Volume 1: Findings and Conclusions
13. What went right and what went wrong?
A recipe for disaster

1141 There is a body of opinion that believes that farmers had only themselves to blame for the epidemic of BSE. Cows are ruminants. They do not naturally eat animal protein. They were fed animal protein in order to boost their milk yield or fatten them up. Some say that it offended against nature to feed animal protein to ruminants. Some say that it was doubly offensive to turn grass-eaters into cannibals. Some say that it was not surprising that a plague was visited upon those that tampered with nature in this way.

1142 Objection can be taken to many intensive farming practices on ethical or aesthetic grounds. We have resisted the considerable temptation to enter into this debate, which would take us well beyond our Terms of Reference. Of relevance to our Inquiry is the narrower question of why those responsible for the practice of using MBM in cattle feed did not foresee that this might be a recipe for disaster?

1143 The MBM used in cattle feed was produced by rendering. This involved pooling and then processing material from hundreds, perhaps thousands, of animal carcasses at a time. As with other processes where ingredients are pooled, there is a risk of contaminating the pool if any single source is infective. It is thus of crucial importance to make sure that the rendering process will destroy any potentially harmful organisms or other agents in animal carcasses. This is particularly important if animal protein is being recycled within the same species, so that there is no species barrier to infection.

1144 The suggestion has been made to us that the 1979 Royal Commission on Environmental Pollution warned against the risk of recycling animal waste. The risk to which the Commission drew attention was that of recycling poultry litter by including it as a protein supplement in ruminant feed. But the Committee went on to encourage this practice as an environmentally sound re-use of materials 'given that care is taken to avoid health hazards'. An Agricultural Research Council report on 'The Nutrient Requirements of Ruminant Livestock' in 1980 drew attention to the value of undigested protein, of which MBM is a prime example, in ruminant rations to promote milk and flesh production. This authoritative report by leading animal nutritionists, including the Agricultural Devolpment and Advisory Service (ADAS), gave a boost to the use of MBM by feed manufacturers.

1145 The practice in the UK of recycling animal protein as an ingredient of animal feed dates back to at least 1926. In the 1970s attention was directed within MAFF to the danger that this practice would result in the spread of infectious diseases. The diseases considered were those caused by conventional viral and bacterial organisms. No consideration appears to have been given to the risk that scrapie might be recycled in sheep, or even transmitted to other farm animals. This may seem surprising. The answer probably lies in the fact that half a century had elapsed without any indication that animal feed containing ovine protein was infecting sheep or any other animal.

1146 The measure that MAFF introduced to address the risk of the spread of infectious diseases as a consequence of incorporating MBM in feed was the Diseases of Animals (Protein Processing) Order 1981. This laid down a mandatory sampling regime designed to ensure that the rendering process inactivated all conventional viral and bacterial pathogens. The measure was not designed to ensure that the rendering process would inactivate Transmissible Spongiform Encephalopathies (TSEs). No rendering process has yet been devised that will guarantee to inactivate BSE.

1147 What went wrong was that no one foresaw the possibility of the entry into the animal feed cycle of a lethal agent far more virulent than the conventional viral and bacterial pathogens, and one which would be capable of infecting cattle despite passing through the rendering process. When regard is had to the experience of what, by 1981, was over 50 years of recycling of animal protein, we can understand why the risk of a disease such as BSE was one which was not anticipated or addressed by farmers, renderers, feed compounders, animal nutritionists or government.