Where there’s swill, there’s a way to reduce food waste

20 April 2016 - 3:51pm -- Gerry Danby
Pigs have been fed food waste for thousands of years

Pigs have been fed food waste for thousands of years

The foot and mouth disease (FMD) outbreak in 2001 witnessed the slaughter of millions of animals and horrific images of burning pyres of dead livestock across the British countryside that will be etched on the memories of many for decades to come. Official figures put the cost of the outbreak at over £8 billion. The economic, environmental, social and human cost was, however, much higher and far in excess of what it ought to have been.  The scale of the outbreak was due largely due to the fact that it was one of the most poorly managed. The ban on swill-feeding pigs was one among many hasty, ill-considered actions.

We live with the legacy of the ban on swill-feeding today, at a time when the imperative is to eliminate food waste and reduce food miles to combat climate change. The rationale which underpinned the ban must be brought into question.

Foot and mouth disease

FMD represents an economic threat, it carries no implications for the safety of the human food chain. FMD is a highly contagious virus most commonly affecting cattle, sheep and pigs and manifests in symptoms of fever, lameness and vesicular lesions. It first appeared in Britain in 1839 and became increasingly prevalent throughout the mid-nineteenth century, so much so it was considered unavoidable and a mild ailment which all cattle would, at some point, contract.

In 1865 Britain lost 7 per cent of the national herd to the equally contagious rinderpest or ‘cattle plague’ which carries a high fatality rate. Legislation introduced to combat rinderpest brought FMD and other contagious diseases within its remit. Whole herds had to be slaughtered where only one beast was infected. The provision made for FMD within legislation designed for a virus of much greater significance, however, cemented the reputation of FMD as a serious plague-like disease.  The belief in FMD-as-plague took hold and formed the basis of all future control measures.

Burnside Farm, Heddon-on-the-Wall

In 1995 the Waugh brothers ran Burnside Farm at Heddon-on-the-Wall in Northumberland as a swill feeding pig farm. The feeding of catering waste to pigs had long been the subject of regulation. In 2001 the rules were set out in The Animal By-Products Order 1999 which gave effect to EU Directive 90/667/EEC on the disposal and processing of animal waste. Cooking catering waste for 60 minutes at a temperature not less than 100oC was a critical control in mitigating the risk associated with swill feeding.

Burnside Farm had a history of poor management and inspections by the State Veterinary Service (SVS) in the run-up to the outbreak of FMD had found conditions unacceptable, including pens destroyed by pigs, overflowing slurry backed up into the pens and dead sows in their pens. On one visit the SVS failed to take note of containers of unprocessed catering waste on an adjacent hard-standing area, modifications to the feeding system and the presence of 1,300 items of cutlery strongly evidenced that unprocessed catering waste was being fed to pigs. The SVS took no formal action and the Waugh brothers licence to swill feed was renewed in early 2001, a few short weeks before FMD struck.

On 19 February 2001 a suspected case of FMD was discovered in an Essex abattoir, confirmed the following day and traced to Burnside Farm where it could have been present as early as 26 January. There had been significant movements of livestock in the intervening period. The most likely source of infection was meat or meat products contaminated with FMD, most likely meat illegally imported from the Far East or catering waste from ships or airlines, and fed to pigs as unprocessed or inadequately processed food waste.

Light-touch enforcement by regulators and a superficial examination of evidence had combined to allow the feeding of unprocessed catering waste to pigs at Burnside Farm. It was neither an accident nor a simple case of cutting corners, but a persistent and flagrant course of misconduct which was allowed to go unchecked - a disaster in the making.

The Government’s management of the outbreak

Crucial time was lost in the early days managing the outbreak of FMD. The virus had been discovered approximately three weeks after the first likely onset of clinical signs and had already reached as far south as Devon and north up into Dumfries and Galloway across more than 50 locations. This was to determine the extent of the outbreak which followed.

Neither MAFF nor the farming industry had been prepared for a large scale outbreak of FMD. The Government’s contingency plan was limited in scope, out of date and not integrated into a national programme of rehearsal and testing. Awareness of the plan was low, described by one stakeholder as the “best kept national secret”. European Commission guidance provided that each member state should have sufficient trained staff to deal with 10 cases at any time and maintain surveillance of premises within a 3 km protection zone around each. There were at least 57 premises already infected before FMD was first confirmed.

It took four days for national livestock movement restrictions to be introduced. If a ban had been in place on 20 February on one estimate the extent of the epidemic would have been a third to one half of what it became. Vaccination received only cursory consideration.

On 27 February public footpaths in infected areas were closed and the whole of Great Britain was declared a Controlled Area under the Foot and Mouth Disease Order 1983, a day which became known as ‘The day they closed the countryside’. The strategy was to cull all susceptible animals on infected premises and those considered dangerous, but it did not work. Public confidence in MAFF fell away as relationships within and between the agencies involved grew tense, communications became erratic, decision-making haphazard and messy, and a sense of panic emerged.

On 24 March a policy of slaughter on suspicion was introduced, clinical confirmation of FMD was no longer required, and soon after the contiguous cull of all animals on premises neighbouring infected premises was undertaken. The piecemeal policy evolved unsupported by any scientific rationale and the manner of its introduction and poor communication generated widespread mistrust.

Cognitive dissonance

MAFF’s actions during this time have been described as a case of ‘cognitive dissonance’. A state which arises when organisational knowledge or belief conflicts with decisions taken. When there is pressure to justify a decision, the less justified it is the greater the dissonance. The inability to admit to error increases with the seriousness of the error and the more incredulous become attempts to justify the unjustifiable. A change in policy became unthinkable which meant “the killing intensified and the ‘cure’ became worse than the disease.”

The end of FMD – and the cost

The last reported case of FMD was on 30 September 2001, the outbreak lasted 221 days, one day shorter than the 1967 outbreak, but at a much higher cost.

Official figures put the cost of the eradication of FMD in 2001 at over £8 billion of which £5 billion fell on the private sector and over £3 billion directly on the public purse. In all 2,026 premises across 44 counties, unitary authorities and metropolitan districts were officially declared infected and over six million animals were slaughtered. The loss to agriculture was largely compensated by Government but an estimated £355 million, representing 20% of farming income in 2001, was not compensated.

The cost in numbers does not take account of the environmental impact of carcass disposal, the 200 incidents of water pollution and the degradation of air quality; or the human cost, the lives of the many traumatised farmers and damage to the health and well-being of rural communities.

The picture painted was one in which the lessons of the past had not been learned, contingency planning for a possible recurrence was poor, the initial management of the response to the outbreak was slow and poorly informed, the full range of options, including vaccination, were not considered and decision-making lacked a clear rationale and focus. It becomes easy to see how a serious veterinary problem became a national disaster.

The ban on swill feeding

The practice of swill feeding had been in decline and MAFF estimated that in 2000 there were approximately 82,000 pigs, 1.4% of the total number of pigs, which were fed swill in 93 premises licensed for feeding swill to pigs and poultry. A modest but significant number. On 27 March 2001 the Government proposed an amendment to The Animal By-Products Order 1999 which would ban feeding swill to livestock.

The reasons advanced by MAFF for the ban were far from compelling. Those on both sides of the argument also failed to take account of the wider economic and environmental impact that would follow such a ban. The Animal By-Products (Amendment) (England) Order 2001 prohibited the feeding of swill to livestock and came into force on 24 May 2001. The European Union followed the lead given by the UK and a ban throughout Europe was soon implemented.

The change brought a swift end to a practice which had been widespread in England for hundreds of years. Throughout the world pigs have lived alongside people for over 9,000 years consuming the refuse and detritus people leave behind.

The combined effect of the ban on feeding processed animal protein (PAP) to livestock introduced across the EU in 2001 and the subsequent ban on feeding catering waste resulted in a deficiency in animal feed protein equivalent to 2.9 million tonnes of soymeal. EU imports of soymeal increased by 3 million tonnes between 2001 and 2003. In 2007 the then 27 countries of the European Union together imported over 40 million tonnes of soy products, most originated from Brazil and Argentina.

The cultivation of cereals, including soybeans, is one of the main causes of rainforest deforestation in Brazil and a major contributor to climate change. The Amazon rainforest has lost 18% of forest cover since 1970 and, despite recent attempts to reduce the rate of decline, losses still proceed at a rate around 5,000 km2 a year. This increased production and shipment of soybeans has a significant environmental impact in terms of the erosion of biodiversity, pollution and greenhouse gas emissions.

A proportionate and rational response?

The swill-feeding ban was driven by the events which unfolded after FMD was discovered in an Essex abattoir on 19 February 2001. The picture painted is one in which those charged with managing the outbreak wanted to be seen to be doing something.

Little investigation was undertaken into the source of the illegally imported meat, present in the unlawfully processed swill-feed used on Burnside Farm. Who was responsible for importing it? What failings allowed the import of infected meat? Why was the meat not detected on import? Who purchased the meat? Where was it prepared? All these and other questions remain unanswered, leaving the Waugh brothers inexcusable but convenient scapegoats. A ban on swill feeding was an easy next step.

The Waugh brothers were not responsible for the scale of the outbreak whatever view is taken about its cause. The lack of contingency planning may well have been fuelled by complacency. It had, after all, been 34 years since the last outbreak in 1967. On the other hand, this ought to have focussed thinking since FMD remained a global threat and had not been eradicated.

MAFF’s calamitous management of FMD, when it did return, compounded the situation. The initial response lacked urgency, valuable time was lost, animal movement restrictions were slow to be implemented, there was no effective vaccination policy and the culling policy was in disarray.  As Magnus Linklater, writing in The Times, rather acerbically put it at the time:

So there you have it: the research, it seems, was wrong, the science was outdated, the slaughter unnecessary, the policy unethical, and the strategy ineffective. Apart from that, things seem to have been just fine.

It was not swill-feeding which caused FMD. A failure of enforcement played a significant role in creating the circumstances which led to the outbreak. The lack of effective contingency planning and outbreak control management were key factors in the scale of the outbreak, not least the absence of a clear vaccination policy.

The view of FMD-as-plague is a legacy from the nineteenth century. If cattle plague had not invaded Britain in the mid-nineteenth century, FMD-as-plague would never have existed, it would not have been manufactured and FMD would have remained an unavoidable mild ailment and not become a high-profile public issue with major social and economic implications for entire rural communities.

FMD and swill-feeding to pigs on Burnside Farm will be closely associated for many years to come. While the public at large may be forgiven for thinking a ban on catering waste in animal feed was the right thing to do, more is expected of policy makers and legislators. A sledgehammer, the full weight of domestic and EU law taking a zero tolerance approach, brought an end to a method of meat production with a tradition going back many hundreds of years. The ban is no better enforced than the regulations which governed swill-feeding, there are no inspections and swill-feeding, albeit illegal, is likely still continuing.

A more rational appraisal of the nature of FMD would help put any risks associated with swill feeding into perspective. Feeding catering waste to animals does not mean we turn the clock back to the days of swill feeding as it existed in the late 1990s.  Catering waste is a valuable source of animal feed, today’s technology is more than capable of coming up with a means of processing catering waste so it can safely be used with confidence.

Taiwan has succeeded in diverting two-thirds of the country’s food waste to feed its 5.5m pigs. While the introduction of this initiative has not been without its difficulties, notably in the area of compliance and enforcement of regulations governing the scheme, it is now regarded a success and can save pig farmers 30 per cent on the cost of commercial pig feed.

Recent research has highlighted the pressing need to reduce the footprint of livestock farming. A recent study demonstrated that changing EU legislation and promoting the use of food waste in animal feed could reduce land use for EU pork production by 20% saving 1.8 million hectares of agricultural land.

In the UK some 15 million tonnes annually of food and drink is wasted in the food chain, domestic food waste accounts for 7 million tonnes. Much of this is avoidable, but up to 3 million tonnes, is unavoidable. There is plenty of scope for using all unavoidable catering waste in animal feed. The benefits are many, not least providing pig farmers and others with more competitively priced animal feed, at the same time as making possible a more appropriate use of South American soybeans presently used to feed pigs and provide relief for the beleaguered Amazon rainforest.

Whichever way you look at it, we have ended up with a contemporary legal framework which is neither proportionate to the risks it seeks to address, nor is it entirely rational. In short, so far as pig swill is concerned, the law is an ass.


An expanded and fully referenced version of this blog post can be found here.

Photo credit: flickr.com


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Detailed and informative. Artisan Food Law is excellent.

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Thanks Ian - we aim to redress the balance in support of artisan and small scale food production. Coping with law and regulation can be a tough nut to crack!

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