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[1]The report from an independent inquiry into a failure by the Meat Hygiene Service (MHS) to test all eligible casualty cattle aged between 24 and 30 months for BSE before they entered the food chain, which was published earlier this month*, makes interesting reading. This is not just because of the specific findings, which are of interest in their own right, but also because of the lessons that might be drawn regarding management and communication in and between the Government and its agencies generally. At a time when the agency concept is being extended, with the State Veterinary Service set to become an agency from April 2005, and with the possibility that more work may be 'contracted out' as the Animal Health and Welfare Strategy is developed, management and communication issues of the kind identified in the report are becoming more and more important.
The inquiry, conducted by a steering group led by Professor Patrick Wall, professor of food safety at University College, Dublin, and former chief executive of the Food Safety Authority of Ireland, was set up by the UK's Food Standards Agency (FSA) in June, following an internal MHS audit which had uncovered a number of failures to test casualty cattle aged between 24 and 30 months, as required under EU legislation on surveillance for TSEs. Following an initial report of four cases, subsequent investigation by the MHS revealed that there were 128 cases in Great Britain that were confirmed as not having been tested according to instructions, and 133 possible further cases. On the basis of advice from the Spongiform Encephalopathy Advisory Committee, the FSA considered the risk to human health as a result of these failures to be very low.
This was because there had been no confirmed cases of BSE in cattle under 30 months of age in the UK since 1996, because no BSE-positives had been detected in more than 2800 casualty animals that had been tested to date, and because controls on specified risk material had been applied. Nevertheless, in initiating the inquiry, the FSA's chairman, Sir John Krebs, described the failures as 'unacceptable', noting that 'We need to be confident that all measures are properly enforced - both food safety and surveillance if BSE risks are to be effectively managed' (see VR, June 19, p 771).
In establishing reasons for the failures, the steering group's report does not identify any one factor in particular. Rather, it concludes that 'there were a number of reasons for the GB testing failures and that all organisations involved FSA, DEFRA, MHS and their contractors contributed to the failure to one degree or another.' It believes that the failures occurred because the requirements and the objectives of testing were not clearly agreed or communicated effectively, and not properly monitored by contractors or the MHS. Factors contributing to this 'systems failure' included a lack of specific measures of technical performance or standards in the DEFRA/MHS Service Level Agreement, and poor communication of the instruction regarding the requirement to test casualty animals. This was changed five times, with the most significant change, withdrawing the right of official veterinary surgeons (OVSs) to exercise professional judgement on testing, not being flagged as a key change. Where OVSs sought further guidance, the response, the steering group says, was often inconsistent and contributed to variations in the way the instruction was applied. There was, it says, 'an inadequate supervisory structure' for OVSs, who often lacked monitoring and support and consequently were often isolated. 'Some of the OVSs involved, particularly those trained abroad, were clinically inexperienced and not familiar with GB slaughterhouse practices. They needed a higher level of training, guidance and support than was available, whether from the MHS (in the case of directly employed OVSs), or from their employer (where this was a contractor).' It notes that the instruction was not practical to implement in all circumstances, and that the casualty testing requirement was interpreted by some OVSs as being primarily for disease surveillance purposes and so of lower priority than requirements to ensure food safety.
Discussing supervision and monitoring, the report notes that there was no FSA auditing of the testing requirement, and that DEFRA, which has overall responsibility in this area, did not have a separate mechanism in place for checking on satisfactory delivery. Regarding contract arrangements, it suggests that 'the contractor process for OVS supply gives insufficient priority to actual technical performance compared with costs throughout the tendering, delivery, and monitoring process'; it suggests that contractor accountability needs to be improved, and that the process for evaluating tenders for the supply of OVSs should have 'an increased focus on quality assurance'. As far as the development of an integrated meat hygiene service is concerned, the steering group suggests that 'current line management arrangements are unsatisfactory and appear to place OVSs in a difficult position managerially, with legal responsibility for all meat hygiene official controls, but without the organisational authority to support it'. It believes that there needs to be better communication between the MHS, the FSA and DEFRA, with clearer definitions of roles and responsibilities, so that the practicalities of implementing legislative and policy requirements are fully taken into account when instructions are formulated.
The steering group makes a number of recommendations aimed at correcting the deficiencies identified and, on publication of its report, Professor Wall stressed that its investigations 'did not uncover any problems that cannot be remedied without too much difficulty'. The FSA, meanwhile, noting that it had acted promptly to ensure that the testing of casualty cattle was being properly applied, has promised to consider the findings carefully and commission an action plan to address the recommendations in 'a robust and thorough way'. Nevertheless, the incident serves to highlight the importance of clear lines of command, with roles and responsibilities being clearly defined, and the importance of good communication at every level.
It also illustrates the difficulties of ensuring that decisions made at one level are effectively applied in the field. This is true in any organisation. The State Veterinary Service has still to be established as an agency of government and its responsibilities in disease control and animal health and welfare - will be different from those of the MHS. Nevertheless, the lessons being learned are clearly relevant, and account must be taken of them from the start.
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