Volume 6: Human Health, 1989-96
9. Bovine eyeball dissection
Consideration of the risks associated with bovine eyeball dissection: a chronology
June 1988
1989
February 1990
April-August 1990

June 1988

Early consideration within the DES

9.20 Dr Ernaelsteen told us that in June 1988, having read articles in medical journals and papers about BSE in cattle, she was concerned about the possible risks posed by the use of bovine tissue in education, particularly in bovine and ovine nervous system dissections. ¹ She minuted Staff Inspector (SI) Mr J Ungoed Thomas of Her Majesty's Inspectorate of Schools (HMI). ² Her minute did not suggest any immediate action, but rather that they should consider and debate the potential hazards arising from the use of bovine nervous tissue in education. She asked:

Does the education service use sheeps eyeballs to study the eye; or cows or sheeps brains for dissection? Entry of the infectious agent seems through consumption. Advice on the use of plastic gloves and thorough hand washing after dissecting such materials would seem to be sufficient protection.

9.21 Having received the minute, on 28 June 1988 Mr Ungoed Thomas, in a handwritten note on it, sought 'advice as requested' from others. We are not aware of the responses this minute prompted, if indeed there were any. It would appear that Dr Ernaelsteen took no further action on this during 1988.

1989

Early consideration within MAFF

9.22 The question of bovine eyeball dissection was raised within MAFF in the context of the forthcoming SBO ban. MAFF was developing policy on which offals to include in this ban during the second half of 1989. ³

9.23 On 12 July 1989, Mr John Wilesmith (CVL Epidemiology Unit) minuted Mr Alan Lawrence (Animal Health Division) informing him that officials in Guernsey had decided to stop the supply of bovine eyes for the teaching of biology in schools. He queried whether the issue had arisen in the light of the proposed ban on offal for human consumption and whether there was a line on the harvesting of bovine eyes. ⁴ The minute was also copied to Mr John Maslin (Head of Animal Health (Disease Control) Division) who, in turn, raised the issue with others in MAFF in the context of the SBO ban. His minute dated 27 July 1989 was copied widely within MAFF and to Territorial Departments. ⁵ It discussed issues surrounding sutures, spinal cord, thymus, spleen and mechanically recovered meat (MRM). In relation to bovine eyeballs, Mr Maslin stated:

This raises the question of whether there will continue to be a source of bovine eyes for teaching from the rest of Britain or whether our ban on certain offal will affect this trade.

The UK ban does not of course include eyes but I should be grateful for any information recipients have on this unusual aspect. Are eyes removed at the slaughterhouse or at a specialist company? In the latter, the requirement for staining the head before removal from a slaughterhouse would presumably affect the eyes. Is this an important industry for teaching or are alternative sources (eg sheep eyes) available or suitable?

9.24 Mr Keith Meldrum, referring to Mr Maslin's query, minuted Mr Robert Lowson, Animal Health Division (MAFF), stating:

These new questions support the view that the ban should be age limited so that bovine eyes, sutures and thymus can still be obtained for the purposes described . . .

I will restrict circulation of these preliminary comments until we hear from the action recipients. ⁶

9.25 On 1 August, Mr Bradley replied to Mr Maslin. With regard to bovine eyeballs he stated:

We have no knowledge of the BSE infectivity of bovine eyes. Professor Southwood indicates that the risk of transmission of BSE to humans is remote. On that basis they can be regarded as low risk. Furthermore epidemiological evidence connecting the human consumption of sheep eyes (some possibly being derived from scrapie-infected sheep) and the occurrence of spongiform encephalopathy in the consumer is lacking. ⁷

9.26 However, he added that it might be advisable as 'a measure of extreme prudence' to recommend certain precautions in the selection and collection of bovine eyeballs for dissection. This changed the issue from considering the potential difficulties with supplying bovine eyeballs to considering whether the practice should be continued at all. He concluded:

The Southwood Report is the start point for any decisions. Once MAFF goes beyond that there is no clear dividing line to define what constitutes an unacceptable risk to human health. There is a requirement for more knowledge in some or all of these areas before decisions are made. So far as I am aware the offal ban only relates to human consumption (ie. eating it). We are now getting into a whole new ball game and the consequences of over - or inappropriate reaction could be very costly and without much benefit. Nevertheless it is right that risks should be examined and actions taken (including no action) based on scientific findings. ⁸

9.27 On 7 August, Mr Stephen Hutchins (MAFF) minuted Mr David Taylor (SVS) referring to Mr Maslin's query of 27 July. ⁹ On bovine eyeballs he stated:

The procurement of specimens for biology teaching (including bovine eyes) is apparently left to the discretion of the Local Education Authority.

I would imagine that eyes would be harvested to special order either from the abattoir or a specialist head deboner or even obtained from the local butcher, as and when needed. I am not aware of any company that specialises in collecting bovine eyes from heads specially despatched from abattoirs.

I would not have thought that the proposed ban would lead to major problems for schools in obtaining adequate supplies.

9.28 On 27 September 1989, the issue of bovine eyeballs was raised at a meeting discussing the responses of the consultation process regarding the SBO ban. The minutes of the meeting record:

As sheep and pig eyes could provide an alternative source for educational use it was felt that any effects of the ban would be minimal. However if a simple amendment could be made, the Regulations should be changed to allow eyes to be removed before staining. ¹⁰

9.29 In the event, this proposed amendment to the Regulations was not made. Indeed, there was no mention of bovine eyeballs in the submission on the details of proposed offal ban put forward on 2 November 1989 by Mr Lawrence to MAFF Ministers. The SBO ban came into effect on 13 November.

9.30 The subject of bovine eyeballs was raised again on 10 November 1989, when Mr T Jones, Veterinary Investigation Officer (VIO, MAFF) wrote to Dr Danny Matthews, Senior Veterinary Officer (SVO) seeking guidance on whether bovine eyeball dissection in schools should be discouraged because of BSE. ¹¹ This letter was referred to Mr Bradley, who responded to Dr Matthews later that month, identifying a number of relevant factors and possible approaches. He concluded:

Overall I believe the risk of BSE causing disease in man is remote. The risk of exposure of children is small. Professor Southwood made no specific recommendations on this point and indeed had we followed his advice eyes from any age of animal could even have been eaten quite legally (and safely). The advent of the offal ban may suggest to the public a degree of risk exists which did not before. This could be overcome by selecting bovine eyes from calves under 6 months, using disposable dissection instruments, incineration of waste and after HSE advice or other safety rules in schools ensuring the necessary protective clothing and procedures are followed such as washing hands before eating. ¹²

9.31 Dr Matthews replied to Mr Jones on 24 November 1989, explaining:

. . . retina can become infected in murine experimental scrapie. Given that invasion of the CNS is usually relatively late in development of disease, it may be assumed that only eyes from mature cattle will present a significant risk if BSE agent follows the same pattern of invasion.

Nevertheless given that scalpels will be used for dissection, and the possibility that the children may have pre-existing cuts, we would advise the following for the moment:

(i) If possible use porcine eyes.

(ii) If bovine eyes are essential, use ones from animals under 6 months of age.

(iii) Wear gloves when dissecting, and ensure sterilisation of equipment before further use. ¹³

9.32 Dr Matthews also said that he suspected that if any advice was to be issued to schools in general it should come from DH or the Health and Safety Executive (HSE).

February 1990

Guidance issued in Scotland

9.33 The SED was the first of the UK Education Departments to issue guidance on bovine eyeball dissection.

9.34 On 19 February 1990, Mr Currie (Scottish Home and Health Department (SHHD)) sent a minute to Dr Thores informing him that Mr Graham Watkin (Professional Adviser on Health and Safety, Tayside Regional Council) had expressed concern about whether bovine eyeball dissection should be forbidden in local schools. ¹⁴

9.35 Dr Thores responded in a minute to Mr Currie on 20 February 1990 agreeing with Mr Watkin's concern about the safety of the dissection of bulls' eyes in schools. ¹⁵ He reasoned:

In view of the recommendations of the Southwood Committee, and the significant nervous tissue component of the eye from the optic nerve, it would seem desirable to discontinue this practice, since there are alternative possibilities (e.g. anatomical models).

9.36 He also asked that Mr Watkin and Mr N Atkinson (SED2) take this advice into account in any circulars to schools. A handwritten note on the minute, dated 21 February 1990, stated that Mr Atkinson was content with Dr Thores's advice and wished to see any circular issued as 'SED may wish to consider a general circular to all schools'. ¹⁶

9.37 On 22 February 1990, Mr Currie wrote to Mr Watkin stating:

The advice of our Departmental Medical Adviser is that in view of the recommendations of the Southwood Committee, and the significant nervous tissue component of the eye from the optic nerve, it would seem desirable to discontinue this practice, particularly since there are alternative possibilities eg anatomical models. Should you decide to pass on this advice to schools in Tayside I would wish to be kept informed of what action you take, including sight of any circulars which issue, so that the Department can alert Health Board staff with a school liaison function. ¹⁷

9.38 On 27 February 1990, Tayside Regional Council sent a minute to all secondary schools and all further education colleges within its municipality advising that all eye dissections cease forthwith. ¹⁸ The Scottish Education Department relayed the same message to all Directors of Education in Scotland in March 1990. ¹⁹

9.39 The consultative process involved in producing the guidance (which was issued within one month of the initial concerns) received some criticism. In response to the decision, on 19 April 1990, Mr K Duncan (Science Adviser, Grampian Regional Council, Department of Education) wrote to SED stating that his authority would certainly implement the advice. ²⁰ However, he also asked for clarification on the use of other biological material and 'in particular offal in the form of heart and lungs from either sheep or cows'. This request prompted Mr McDonald (SHHD) to write to colleagues stating:

I understand that Mr K Duncan . . . has written to Secretary SED asking if other biological material, including offal in the form of heart and lungs from either sheep or cows should be included in the advice contained in the recent letter to EAs [Education Authorities] on the subject of BSE. My advice is that the Department should consult fairly widely before replying to this letter.

. . .

I would also like to take this opportunity to raise some concerns regarding the process leading to the distribution of the letter and its final content . . . My expectation was that such a draft would have been prepared after taking account of HMI advice on the educational implications. I was in the process of consulting with my Science colleagues on the draft when I learned that the letter had been issued. I had expected to be included in the list of copy recipients for correspondence with medical services and that I would be able to provide HMI advice before publication of the letter. In fact I did not see a copy of the letter in its final form either before or after issue to education authorities . . . ²¹

9.40 Mr McDonald then listed the ways in which he thought the letter was 'inadequate'. He noted that the letter referred to bulls' eyes whereas normally cows' or bullocks' eyes were used; that dissection was part of the science course and not the biology course; that anatomical models were no substitute for the real experience; and that there was no mention of other possibilities, for example the use of pigs' eyes.

9.41 The Schools Equipment Research Centre took the opportunity to comment in July 1990:

Whilst we were disturbed by the manner in which the advice was issued, in that a number of interested parties were never properly consulted before the letter to Scottish EAs was sent out, and that it contained some unfortunate mistakes of wording, we could not seriously quarrel with its substance. The major reasons we have to concur with this advice are:

That it is now too late for us to do otherwise, although we are given to understand that the DES apparently has no intention at the moment of issuing similar advice to LEAs [Local Education Authorities] in England.

The advice is at least consistent with what little real scientific evidence is currently available.

. . .

We strongly caution against anyone against being over zealous in these matters. This is especially so when the ground on which to base advice is none too firm and the potential for real educational damage is so obvious. ²²

Dr Pickles raises the issue of bovine eyeballs with MAFF and DES

9.42 On 20 February 1990, Dr Pickles, who had been alerted to the practice of bovine eyeball dissection by a Scottish colleague, sent a minute to Mr Maslin. ²³ She stated:

The current regulations would permit collection of eyes for such use from abattoirs. The Southwood report in para 5.3.4 accepted a theoretical hazard in accidental inoculation of bovine tissues. As an extension of the brain, perhaps the eye is a suspect tissue. Dissecting school children must surely cut themselves sometimes. Thus on the face of it there is a theoretical hazard from this practice, for which there are safe alternatives e.g. horse/pig eyes.

9.43 The minute was also copied to Mr J Creedy (HMI) and Dr Ernaelsteen among others. ²⁴ Dr Ernaelsteen responded on 22 February 1990 stating that she had previously taken the view that the matter of dissection in school was one for good practice and basic hygiene rules. However, she pointed out:

There is an inherent difficulty similar to the tension previously with AIDS/HIV. If one points to particular dangers in school, then housewives, butchers, abattoir workers are at equal theoretical risk.

Would it not be valid to take the view that there is no medical evidence to suggest that CJD/BSE/Scrapie has been transmitted by dissection in schools (or butchery and abattoir work?). One certainly would not wish to raise unnecessary anxieties or provoke further media attention. ²⁵

9.44 She advised that the educational advantage must be measured against theoretical or actual risk to consider whether a school or college practice should take place. She suggested that referring the issue to the new 'Tyrrell group' (SEAC) might be helpful. She also asked for advice from HMI about dissection practice in schools.

9.45 On 7 March 1990, Dr Ernaelsteen minuted Dr Pickles attaching a copy of a response from Mr Creedy. She noted that the educational advantage of the exercise was considerable, but added that the medical and veterinary evidence regarding BSE and bulls' eyes was less secure than that relating to scrapie. ²⁶ In his response, Mr Creedy pointed out that students were normally expected to wash their hands after any contact with dissection material and that, increasingly, disposable gloves were worn. He added:

Dr Pickles suggestion of horse/pig eyes has a practical drawback - horses are not slaughtered for food in UK and supply would be too limited. Pigs are often slaughtered in specialised 'bacon factories' and I have rarely, if ever, seen pigs eyes in schools. ²⁷

April-August 1990

Advice from SEAC

9.46 In April 1990, Dr Pickles wrote to Mr Lowson regarding the agenda for the forthcoming first meeting of SEAC. She asked whether they were going to raise the 'relatively minor matter' of bovine eyeball dissection and offered to put some brief papers together. ²⁸ On 12 April 1990, Dr Pickles faxed Mr Lowson a draft paper entitled 'Routes of possible transmission of BSE to man' stating that this would ' . . . challenge the committee about possible routes of transmission to man that may have been overlooked'. ²⁹ The paper asked SEAC to advise on, among other things, the practice of dissecting bovine eyeballs and stated:

Dissection of bulls' eyes still takes place in some schools and it is now being questioned whether this might present a hazard from BSE. Can the committee advise whether the eye is likely to be infected in BSE cases, and if so whether the chance of a schoolchild inadvertently inoculating themselves with such material is great enough for us to advise against this practice? If the worry is injuries with contaminated sharps, gloves may be no protection. Horse/pig eyes could be alternatives, but supplies of the former are too limited and of the latter not readily available.

In conclusion, the committee is asked to consider whether additional advice is needed to guard against the remote chance that exposure to certain bovine tissues by certain routes could present a hazard to man. ³⁰

9.47 On 23 April 1990, Mr Meldrum commented on Dr Pickles's paper:

Unfortunately I do not agree with the thrust of the paper . . .

. . . Bearing in mind that these eyes are derived from perfectly healthy animals which do not show evidence of BSE it would be illogical to take the action that she describes. If such eyeballs were a human health hazard then they should be included in the definition of specified offals and be destroyed at source. I have no objection to the issue being raised with the Committee but not in this blank and unhelpful way.

. . . The whole paper needs far more detail and background before it can be put to the Tyrrell Committee, with particular reference to the general background of our control measures and the offal ban. I suggest it be drafted and expanded and cleared with us before submission to a later meeting . . . ³¹

9.48 On receipt of the Mr Meldrum's comments, Dr Pickles faxed Mr Lowson stating that there was no alternative but to withdraw the paper from the agenda of the first SEAC meeting pending a more detailed version. ³² Dr Pickles also referred to a point she had discovered at a recent (unspecified) 'lunch' meeting:

. . . eyes are infected in spongiform encephalopathies and indeed are used in some experimental models. Like placentae, they did not need to be included in the offal ban since this only concerned human consumption in this country. There is no illogicality in what I was proposing. The speculated route of transmission during eyeball dissection, whilst having no relevance to the offal ban, might of course be relevant to advice given by HSE to abattoir workers and indeed seems consistent with it. I regard the eye as an extension of the brain. Whilst abattoir workers have no alternative but safe handling, there is a real alternative for schools. The question for the group was whether they agreed there was a theoretical hazard. And if so, whether the level of risk was such, when weighed up against the educational benefit of using bovine eyes rather than eyes from alternative species, they advised against this practice.

Maybe on further reflection, CVO will not be so negative about my paper. Of course I can add further detail about the infection in the eye in the established spongiform encephalopathies. But the simple question to the committee remains the same.

9.49 We discuss these events in further detail in vol. 7: Medicines and Cosmetics. (Further details of SEAC's deliberations on bovine eyeballs are given in vol. 11: Scientists after Southwood.)

9.50 On 23 May 1990, Dr Ernaelsteen wrote to Mr Creedy. ³³ The letter was copied to Mr T P Melia (Chief Inspector, whose responsibilities included safety in schools) and Mr Tomlinson (Chief Inspector, whose responsibilities included schools and sixth form colleges - ages 16-19). ³⁴ Dr Ernaelsteen told Mr Creedy that the position with bull and ox eyes was not certain and that Dr Pickles had put a submission to SEAC to consider the position and advise. She said that for the time being she believed the issue to be a matter of balancing risk against educational benefit and continued:

The scientific facts must be carefully considered to avoid any alarmist reaction and loss of what is a very valuable biological dissection learning exercise. Should this be withdrawn I believe we would be into substantial media argument and a not insignificant problem as well as educational loss.

9.51 A revised paper entitled 'Route of Possible Transmission of Bovine Spongiform Encephalopathy to Man via the Practice of Eyeball Dissection' was prepared by Ms A McGinty at Dr Pickles's request. ³⁵ This was submitted to SEAC in June 1990 and discussed at SEAC's fourth meeting held on 2 July 1990. The paper considered the theoretical route of transmission of BSE to man via the practice of eyeball dissection and asked what action, if any, needed to be taken. It set out what was known about infectivity in the eye in experimental rodent scrapie and CJD and reached the following conclusions:

1. It seems likely from scrapie models that the retina of eyes from cattle with clinical BSE will contain the BSE agent.
2. It is feasible that some sub-clinical cases of BSE may be slaughtered in abattoirs, and therefore it is possible eyes infected with the BSE agent may be amongst those used for dissection.
3. Dissection involves the use of instruments capable of causing deep penetrating wounds, and the possibility of parenteral inoculation of the BSE agent therefore exists.
4. Sterilisation of eyeballs prior to dissection is not an option, and disposable instruments do not remove the risk of penetrating injuries occurring during the dissection procedure.
5. Viable educative alternatives are available in the form of anatomical models, videos and other teaching aids. Ovine and pig eyes may be available but are less suitable on a size basis. With other types of bovine dissection carrying similar risks of inoculation injury such as veterinary studies or abattoir practices, unlike eyeball dissection in schools, there may be no acceptable alternative.
6. The Scottish Education Department has already recommended that the practice of bovine eye dissection be discontinued (March 1990). Inevitably pressure will be brought to bear for a similar recommendation in England.
7. The eyeball is not included in the 'offal ban' since like the placenta it is a tissue not usually chosen for human consumption. Thus there should be no particular presentational issues with any new advice concerning eyeballs.

9.52 The paper also concluded that:

If the rodent scrapie model is accepted as a reasonable parallel for BSE, it is likely that the BSE agent is present in the eyes of BSE cattle, and it may be present before the clinical symptoms of the disease are apparent. ³⁶

9.53 The document asked SEAC whether the balance between educational value of eyeball dissection, and the potential risk of exposure to the BSE agent was such that the practice of bovine eyeball dissection in classrooms should be discontinued.

9.54 The minutes of SEAC's meeting recorded:

[The paper] was discussed and its findings accepted. The Committee agreed to advise that the use of the eyes of cattle more than six months old should not be used for dissection in schools. ³⁷

9.55 Dr Pickles sent a minute to Dr Ernaelsteen to inform her of SEAC's advice. ³⁸ She referred to the SED's advice against bovine eyeball dissection and stated:

I believe MAFF have been offering similar advice informally for some time. I have responded to a specific request from Kent County Council.

9.56 She indicated that she would leave it to Dr Ernaelsteen to discuss within DES whether there was a need for promulgation of general advice within England.

DES guidance

9.57 On 24 July 1990 Dr Jacobs (Welsh Office) wrote to Dr Pickles about BSE and bovine eyeballs. She referred to SEAC's meeting on 2 July 1990, and its decision to discourage the practice of dissecting bovine eyeballs in schools, and asked whether any guidance had been issued to schools or was planned. ³⁹ Dr Pickles referred her to Dr Ernaelsteen. ⁴⁰

9.58 On the same day, Dr Ernaelsteen initiated the task of issuing guidance on bovine eyeball dissection within the DES. She sent a minute to Ms J Cramphorn (Head of Division C, Schools Branch 2). ⁴¹ The minute was copied to Mr J Creedy, Dr Pickles and Ms McGinty. ⁴² She attached to her minute the paper that SEAC had considered and said:

Attached for DES and HMI information and action is the definitive scientific advice on eyeball dissection in education from the expert Tyrrell Committee.

DES guidance will need to be provided and the Inspectorate informed.

9.59 Dr Ernaelsteen told us in a written statement that she did indeed regard the SEAC advice as definitive, and that she was personally convinced of the need for DES to issue guidance to schools. ⁴³

9.60 Although Dr Ernaelsteen had sent SEAC's advice to Schools Branch 2 to take forward the development of guidance, it was Branch 3, headed by Mr Baker, which took it forward. On 26 July, Mr Baker wrote to Mr Jacobs, with copies to others in DES, including Mr Creedy of HMI, accepting that the need for guidance on bovine eyeball dissection was a matter for their division of Schools Branch 3:

I think that I accept that the need for advice on eyeball dissection is a matter for us rather than Miss Cramphorn's Division. I am not sure I understand the status of the advice from this particular SEAC . . . The paper Dr Ernaelsteen refers to as the definitive advice actually ends with a request for advice.

Perhaps you would sort this out. Presumably the answer is that the Committee met and returned the answer 'yes' to the question in the paper. But there is a prior question whether bovine eyeball dissection is actually practised in the classrooms. The author says 'we do not know how widespread the practice . . . is?' Perhaps it does not exist.

Would HMI addressees please advise on the need for advice. I find it difficult to decide whether this would be a suitable addendum to the 'Animals' AM, if we do need to give advice . . . ⁴⁴

9.61 Mr Creedy replied to Mr Baker on 1 August 1990:

It is very difficult to place an accurate figure on the amount of eyeball dissection in schools. Ten years ago I would have estimated that 80% of schools would have carried out this dissection. In recent years I have seen less eye dissection but would guess that it occurs in 30-50% of schools.

Ox eye is the usual material but the sheep eyes and probably pig eyes are also used. The dissection is usually carried out in year 9 or 10 with pupils working in pairs or groups and the instruments usually are sharp pointed dissection scissors or a scalpel. The material usually used is fresh or freshly thawed from a freezer. In school dissection work, gloves are rarely worn and I have never seen instruments sterilised.

. . .

It is unfortunate that the Tyrrell Committee has no evidence on bovine eye material, but the evidence that the retina of rodents is infected in experimental scrapie, and that sub clinical BSE material could reach schools seems to call for a very careful review of our current advice.

. . .

I feel that it should be a medical decision to balance the medical and educational considerations and if the DES comes down on the side of caution perhaps it would be wise to write to LEAs pointing out that the evidence is not direct but that a temporary suspension of this dissection until the evidence is much clearer would be a wise precaution. ⁴⁵