Volume 6: Human Health, 1989-96
8. Development of guidance on occupational risks from BSE and other TSEs
1995
CDTFZ & BSE meetings reinstated

CDTFZ & BSE meetings reinstated

8.133 On 3 October 1995, Mr North sent another memo to Mr Lister headed 'Possible need to update guidance on prudent precautions against BSE'. He asked for advice on two specific issues which he said might indicate a need to revise the current sector specific guidance published on prudent precautions against BSE.

The first question relates to the need to wear eye protection and swab some surfaces as envisaged in the Precautions for Work with Human and Animal Transmissible Spongiform Encephalopathies Publication. My earlier minute of 7 December 1994 (copy enclosed) gives a full explanation of this question - but I cannot trace having received a reply from you.

The second question relates to whether or not there is still a potential risk for BSE in cattle passing through abattoirs. In the period when we had regular Zoonoses and BSE Working Group Meetings, we had regular updates from DH and MAFF on the increasingly lower incidence of BSE infection in cattle. If this progress has subsequently been continued, then I presume virtually no cattle passing through slaughterhouses will now have BSE, owing to changed feed regimes. In that case, there may be no risk and hence, we could advise industry and Inspectors that the 'prudent precautions' which we envisaged, could now be relaxed.

On the other hand, I note that MAFF have just revised the Specified Bovine Offal Order 1995 which controls what happens to specified bovine offal. I presume they only made these regulations because they feel that there nay be an incipient risk still from BSE and this was a legislative tidying exercise. If there is still a risk, then I ought to advise Inspectors of this new legislation. ¹

8.134 On 23 November 1995, Mr Lister minuted members of the group stating:

Some recent events and emerging information have prompted the need to review the position with regard to possible occupations exposure to BSE. It is in any case timely to do so.

I write to suggest that we re-convene the Inter-Departmental group on BSE (later merged with the Zoonoses WG) which last met several years ago.

There is some urgency to this partly because there may be the need to revise or supplement the ACDP guidance on TSE and other guidance issued by HSE and others.

I would be grateful if you could attend a meeting . . . at the earliest opportunity. ²

8.135 The group met on 6 December 1995. The minutes record that the purpose of the meeting was 'to review the position with regard to possible occupational exposure to BSE in the light of recent events and emerging information'. Mr Lister explained that HSE were concerned with:

- whether the guidance given to those in the meat trade needed to be updated;

- whether the ACDP TSE guidance should be updated in the light of attention given to certain points in this document during the interview with Dr Crumpton by World in Action;

- the use of bovine eyes for research purposes;

- the need for HSE to be fully in touch with all new developments. ³

8.136 Mr North reported that EHOs had been pressing slaughterhouses to follow the guidance given in the ACDP TSE publication. He said that the guidance was not meant to apply to such situations and this should be made clear. Dr Matthews commented that because the recent SBO Regulations prohibited the splitting of heads this would decrease the risk of exposure and that overall the risk of exposure to BSE-infected animals in slaughterhouses was declining. ⁴

8.137 Mr Fleetwood stated his greatest concern was the rendering industry because the great majority of SBO was being rendered now and there were four or five plants which dealt with nothing but this material; the industry was concerned about the risk involved. Mr Lister suggested that the Inspectors who dealt with those premises could undertake a preliminary inspection and then talk through the situation with employers and help them produce their own guidance in collaboration with HSE. Dr Matthews updated the group on the latest available figures on BSE and the fact that there appeared to be a problem with cross-contamination of feed. Dr Wight reported on CJD surveillance. She reported that there was no evidence of any change in the pattern of CJD in the UK since the CJD surveillance project had been set up in 1990, but that the latest figures available (1994) did not take account of the fourth farmer and two teenagers who were confirmed as having CJD. The implications of this were being discussed by SEAC. Mr Bowden asked whether it would be appropriate for HSE to attend SEAC meetings as observers and Dr Wight undertook to investigate this further. ⁵

8.138 Ms Lawrence (DH) asked whether it was appropriate for the ACDP to review the TSE guidance. Dr Wight said that there might not be sufficient new data to warrant a review at that stage and it might be wise to wait until results of ongoing pathogenesis experiments were available in 1997.

8.139 Mr Render (MAFF) expressed his concern about the use of bovine eyes for research purposes and asked whether such researchers were aware of the ACDP TSE guidance. Mr Fleetwood said that 'because of the change to the SBO Order, researchers now had to buy the whole head rather than just the eyes and were reluctant to do so because of the cost. However, this may have drawn their attention to the risk of BSE/TSEs.' ⁶

8.140 It was agreed that there was no case for changing or adding a supplement to the TSE guidance until further results on the pathogenesis of BSE were available, and that there need be no change in the guidance given to the meat industry, but that the message needed to be reinforced somehow. The guidance issued to farmers, vets and zoo managers needed no change. The issue of bovine eyes warranted further attention and the appropriate bodies would be approached.

8.141 After this meeting, HSE's Food NIG issued a minute to Inspectors, Employment Advisers and Field Consulting Groups entitled 'Review of Precautions advised against occupational risks from BSE and of guidance for abattoir workers, carcase handlers and renderers'. ⁷ It said:

This minute advises Inspectors that the existing guidance on 'prudent precautions' remains relevant and necessary for carcase handlers and abattoir workers and that some additional precautions will hopefully be agreed for the specialised rendering plants handling specified bovine offal.

8.142 The minute stated that the guidance contained in British Meat Manufacturers' Association Guidance Note 5 (written by the NIG and agreed with MAFF and DH) remained 'appropriate, current and necessary' and:

In view of the current concerns it is necessary to re-emphasise to the trade that the risks have been reviewed and that, if there are any risks, they would be controlled through the precautions advised in that Guidance Note: that is through the measures they should be taking anyway for other reasons to achieve good hygiene and protection against deep cuts. ⁸

8.143 On head-splitting, the minute said that bovine heads now had to be taken off whole from the carcass and treated separately, and that previous guidance on this (BMMA Guidance Note 5) remained current although the risk was decreasing. Previous advice about knackering remained valid. On rendering, the previous advice remained appropriate, in general terms. However, it continued:

MAFF report that the rendering process has now significantly changed as all specified bovine offal has to be treated in dedicated plants. This has led to the concentration of the process into relatively few plants in the country with increased concentration of risk at those plants. Additionally, research indicates that the BSE agent is not killed by the heat process of drying into bone meal. For these reasons, MAFF have asked HSE to give further advice to the rendering industry to control the risk of contamination, including from aerosols. ⁹

8.144 With regard to the 1994 ACDP guidance, the minute stated that this did not apply to non-laboratory applications such as slaughterhouses. ¹⁰