FMD Review (Scotland) 2007: Independent Analysis and Evaluation of Scotland's FMD Contingency Plan

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INTRODUCTION

A. Project Aim & Objectives

The FMD Review (Scotland) 2007 incorporates a review of the adequacy of current contingency planning arrangements. Analytic Red has been contracted to provide independent analysis and evaluation of Scotland's FMD Contingency Plan (hereafter ' CP'). This report will become an Annex to the main report of the Review, with our Conclusions and Recommendations incorporated into the body of that report.

The Scottish Government's Aim for this project is the independent analysis and evaluation of Scotland's current Foot and Mouth Disease Contingency Plan to:

  • Evaluate whether the CP provides sufficient information to facilitate an effective response to foot and mouth disease incursion in GB
  • Analyse whether the CP is suitable for leading a response to disease outbreak in Scotland, and
  • Identify steps in the CP to be taken in the event of FMD incursion elsewhere

(Source: Schedule 2: Research Specification)

The Project Objectives provided by the client are:

  • To review the objectives which underpin the CP;
  • To identify any gaps either in scope or content;
  • To advise on the suitability of the layout and practicality of the CP;
  • To consider links to the supporting infrastructure (e.g. Local Authorities and Animal Health agency);
  • To make recommendations on areas for improvement - to form the basis of a future revision of the CP, and
  • To consider the relationship between the Scottish CP and arrangements elsewhere in Great Britain.

Specific evaluation was further required by the client on:

  • The adequacy of the CP in terms of organisational structures - HQ and overarching command and control structures - and operational issues
  • The flexibility of the CP in terms of it supporting the response to a variety of FMD outbreak scenarios.

B. Approach to the Project

Analytic Red has a substantial track record in reviewing complex contingency plans. Our analysis and evaluation focused on assessing the CP's fitness-for-purpose in both conceptual (the logic of the content) and functional (usability) terms.

Analytic Red has conducted a desk review of the CP and relevant local, national and international documentation, such as DEFRA's Framework Response Plan for Exotic Animal Diseases and European Union Council Directive 2003/85/ EC as well as taking into consideration the various Lessons Learned Reports following the 2001 outbreak.

Analytic Red also interviewed key operational partners and other relevant individuals (see Annex B). These contacts provided us with insight on the use made of the CP during the recent outbreak of FMD (2007 outwith Scotland) and the CP's relevance in supporting the induction of individuals new to posts with roles and responsibilities under the CP.

Our analytical approach is guided by two key and related concepts: resilience of response and quality of decision-making. We expect the CP to deliver resilience by enabling the effective strategic management of an FMD crisis and the mitigation of its direct and indirect impacts. Whilst there is general acceptance that there will be considerable uncertainty about the scale of outbreak at the outset, a fundamental requirement of a CP is that those charged with roles and responsibilities are able to make and execute the highest quality of decisions under difficult circumstances.

Resilience is usefully defined as the "ability to recover quickly from difficult conditions" (Shorter Oxford English Dictionary 2002). An interpretation of the term for Government would be the ability to identify, assess and respond to a potentially disruptive situation in order to prevent it from becoming an uncontrolled crisis.

The FMD outbreak of 2001 highlighted the need to activate contingency plans which cover the full spectrum of the consequences of FMD. Such plans have to be relevant to all individuals and organisations with a role in 'stamping out' the disease and managing the myriad consequences across all sectors of the economy and national life. Given the volume of work and speed of actions required in such a crisis, a clear structure for strategic-operational-tactical management has to be established in advance which embeds the capacity for subsidiarity and mission command to preserve the focus of strategic leadership on issues that really matter.

C. Structure of the Report

This report presents Analytic Red's independent analysis and evaluation of the plan in terms of:

* Key Judgements
* Conceptual Content
* Functional Format
* Structures and Systems
* Conclusions and Recommendations

D. Needs Analysis for an FMD Contingency Plan

This section sets out some of the major contextual drivers that Scotland's FMDCP would be anticipated to have considered.

Context 1: Increased Flow of Animals To, From and Around Scotland

Analytic Red understands that Scotland needs to be resilient to FMD. Whilst controls are in place to minimise the risks of infection entering the country through the introduction of the thirteen day 'standstill period' and the awareness of the need for on-farm biosecurity has been boosted, (a) the risk of outbreaks in Scotland remains, and (b) the country is open to the implications of suspicion or outbreak of FMD elsewhere in the United Kingdom.

In addition, our consultees informed us that the speed with which any outbreak would be communicated to, from and around Scotland is increasing due to changes in the Scottish agricultural economy where animals are frequently transported over substantial distances and via 'multi-drop' routings into and out of the country.

Scotland therefore has to have the means in place to (a) effectively contain and eradicate FMD in a range of outbreak scenarios and manage the wider impacts of that outbreak and (b) manage all consequences of an outbreak where the disease remains outwith Scotland.

Context 2: Devolution and UK-Co-Ordination

Whilst policy responsibility for animal health and welfare has been devolved to the Scottish Government, it is the GB contingency plan which is EU-approved. Scotland's FMDCP must therefore assure and enable both the effective delivery of response that meets the requirements set out in EU Council Directive 2003/85/ EC and also align with and deliver the GB plan in Scotland through close co-ordination with partners in England and the other Devolved Administrations. This is especially important given the UK-wide management of key resources (e.g. vaccine, disposal logistics) and the need for effective working between Edinburgh and London around specific decisions (e.g. emergency vaccination) and notification to EU bodies via Member State representation.

Beyond the strict disease control aspects, the Scottish CP should have identified and enabled appropriate structures to 'key-in' to relevant central crisis and other machinery in Whitehall and beyond (e.g. CCU interfacing with CCS; Scottish Ministers or Officials represented at CCC or CCC(O) respectively).

Context 3: Scottish Government's Additional Aspirations

The Scottish Government also wishes to integrate additional responsibilities under the rubric of the FMDCP: "the wider impact of a disease outbreak will be taken into consideration and contribute to the strategic decision making process" ( Foreword, p. 3). These consequence management responsibilities place an additional duty on the CP.

Context 4: Foot and Mouth Disease 2001: Lessons to be Learned Inquiry Recommendations

Prior to 2001, local plans existed for managing an FMD outbreak but there was no FMD Contingency Plan for GB or for the Devolved Administrations. Since the 2001 outbreak, significant work by the Devolved Administrations took place to address this gap. The Lessons to be Learned Inquiry (amongst others) into the FMD outbreak of 2001 contains significant recommendations for the enhancement of contingency planning for FMD throughout GB. We would expect to see evidence that findings have led to appropriate revisions of the Scottish CP, especially as the Scottish Government has formally accepted recommendations (see Annex A).

Context 5: Strategic Performance Depends on Operational Effectiveness

In order to effectively deliver to the exacting challenges posed by any outbreak of FMD, the CP must support the Scottish Government's leadership in disease control and consequence management. As a strategic document supporting induction, training, exercising, awareness-raising and the response to real-world events, the CP must detail the structures and processes which would be initiated from the first suspicion of an outbreak and, thereafter, be a resource for individuals leading and staffing structures and processes which may have to be in place for a sustained duration should FMD be confirmed.

Given that the nature and trigger points of many of the key decisions that would have to be taken can be anticipated, the CP should set out clear criteria and information requirements for decision-making. It would be reasonable to expect that key decisions and options to limit the spread, stamp out and mitigate wider impacts of FMD have been anticipated. These could be worked through in concert with stakeholders to understand the implications of potential decisions. This 'peacetime' preparation of a suite of options would enable the CP to be scalable and flexible to the unpredictable reality of an FMD outbreak.

In particular, Analytic Red sought evidence that the five fundamental processes of decision-making are addressed in terms of overall and individual structures and processes have identified inputs and outputs. These fundamental processes comprise Information Gathering; Assessment of the Situation; Decision-Making; Action and Monitoring and Communication and - in some form - should have been assured for all elements of the response.

Information Gathering refers to the means by which information is acquired and processed in order that decision-makers are provided with a valid Assessment of the Situation. This Assessment is then drawn upon in the Decision-Making process. Here, a group collectively reflects on the Assessment - and other information - to make timely, proportionate and sustainable decisions. These decisions are then executed and tracked through an Action and Monitoring activity. In turn, the Communication function delivers key information to internal and external stakeholders (staff, stakeholders, operational partners, etc). This sequence should be seen as a continuous process whereby any change in information is reflected by a timely change in decision-making.

These inter-dependent processes require infrastructure to be in place. This infrastructure includes all of the skilled people tasked to work within each process, the technology they need to achieve their tasks and specialised (e.g. critical information) and mundane resources (e.g. food and drink).

Page updated: Wednesday, June 11, 2008