Volume 6: Human Health, 1989-96
8. Development of guidance on occupational risks from BSE and other TSEs
1989
The Southwood Report
HSE's, MAFF's and DH's initial response to the Southwood Report

The Southwood Report

Occupations identified for HSE's consideration

8.50 On 9 February 1989, Dr Pickles sent an advance copy of the forthcoming Southwood Report to HSE. ¹ The Report was published on 27 February 1989 and in addressing the possible transmission routes of BSE it concluded:

The greatest risk, in theory, would be from parenteral injection of material derived from bovine brain or lymphoid tissue. Medicinal products for injection or surgical implantation which are prepared from bovine tissues, or which utilise bovine serum albumin or similar agents in their manufacture, might also be capable of transmitting infectious agents . . . ²

8.51 The Report went on to raise concerns for certain occupations:

Direct inoculation of bovine tissue could also occur accidentally in certain occupations, such as slaughtermen, veterinarians and laboratory workers. Guidance on safe working practices in general are drawn up by the Health and Safety Executive who have been alerted to the potential concern about BSE and in particular to the possible infectivity of placentae. No specific additional guidance on BSE is thought appropriate at this time. However, adherence to recommended procedures in handling animals and animal products is clearly very important. ³

8.52 The Report recommended:

. . . the potential problems caused by BSE are brought to the attention of the Health and Safety Executive who can consider whether further guidance should be given to such groups. ⁴

8.53 The Southwood Working Party's proposals on potential research areas included the surveillance of humans at risk and formal monitoring of CJD cases, particularly in occupational groups exposed to bovine tissues. For a full discussion of the Southwood Working Party and the Southwood Report see vol. 4: The Southwood Working Party, 1988-89.

8.54 The Government's press release which accompanied the publication of the Southwood Report stated:

The Health and Safety Executive will be considering what further action is necessary to ensure that the existing guidance to occupational groups involved with cattle is followed: this guidance outlines hygiene procedures which are considered to be appropriate for BSE. ⁵

HSE's, MAFF's and DH's initial response to the Southwood Report

8.55 On 1 March 1989, HSE sent a circular headed 'Bovine Spongiform Encephalopathy' to its Area Directors and Inspectors of Factories and Agriculture. This advised Inspectors about guidance to handlers of animals, carcasses, tissues and products following previous guidance of May 1988 (see paragraph 8.29). It drew attention to the Southwood Report and advised that normal hygiene precautions prescribed for the prevention of zoonoses were adequate for the present time. It said:

Medical Division have had discussions with representatives of the DoH and MAFF in respect of any possible occupational implications. It is agreed that there is no immediate need for any new precautions for those handling cattle, their products, or those in the animal feed industry, in respect of BSE as a hypothetical hazard to man. The adoption of those hygiene precautions prescribed for the prevention of zoonoses in the various occupations is all that is needed at the present time. It is thought that just as AIDS (HIV) infection has encouraged all at risk occupationally to improve their normal standards of work hygiene, we should use BSE as our stimulus to do the same with those handling animals, their carcases, tissues and products. However, this should be done under the general umbrella of prevention of zoonoses and BSE should not, at this time, be singled out. ⁶

8.56 On 1 March 1989, Dr Gompertz minuted others at HSE about the latest initiatives following the Southwood Report on BSE. As suggested by Dr R Nourish (Head of Occupational Hygiene Biosafety and Environment Unit, Technology Division 4, HSE), ⁷ a cross-divisional task group was being set up to decide HSE's policy, operational advice and research requirements concerning various zoonoses. Also, the role of ACDP was being discussed with Dr Tyrrell (Chairman of the ACDP and also Chairman of the recently formed Consultative Research Committee on BSE: the 'Tyrrell Committee'). ⁸ Appropriate representatives from the relevant NIGs would also be invited to attend meetings. ⁹

HSE, MAFF and DH consider the need for further guidance

8.57 On 9 March 1989, Mr Lawrence wrote to Dr Gompertz about follow-up to the Southwood Report. He suggested that they should meet to discuss the development of written guidance for the occupational groups outside MAFF most likely to come into contact with affected cattle: farmers and farm workers, knackermen and personnel working at the disposal sites. ¹⁰ Dr Gompertz wrote back on 14 March 1989, stating that HSE were discussing the matter internally to review their response to BSE and that he would contact MAFF following that. ¹¹

HSE meeting on BSE: slaughterhouses identified as a potential problem

8.58 On 29 March 1989, Dr Gompertz chaired a meeting to establish an HSE policy line on BSE in response to events arising from the Southwood Report, and to consider the adequacy of HSE's existing general guidance in relation to BSE risks. ¹² The group also discussed whether there was a need to provide specific guidance for butchers, slaughterhouses and veterinarians. ¹³

8.59 They agreed that if there was any danger of transmission of BSE this was most likely to occur within the slaughterhouse. It was noted that slaughterhouses were mainly a local authority responsibility and that HSE had not traditionally carried out much work in that area. However, although there could be some overlapping of responsibility, the 1974 Act needed to be enforced there. There was also a need to improve hygiene standards and provide guidance on general precautions. ¹⁴ It was agreed that the Medical Division would take the policy lead and that, as suggested by Dr Nourish earlier in March (see above), a cross-divisional task force on zoonoses (CDTFZ) would be established and meet on 9 June 1989. A meeting between HSE, MAFF and DH was also agreed for that date.

8.60 The meeting concluded, among other things:

Initially there was some concern expressed that it might appear that HSE did not seem to be taking positive action in this area. Dr Nourish urged the meeting to be more confident and pointed out that HSE had carefully considered the Southwood report, and had taken heed of its recommendations. HSE had used its expertise in hazard/risk assessment and its suggested approach of minimising risks by upgrading general hygiene precautions was consistent with current information on hazards and risks of the agent. Slaughterhouses in particular had been identified as a potential problem area and guidance to improve general hygiene was being proposed; while for laboratory work, a link to ACDP containment level 2 was being suggested and that taken together this was a reasonable line to take on all the available evidence. ¹⁵

HSE advised by Dr Tyrrell

8.61 On 12 April 1989, Dr Gompertz, Mr Lister and Dr Nourish met with Dr Tyrrell. ¹⁶ Dr Tyrrell told them that he hoped to have agreed a document on research proposals by May. He advised that, at that time, it was best to continue by analogy with scrapie, which was not highly infectious and in respect of which there was no evidence of transmission to man. In the present state of knowledge, hygiene was important. ¹⁷ Dr Mayatt told us:

The matters discussed at that meeting confirmed in our minds that we were on the right track as regards the HSE's response to BSE, primarily that good hygiene practices were the most effective response and that the occupational risk was still conjectural. ¹⁸

MAFF ask for interim advice

8.62 On 12 April 1989, Mr Lawrence wrote again to Dr Gompertz expressing concern about the delay before the meeting to be held on 9 June 1989. In the meantime MAFF had been receiving a number of enquiries, particularly from local authorities, about burial of carcasses on waste tips. ¹⁹ He stated:

It will be difficult to remain non-committal for another 8 weeks, and such delay could well provoke criticism and adverse publicity.

In the circumstances I think we must be in a position to provide some guidance now, certainly if asked to do so . . .

8.63 Accordingly, Mr Lawrence proposed to offer four advice points and attached a draft of these. He described them as 'an adaptation of new instructions which are going out to our own staff'. The advice was similar to that issued by CVL in July 1988 (see paragraph 8.35). He added:

. . . we are in regular contact with a number of these occupational groups and as such we are perhaps in the best position to offer advice. ²⁰

8.64 Mr Lister replied on behalf of Dr Gompertz on 24 April 1989. ²¹ He stated that, in the circumstances and subject to a few amendments, the advice was suitable.

8.65 On 26 May 1989, in response to a Parliamentary Question about Government action on BSE, MAFF issued a press release listing 14 measures that had been taken by the Government thus far. ²² One of the measures listed was:

A review by the Health and Safety Executive to determine what guidance may be appropriate in relation to all diseases of animals, including BSE, that may present a hazard during occupational exposure. ²³