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IT may or may not be a coincidence that DEFRA should have published a revised draft of its contingency plans for dealing with exotic animal disease outbreaks in the same week that the National Audit Office (NAO) reported on the efforts being made to stop illegal imports of animal products into Great Britain but, either way, it is useful to consider the two documents together. A key conclusion of the NAO’s report is that it is impossible to eliminate the ‘constant but low’ risk of livestock being infected with disease from illegal imports – which makes contingency planning all the more important. Prevention represents the first line of defence against disease, and having effective measures in place to deal with disease is the second – and, as the NAO recognised in its report in the immediate aftermath of the foot-and-mouth disease (FMD) epidemic of 2001, attention needs to be paid to both (VR, June 29, 2002, vol 150, pp 793, 794-798). It is only a few weeks since the NAO examined the steps taken by DEFRA to apply the lessons of the 2001 outbreak and reported that good progress had been made (VR, February 12, 2005, vol 156, p 189). Its latest report* looks at the action being taken to stop illegal imports of animal products such as meat and dairy produce from countries outside the EU, focusing particularly on progress in this area since HM Customs and Excise became responsible for tackling the problem two years ago (VR, March 29, 2003, vol 152, p 378). It provides some fascinating insights and statistics on the extent of the problem, so far as this is known, as well as on the approach being taken and the uncertainties that remain.

The NAO reports that Customs ‘has moved quickly’ to tighten border controls against illegal imports, with the result that the number of seizures has more than doubled since it took over, from 7800 in 2002/03 to 15,800 in 2003/04. The weight of seizures increased to 186 tonnes in 2003/04, 70 per cent more than in the previous year. This in itself is impressive but, as Customs and DEFRA recognise, the results are open to interpretation. For example, the increasing trend in seizures could suggest that Customs is detecting a higher proportion of illegal imports; alternatively, it could indicate an increase in the underlying levels of illegal imports, making detection easier.

There is uncertainty, too, about the precise level of risk from illegal imports. The control strategy being adopted is partly based on a risk assessment model developed by the Veterinary Laboratories Agency (VLA) which estimates, with 90 per cent certainty, that between 4400 and 29,000 tonnes of meat and meat products are illegally imported into Great Britain from countries outside the EU each year. However, the VLA points out that the model is based on little hard data and that a large number of assumptions have to be made in estimating the risk of animals being infected. The degree of uncertainty is indicated by figures included in the NAO report which suggest that an outbreak of FMD from illegal meat imports might be expected once every 65 years, and of classical swine fever every three years, again within 90 per cent confidence limits. The figures nevertheless demonstrate that the threat is real, and that preventive action is necessary.

Much of the Customs activity has focused on baggage checks at airports, as the VLA’s risk assessment indicated that air passengers’ baggage posed the greatest source of risk, although checks are also undertaken on freight and mail. The NAO reports that Britain is the first EU member state to have introduced dog teams to detect illegal imports of animal products, and that the number of teams currently operating is to be increased from nine to 10.Mindful of budgets, it notes that one-off costs for a dog detector team are nearly £40,000, and that running costs are over £60,000 per year, including the handler’s salary. In addition, Customs is installing new x-ray baggage scanners at UK airports to combat smuggling generally, and these will also be used to help in the detection of animal products. Throughout, the report gives the impression that the Government is adopting a cost-benefit as well as a risk-benefit approach to prevention, and that efforts are being made to target limited resources on areas where it is considered they can be used to best effect.

One of the recommendations in the NAO’s report on the 2001 FMD outbreak was that DEFRA should adopt measures in the UK that were at least equivalent to those elsewhere in the developed world, including those in Australia and New Zealand. Its latest report indicates that the UK spends considerably less on controls than those two countries – £7 million a year in the UK compared with £31·5 million a year in Australia and £10·5 million in New Zealand – but that the UK ’s controls compare favourably with those in place elsewhere in the EU. This raises questions about border controls elsewhere in Europe – on which, given the free movement of goods within the EU, the UK is partly dependent – and whether the UK is spending enough. The Government’s aim of ‘continuing to enhance the procedures that are in place to detect and prevent illegal imports and to ensure that they are evidence based and proportionate’ sounds reasonable, but it does rather depend on what is considered proportionate. It is true that, as the NAO points out, agricultural products contribute more to the economy and to the export trade in Australia and New Zealand than they do in the UK, but account must also be taken of the cost of a serious disease outbreak. The NAO estimates that the 2001 FMD outbreak cost £8 billion.

The uncertainties surrounding illegal imports emphasise the importance of effective contingency planning; this is a no belt and braces situation, as both types of safeguard are essential. The latest plan from DEFRA (see below) needs to be considered carefully, not least because it has been modified to take account of changes resulting from the establishment of the State Veterinary Service as an agency of DEFRA. On contingency planning, as with controls on illegal imports, the NAO believes that progress has been made, but concern must remain that much of this progress has been on paper. Of particular concern to the veterinary profession is whether, as a result of the changes occurring in farm animal practice, the necessary practice infrastructure will be available to support the Government’s strategy. This very practical issue has still to be properly acknowledged by the Government, but it needs to be addressed as a priority.


  • * ‘HM Customs and Excise – Stopping Illegal Imports of Animal Products into Great Britain. ’Report by the Comptroller and Auditor General (ref HC 365 2004-2005) (ISBN 0102935281) can be downloaded from the NAO’s website at, or purchased from The Stationery Office, telephone 0845 702 3474, price £9.25.

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