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

4.593 This is an unhappy chapter in the BSE story. The animal Specified Bovine Offal (SBO) ban should have kept out of the feed chain those bovine tissues most likely to transmit BSE to other animals (including poultry). ¹ Some four years after its implementation it was appreciated that it was not doing so. Infectious tissue was being incorporated in feed for non-ruminants and penetrating by cross-contamination into cattle feed.

4.594 We propose in this discussion to analyse (with the benefit of hindsight) what went wrong, by looking at the effectiveness of the ban and the reasons why it was not effective. For each category of these reasons we examine whether there were inadequacies of response meriting criticism of individuals, given the knowledge available to them at the time. This will include discussion of the questions we mentioned in Chapter 3, namely, whether adequate consideration was given to the terms of the 1990 Order; and whether those terms were adequate to achieve the objective of the Order. We consider whether shortcomings in the regulations, or the manner in which they were operating, should have been identified and addressed before 1994, and whether action was taken promptly after 1994. Finally, we discuss a simple lesson which emerges from this part of the BSE story.