Report on: BSE Crisis
Misconception of Risks
& Flaws within the system

Abstract
The BSE or the mad cow epidemic was a major crisis in British history. The BSE disease was first identified in cattle in 1986. Though the cause of the disease is not known till now, but how the disease spread was known at initial stage. Contamination of BSE into cattle happens due to consumption of BSE contaminated MBM. There was a scientific assumption that BSE might not be transmitted to human, but there was a risk of contamination to human also. But policy-makers’ perception of risk was wrong and they were consistently assuring people that beef is safe to eat, and BSE is not transmissible to human. There existed a great divergence about the perception of risks between the scientists, policy-makers and the public. Message of risk was not communicated to public in fear of irrational over reaction or risks to the industry. Scientific risk assessment was understated and misinterpreted by the policy-makers’ risks assessment on economic views, and the public was kept unaware about the risks. The flaws and shortcomings that existed in the then system aggravated the crisis. It had become necessary to separate scientific risks assessment from the political risk assessments. The outbreak of the epidemic in 1996 after 10 years of denial brought disaster to the British beef industry and created sense of betrayal and mistrust among the public. To re-establish the confidence a wide range of reforms regarding the structural and procedures in policy-making processes were undertaken. These steps supposed to establish transparency and independency, but there are still some shortcomings and residues of the old system still remain there. Whatever steps have been taken, they were not sufficient to gain the trust of the British people. British people still do not have the confidence on policy-makers on assessment of risks and food safety, which was reflected by their outburst opposition against the GM food.

Table of Contents 1. Abstract 2 2. Table of contents 3 3. Preface 4 4. Introduction 5 5. The Risks 5 6. Flaws within the system 6 7. The Changes 7 8. Conclusions 8 9. Appendices
Appendix1 9
Appendix2 10
Appendix3 11 10. References 12

Preface

It is unusual to have a preface for a report. But the conditions and constraints that were set to write this report make it necessary to write a preface to let the reader know about the circumstances I have to face to write this report. The report has to discuss about BSE outbreak and the importance of separating scientific advice on risk from political risk management (with discussion on BSE crisis and the concept of risk). The report has to assess whether the institutional and procedural reforms ensure institutional independence and transparency. Though Lord Phillips’ report about BSE was of 16 volumes, the word limit to write this report has been set to 1000 words only. A lot of efforts have been taken to abide by the word limit, many points were shortened, and many descriptions were made abridged and concise, some descriptions were put to the appendices like the description about methodology and BSE disease and many others in the footnote. But it was not possible to abide by the limit and word count has to cross the set limit. By reducing the number of words fluidity of the report has already been compensated and I believe any further reduction to the report will curtail much necessary information and facts and the report will lose its shape.

Introduction
1. The outbreak of BSE epidemic left its scars in the British people. After its first detection in 1986, for ten years the government was strongly and consistently assuring people that beef is safe to eat and BSE is not transmissible to human. But after 10 years they had to declare that BSE is likely to be ‘TRANSMISSIBLE’. It was a ‘policy failure’ and ‘policy disaster’ or maybe ‘failure of good governance’ (Forbes, 2004). The epidemic infected more than 170,000 cattle, 4.7 million cattle were destroyed (Phillips, 2000) and 164 people died to date in Britain from vCJD (Cleeland, 2009). This report discusses how the risk was assessed and addressed, the flaws within the then system, the reforms made, whether these ensure independency and transparency.

The Risk
2. The origin of BSE is not clear. Possibly it happens due to a gene mutation. The first cases of BSE identified by SVS in 1986 were not index cases. They were the results of recycling of cattle infected with BSE into MBM. Incorporation of MBM into animal feed has some risks, and it was well known before the BSE (Cleeland, 2009). The BSE agent transmitted into cattle via the consumption of contaminated MBM. It was not clear whether BSE is transmissible to human. It was assumed that BSE could behave like scrapie (BSE version in sheep). Scrapie is not transmissible to human, so BSE was not likely to transmit either. It was assumed that the risks were remote. Scientists warned if it was otherwise the consequence would be extremely serious. But scientific warning and prediction of risks was not taken into consideration. Again BSE has very long incubation periods. Thus the question if BSE was transmissible to human was unlikely to be answered with certainty for many years. The government had to deal with BSE against this background of uncertainty. So though the risk of transmissibility to human thought was remote, number of bans was introduced as precautionary measures (Phillips, 2000 & Cummings, 2011).

3. Relying on the scientific assessment the government tried to assess the risk on economic perception and suppressed information to curtail irrational public over-reaction; public perception of risk was not taken into account. Due to conflict of perception of risk, the government adopted a proportional (regulate as per evidence), rather than precautionary (keep safe in doubt), approach to risk (Phillips, 2000 cited in Smith, 2004). The problems were three folded: disagreement over the science; different perceptions of risk; and more concern to the beef industry than to the consumer (Smith, 2004).

Flaws within the system
4. The crisis was aggravated as policymaking actors actually failed collectively to address the crisis. It was multiple implementation failures (Gerodimos, 2004). There existed many flaws and shortcomings within the system.

5. The main actor in BSE crisis was MAFF. It used to play a dual role, both the regulatory and the promoting authority for the industry. So it was supposed to make a balance. But in reality, when decisions about how best BSE risk could be mitigated, priority were given to the economic interests (Cleeland, 2009).

6. Culture of secrecy is maintained in most policy system. It is often unlawful to let the public know how decisions were made and what evidences were taken into account (Millstone & Zwanenberg, 2002). Large numbers of decisions were based on (confidential) expert advice by (unelected) civil servants with minimum consultation (Gerodimos, 2004). Sharing, or making public, of any BSE-related information and access to BSE data for conduction of studies were denied initially, despite the fact that updated knowledge of the disease would minimise the impact of the epidemic (Cleelan, 2004). The communication of risks was controlled and shaped in fear of creating irrational public scare or over reaction (Phillips, 2000).

7. Many policy decisions were said to been made on ‘need’ and ‘scientific basis’. But in practice it was the need of the producers rather the consumers; and the ‘scientific basis’ was shadowed with implicit and covert economic and political consideration. For BSE, science was interpreted wrongly. As scientific uncertainties were concealed and denied the government failed to take a precautionary approach (Millstone & Zwanenberg, 2002 & 2007). Practically every decision on BSE had to be made when much was uncertain, but that was never expressed (Phillips, 2000). There existed conflict of interest within the actors of policy-making, but there was no mechanism to check conflicts of interests (Millstone & Zwanenberg, 2002 & Gerodimos, 2004).

8. Political culture in the UK is to maintain position. ‘Holding position’ is being prioritised over accuracy (Dressel, 2000 cited in Cleeland, 2009). It resulted in the government insisting on the absence of risk of BSE to the population, keeping position despite mounting evidence against it.

The Changes
9. There is a great divergence about perception of risk between scientists, policy-makers and the public. Whenever question of risks aroused scientific risks assessment was understated and concealed by the policy-makers. The public was kept unaware of the risks. It was essential to separate scientific risk assessment from the political one. After outbreak of BSE many structural and procedural reforms to the public policy formulation process has been taken to regain public confidence (Millstone & Zwanenberg, 2002). The key recommendations of Lord Phillips report about the BSE crisis are mainly four: 1. Do what has always been done properly (maintain high standards) 2. Separate promoter from regulator 3. Improve coordination between departments with overlapping (conflict of) interests 4. Keep the public informed, especially where there are uncertainties (risks) (Forbes, 2004).

10. In order to separate promoter from the regulator MAFF was abolished and a new independent agency FSA was established as the regulatory agency. But complete separation is still not ensured. FSA has to assess cost and impact of regulations on the private sectors, which means it has to look for promotion also. The same is for DEFRA. The institutional dependencies and conflict of interest of these agencies are still questionable.

11. It was supposed that scientific and political aspect of risk management will be separated and food safety policy will decided by democratic politician. But in practice FSA has been taking all food safety decisions while the ministers are only holding ornamental post.

12. Mechanism to resolve conflict of interest is still to be implemented, there has been partial implementation.

13. As for transparency, FSA makes public the information on which its decisions are made, with explanation of options, differences, assumptions and uncertainties. Traditional dependency on ultimate science no longer exists. Decisions are taken with consultation with diverse experts and stakeholders including consumers. But there still remains some ambiguity with the definition of transparency and confidentiality. FSA still maintain some level of secrecy and not all relevant information are available to public. The experts and agencies are said to be independent. But absolute independency is yet to be established. However, change in transparency and decision making process is a big change to the traditional practice. (Millstone & Zwanenberg, 2002).

Conclusions
14. The lessons we got from BSE that misperception of risks and supressing flow of information created the mistrust and aggravated the crisis. There has been positive change made to policy process. But still there are some shortcomings; many recommendations are yet to be complied. To re-establish trust there must be flow of information, uncertainty should be expressed. Scientific investigation of risk should be open and transparent, out of political or economic influences. Whatever measures were taken there is still much way to gain the trust of the British people.

Appendix 1
Methodology
The report will be based on secondary textual analysis of different reports, papers and articles about BSE especially BSE report of Lord Phillips and paper by Millstone, E. & Zwanenberg P. van (2002). The report will try to find perception of BSE risk in view of the scientist, policy-makers and the public. The second part of the report will try to find the flaws and shortcomings of the policy-making system which aggravated the epidemic. The third part of the report will try to evaluate the reforms undertaken to regain trust.

Appendix 2
The ‘Bovine Spongiform Encephalopathy’ Disease
BSE or popularly the mad cow disease affects cattle. It is a transmissible neurodegenerative disease with long incubation period from 30 months to eight years. How BSE is originated is not clear. It is assumed that it happens due to a gene mutation. It is thought that the disease is caused by mis-folded protein called ‘prion’. These mal-formed prions cause other native prion proteins in the brain to mis-fold and aggregate, leading to a spongy degeneration of the brain and spinal cord. Transmission of disease between cattle occurs via consumption of contaminated meat and bone meal (MBM) in cattle feed (protein additive in cattle feed). BSE is fatal. It has no known cure or treatment. It is now believed that BSE can be transmitted to humans by consuming infected beef.

BSE cases were first identified in 1986. These were not the index cases. Contamination of BSE happened due consumption of cattle feed contaminated with BSE itself. Only small amount of contaminated MBM can spread BSE. As BSE has a very long incubation period it is believed that contamination of BSE was spread out largely before even it was being noticed.

It believed that human contamination to BSE occurs due consumption of contaminated beef. The human variant of BSE is known as Variant Creutzfeld-Jacob Disease or vCJD (Phillips, 2000).

Appendix 3

From BSE to CJD and What We Were Told At the Time
Special report: the BSE crisis
Courtesy: The Guardian, Friday 27 October 2000 02.38 BST
. . . . . . . . . . . . . . . . . . . .
November 1986 New cattle disease formally identified by scientists working for Ministry of Agriculture.
. . . . . . . . . . . . . . . . . . . .
May 1990 Chief medical officer, Sir Donald Acheson, reassures public that beef is safe to eat.
May 1990 Minister of Agriculture John Gummer claims beef is "completely safe" and appears on TV encouraging daughter Cordelia, four, to bite into a beefburger.
. . . . . . . . . . . . . . . . . . . .
March 1993 New chief medical officer, Kenneth Calman, repeats 1990 reassurance as BSE rates start to decline.
July 1993 100,000th confirmed BSE case.
May 1995 Stephen Churchill, 19, dies. First recorded death from vCJD.
. . . . . . . . . . . . . . . . . . . .
December 1995 "There is no scientific evidence that BSE can be transmitted to humans or that eating beef causes it in humans" - Prime Minister John Major.
March 8 1996 CJD surveillance unit informs spongiform encephalopathy advisory committee of findings of vCJD.
March 17 1996 Minutes of meeting between the then health secretary Stephen Dorrell and then agriculture minister Douglas Hogg: "Mr Dorrell felt strongly that the government should not accept reponsibility for compensation".
March 20 1996 Government admits probable link between exposure to infected meat and vCJD.
. . . . . . . . . . . . . . . . . . . .
September 1997 Studies on mice show convincing evidence for link between vCJD and BSE.
December 1997 New Labour government announces BSE inquiry into events up to March 1996 and bans beef-on-the-bone.

References:
Ashraf, H. (2000) BSE Inquiry Uncovers “A Peculiarly British Disaster”. The Lancet 356(9241) p 1579-1580
Cleeland, B. (2009) The Bovine Spongiform Encephalopathy (BSE) Epidemic in the United Kingdom. International Risk Governance Council, Geneva, Switzerland.
Cummings, L. (2011) Considering Risk Assessment Up Close: The Case of Bovine Spongiform Encephalopathy. Health, Risk & Society. 13(3). p. 255–275
Forbes, I. (2004) Making a Crisis out of a Drama: The Political Analysis of BSE Policy-Making in the UK. Political Studies. 52(2). p. 342–357
Gerodimos, R. (2004) The Uk Bse Crisis As A Failure Of Government. Public Administration. 82(4) p.911–929
Hinchliffe, S. (2001) Indeterminacy In-Decisions – Science, Policy and Politics in the BSE (Bovine Spongiform Encephalopathy Crisis. Royal Geographical Society. 26(2). p. 182–204
Jones, K. E. (2001) BSE, Risk and the Communication of Uncertainty: A Review of Lord Phillips' Report from the BSE Inquiry (UK). Canadian Journal of Sociology. 26(4). p. 655-666
Kewell, B. & Beck, M. (2008) The Shifting Sands of Uncertainty: Risk Construction and BSE/vCJD. Health, Risk & Society. 10(2). p. 133–148
Little, G. (2001) Reports, BSE and the Regulation of Risk. The Modern Law Review Limited. 64 (5) p.730-756
Meikle, J. (2000) Denial, Failure and the Betrayal of the Public, Special Report: The BSE Crisis
The Guardian, Friday 27 October 2000 02.38 BST
Millstone, E. & Zwanenberg P. van (2002) The Evolution of Food Safety Policy-making Institutions in the UK, EU and Codex Alimentarius. Social Policy and Administrations. 36(6). p. 593–609
Millstone, E. & Zwnenberg, P. Van & (2003) BSE: A Paradigm of Policy Failure. The Political Quarterly. 72(1). p. 27-37
Millstone, E. & Zwanenberg P. van (2007) Mad Cow Disease- Painting Policy-Making Into A Corner. Journal of Risk Research. 10(5). p. 661–691
Phillips, Lord (2000) The Inquiry into BSE and Variant CJD in the United Kingdom (Vol 1)
Smith, M. J.(2004) Mad Cows and Mad Money: Problems of Risk in the Making and Understanding of Policy. Political Studies Association. 6(3). p. 312–332
The BSE Inquiry Report. Archive: BSE: Disease Control & Eradication – Causes of BSE. DEFRA. Available at: http://archive.defra.gov.uk/foodfarm/farmanimal/diseases/atoz/bse/controls-eradication/causes.htm. [Accessed on: 01/11/2013]
The Guardian (2000) BSE Report: The Main Findings. 26/10/2000. Available from http://www.theguardian.com/uk/2000/oct/26/bse1. [Accessed on: 01/11/2013]
The Guardian (2000) From BSE to CJD and what we were told at the time. 27/10/2000. Available from http://www.theguardian.com/uk/2000/oct/27/bse. [Accessed on: 01/11/2013]
The Guardian (2000) Criticised: key players who took leading roles in growing crisis: Special report: the BSE. 27/10/2000. Available from: http://www.theguardian.com/uk/2000/oct/27/bse. [Accessed on: 01/11/2013]

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[ 1 ]. GM: Genetically Modified. ‘There is no scientific evidence that GM food is not safe, but there is risk’.
[ 2 ]. BSE: Bovine Spongiform Encephalopathy. Short description about the BSE disease is given in appendix 1
[ 3 ]. For chronology events of the epidemic see www.defra.gov.uk
[ 4 ]. For what assurances were given about BSE and safety of beef see appendix 2
[ 5 ]. Lord Phillips. The head of the commission which inquired into BSE and make a 16 volume report submitted to the British Government.
[ 6 ]. vCJD: Variant Creutzfeld-Jacob Disease. Human version of BSE
[ 7 ]. SVS: State Veterinary Service
[ 8 ]. MBM: Meat Bone Meal. A food additive to cattle feed made from animal carcasses
[ 9 ]. MAFF: Ministry for Agriculture, Fisheries and Food
[ 10 ]. FSA: Food Standards Agency
[ 11 ]. DEFRA: Department for Environment, Food and Rural Affairs , it retained the responsibility for promoting farmers but also it has to look after environment regulations