The inclusion of beef imports into the British Food Standards Agency's (FSA) review of BSE(bovine spongiform encephalopathy), mad cow disease, control measures may yet result in a ban on British imports of French beef. The decision will be likely be determined by the government perception of public opinion on the issue.

The British public now seems to accept that BSE is contained and that British beef is safe. The issue of a potential variant Creutzfeldt-Jakob disease (vCJD) epidemic is, however, still alive and well.

The two issues are, of course, linked. There is a widely held presumption that vCJD results from the consumption of BSE infected beef in the late 1980's and early 1990's. This arises from the similarity of the two diseases and the timing of the two events, rather than any scientific evidence.

Ever since BSE was first identified in 1986 and the cattle epidemic that rapidly followed, there has been a very natural concern that humans might contract the disease by eating beef. In 1985 a new form of CJD was identified and in 1986 it was concluded that "in the absence of any credible alternative the most likely explanation" for this was exposure to BSE.

Measures closing any means by which BSE infected beef might get into the food chain were implemented. And a major research effort into vCJD, which has to date cost more than £140 million, was mounted.

The major epidemic of vCJD predicted by some has, however, yet to occur. The number of cases of vCJD rose to 18 in 1998 and may, after declining last year, reach or exceed that level again this year. Confirmed deaths from vCJD to the end of August stand at 14, compared with 16 in 1998.

The supposed source, BSE infected beef, has been eliminated from the food chain for over four years. Cattle themselves, typically infected as calves through feed containing meat and bone meal, do not, however, usually show symptoms until they are over three years, and more usually five or older. Hence, a delayed human epidemic is possible.

Direct research into the transmission from cattle to humans is difficult, most obviously because vCJD is fatal and there are no known antidotes. Researchers have managed, however, to shuffle BSE between other species usually by direct infusion of BSE infected tissue rather than the feeding of beef. The most recent "success" involved infection of sheep through blood transfusions.

Because of the amount of research being undertaken, new findings are reported almost every week. The issue continues, therefore, to be kept in the public eye.

Back in March the Prime Minister asked the FSA to review BSE control measures which are extremely expensive to maintain. The first draft of the review which will now be subject to public input was recently published.

The review focuses on the three main control measures. In each case the FSA draft suggested that the measures might be lifted some time in the future when the incidence of BSE has finally died out.

More controversial was reference to beef imports. European controls are less stringent. And the reluctance of member states of the European Union to adopt recommended controls on Special Risk Material, those parts of the carcase believed to be most infectuous, has already been raised publically by the European Commission and acknowledged by the FSA.

The situation in France, however, has to be of greatest concern. The incidence of BSE in France has been increasing in recent years. Although it is still well below British levels there have for some time been concern over under reporting.

This has been confirmed by a recently implemented French program which spot checks fallen stocks. Early results indicate that 0.2 percent of cattle tested, which due to their condition might have been suspected of having BSE but had not been so diagnosed, had BSE. This suggests that actual cases of BSE may be more than ten times those actually reported.

Unfortunately this might be just the tip of the iceberg.

As France like most European countries has a whole herd slaughter policy for BSE, a farmer faced with a cow which he suspects might have BSE may be tempted to dispose of it through conventional market channels, immediately and before it develops obvious symptoms.

The implications of this go beyond a further level of under reporting. BSE infected beef would be entering the French food system.

This clearly presents a challenge for the British FSA in the context of beef imports from France. There has for some time been suspicion about under reporting in France and indeed elsewhere in Europe. But, as it was just a suspicion, it was generally ignored.

A January 2000 report of a 1999 European Commission veterinary mission to France concluded amongst other things that in the context of BSE surveillance ''under-reporting cannot be excluded.'' As this has now been confirmed by the French, at least for fallen cattle, it will be difficult for the Foods Standards Agency to turn a blind eye. It will almost certainly be reminded of the danger during the public input process of its review.

The interesting question is how the British government will respond. At the time the veterinary mission report both the British government and European Commission concluded there was no reason to suggest that French beef posed a risk to human health.

This conclusion seems increasingly suspect. Without actual proof, however, a British decision to ban French beef import would be not be very different from the French decision to ban British beef. This was based on existence of some mysterious and unspecified third way of transmission of BSE which British control measures did not cover.

Such a decision would likely be followed by similar action by the German's who are reputed to be most sensitive to the BSE food safety risk. From there it would be down hill slide as other member states considered their options.

The British government's decision which will not have to be made until after the FSA submits its report in October will almost certainly be driven by its perception of public opinion. With its popularity slipping in the run up to the next general election it is likely to be anxious to avoid finding itself on the wrong side of public opinion as it recently has on fuel taxation. This may mean a ban of French beef.

September 21, 2000