Examination of Witnesses (Questions 40
- 59)
WEDNESDAY 29 NOVEMBER 2000
PROFESSOR SIR
JOHN KREBS
AND MR
GEOFFREY PODGER
40. Not even 99 per cent?
(Professor Sir John Krebs) No, this was not related
to BSE controls. This was more generally looking at the hygiene
performance of abattoirs. So on that basis one would not automatically
assume that we are a darn sight better than other countries. We
are in the pack. Now for BSE control—because, as Mr Hinchliffe
said earlier on that, we have had painful and long experience
of this—our BSE controls are exceptionally tight, are exceptionally
well audited, and exceptionally well implemented. So it would
not surprise me to find that in relation to BSE controls we are
more like Manchester United in the European league table.
41. That is a dangerous analogy. I am a Leicester
City supporter! We will pass over that. On what date would the
report of the findings from the European investigations be available
for the public domain?
(Professor Sir John Krebs) From our own visit to Paris
today—
42. I am talking about the Commission.
(Mr Podger) The United Kingdom will certainly be pressing
for it to be made available as early as possible next month for
very obvious reasons. As I have said, the visit is between the
4 and 8. I think we would obviously hope that the information
would be available before Christmas. It is certainly intended
to stress to the Commission that we think this is essential.
43. If the findings show significantly lower
compliance in terms of precautionary measures, might that prompt
you to give advice with regard to imported meat?
(Mr Podger) If I may say so, if the report illustrates
significant deficiencies, then I think the whole Community would
wish to see action taken, starting with the Commission whose report
it will be. It does not inherently follow that there will be a
need for the United Kingdom to take unilateral action, although
that is always a possibility if we think the consumer is put at
risk.
44. Obviously there is a cost incurred in terms
of raising the standards, and particularly small abattoirs are
covered under that. How do you balance the need for food safety
regulation in abattoirs against the effects of the impact on those
businesses?
(Professor Sir John Krebs) It was very pleasing to
see in yesterday's Rural White Paper that the Maclean Report,
which we had been responsible for, recommended a new way of charging
for meat inspection that will help small abattoirs. That has now
been implemented by Government with support from MAFF. So we are
very pleased that the financial crunch, which was particularly
facing small abattoirs in relation to 100 per cent veterinary
inspection, has now been alleviated. More generally, we have in
our BSE controls review, considered the very difficult question
of whether the amount of money that is being spent on BSE controls
is proportionate in relation to the number of lives saved. Now
it is an extraordinarily difficult question to address, partly
because of the emotional sensitivity of it, but also because we
do not have some of the critical numbers. We do not know how many
lives are being saved by the current BSE controls, so it is not
like the fitting of the train safety system, where you are able
to estimate that it would save X, Y — £14 million per
life, I think, is the number attached to fitting the APT. What
we conclude in our review is that the current BSE controls cost
a total of about £550 million a year to the United Kingdom.
Some of that is a cost to industry but the bulk is a cost to the
taxpayer—in excess of £400 million. We also note that
in other contexts people have done studies of willingness to pay:
how much do people think it is worth paying to save a life? I
accept that this is an extraordinarily sensitive and difficult
area to work with, particularly in relation to a tragic disease
like variant CJD, but the figures that are generally seen around
is that people consider that paying up to £10 million per
life saved is an acceptable figure, and the figure tends to be
higher for things that are hideous diseases with long-term unknown
effects that impact upon the general public and children in particular.
So all of the things that CJD has, has pushed the number up. All
one can say is that if that number of £10 million were applied
to the current control measures, if one were saving 55 lives a
year by the control measures, it would be in the kind of ballpark
that people consider acceptable. The trouble is that we do not
know how many lives we are saving because we do not have any data
on which to base them. It would seem to me that it is not outwith
the sort of number of lives that one would expect to be saving.
My conclusion is that the current investment in control measures
is not an order of magnitude out of the range that will be reasonable
from the point of view of the general population's willingness
to pay. I am afraid that is a rather complicated answer but it
is a very difficult area.
Mr Öpik: That is a very helpful answer.
Dr Brand
45. If the Health Service got £10 million
for every life saved it would be extremely well funded. We have
been concentrating almost entirely on the infective agent and
control of the infective agent. Given that BSE must have been
fairly prevalent in the 1980s, are you surprised at the low number
of people who have gone down with this very ghastly new disease?
(Professor Sir John Krebs) It is difficult to answer
that question straight so I am not going to answer it straight.
I am going to say that without knowledge of the size of the infective
dose, which depends in part on the species barrier; without knowledge
of the incubation period, which we do not know; without the knowledge
of genetic variation and other sources of variation and susceptibility;
it is very difficult to ascertain what you would have expected
the size of the CJD epidemic to be; and, indeed, what the size
actually will be. At the moment, scientists from Imperial College,
Professor Roy Anderson's group, have built a model of the CJD
epidemic. They predict that it might have an upper limit of somewhere
in the 140,000 range but that is built on a lot of assumptions.
The straight answer to your question is that I cannot tell whether
I am surprised or not because I do not know what the answer is;
I do not know the size of the epidemic; and I do not know the
values of some of the key factors that would influence the expected
size and nor does anybody else.
46. Does this illustrate that your risk management
is, at the moment, based on fairly inadequate risk assessment?
I remember 30 years ago, in very small print in medical textbooks,
CJD was something which was genetically determined. A few years
later it was transmission through neurosurgical instruments. But
we did not have an epidemic of it and I am not sure that we have
an epidemic at this particular time, certainly not in statistical
terms. Are we looking at the predisposing and concomitant factors?
I was very disappointed in Phillips, where it looked at genetics
and organophosphates, for instance, and said that this was the
cause. It would be a very foolish person who said that this was
the cause but I am very surprised that no comment was made, for
instance, whether exposure to organophosphates predisposes a susceptibility
to the infected part. Is there work being done on that? Is it
your Agency or do you get advice from other agencies on the risk
assessment that you are being asked to manage?
(Professor Sir John Krebs) If I can go back to the
beginning of the last bit of your comment. We are clearly managing
a risk in the face of great uncertainty and knowledge, so I accept
that and am completely open about that. We are reducing the risk,
managing the risk, in the face of very incomplete knowledge. That
has to be said right from the beginning. Coming to the more specific
question about whose job it is to look at those factors that may
be predisposing if not causative—they are not necessarily
sufficient antecedents to be causative but they may be predisposing—that
really is the job of SEAC, the expert advisory committee. They
have looked at the organophosphates hypothesis and, in my view
and in line with Phillips, expert committees should revisit issues
in the light of emerging knowledge. They should not tick the box
and say, "We have studied this, goodbye." It would be
quite appropriate, particularly for DH in relation to variant
CJD, to come back and say, "Could you look again at whether
there is any evidence of predisposing factors to developing CJD,"
as more cases emerge. If it was an animal health issue, who is
concerned about the development of BSE in cattle and the predisposing
factor, that would really be a MAFF question. We come between
the two. MAFF is concerned about the cause of BSE in cattle. DH
is concerned about the future of the variant CJD epidemic in humans
and the consequence of that. We are in between the food chain
link from cows to humans. That is an important link. Our job is
to manage the risk in that link.
47. I remember when your Agency was set up,
we had all sorts of wonderful diagrams showing links to various
committees of who was going to do what. But I am very concerned.
We seem to be spending an enormous amount of money on trying to
reduce exposure to the infective agent. There is nothing wrong
with doing that but we do not seem to be terribly committed to
finding out why some people get this disease and others do not
and what are these predisposing factors. If we are going to leave
that to SEAC, I am afraid that one of the things which has come
out of certainly popular opinion, is that SEAC are not seen to
be extraordinarily proactive as an organisation which looks with
a slightly wider horizon on scientific phenomena.
(Professor Sir John Krebs) I should perhaps just clarify
the role of committees involved in research co-ordination because
that is your point. Where are the priorities for acquisition of
new understanding?
48. No, with respect, not really. What I am
saying is: do you have any powers to say, "Fine, you have
given us this task," or you have taken on the task through
the Meat Hygiene Service, who spend many millions of pounds, hundred
of millions of pounds, to control an infective agent. You have
got all sorts of things in place to look at the infection part
of things. But do you have any influence over other research questions
which should be answered? Are you the people who should be asking
those questions or can you commission that work?
(Professor Sir John Krebs) Yes, we do have influence
over the research questions asked. Sometimes it will be our job
to commission the research. Sometimes it will be the job of others.
The key thing is the co-ordination of research in the TSE area,
as in other areas, so the questions that need to be answered by
the Policy Departments at MAFF, DH and the Food Standards Agency
are being answered in a timely way. The way that co-ordination
is achieved is through the high level committee on TSE, which
Sir Richard Wilson chairs, of which I am a member, as is the Chairman
of SEAC, and beneath that there is a TSE Funders' Group who does
the nitty-gritty co-ordination. So if it was a priority for us
to have a greater understanding of predisposing factors, we could
make that case through the TSE Funders' Group. It would not necessarily
be our money. It might be MRC or DH money that goes to meet that
objective, but we could argue why that is a strong priority for
us and ensure that this research is put in place.
49. On the infection side of things, you are
happy that you put measures in place to improve co-ordination
between detection, monitoring and controlling infection? The problems
with food, cosmetics, medicines: not having a common approach
early on in the BSE events.
(Professor Sir John Krebs) I am not sure what the
question was or was it rhetorical?
50. Are you happy that you now have something
in place which co-ordinates that activity? Are the same people
now responsible for the monitoring and controlling of the infection
as well as debating it?
(Professor Sir John Krebs) I will ask Geoffrey Podger
in a moment to fill in further details. I am not complacent about
the degree of co-ordination. I am relatively new to the job. I
have been quite impressed by the degree of co-ordination cross-government
in looking at the TSE issue. It is certainly seen as something
that has to be integrated across the piece. Geoffrey probably
has more experience and can tell you more specifically the answer
to your question.
(Mr Podger) The point is well taken. Phillips spells
out quite clearly that different products were handled differently,
which is rather unsatisfactory. I think I must speak quite clearly
that the Food Standards Agency does not have responsibility for
cosmetics or medicines. Equally, what we do have are very close
links with the Department of Health because we report to Health
Ministers. We do engage in quite a lot of discussion which I,
myself, engage in as to the various measures which can be taken
in the different areas and whether they are, in fact, consistent
and reflect a common approach to risk. So I would like to hope
that the lessons of Phillips in that area are beginning to be
learnt but I have to say, quite frankly, that there is always
this difficulty that government is like a cake, you have to cut
it one way or another. So actually getting co-ordination within
that is not always easy. A better arrangement is in place now
with Phillips but we do have to be vigilant on that.
51. I am a bit concerned, Chairman, that we
rely on hope here. I would have thought that it would be quite
clear that somebody should take an overall responsibility to make
sure that the infective agent does not get into a typical tumour
irrespective of its root.
(Mr Podger) It is an issue for co-ordination between
the Departments involved, which in England are MAFF, the DH, and
ourselves.
52. Do you think there should be one single
lead agency?
(Mr Podger) I think it is clear that given the difficulties
that were in the past, Phillips suggests himself that there would
have been an advantage in doing that. We would like to think that
now this lesson is learnt. I have to say one very obvious co-ordinator
across the patch is the Chief Medical Officer, who does take a
strong interest in the work of the Food Standards Agency, in the
area of medicines, cosmetics. It is not his direct responsibility
but it is his responsibility as the Government's principal health
officer.
53. It would be quite useful to make that a
formal responsibility?
(Mr Podger) I think the Chief Medical Officer would
take the view that he has that responsibility. Of course, I cannot
speak for him but I would be surprised if he did not.
54. On a specific issue, has the FSA been consulted
on the use of blood and meat and bonemeal fertilisers? There is
quite a lot of concern about that.
(Professor Sir John Krebs) I am sorry, I missed the
question.
55. Do we use blood, meat and bonemeal as fertilisers?
(Professor Sir John Krebs) That would be of concern
to us if we saw a food chain dimension to it. What we have said
in the BSE control review report is that SEAC is going to consider
the issue, particularly of sheep blood, now that some evidence
is emerging that the infective agent could be transmitted through
blood in sheep. There is some preliminary work from the Institute
of Animal Health, which was covered in The Lancet earlier
in the autumn. So the dimension for us is: does it pose a food
chain risk? Well, it clearly could pose one if the infective agents
were being recycled through the environment and back into animals
and, therefore, into the food chain. At the moment, we are waiting
for SEAC to take an expert view of the risk of using sheep's blood,
in particular, as a fertiliser.
56. But there is no certainty on that yet, I
take it? Is it not a little late? These questions have been around
now for five years. Do you have specific advice to the Government
on the rendering industry?
(Professor Sir John Krebs) To be fair, the question
about blood has been around for a long time. But the state of
scientific knowledge is changing and the key thing which changed
this year was the experiment that Professor Bostock and colleagues
from the Institute of Animal Health did—so far, only on
one sheep—but showing that you could transfuse blood from
a BSE infective sheep into another sheep, and transmit the infection
along with the blood. That was a new finding, a new piece of science,
and—as indeed Phillips recommends and should be done as
a matter of commonsense—one revises one's assessment of
risk as new knowledge emerges. So having previously said that
blood does not contain infectivity, so it is not a problem, if
we now have a sheep that may contain infectivity, then we have
to look at the issue again. This is why one goes back to SEAC
and says, "In the light of this new evidence, what is your
risk assessment?"
57. Does that mean that I can spray bonemeal
over my raspberries and eat them the next day?
(Professor Sir John Krebs) Of course, the use of fertilisers
in agricultural products is really the responsibility of MAFF
rather than the Food Standards Agency.
58. But you have a very clear link, in the way
you were set up, into the use of fertilisers on plants.
(Professor Sir John Krebs) In so far as they relate
to human health risks in the food chain.
59. Because you sit on the Committee, do you
not?
(Professor Sir John Krebs) I sit on the Advisory Committee,
the Pesticides Committee, and the Veterinary Products Committee,
yes.
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