commission proposals, we are also informing you of a possible new domestic requirement, relating to goats, if the Commission proposals receive a positive vote. At present, there is no difference between tissues designated SRM in goats and tissues designated SRM in sheep. That position will change if the proposals relating to goat SRM are accepted. As it would be difficult to differentiate between sheep and goats once carcases have been dressed, it would be necessary to introduce an additional measure to enable such differentiation for enforcement purposes. We would therefore need to consider introducing a 'goat stamp' to aid correct identification and removal of SRM. This stamp would probably be applied by the MHS. We would welcome your views on this proposal and any effects – positive or negative – it might be likely to have.