It has included the issue of beef imports, of which almost 5,000 tonnes come from France, in its review. But action on any recommendation on beef trade restrictions which have to come from the European Commission is likely to be politically difficult and slow. The FSA which has to complete its report in a matter of weeks has so far avoided the issue.

The emergence of a variant of Creutzfeldt-Jakob disease, a rare but fatal human disease, in Britain is widely attributed to the consumption of BSE infected beef in the late 1980's and early 1990's. About 70 cases of vCJD have been diagnosed since the disease was first identified in 1995.

During the last week of September, the most recent for which data is available, 23 new cases of BSE were confirmed in Britain. During the same week the French confirmed six new cases, three of which were the result of direct reporting and three from random post mortem testing of fallen stock.

While a superficial comparison of these figures suggests Britain still leads this league, lifting a few stones indicates otherwise.

As the French port mortem tests only cover a small percentage of fallen cattle, the actual incidence is many times that uncovered. The French newspaper, Figaro, recently suggested a figure of 1,200 per year.

Also, as France has a whole herd slaughter policy, a single report almost certainly represents a much larger number of incipient cases.

A total of 1,178 animals was slaughtered in France as a result of the six reported cases. Most of these animals were, of course, free of BSE. But "back of an envelop" calculations using British experience of the epidemic suggest that ten or more from each of the six herds would have been infected and have developed the disease.

With an average herd size of 200, after allowing for young stock, about half or 100 animals would be milking cows. To sustain a herd of this size it is necessary to retain between 15 and 20 calves per year for herd replacement. As BSE is transmitted through contaminated feed particularly calf feed, it was the British experience that most, if not all, of the cows born in the same year as a diagnosed animal eventually go down with it.

But beyond official measures of the French BSE epidemic must be added concerns about the level of under reporting. The possibility of this was first officially raised by a January 2000 report of a European Commission veterinary mission to France the previous summer. The recently implemented French program for random post mortem testing of fallen cattle, not previously reported as having BSE, has been turning up as many cases as are being reported directly.

Of greater concern, however, is the potential for beef with BSE from apparently healthy animals entering the French food chain. If BSE is missed in diagnosis of sick animals, it is more than possible that the same is occurring in apparently healthy animals destined for human consumption.

The clinical symptoms of BSE are progressive, with early symptoms being behavioral in nature. A farmer milking cows twice a day would pick up on this. Faced with the threat of losing his entire herd, a farmer in a country which has a whole herd slaughter policy might understandably be tempted to dispose of a BSE suspect cow before it developed more obvious symptoms.

All this should be of concern to the British Food Standards Agency(FSA) which is currently in the final public input process of a BSE Controls Review. It has included beef imports in this review.

In its initial review draft the FSA notes "imports should not carry a greater proportionate risk than domestic produce." But of the restrictions on imports including that of beef from cattle over 30 months of age after which they may be infectious the draft simply notes, "the only effective check is for the UK importer to ensure that the imported product complies with the rule."

In view of the widespread short comings of the French beef industry controls identified in the report of last year's European Commission veterinary mission to France and the high and increasing incidence of BSE in France, this does not wash.

The very tight control of British beef industry required by the European Commission limits exports to just two abattoirs. No equivalent controls exist in France.

This is, of course, a difficult issue for the FSA. By raising it they may set in motion a process that will create another crisis in consumer confidence in beef, particularly on the continent. At the same time Britain is unlikely to be able to impose a ban on French imports very quickly, unless of course it resorts to an illegal beef trade ban as the French have. The European Commission is unlikely to be able to deliver such a politically difficult decision quickly.

But the FSA must be concerned about food safety perceptions. Their diligence in a domestic context is not in question. Most recently they have raised concern about a potential food hazard arising from unregulated cattle slaughter permitted for farmers' personal consumption and the potential loop hole this creates for BSE infected beef entering commercial channels.

The public interest would be better served if the FSA was more concerned about the almost 5,000 tonnes of French beef being imported annually into Britain.

October 17, 2000