Memorandum submitted by The National Farmers'
Union of England and Wales (R 7)
1. INTRODUCTION
The NFU has recently made a submission to Government
on MAFF's Research Strategy 2001-05, and some important points
have already been made in this. To some extent all of them relate
to the Agriculture Committee's present inquiry. The key points
we made to Government are as follows:
MAFF should direct its research and
development funding into five priority areas: functional genomics,
quality predictions, alternative crops, soil-root interactions,
and organic farming and integrated crop management;
there should be the fullest integration
of public research in agriculture and food, whether through MAFF
or the Research Councils, with agricultural levy-funded research
and with privately funded programmes;
there is concern about the collapse
in farm incomes and the real need to ensure that publicly-funded
research and development, which is intended to improve the competitiveness
of UK agriculture, is sustained. Without a more prosperous agriculture
the uptake of environment-enhancing research and development will
be slowed and weakened;
there is a need to retain a critical
mass in key areas of research, and MAFF should actively consider
whether the creation of "centres of excellence" can
assist in cost-effective delivery of its priorities as well as
retaining the science base of the UK as a whole; and
there is concern about the somewhat
uncomfortable research division that has arisen with the transference
of "food safety related research" to the Food Standards
Agency (FSA).
While there could be considered to be some relationship
between TSEs and intensive farming, for the purposes of this submission
we deal with these issues separately.
We are not completely clear what is meant by
the term "intensive farming" which, in popular perception,
tends to have a pejorative meaning or has come to connote "unnatural"
practices. In some ways the very process of farming itself could
be considered to be "unnatural" and each farming method
is in some way a compromise or balance between the need to adequately
and safely feed the human and animal populations, while ensuring
(a) sustainability, maintaining biodiversity, safeguarding the
countryside and the environment, and protecting animal health
and welfare, and (b) a fair return to the primary producer to
cover the cost of his labour and a return on capital invested.
Probably no single farming system fully satisfies all these desiderata.
The average person probably conceives "intensive"
farming to be the process of farming that utilises to a greater
or lesser extent, pesticides, herbicides, and fertilisers and
which, in livestock production, applies more closely confined
housing (at least for some part of the husbandry cycle), the use
of modern veterinary medicines and feeding regimes based on industrially-produced
feeding stuffs. The NFU would prefer to call these "conventional"
farming methods as they have predominated since the Second World
War in the UK and other developed countries.
2. SCALE AND
FOCUS OF
GOVERNMENT RESEARCH
INTO TSES
The actual or potential presence of TSEs in
a range of mammalian speciesincluding humansindicates
the broad nature of research required in this area.
The current MAFF programme subdivides into four
headings:
The NFU is not scientifically competent to comment
on the validity or even the potential or any single project, but
we can attempt to identify priority areas from the point of view
of the livestock farmer.
The main policy objectives of the research programme
relate either to animal or human health, with a pronounced leaning
towards the latter. This clearly has funding implications.
While resources must continue to be available
to support work into a range of diseases, about which relatively
little still is known, sources of funding should reflect the fact
that TSE research is aimed in the main at protecting public health.
In other words support for this work should not be at the expense
of research in other areas of more direct animal health importance.
The Scale of Current Research
There appear to be around 60 MAFF research projects
spread over the disciplines listed above. Once again, the NFU
is not competent to judge the merits and demerits, the usefulness
or otherwise, of any part of this work. There are certain issues,
however, which recur.
One of these is the need to improve the reliability
of the BSE post mortem tests which are currently available being
developed. Related is the need for an inexpensive live diagnostic
test in the foreseeable future for pre-clinical presence as well
as for clinical infection. The need for these tests has been given
particular impetus by the appearance of BSE cases in other EU
member states. In addition to this the value of a test that differentiates
between BSE and scrapie could be enormous. The Central Veterinary
Laboratory project on "assessment and validation of emerging
methods and reagents for BSE diagnosis" will be a particularly
valuable part of the research effort.
The behaviour of a TSE within its host species
and its susceptibility to factors outside of itself (eg heat,
enzymes) form a significant part of the epidemiological programme.
This work is obviously crucial in terms of control of spread within
a population, and in the calculation of risk factors. It might
also help pinpoint causes, thus helping to identify the quickest
route to eradication.
The NFU recognises the importance of ensuring
a complete knowledge of TSE strain types, particularly in relation
to the assumption of a single predominant BSE strain. If other
strains do exist, the implications for eradication and for human
health, must be addressed. Similarly, the possible survival of
the agent in the environment must be addressed.
Work on pathogenesis in tissues outside the
central nervous system will lead to a better understanding of
infectivity, and enable differentiation between TSEs, a point
of particular significance in relation to the scrapie/BSE issue
in sheep. The associated identification of host factors influencing
susceptibility to disease would have relevance for diagnosis,
ultimately.
From the point of view of the protection of
public health the importance of determining experimentally which
species are susceptible to BSE, and the tissues that might carry
infectivity, is of primary importance. Work in progress, among
other aims, looks to establish the extent of maternal transmission,
and the relation of "dose" of agent to the appearance
of clinical disease. We see these as valuable exercises, providing
information on which control/eradication programmes, and therefore
consumer protection, depend.
3. SCALE AND
FOCUS OF
GOVERNMENT RESEARCH
INTO "INTENSIVE
FARMING"
The present research projects undertaken by
MAFF are linked to 10 policy objectives, though one of these (Objective
IIIon securing a more economically rational CAP) does not
have research projects associated with it as such. The following
specific comments are made on what we see as the main research
areas related to intensive farming.
(a) Zoonoses and Appropriate Control
Methods for Animal Diseases
In our view the area that needs increased priority
is that of determining whether different methods of farming (eg
organic farming, integrated crop management, conventional farming)
can modify the carriage of the main bacterial human disease-causing
agents (eg Campylobacter, E. coli O157, Salmonella). There
are also concerns about the carriage of such bacterial agents
on produce, such as leafy vegetables, that are likely to undergo
minimal processing before human consumption. The NFU also supports
increased funding devoted to bovine tuberculosis.
(b) Veterinary Medicines
The NFU has already stated that it considers
that the surveillance of food for the presence or absence of veterinary
and pesticide residues is a food safety issue and should not be
carried out by MAFF. As such the FSA should take the lead and
run the present or similar programme.
(c) Pesticide Safety
The NFU has already welcomed the increased funding
of strategic research and development research on the biology,
genetics and chemistry of pests, pathogens and weeds. This will
assist in the increased adoption of organic farming, integrated
crop management, and other low impact farming methods. An area
that may require more attention is the use of viral control agents
as alternatives to or in concert with pheromone or limited pesticide
applications for the control of insect pests.
A recent initiative to form a Working Group
under the auspices of the independent Committee on Toxicity of
Chemicals in Food, Consumer Products and the Environment (COT)
to examine possible synergistic health effects of chemical and
veterinary food residues, may lead to new concerns, and point
to areas where new or further research is needed. The COT advises
the FSA on chemical safety issues, and so any new research that
is initiated may need to be carried out with the co-operation
of the Agency.
(d) Environmental Protection
In this area research is aimed at controlling
nutrient pollution (eg nitrates) from agriculture. However, we
are concerned that any regulatory requirements also reflect any
risks to human health. In this connection, it is important that
research into any beneficial or negative effects of nitrates on
human health secure definitive answers so that they can provide
appropriate background information to inform the regulators.
(e) Development of Sustainable Systems
of Farm Waste Management
Research to assess the potential risks of the
transmission of pathogens from animal manures to the environment
is one item of relevance in this section.
(f) Quantification and Abatement of
Ammonia Emissions from Agriculture
Apart from the overall benefits of reducing
the emissions of what is a global warming gas, there are also
the aesthetic benefits to humans of reducing the emissions of
ammonia produced by intensive livestock production.
(g) Risk Assessment of GMOs in the
Agricultural Environment
While a risk assessment clearly needs to be
carried out, the risks to humans, if any, that accompany the introduction
of biotechnology into farming, are likely to be minimal.
(h) Conservation, Farm Woodlands, Countryside
Management
Most of the projects in these three areas relate
more to human quality of life.
(i) Organic Farming
The NFU has lobbied for, and welcomed, the increase
in funding for research into organic farming. With the continued
expansion of this farming method, a further extension of this
research is justified. However, to ensure that this research has
maximum impact it needs to be fully integrated with appropriate
conventional farming research and development. There is also a
need to carry out research that investigates assertions that organic
farming uses methods that produce food which tastes better, is
safer, and is better for the environment.
(j) Arable Crops
Three broad areas of research are supported
under this heading: improvements in crops, in crop protection,
and in crop management and nutrition. Research in this area is
increasingly aimed at topics relating to sustainable production
techniques, the NFU supports this approach.
(k) Horticulture and Potatoes
Future research in this area is mainly aimed
at genetic improvement, crop protection, and crop production.
Current research on the antioxidant benefits of fruit and vegetables
in the diet should be continued.
(l) Animal Disease Control
Exotic diseases represent a serious threat to
the UK livestock industry. Some of these exotic diseases could
potentially represent a risk to humans. Because of the widespread
impact that such diseases can have, the NFU has already urged
that every effort be made to co-ordinate UK research programmes
with those of other European countries to secure the most cost-effective
research effort.
(m) Livestock
Of necessity this area has comparatively high
funding. However, in practice most of the projects do not have
an immediate impact on consumers.
(n) Animal Welfare
We strongly support Government research into
a wide range of animal welfare issues. This is a complex and often
emotive area and it is important to recognise that, in some instances,
no single husbandry system may satisfy all the Five Freedoms and
that acceptable compromises may need to be made. Nevertheless,
in such areas, research should continue in an effort to discover
improvements. In the meantime, a presumption that "intensive"
systems are undesirable should not be allowed to prevail or to
dominate the decision-making process and the formulation of legislation.
Research should also bear in mind the possible
links between animal welfare, intensive farming, food safety,
and the quality of food.
(o) Chief Scientist's Science Policy
Programme
This gives flexibility to the overall research
programme, and would potentially allow the funding of projects
that could have an impact on the potential consequences for animal
and human health of intensive farming.
4. CONCLUSIONS
The NFU is only qualified to contribute general
remarks to the Committee's inquiry as it relates to TSEs. Our
concerns are focussed on the need to bring under control the TSEs
that affect farm livestock, both for animal health and welfare
reasons and for the protection of the consumer. It seems to us
that the range of projects being carried by various Government
agencies covers all those areas of study that are needed to provide
the information on which such a programme can be based. By extension,
it should be possible for the livestock industry to give consumers
the reassurance that they are entitled to.
The NFU recognises that there is a considerable
range of projects funded by MAFF that relate in some form or another
to "intensive farming". In general we are satisfied
that the present programmes are sufficiently broad to address
most potential concerns about such farming.
January 2001
|