Memorandum submitted by the RSPCA (J3)
1. The RSPCA welcomes the Committee's continuing
interest in the problems regarding bovine tuberculosis and its
monitoring of the progress in implementing the Krebs report. For
the purposes of this brief submission we will focus on some aspects
that cause concern. Paragraph references refer to the recommendations
in paragraph 131 of the Committee's report (HC 233).
2. Responding to the concerns expressed
by the RSPCA, and others, the Committee recommended that the number
and age of cubs and lactating sows caught after the close season
be monitored. The Government accepted this and said the relevant
data were being collected.
3. The second report of the Independent
Scientific Group (ISG) points out (paragraph 4.2.7) that the closed
season was selected on the basis of the experience that once cubs
are old enough to appear above ground regularly they could be
easily caught and despatched humanely. However, there were claims
that this summer badger cubs had been left to starve after MAFF
operatives removed the sows but not some of their cubs. Data has
not been forthcoming from MAFF that would clarify the extent to
which this may have occurred. However, according to published
data from the North Wiltshire proactive triplet, 602 badgers were
caught when operations resumed and, of these, 35 were lactating
females (House of Commons Written Answer, 12 June 2000, col 457W).
Therefore, the question and concern is how successful were the
operatives in catching the associated cubs?
4. We note that in their report the ISG
appear sensitive to this concern. In paragraph 4.2.7 they refer
to their recommendations to MAFF that in May and June working
practices for reactive culling operations should include continuous
trapping over weekends to avoid cubs being left unattended if
their mothers were captured late in the week.
5. The Committee made a recommendation regarding
publication by MAFF of how the requirements of the monitoring
processes were met. In their response the Government set out the
arrangements for internal and external auditing. The ISG's second
report, published in December 1999, stated (paragraph 4.8.5) that
both external auditors had submitted interim reports. Presumably
the ISG and MAFF have taken account of whatever information was
in the reports. However, their contents have not been made public.
The RSPCA's concern therefore is that, to date, the reports of
the two external auditors covering (i) humaneness aspects and
(ii) the effectiveness of surveying, social group delineation
and culling, have not been published and therefore the results
of this independent scrutiny are not available. Unfortunately,
in our view, this delay somewhat negates the potential value of
such auditing arrangements.
6. Responding to a Parliamentary Question
regarding the auditors report, assessing the effectiveness of
the surveying, social group delineation and badger culling, Ms
Quin stated that they intended to publish the report, together
with the Government's response as soon as possible after the final
report is received from the independent auditor. (House of Commons
Written Answer, 12 June 2000, col 458W) "On current expectations,
this will be during the summer". Although "summer"
was a rather indeterminate timetable it has now passed with still
no public sign of either of the reports.
7. The Committee made a number of recommendations
regarding farm husbandry. Since then action has been taken on
various aspects including the fast track review of the available
scientific evidence on husbandry by a panel under the chairmanship
of Dr Phillips. A concern expressed by the RSPCA, and reiterated
in the report of the husbandry panel (Section 9), is that there
is a need for monitoring the effectiveness of the current guidelines
to farmers otherwise their purpose remains equivocal and their
effectiveness in doubt. There is, at present, no way of assessing
the extent to which guidance is being implemented. Whilst it is
possible that analysis of the TB99 questionnaire may provide some
clarification on this point the RSPCA believes that a more effective
method of monitoring is needed.
8. In their second report (paragraph 8.2.11)
the ISG anticipated that the first analyses of the existing TB
data set should be complete by the end of 2000. They expressed
the view that this should then help inform the Government's efforts
to strengthen existing TB controls and to advise the farming community
on appropriate husbandry practices. The Committee may wish to
enquire whether this aspect of the work is on target and whether
it is likely to fulfil the expectations expressed for it.
9. The report of the husbandry panel is,
at present, still under consideration by MAFF and the TB Forum
so the outcome of the work is unknown.
10. The Committee recommended that no action
be taken regarding culling badgers outside the trial areas. The
ISG counselled against any such culling and their detailed advice
to ministers was contained in their second report. Notwithstanding
this, the RSPCA was therefore very concerned that, at one stage
in the year, a subgroup of the TB Forum was considering proposals
to kill badgers outside the trial areas. The Society believes
that the ISG's advice on this aspect is still very pertinent and
that culling badgers outside the trial areas would have profound
implications for the trial itself as well as the programme of
work developed by the ISG. We believe that in such areas action
should focus on other aspects and we welcome the fact that the
husbandry and biosecurity subgroup of the TB Forum is now focusing
its efforts on husbandry aspects.
3 October 2000