Volume 5: Animal Health, 1989-96
4b. Implementation, enforcement and monitoring of the animal SBO ban: discussion
The lesson

4.918 There is one simple but vital lesson to be learned from the history of the animal SBO ban. When making regulations, rigorous consideration must be given to all aspects of their practical application.

4.919 In the course of his oral evidence Mr Lowson was asked whether he thought it desirable to think through what practical problems might arise in trying to implement a ban such as the animal SBO ban. He replied:

My experience is that if you try to think through such problems, you always fail to identify the one which actually comes up. What is necessary is to be sure that you have mechanisms in place that will identify problems if they emerge. ¹

4.920 We do not subscribe to this philosophy. If problems are not identified when regulations are made, it can often be much more difficult to identify and rectify them after the event. In the case of the animal SBO ban there was neither rigorous forethought nor a satisfactory mechanism for identifying problems with the operation of the scheme. The mechanism that identified problems was the death of BABs. By the time the problems were identified, many thousands of cattle had been fatally infected.