Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by Dr Elaine King, National Federation of Badger Groups (J13) (continued)

100.  Staggering of the test date of herds within a parish (G)

  101.  In 1993, the TB testing frequency for most of Great Britain was reduced from three to four yearly. To ensure that some herds in each parish were tested each year, the changes were phased but MAFF admits that, ". . . in some cases there would be no TB testing within a particular locality for up to three years" (TB Forum 1999c).

  102.  MAFF even admits, "This would be of particular concern in areas which have become new foci of infection". TB Forum (1999c). The NFBG believes that there may be far worse implications for the potentially large numbers of cattle remaining undetected in high incidence TB areas.

  103.  Despite these admissions, this appalling situation has remained the same for the past seven years.

  104.  The proposal to remedy this situation is another high cost proposal from MAFF (an estimated £540,000-£1.2 million to bring herd tests forward) and funding has not been secured. The NFBG has recommended that this be a high priority for funding.

105.  Pilot trial of the gamma interferon test (H)

  106.  The Government is currently investigating the gamma interferon blood test as a potentially more reliable test than the tuberculin test. Although the test produces a higher number of false positives than the tuberculin skin test, it is the more sensitive test, and is able to detect some infected cattle which are missed by the tuberculin test.

  107.  The study is another of MAFF's proposals with "significant resource implications" and is endorsed by the NFBG, which is a member of the Forum sub-group involved with investigating the test.

  108.  However, the NFBG is concerned that the pilot trial may repeat similar research on the gamma interferon test, such as that conducted in the US, New Zealand and Australia, which has found that the gamma interferon test is not completely reliable (see Neill et al, 1992; Griffin and De Lisle, 1995; Thoen and Steele, 1995). The NFBG therefore asked MAFF, at a meeting of the gamma interferon sub group, to provide group members with details of published research on the test. MAFF failed to do so.

  109.  The NFBG supports the trial only on the premise that the Government is not "reinventing the wheel" by conducting this pilot trial, when other measures to strengthen testing and movement still require the necessary funding.

  110.  Notwithstanding the point made above, in view of the urgent need for a reliable test for bovine TB in cattle, it is regrettable that the Government is spending only £170,449 each year for three years on developing a new test (MAFF, 2000g). In addition, it is regretable that it has started so late and is only a pilot study, rather than a full-scale trial. The NFBG understands that the one-year pilot trial is estimated by MAFF to cost £100,000 (testing and compensation) and that funding has not yet been secured for a full-scale trial.

  111.  This is in contrast to the badger culling trial which was fast-tracked by the Government and started over two years ago in August 1998. Moreover, no pilot trial was conducted, despite the controversy and the inevitable practical problems which were predicted at the time and which have now become a reality. The Government has committed over £34 million to the culling trial (MAFF, 1999), compared to a fraction of that for the gamma interferon pilot trial, despite the latter presenting a far more likely candidate for being part of a package of measures to control bovine TB in cattle effectively.

112.  Isolation and testing of incoming cattle (I)

  113.  This is a proposal originating from the British Cattle Veterinary Association (BCVA) and is supported by the NFBG. As the incidence of bovine TB in cattle increases, there is an increased risk of purchasing infected cattle and these proposals specifically aim to reduce the risks to farmers of purchasing infected cattle and to reduce the risks of incoming cattle infecting the existing herd.

  114.  The paper recommends a plan whereby incoming cattle are TB tested and isolated from the existing herd until a clear result is obtained. NFBG has recommended that grants be made available to farmers to help them comply with the isolation requirements, such as improving existing facilities or building new facilities. However, MAFF officials and Ministers have consistently ignored these proposals.

  115.  MAFF has estimated the cost to have "significant resource implications" (£250,000-£300,000 per year) but has still not made the funding available. It has also failed to explain how the estimate of cost was obtained.

116.  Conclusion on proposals to strengthen cattle testing and controls

  117.  The NFBG is particularly concerned that the Government emphasises its commitment to improved testing and movement controls, but has still not implemented the major measures discussed above. In particular, the NFBG believes that the following measures should be approved, funded and implemented immediately: more frequent testing in low TB incidence areas following a confirmed TB incident (F); staggering of the test date of herds within a parish (G) and isolating and testing incoming cattle (I).

  118.  The NFBG proposal not recommended by the Government, to conduct more frequent testing in high TB incidence areas, should also be implemented immediately.

  119.  The four measures above represent essential elements of a disease control package and, despite support from most Forum members, the Government has taken no action but to create further delays by repeatedly referring back to the TB Forum, even after comments have been submitted.

  120.  We are concerned that the lack of funds means the Government is forcing the TB Forum to choose between control measures, all of which are vital in reducing the spread of bovine TB in cattle. We are also concerned that funding has still not been allocated to implement these vital disease control measures.

  121.  The NFBG would invite the Agriculture Committee to ask the Minister when these vital control measures will be implemented.

122.  Evidence of MAFF delays

  123.  The Government appears to be unacceptably delaying the implementation of control measures. For example, in September 1999, at the first Forum meeting, MAFF described Point 4 of the five-point plan, the "Prevention of cattle to cattle spread", as the "main plank" of the strategy. MAFF goes on to state that " . . . existing testing, slaughter and movement restriction arrangements continue, at a cost of around £17 million in 1998 . . . Possible strengthening of these arrangements under consideration (sic)". (TB Forum, 1999d.)

  124.  Since that time, little progress has been made by the Government. In March 2000, at the third TB Forum meeting "MAFF pointed out that implementation of the package was subject to Ministerial agreement and to the availability of resources". (TB Forum, 2000h.)

  125.  Over one year later, at the TB Forum meeting on 19 October 2000, the NFBG asked MAFF what funding will be available to implement these control measures and when it would be available. MAFF explained that it would know how much money the department has to spend in January/February 2001, but then there will be competition for the money from other departments and Ministers must decide on how it is spent.

  126.  There is therefore still no guarantee of obtaining the necessary funding to implement these vital measures, despite first being proposed to the TB Forum over a year ago and despite the NFBG and others having made these recommendations long before that. In contrast, over £34 million has been committed to the culling trial, which started over two years ago.

127.  Additional testing and movement control measures which are not being considered by Government

  128.  The NFBG has proposed control measures to the Government which are important measures to control bovine TB in cattle. However, the Government has not taken any positive action on the following points.

129.  No routine testing of cattle

  130.  In its report to the Agriculture Committee in January 1999 (NFBG, 1999) , the NFBG expressed its concern over the fact that some cattle are never TB tested. This often occurs when cattle are sold prior to a routine TB test. The loophole in the testing system has been admitted by MAFF, "The tuberculin test is normally used as a herd test, so the movement of individual animals are not normally relevant for this purpose. For various reasons, some cattle are never tested for TB" (statement from MAFF press office, dated 10 September 1998).

  131.  The NFBG has urged the government to ensure all cattle are routinely TB tested but the loophole remains. Indeed, the situation is likely to have worsened in recent months, as more farmers give up farming and sell entire herds at one time.

132.  No pre-movement testing

  133.  The proposal to test cattle herds prior to dispersal was proposed by MAFF in the TB Forum paper TBF3/revised (TB Forum, 1999c) and was endorsed by the NFBG and others. However, the proposal was dropped due to opposition from farmers and vets. The weaker system in place is "buyer beware" where the onus is on purchasers to check the disease status of cattle (which is not always possible) and to isolate and test incoming cattle themselves.

  134.  The NFBG is concerned that current advice to farmers considering a whole herd dispersal sale is to sell before a routine TB test is due, in case bovine TB is found in the herd. If this were to be the case, the value of the herd would be reduced and it would be placed under costly movement restrictions. In 1999, an article in Farmers Weekly recommended that farmers sell before a TB test, in case a positive test resulted in devaluation of the herd.

  135.  This advice was confirmed at a meeting of the TB Forum on 19 October 2000, where one of the veterinary representatives admitted that many vets advise farmers to sell cattle once they receive their TB test dates, particularly if TB movement restrictions would result in cattle needing to be housed, which is costly. The vet admitted that, "financial advice is counterproductive to disease control advice".

  136.  The NFBG believes that all cattle should be TB tested prior to movement and/or sale, particularly entire herd dispersals. This used to be the case in Ireland until 1998, after which the incidence of bovine TB in cattle increased dramatically. We urge the Agriculture Committee to ask the Minister to insist that this vital control measure is considered as part of the Government's strategy to strengthen testing controls.

137.  Hired bulls spread bovine TB

  138.  Hired bulls are not always TB tested as they are rarely "at home". Forum members at the Husbandry sub group meeting in September 2000 raised this issue. Concern was expressed at the potential of hired bulls to be sources of TB spread between herds. MAFF admitted that no provision is made to ensure that hired bulls are tested regularly and MAFF officials undertook to investigate closing this loophole.

  139.  The NFBG would urge the Agriculture Committee to ask the Minister when this loophole will be closed, to ensure all hired bulls are tested routinely.

140.  Tuberculin skin test is unreliable

  141.  The current comparative intradermal tuberculin skin test, used in Britain to detect bovine TB in cattle, is the only test recognised by the EU. The test has been effective in virtually eradicating bovine TB from most countries in the world but has been ineffective in reducing the disease in parts of Britain.

  142.  One of the shortcomings of the test is that its sensitivity can be as low as 68 per cent, resulting in 30 per cent of infected animals passing the test undetected. At best, assuming a sensitivity of 91 per cent, almost one in 10 infected animals will pass a test undetected (Phillips et al, 2000). The result is false positives, but more significantly in terms of disease control, the test produces false negatives. Other problems with the test include the fact that it relies on the subjective interpretation of a skin reaction by a veterinary surgeon.

  143.  When infected cattle are missed by the tuberculin skin test, no movement restrictions are imposed and the animal will remain in the herd to infect other cattle, cattle in contiguous herds and cattle in a new herd if sold or moved without a pre-movement TB test.

  144.  It is therefore vital that an improved test for bovine TB is developed and, in the meantime, all herds in endemic TB areas are placed on annual testing regimes.

145.  The movement of cattle from endemic TB areas to the rest of Britain is not restricted

  146.  The obvious result of the tuberculin test missing infected cattle, and of the fact that some cattle are never TB tested, is that infected cattle remain undetected and likely to spread infection into new herds. Undetected infected cattle may be the cause of the spread of bovine TB into cattle in new areas of Britain, in addition to presenting a disease risk to domestic animals, livestock and wildlife.

  147.  The NFBG believes that the risk of undetected cattle spreading TB into new areas should not be under estimated. Indeed, bovine TB still affects less than 1 per cent of the national herd and most parts of Britain do not have TB in either badgers or cattle. It would be a tragedy if bovine TB were to be spread to new areas of the country simply because the Government has not imposed strict controls on the testing and movement of cattle.

  148.  The NFBG has long recommended that the Government prohibits the sale or movement of cattle from endemic TB areas to "clean" areas. Despite evidence that movement bans do protect TB-free areas, the Government has taken no action and cattle movements continue at an alarming rate.

  149.  Indeed, the report of the Husbandry Panel (Phillips et al, 2000) states that, in the absence of a wildlife reservoir, most transmission of bovine TB in cattle in Britain is thought to derive from cattle movement. Indeed, 15 per cent of outbreaks in the southwest region of Britain are attributed to cattle movement and the report states that it is higher outside this area.

  150.  However, while the impression is given that wildlife are the main cause of infection in cattle in the south-west of Britain, the report concludes that the "localised occurrences of the problem in disparate regions", suggests "the involvement of cattle movement . . . rather than gradual spread through a wildlife vector" (Phillips et al, 2000). This observation is not surprising, as it is cattle, not badgers or other wildlife, which travel large distances across the country.

  151.  The report also cites evidence from Italy, that imported infected cattle can maintain the disease in the absence of a wildlife vector. This may occur in the UK, where TB infection persists in cattle, while not existing in the local wildlife population. Indeed, in these circumstances, infected cattle may infect local domestic animals, livestock and wildlife.


  153.  The NFBG believes that the development of a cattle vaccine must be part of a strategy to control bovine TB in cattle. However, in view of the numerous obstacles in the path of developing an effective vaccine, delivering it to cattle and obtaining approval from the EU, the NFBG believes that it should not be considered a panacea.

  154.  The NFBG is also mindful that 10 to 15 years ago, the Government claimed that a vaccine would be available in 10 to 15 years time. But a vaccine is not available and the Government is saying that it may require another 10 to 15 years. When an effective vaccine has still not been developed for human tuberculosis, it appears unlikely that one for bovine tuberculosis will be available soon, when far fewer resources are available for the latter. Government figures show that only £6.5 million over five years is being directed towards developing a bovine TB vaccine (TB Forum, 1999d).

  155.  The NFBG supports the recommendation in the Krebs report that a badger vaccine continues to be developed alongside a cattle vaccine, as the early stages in the development of the two vaccines will be very similar. However, we believe that there are serious practical and ethical issues to be overcome before a vaccine can be used for badgers. These concerns are outlined in answer to a supplementary question provided to the Agriculture Committee in March 1999.

  156.  In its report on this issue (HMSO, 1999) the Agriculture Committee recommended that the Government should keep the EC informed of developments in this field. It is not clear whether or not MAFF has yet made contact with the EC on this issue.


  158.  The NFBG regrets the persistent Government focus on badgers in its funding of TB research.

  159.  The Government has stated that the trial would cost £34.3 million over five years (MAFF, 1999). More recent figures show slightly lower figures, but this is likely to be due to delays, resulting in the trial taking at least seven or eight years, instead of the five proposed by the Krebs report.

  160.  The trial is still by far the single most expensive part of the Government's "Five Part Strategy", despite being listed as number five. Recent Government figures show that badger-related projects, including the trial, still amount to almost £44 million over five years, compared to a total research budget of £55.2 million (DETR, 2000). This amounts to almost 80 per cent of the entire TB research budget. Put another way, the trial is expected to cost over £34.3 million over five years, compared to only £20.9 million being spent on all other TB research during that period (DETR, 2000).

  161.  The NFBG welcomes the additional research initiatives recommended by the ISG and which go further than those in the Krebs report. In particular, we believe that research into the transmission, pathogenesis and immunology of M. bovis in cattle will provide information essential if the disease in cattle is to be understood and controlled effectively. However, the NFBG regrets that these projects were delayed in starting and that some have still not commenced.

  162.  There is a very real danger in the Government relying so heavily on the trial to provide a solution to the TB problem. When, as we expect, the current Krebs' experiment finds that badger culling is not humane, efficient, economically-viable, publicly-acceptable or practical, Ministers will have no alternative, considered strategy for the management of bovine TB in cattle. This will be catastrophic for farmers and for badgers.

  163.  The NFBG would urge the Agriculture Committee to satisfy itself that the Government is directing sufficient funds into alternative measures which will provide a real an lasting solution for farmers, but which will also be humane for livestock, caring for wildlife and acceptable to the public.


  165.  Despite the Government's protestations to the contrary, it is clear that the badger culling trial is the main priority in the Government's "five-point strategy". Even though the trial started late in terms of the Krebs report's recommendations, the trial still started long before most other research started. The trial has also been provided with funding at the expense of other, deserving research. Indeed the trial commenced before much of the other research had even been conceived. It is clear that, over the past two and a half years, the Government has prioritised its resources (funding and staff) into the trial.

  166.  Here we demonstrate that the trial is wasting valuable resources, that the science is fundamentally flawed, that the trial is proving practically difficult to conduct properly that the trial seriously compromises animal welfare.

167.  Wasting money

  168.  In addition to fast-tracking the trial, the Government has repeatedly confirmed that money would be made available for the trial. At the same time, it claims that vital measures such as strengthening the testing and movement controls on cattle may not be implemented due to the lack of available funds.

  169.  The NFBG believes that the cost of the trial is escalating due to circumstances which have arisen during the course of the trial. These circumstances include the extra costs of complying with the Health and Safety Executive prohibition order, freezing and storing badger carcasses before the HSE requirements were met and additional training for staff after the BBC filmed operatives not killing badgers humanely.

  170.  We urge the Agriculture Committee to request information on the exact costs and to seek confirmation that these will not compromise other, valuable research.

  171.  A number of vital measures to strengthen testing and movement of cattle still require funding. Using the Government's own figures, the annual cost would be £1.6 million to £2.4 million. This could be funded easily by money currently being wasted on the trial and is likely to significantly reduce the incidence of bovine TB in cattle.

172.  Wasting police resources

  173.  We invite the Agriculture Committee to establish what additional burden the trial is imposing on already stretched rural police forces. We understand from a variety of sources that MAFF has:

    (1) made arrangements for police support only to let the service down, literally at the last minute;

    (2) started a culling operation without providing the police with adequate advance notice; and

    (3) conducted surveys without notifying the police that staff are likely to be found wandering private land at all hours of the day and night.

  174.  For example, MAFF appears to be failing to communicate with the police at the highest level. The NFBG understands that the Staffordshire Police were concerned about legal aspects of the trial and met with MAFF officials in London. We understand that the police intended to seek legal advice before allocating MAFF police for the trial on Staffordshire. However, we understand that MAFF started working in Staffordshire in early October 2000, before the police had resolved its concerns.

  175.  In addition, the NFBG understands that, in May 2000, MAFF met with officers from the Devon and Cornwall Constabulary to discuss the policing of the trial. The police expressed concern at the request to provide officers during the summer months, when police resources are already stretched due to the influx of tourists. MAFF was, apparently, determined to carry out the trial during the summer months, regardless of concerns raised by the police.

  176.  At MAFF's request, the police therefore arranged for CID and Special Branch to be available in the first weeks of May, when badger culling was due to take place in Cornwall. However, the NFBG understands that one week prior to the scheduled start of the culling, MAFF informed the Devon and Cornwall Constabulary that it had completed survey work for only 75 per cent of the area and it instead started killing in Wiltshire in early May. This wasted valuable police time and resources.

  177.  The NFBG would invite the Agriculture Committee to seek information on the cost of policing the trial and to question whether MAFF is managing the trial properly and informing all the relevant authorities.

178.  Flawed science

179.  Access to land

180.  Before the trial started, the NFBG warned that landowners denying access to their land would undermine the trial. We believe this has become one of many serious flaws associated with the trial.

  181.  The Government cannot compulsorily gain access to land in order to kill badgers. The Wildlife Trusts, the Woodland Trust, the RSPB and other nature conservation organisations have not allowed culling (or surveying) on their reserves. Neither too has the Countryside Council for Wales. The NFBG has also been contacted by a large number of private landowners who have denied MAFF access to their land.

  182.  The NFBG would like to draw a worrying trend to the Committee's attention. A number of landowners have contacted the NFBG for more information on the trial and have complained of intimidating behaviour by MAFF officials, when seeking approval for the trial. Individuals have felt pressurised to comply and have complained at the lack of information provided to them by MAFF staff. In some cases, MAFF has arrived on their property with vans containing cage traps, expected to set them on the land, without having first sought permission. MAFF officials have also not made it clear to landowners that participation in the trial is voluntary—this is one of the reasons why many people have sought advice and information from the NFBG.

  183.  The NFBG has also received reports from farmers and landowners, that do not support the trial, and have been subject to intimidation by other farmers.

  184.  We regret that the Government is keen to point out that the trial has received an "average of 80 per cent support . . ." (MAFF, 2000c), but is less keen to tell us what percentage of the land area is available for culling, or, for that matter, what is meant exactly by "support" of the trial. Figures could be provided easily without revealing personal details of landowners and the NFBG can see no reason why the information cannot be made available.

  185.  Ministers are also keen to give the impression that rural communities support the trial. We understand that the Government will be commissioning further public attitude surveys from the University of York to back up this claim. However, we believe the pilot research was seriously flawed. The surveyors found that the public were more inclined to support the cull when told of the growing threat of bovine TB, the risk to people and the primary role played by badgers in the transmission of the disease. But the survey failed to explain how low the health risks are likely to be, that the role of the badger has never been proven or—most importantly—that there may be alternative, wildlife-friendly solutions to solving the problem.

  186.  We are pleased to see that rural communities who are fully informed of the issues are often inclined to reject badger culling. For example, Penwith District Council, in Cornwall, recently voted to oppose the trial. We also hear on good authority that while many farmers are allowing the surveying of their land for badgers, they are refusing to allow culling to go ahead.

  187.  It is not at all clear that MAFF operatives are able to access a statistically robust proportion of the culling area. In addition, we have been unable to ascertain how the trial is to take statistical account of insufficient compliance from landowners.

188.  Illegal killing of badgers by farmers and landowners

  189.  The NFBG has repeatedly warned that one of the major factors likely to undermine the trial is the killing of badgers illegally by farmers and landowners in trial areas. The illegal killing of badgers in the "no cull" areas of the trial will result in there being no scientific controls, which are needed to validate the trial.

  190.  Illegal killing of badgers in trial areas is rife and the number of reported incidents is increasing.

  191.  The NFBG has evidence that farmers, especially those in the TB areas, have been killing badgers illegally for some time. Evidence comes from MAFF reports, press reports, badger groups, the police and conversations with farmers in the TB areas. For example, when invited to speak at a meeting of farmers in Staffordshire, a farmer informed the NFBG that he, and others, had killed all the badgers on their land. This was admitted to the full meeting and in the presence of the local MAFF officials. Other farmers have made similar admissions at meetings with Ministers when the NFBG has also been present, but the Government has taken no action.

  192.  More recently, the NFBG has received reports of farmers shooting badgers at night, using poison mixed in food put out for badgers, pumping slurry into setts and bulldozing active setts containing badgers. In one area of Staffordshire, a landowner informed the NFBG that a MAFF official surveyed his land for badgers and expressed concern at the lack of badger activity at setts on his land, and suggested that this was a result of foul play.

  193.  Farmers have also informed the police that they are killing badgers. A Police Wildlife Liaison Officer who attended the Royal Show this year, expressed concern to the NFBG at the large number of farmers who admitted to him that they kill badgers on their land. They even gave examples of their methods.

  194.  Despite evidence that badgers are being killed illegally, the Government appears not to be taking this issue seriously. The Government is, apparently, carrying out, unannounced, walkover spot-checks of only 10 per cent of known setts in trial areas—but only in "survey only" areas. However, farmers themselves have admitted to the NFBG that most methods used to kill badgers leave no outward signs. Such methods include poisoning and shooting.

  195.  The Government has still not explained how the extent of illegal killing will be assessed properly and built into the statistical analysis of the trial.

  196.  The NFBG would urge the Agriculture Committee to press the Government and the ISG on how this problem is being addressed.

197.  Direct interference with trapping operations

  198.  The NFBG predicted that local opposition to the trial would result in badgers being released from traps and traps being destroyed and/or removed. The NFBG does not support or condone any action which is illegal, but nevertheless believes that this kind of action is undermining the trial.

  199.  The NFBG has asked the ISG how it will account for this action in the statistical analysis of the results, but it has persistently refused to provide an explanation.

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