44. AN
ANALYSIS OF
THE KREBS
REPORT
45. This section reviews the NFBG's view
of the recommendations contained in the Krebs Report. It particularly
focuses on areas of research which the Government either has no
plans to address or is not addressing with sufficient rigour.
It then identifies further issues which were not addressed in
the Krebs Report because its terms of reference focused on badgers.
46. (Figures in parentheses refer to paragraph
numbers in the Krebs Report).
47. TB in humans (7.2.1)
48. The NFBG welcomes the fact that the
Government is now communicating with the Public Health Laboratory
Service (PHLS) and cases of TB infection in humans, normally caused
by Mycobacterium tuberculosis, will be tested for bovine
TB, caused by Mycobacterium bovis.
49. Cause of herd breakdowns (7.3.2)
50. The NFBG welcomes the fact that the
previous form used for attributing the cause of herd breakdowns
has now been updated (TB99 form). However it believes the questionnaire
is not sufficiently rigorous to comply with the recommendations
in the Krebs Report. Furthermore, the forms must be "ground-truthed"
to ensure the data are reliable.
51. The design of an epidemiological
questionnaire for wider research purposes
52. The epidemiological questionnaire was
recommended by the Krebs Report so that TB-contributing factors
other than badgers could be identified.
53. The questionnaire currently being piloted
contains many questions which are "wooly", being qualitative
rather than quantitative. It is not obvious what specific scientific
questions are being addressed. It is also not clear how the results
will be analysed to provide meaningful information.
54. As part of the piloting process, the
questionnaire was sent to a range of individuals and organisations,
including the NFBG, asking for comment on the forms. The NFBG
provided constructive comments on the forms but has recently been
informed that the piloting on farms and the external consultation
process was simply to test the general layout of the form, rather
than to test its scientific rigour. This is hardly a consultation
process and nor is it scientifically sound.
55. The full methodology behind the questionnaire
must be published in full after open consultation with the scientific
community. Otherwise, we predict that the epidemiological questionnaire
will be of limited value unless its methodology and management
is drastically improved.
56. The NFBG respectfully requests that
the Select Committee asks:
Whether Professor Krebs believes
the new TB99 epidemiological questionnaire satisfies all his recommendations
for a more transparent and objective questionnaire?
What specific questions will the
questionnaire answer and how will the data be analysed and utilised
at a practical level?
57. The use of the epidemiological questionnaire
58. The epidemiological questionnaire is
not being implemented as the Krebs Report recommended. The Report
recommended that data be collected from areas of high and low
TB risk (7.5.7), in order that data from farms with high and low
breakdown rates could be compared.
59. Instead, the Government is planning
to target the questionnaire only on high risk farms. Low risk
farms will only be surveyed if there is enough money left over.
It will therefore not be possible to make a comparison between
farms with high and low breakdown rates and the research will
consequently provide little useful information.
60. We are also extremely concerned that
the questionnaire shows an unnecessary bias in seeking information
about badgers on the farms in question, yet includes relatively
few questions on animal husbandry on the farm, even though this
is identified by the Krebs Report as a potentially important factor.
61. Moreover, the Krebs Report recommended
the epidemiological study be conducted outside the badger culling
trial areas (5.7.3). Instead, the epidemiological study is being
conducted inside the badger culling trial areas. The data derived
from this will be distorted because the experiment will impose
artificial conditions on these areas.
62. Other wildlife (7.3.4 and 2.2)
63. The Krebs Report specifically recommended
that "the risk to cattle from other species should be assessed
in the areas of high herd breakdown risks, taking account of four
key factors:
prevalence of the disease;
the severity of the disease and its
effect on infectivity;
abundance of the species; and
the extent of contact with cattle,
including the movement range of the wildlife".
64. The Independent Scientific Group led
by Professor John Bourne watered down this recommendation, requesting
only that "data collected during the trial should include
information on other potential wildlife sources of the disease.
This should include accurate estimates of population density and
disease dynamics".
65. Despite evidence that other wildlife
represents a potential reservoir of infection, MAFF has so far
not investigated other species with anything like the same rigour
as it has applied to badgers.
66. The NFBG welcomes any new research initiative
on this front provided that data are collected with sufficient
rigour. Careful consideration must be given to the wildlife species
to be investigated and to the methods of sampling utilised.
67. We wish to alert the Select Committee
to the fact that the epidemiological questionnaire will not provide
the answers needed on the role of other wildlife. Rather, the
piloted questionnaire asks highly subjective and unscientific
questions which are extremely unlikely to provide "accurate
estimates of population density and disease dynamics", as
recommended by the Independent Scientific Group.
68. The question regarding wildlife asks
the farmer, "Approximately how often have you seen these
species on your farm in the last 12 months? (Indicate Weekly,
Monthly, Yearly, Never)". Information is then required on
whether animals (including deer, feral cats, fox and mink) were
dead or alive, whether they were observed in or near buildings,
or elsewhere on the farm. If alive, it is asked if the animals
appeared sick.
69. Future research on badgers (7.4.5)
70. The Krebs Report recommended that future
research on badgers should include three priorities:
71. Badger surveys
72. Road traffic accident victim surveys
(7.5.5)
73. At a meeting with Nick Brown MP, Minister
of Agriculture and Jeff Rooker MP, Food Safety Minister, on 12
January 1999, it was confirmed that badger road traffic accident
(RTA) victims will be sampled. However, sampling will not commence
until the start of the new financial year. Furthermore, due to
the high cost of badger post mortem examinations, badger
RTAs will be sampled only in high risk areas.
74. The NFBG welcomes the resumption of
RTA sampling.
75. However, badger RTAs should be sampled
over the entire country to establish the relative levels of infection
in badgers on a national level. RTA sampling on a national scale
by MAFF ceased in 1989. The only badgers to be post mortem
examined post-1989 were those killed by MAFF in badger removal
operations and, more recently, by MAFF in the culling trial. This
is clearly a biased sample and there is therefore no information
on the current distribution and prevalence of TB infection in
the wider badger population.
76. Local variation in risk (7.5.7)
77. The NFBG understands that the Government
is attempting to determine the "correlates of local variation
in risk" through the epidemiological questionnaire and through
a separate research project. The NFBG will make detailed comment
on this project when information is made available. In principle,
we welcome the fact that efforts are being made to investigate
local risk factors, including those which have previously been
ignored. It is essential that the investigation includes all the
other factors noted by the Krebs Report, including the presence
of badgers, and TB prevalence in badgers, including the severity
of the disease, cattle husbandry, climate and landscape variables.
78. Establishing transmission routes
(7.5.11)
79. The NFBG welcomes the Krebs Report recommendation
that "further consideration should be given to whether appropriate
techniques can be developed to research this issue".
80. Consequently, we are extremely concerned
that the Government has not yet announced whether it will be funding
this vital area of research.
81. Molecular epidemiology (7.6)
82. The Krebs Report recommended that "molecular
epidemiology is used to understand more about the badger to cattle
transmission dynamics". It also recommends that molecular
techniques are used to "analyse the spatial and temporal
dynamics of the disease in badgers and other wildlife as well
as cattle".
83. The NFBG welcomes this recommendation
and understands that it is being implemented as part of an on-going
programme of research at MAFF's Central Science Laboratory. We
are concerned, however, that it is not yet clear whether the research
extends to wildlife other than badgers.
84. Estimation of recolonisation times
(7.8.9 and 7.8.15)
85. The Krebs Report called for further
research on recolonisation times "in areas subject to both
the reactive and proactive control strategies". We regret
that the Government has not yet announced whether it will be funding
this area of research. Given that the Government has assured the
Bern Convention that it has no plans to make badgers locally extinct
in the long term, it is imperative that this research is undertaken
if the Government is not to remain in permanent breach of this
international wildlife treaty.
86. This is particularly important when
there is evidence that some farmers are killing badgers illegally.
The NFBG is concerned that such farmers will also ensure that
badgers are prevented from recolonising areas where MAFF has removed
them as part of the culling trial.
87. Mathematical modelling (7.7)
88. The Government has not yet announced
whether it will utilise the techniques employed in medical epidemiology
or that it will "harness external expertise" and ensure
"better liaisons between modellers and MAFF to ensure that
data gathered are better able to meet research needs".
89. Future strategies (7.8.12)
90. Efficiency of badger removal operations
(7.8.21)
91. The Krebs Report recommended that badgers
are removed more rapidly once a herd breakdown is confirmed in
cattle. This will be applicable only in the reactive areas of
the trial, as the Government has adopted a policy not to kill
badgers outside the trial areas.
92. We are extremely concerned about the
animal welfare implications of such a policy, because the closed
season for removal operations between 1 February and 30 April
will still leave between 20 and 55 per cent of cubs to die below
ground when their lactating mothers are killed.
93. Snares to trap badgers (5.6.8)
94. The Krebs Report recommended the use
of snares to trap badgers in the trial but, following a high-profile
media campaign orchestrated by the NFBG, the Government decided
not to use snares in the culling trial. It also announced that
experiments would not be conducted on captive badgers to investigate
the welfare implications of using snares.
95. The NFBG produced an illustrated report
for Ministers on the cruelty associated with snares. In addition,
a 50,000 signature petition, calling for a ban on snares, was
presented to Parliament on 1 July 1998, by Roger Gale MP, then
Chairman of the All Party Parliamentary Group for Animal Welfare.
96. The NFBG remains extremely concerned
that the Government is currently using captive badgers to investigate
"leg cuffs" or, more accurately, "leg snares".
This work is being conducted with a view to using leg snares in
the culling trial, but little information is currently available.
If the Government is to claim that snaring badgers is acceptable,
it can only do so if its experiments have been conducted openly
in order to garner public confidence.
97. Independent Expert Group (7.8.23
and 5.6.14, 5.6.15 and 5.6.19)
98. The NFBG acknowledges that the "Independent
Scientific Group" has been appointed and we have held meetings
with the Group's chairman on two occasions.
99. However, we are concerned that the Group
does not have members with more expertise in badger welfare, on
farming practices and in dealing with the practical issues of
bovine tuberculosis in badgers and cattle.
100. It is essential that the Group consults
widely to ensure all practical issues are addressed thoroughly,
but an effective consultation process is not in place.
101. The NFBG recommends that a mechanism
is set up whereby interested parties can review and comment on
the progress made on all recommendations in the Krebs Report,
including the five-year experiment and research into cattle husbandry.
Information should also be made more readily available on the
method used, particularly in the trial.
102. The NFBG is concerned that, while the
Independent Scientific Group has provided some answers to the
NFBG's questions and concerns, it has failed to explain how it
will ensure the results of the trial are statistically sound.
103. Culling outside TB areas (7.8.25
and 5.6.34 - 5.6.36)
104. The Krebs Report recommended that no
culling should be carried out outside the "hot-spot"
areas, as it would be of limited value and the NFBG understands
that these recommendations are being implemented. However, we
are concerned at the evidence that some farmers are killing badgers
illegally, particularly outside the culling trial area. Wildlife
crime is not a recordable offence under current Home Office rules,
and it is therefore not only difficult to detect crimes against
badgers but there is no national system to record the incidents.
105. Professor Bourne is concerned that
illegal killing is a "sinister" issue, but we have not
been able to establish how the Expert Group will statistically
account for this in the experiment.
106. Diagnostic tests (7.9)
107. Diagnostic tests for Cattle (7.9.1
- 7.9.3)
108. We regret that the Government has not
yet announced a research programme into a diagnostic TB test for
live cattle.
109. Diagnostic tests for Badgers (7.9.4)
110. We regret that the Government has not
yet announced a research programme into a diagnostic TB test for
live badgers. The so-called "live test", a blood test
for badgers is, at best, only 41 per cent sensitive and was abandoned
by MAFF in 1996, part-way through a five year trial to test its
effectiveness.
111. Vaccines (7.10)
112. Cattle vaccine (7.10.1)
113. The NFBG believes that the development
of a cattle vaccine should be given a high priority by the Government.
114. EU legislation (7.10.9)
115. The Krebs Report recommended that,
to satisfy EU legislation, a cattle vaccine must be developed
alongside a diagnostic test which can distinguish between infected
and vaccinated cattle.
116. It is not clear that the Government
has yet addressed this problem and the NFBG recommends that it
is investigated immediately.
117. In addition, the type of vaccine proposed
for development will be a "sub-unit" vaccine which involves
the use of Genetically Modified Organisms (GMOs). The release
into the environment of GMOs is strictly regulated. In addition,
the vaccine will need to undergo rigorous trials to ensure it
is not pathogenic to other wildlife, livestock and domestic animals.
118. Resources directed to vaccine development
119. The Krebs Report was critical of how
few resources have been directed into vaccine research by the
UK Government. Only £429,000 was allocated to vaccine research
in 1997-98 out of a total TB budget of £16 million for TB
control and £1.7 million for research.
120. The Krebs Report went on to state that
"a vaccine for field trials could be available within 10
years... However achieving this timetable will require considerably
more resources than the £0.4m a year currently spent by MAFF"
(7.10.5). The latest Government figures state that £1 million
per year will be spent on vaccine development, from 1999. The
NFBG would therefore respectfully request that Professor Krebs
is asked whether this sum is sufficient.
121. Biological control (7.11 and 6.5)
122. We regret that the Government has not
announced a research programme into "techniques for reducing
TB infection in badgers through biological control, for example
using bacteriophages to destroyM. bovis in the environment",
as recommended by the Krebs Report.
123. Data availability (7.12)
124. The NFBG endorses the recommendation
that the Government should make a clear commitment to make data
available at the earliest opportunity. However, it is important
that balanced data sets are made available rather than just those
which focus on badgers.
125. Research (7.13 and 1.7)
126. It is not clear what proportion of
the research recommended by the Krebs Report has been contracted
out. We understand that not all of the Krebs Report recommended
research programme is being implemented and details about issued
contracts have not yet been released. We regret that the Government
and MAFF can find the time to publicise and implement the badger
culling trial, yet it has so far been unable to publicise and
implement the research which should be undertaken in other areas.
This bias is unacceptable.
127. Imbalance in allocation of resources
(7.13.2).
128. Krebs notes that more than nine times
as much money is spent on TB control (£16 million per year)
as is spent on TB research (£1.7 million per year) in Great
Britain. There remains an imbalance in the allocation of resources.
A major proportion of the TB budget is still being directed towards
badger control (the culling trial) and testing. In 1999-2000 the
total budget for TB control will increase from £16 million
to £23 million. In contrast, the research budget has been
increased from £1.7 million to £3 million. Thus, almost
eight times as much money is being spent on TB control as on TB
research.
129. The NFBG believes that considerably
more resources should be directed towards research. Moreover,
research should be focused on areas in addition to badgers. Unless
this is implemented rapidly, no scientifically robust information
on which to base publicly acceptable policies for the effective
control of TB in cattle will be available.
130. The NFBG respectfully suggests that
the Government is asked why significantly greater resources are
being directed towards TB control rather than TB research.
131. Contributions from the farming
industry (7.13.2)
132. In contrast to Britain, the New Zealand
farming industry pays a levy which is directed towards TB control
and research. It is not known whether the British Government has
considered asking the industry to contribute financially, despite
this being recommended in the Krebs Report. The NFBG believes
that the farming industry should be expected to contribute towards
the cost of controlling and understanding TB in cattle.