Volume 6: Human Health, 1989-96
8. Development of guidance on occupational risks from BSE and other TSEs
The HSE BSE Working Group and the CDTFZ meetings

8.66 The HSE BSE Working Group (BSEWG) and the Cross-Divisional Task Force on Zoonoses (CDTFZ) met separately until the groups merged in May 1990. The following section charts their deliberations.

First meeting of HSE BSE Working Group: division of responsibilities between MAFF, DH and HSE

8.67 As agreed at the HSE meeting on 29 March 1989, the HSE BSE Working Group met for the first time on 9 June 1989. ¹ Mr Maslin and Dr Matthews attended from MAFF. Dr Pickles and Ms McGinty attended from DH. Dr Mayatt's handwritten note of the meeting recorded: 'BSE and MAFF: Media driven problem largely: MAFF has to be seen to be taking action'. ² The formal note of the meeting recorded that MAFF and DH reported that bovine offal (eg, spinal cord, spleen) would be banned for human consumption in the near future and this might well increase concerns about worker safety in the slaughterhouse and butchery trades. The meeting agreed on occupational groups thought to be at risk. These included stockmen, market handlers, vets, slaughterers, fell mongers ³, knackers, renderers, farmers, laboratory workers, those working at incinerator plants, inseminators, and local authority Inspectors. MAFF considered that farmers, vets, slaughtermen, knackermen and (peripherally) butchers needed to be given advice urgently. ⁴ Dr Mayatt told us:

As to the list of occupational groups likely to be at risk recorded at paragraph of the minutes, I believe these were arrived at by a brainstorming exercise. I do not recall an attempt to prioritise these groups. Although I have recorded in my own handwritten notes of this meeting MAFF's comments that there was a need for urgent advice for veterinary practitioners, I was really only recording the comment. It did not mean that the HSE endorsed the view or would act on it. ⁵

8.68 There was also discussion of the type of guidance necessary but no agreement was reached. It was thought that a leaflet suitable for the farming community, inspectors and the general public would not necessarily be suitable and useful in slaughterhouses. ⁶

8.69 It was decided that HSE would lead on advice to slaughterers and consult with the representatives from the meat industry and trade unions. MAFF would take the lead on advice to those dealing with live animals including stockmen, vets and handlers in general. They were to consult initially with the British Veterinary Association (BVA) and later with the relevant trade unions. DH had already asked pharmaceutical manufacturers to provide lists of products based on bovine tissue. ⁷ Specific advice to butchers was not thought necessary at this stage, although it was felt that this area should be given some consideration. ⁸

8.70 Mr Lister said that the forthcoming 1990 ACDP report 'Categorisation of Pathogens' was to include an appendix on slow viruses in general and a reference to BSE. However, as there was no evidence that BSE was pathogenic to humans, it had not been given a Hazard Grouping. ⁹

First meeting of the CDTFZ: BSE not on the list

8.71 The CDTFZ also met for the first time on 9 June 1989. The meeting was chaired by Dr Gompertz and attended by several other officials from HSE as well as both Food and Health NIGs. ¹⁰ In his introduction Dr Gompertz reminded the meeting that the need to constitute the group had arisen following the recent concern about BSE and subsequent MAFF approaches to HSE for advice on worker protection. Several Parliamentary Questions had been answered by referring to this task force. ¹¹ It aimed to prepare guidance for three groups: HSE staff (including Inspectors), external professionals such as GPs, and vets and other workers who might be exposed to zoonoses. ¹²

8.72 The meeting began by agreeing a list of zoonoses that should be dealt with as a priority. The members went through a list of zoonoses from an existing publication and selected 16 for initial consideration. The list did not include BSE. ¹³

8.73 Having attended both the HSE BSE Working Group and CDTFZ meetings on 9 June 1990, Mr McLean minuted Mr North on 13 June 1989. He expressed concern at HSE's role in giving guidance to abattoir workers which MAFF and DH had considered necessary. On the HSE BSE Working Group meeting he stated:

It was obvious from the input from MAFF and the Department of Health that these other Departments are much more concerned about the problem of BSE than was HSE since we had taken several months to arrange this particular meeting.

It appears that the problem so far as MAFF is concerned is the need to be seen to be doing something since the problem is driven by both media and questions to the Minister in the House. MAFF have given advice to their own veterinary officers and have also given advice generally to veterinarians who may be involved in cattle infected by BSE. Whether advice to veterinarians not employed by MAFF is for MAFF or for HSE to give was rather glossed over . . .

As a result of the pressure from MAFF it was agreed at the meeting that a fairly general press notice could be issued giving interim advice on health and safety in handling BSE carcasses. This, however, was regarded very much as a first step and there was a need perceived by both MAFF and the Department of Health to give somewhat more detailed advice on the health and safety precautions which should be adopted in abattoirs.

We managed to resist the commitment to produce definitive and detailed advice on this since it is a problem to which we have directed no attention in recent years and we have no idea at this stage about any additional precautions which we might wish abattoir owners to take to protect from what is at this stage only a hypothetical risk . . . ¹⁴

8.74 He stated that 'stop gap' guidance had been arranged but that the issue would be discussed further at a forthcoming meeting on 26 July, which he hoped Mr North would attend. He considered that because of the lack of evidence as to whether the BSE agent created a hazard to health, any decision would be difficult to enforce in the industry. He stated:

I see your role at that meeting to be about as obstructionist as possible and to make sure that people realise the great difficulties in actually pressing the abattoir owners to do anything unless we can actually prove some risk. ¹⁵

8.75 Mr McLean told us:

In asking Mr North to be 'about as obstructionist as possible' at subsequent meetings I was aware of the pressure by other government Departments and other parts of HSE who appeared to feel that the NIG would be in a position to develop a clear strategy to counter any risk to abattoir workers who might be affected by BSE and to enforce whatever precautions were felt to be appropriate. Because of our lack of knowledge about the risk and about ways of avoiding the risk, I felt that we had to resist these pressures and only agree to do what we could actually deliver in practice. ¹⁶

Slaughterhouse visit indicates problems with guidance for workers

8.76 On 13 July 1989, Mr Lister sent Dr Gompertz a report of his visit to the biggest slaughterhouse in the country. ¹⁷ He had been convinced that gross exposure to blood was virtually unavoidable in the slaughtering business. Nearly all the staff using knives and saws routinely wore metal aprons, chain mail gloves and forearm guards on the holding hand/forearm, but the knife hand was most commonly bare. ¹⁸ He stated:

I think we should speak before we issue any further guidance on occupational exposure to infection in the meat trade. The scale and pace of work in this slaughterhouse would make it very difficult to insist on any additional precautions that were not patently effective in reducing exposure. This unit is well run and well kept but contamination of personnel is unavoidable despite the use of protective clothing. Skin exposure was very marked in some parts of the operation. In the cutting and boning rooms at least, if not right through the process, workers are paid by the weight of meat shifted and this would discourage any impediment. Nevertheless the vet and the safety officer confirmed that the staff are concerned about BSE and it is clear that in smaller units especially those with no vet screening the incoming stock an infected animal could easily get into the system.

There is more but this can wait until we next meet. Meanwhile I plan to arrange a visit to a smaller less well-equipped company. ¹⁹

8.77 On 25 July 1989, following the suggestion at the HSE BSE Working Group meeting on 9 June, a consultation meeting with MAFF, DH and Mr F J Anthony from the BVA was held to discuss guidance, in the form of a press release, for worker protection against BSE. ²⁰ Mr Anthony said that the press release would need to include specific guidance on handling/disposing of placentae. MAFF stressed the importance of early issue of the press release (prepared and agreed by HSE/MAFF), a draft of which had already been agreed. The main action arising from the meeting was agreement that BVA would produce its own guidance for the veterinary profession, to be discussed further with HSE and MAFF on 21 September 1989. After this, simplified guidance could be developed for farmers and farm workers.

HSE issues a news release for groups 'occupationally exposed' to BSE cattle

8.78 HSE issued the news release, entitled 'Guidance for those Handling, Carting and Disposing of Known or Suspected BSE Carcases', on 8 August 1989. This stated:

HSE's advice is being issued following the report of the independent scientific working party chaired by Sir Richard Southwood which was published in February and examined all aspects of BSE. The Report recommended that HSE should consider possible exposure of various occupational groups to the BSE agent.

HSE considers the risk to human health is remote but says that it is very important that all those who come into contact with known or suspected BSE carcases, (for example when handling, carting or disposing of them) observe the following reasonable procedures:

1. protective clothing should be worn, including gloves. After use, clothing should be rinsed free of any debris and washed with water and detergent;
2. eye protection should be worn if there was a risk of splashing into the eyes;
3. cuts and abrasions should be covered with waterproof dressings. Care should be taken to avoid puncture wounds and cuts when handling known or suspected BSE carcases. Injuries should be washed thoroughly in running water;
4. hands should be washed before eating, drinking or smoking;
5. contaminated areas (including transport) should be washed down with detergent and water;
6. all accidents should be recorded . . .

8.79 The press release also stated that guidance for abattoir workers and other occupational groups would be issued shortly. ²¹

8.80 Later, in December 1989, HSE issued an 'Agricultural Information Sheet' entitled 'Zoonoses in agriculture: Preventing the spread of disease to livestock handlers'. ²² It was aimed at people working with livestock in agriculture and associated industries, as there were 'risks to health from a number of diseases carried by cattle, sheep, pigs, poultry, deer and rodents'. It gave some advice about minimising the risk of infection by animal diseases generally and mentioned briefly that BSE was the most recently identified disease of cattle but that there was no evidence that it could be transmitted to humans.

Second meeting of HSE BSE Working Group: draft guidance for slaughterhouse workers discussed

8.81 The HSE BSE Working Group met again on 11 September 1989. ²³ The group discussed guidance for abattoir/slaughterhouse workers, a draft of which had been prepared by MAFF as agreed on 9 June. Dr Pickles thought that the draft appeared too 'complacent', as it was not apparent from it that expert opinion was that penetrating injuries were a possible cause of concern. ²⁴ It was agreed that Mr Lister would redraft it. ²⁵ However, the point had still not been clarified by the end of the year when, in December 1989, Dr Pickles in a letter to Ms Julia Soave (HSE) stated that she still felt 'very uneasy about the draft note on abattoirs'. She pointed out a slight contradiction within the guidance:

The impression is given that if the abattoir worker follows the current rules and regulations (which are claimed here to be designed to protect the worker from zoonoses rather than the meat from infected workers), then there should be no problems. It is thus implied that if the worker does eat or smoke, for example, there would be a risk. But nothing is further from the truth. We do not believe there is any real risk from oral or topical exposure, even if BSE animals are being slaughtered, and every abattoir worker will know that that happens sometimes.

At the same time, it may be that not enough attention is given to these areas where there may be real risk ie parenteral exposure to certain tissues. ²⁶

8.82 Mr D R Fry (Head of Branch C, Meat Hygiene Division, MAFF) had taken a narrower view when consulted about the draft guidance. In a minute to Mr Maslin, Mr Fry said that certain sections of the draft guidance implied that the rules had been developed for BSE when in fact almost all of it was required by existing legislation. He stated:

I would have thought that the message we should be trying to convey is that if slaughterhouse operators and workers observe the existing hygiene rules they need do very little extra to protect themselves. ²⁷

Second meeting of CDTFZ

8.83 On 16 November 1989, the CDTFZ met again. ²⁸ Ms Howe, a representative from DIAS (HSE's publications section), was present. The meeting was mainly devoted to the 16 zoonoses detailed at their June meeting.

8.84 During discussions relating to a Leptospirosis ²⁹ card, the minutes record:

Although not within the remit of this group it was agreed that as Ms Howe was present this meeting would provide a useful opportunity to discuss guidance on BSE. It was explained to Ms Howe that what was envisaged was a 'card' for those handling BSE infected/possibly infected cattle, a guidance leaflet for abattoir managers and later a more general leaflet for abattoir managers and later a more general leaflet relating to working practices aimed at abattoir workers.

Mr Lister pointed out that much would depend on the upcoming meeting with abattoir managers.

Members having discussed briefly the possible distribution of the 'card' e.g. agriculture Inspectors, Vets, hauliers dealing with infected carcases, Ms Howe agreed that she now had some idea of the numbers required. ³⁰

Third Meeting of HSE BSE Working Group: consultation with representatives from the meat industry and trade unions and advice to slaughterers

8.85 HSE had agreed to take the lead on advice to slaughterers at the meeting on 9 June 1989. They met with representatives from MAFF, DH, the meat industry and trade unions on 13 December 1989. ³¹ The minutes of the meeting record that Dr Gompertz pointed out that under the Control of Substances Hazardous to Health Regulations (COSHH) a risk assessment was required, but that in the case of BSE it was not known what the risks were. ³² The COSHH Regulations ³³ controlled exposure to hazardous substances (eg, chemicals and human pathogens). ³⁴

8.86 Mr M Symons (Federation of Fresh Meat Wholesalers) queried the need to issue a document on BSE and asked why BSE was being used as a vehicle to improve hygiene standards, stressing that this could damage the industry. He suggested that HSE could focus on the parts of the job that were BSE-related, for example, removing the brain from the skull. He stated that he was unable to comment on the guidance without further consultation. However, Mr Russell (USDAW) indicated that they were in favour of the guidance and that further consultation on this could be channelled through the HSE Joint Working Party on the Meat Trade. ³⁵

8.87 It was agreed that Dr Gompertz would redraft and circulate the guidance for comment. ³⁶

8.88 Mr North's note of the meeting recorded that DH had pointed out:

On the one hand there is some evidence from scrapie in sheep that a similar type virus has not been transmitted but on the other hand humans are capable of infection with this type of virus - CJ Disease. The experimental evidence to date is that it is only by injecting high titres into the brains of mice that transmission has occurred therefore lower concentrations of virus through occupationally likely routes of infection should give a much lower risk of infection even if the virus was transmissible. Against this background, it is rather difficult to explain why the Government has recently banned the supply of offal into the human food chain: it is really a political/presentational step. ³⁷

8.89 Mr North's note continued:

In the discussion, it was agreed that guidance was necessary because of ministerial pressure, concern which was present in the trade (although the diagnosis was that reassurance was the most appropriate information) and that HSE needed to provide an informed hazard assessment of the risk

. . .

It was highlighted that whilst the existing product safety regulations - ie. good hygiene - would also guard employees against the risk of infection, in the particular case of BSE, guidance founded only on good hygiene would miss the point. BSE precautions are specifically in relation to penetration and contamination with named higher risk products.

It was therefore agreed that HSE would provide a first draft of guidance for subsequent discussion highlighting these aspects. At this stage, the guidance would probably have to end at avoiding penetrating injuries - how that might be achieved would have to be left for more detailed secondary stage more specific guidance. ³⁸