Memorandum submitted by the National Federation
of Badger Groups (P29b)
CONTROLLING BOVINE TUBERCULOSIS IN CATTLE
(A more detailed and fully referenced
version of this report is available on the NFBG website at www.badger.org.uk)
1. EXECUTIVE
SUMMARY
2. In the wake of foot and mouth disease
(FMD) both Government and the public are acutely aware of many
farmers' resistance to taking steps to improving herd health and
biosecurity.
3. DEFRA remains dogmatic about the role
of badgers in the transmission of bovine TB, even though substantial
evidence from its own Independent Scientific Group (ISG) confirms
that cattle to cattle transmission is of major importance.
4. Between September 2001 and February 2002,
DEFRA allowed hundreds, if not thousands, of TB infected cattle
to be sold and moved around the country without being TB tested
first.
5. Since February 2002, DEFRA has failed
to clear the existing backlog of TB tests ands it has failed to
tighten the TB testing regime sufficiently to identify new TB
hotspots and bring the disease under control.
6. Infectious animals may never be detected
before they have transmitted the disease to many other cattle.
7. The current rise in TB incidence is rather
like the spread of FMD in slow motion. DEFRA's incompetence, farming
unions' intransigence and a lack of political will exacerbate
the problem.
8. DEFRA is ignoring the advice of stakeholders
other than the farming unions.
9. DEFRA is unable to manage a holistic
programme of scientific research. Policy decisions are made not
on the basis of sound science, but in order to appease the farming
unions.
10. DEFRA has failed to implement research
into the gamma interferon test in a scientifically robust manner.
11. There is no independent assessment of
the implementation of the Krebs' trial.
12. DEFRA has failed to properly implement
the badger road traffic accident survey, a more detailed study
of cattle husbandry issues, a statistically valid TB99 questionnaire,
reliable TB test data for cattle being sold, or even a holistic
research programme into cattle-based TB control measures.
13. DEFRA is not transparent and proactively
works to conceal vital information.
14. The NFBG expects the number of TB outbreaks
to continue to rise over at least the next two to three years.
15. Scientific research is predominantly
focussed on badgers and research into cattle-based TB control
measures is not adequately prioritised, sufficiently well funded
or being implemented with any sense of urgency.
16. The NFBG expects results from the Krebs
trial to be available before cattle-focussed research. We expect
that badger culling will not prove to be effective, economically-viable,
publicly-acceptable or practical. Ministers will be left with
insufficient evidence on which to formulate a "Plan B".
17. The NFBG expects small and family farmers
to be hardest hit by continued TB outbreaks, with Government and
the farming unions doing little to help their situation.
18. REVIEW OF
RECENT DEVELOPMENTS
IN THE
GOVERNMENT'S
TB CONTROL STRATEGY
19. The NFBG welcomes the Committee's new
inquiry. However, we regret the title of the inquiry which continues
to focus attention on badgers at the expense of a more holistic
approach to controlling bovine TB in cattle.
20. Following the Committee's last report
there has been a large shift in the public perception of, and
the Government's idealised approach to, dealing with farm animal
diseases. The primary motivator for this change was the foot and
mouth (FMD) outbreak in 2001. This clearly underlined the farming
industry's extraordinary resistance to taking responsibility for
biosecurity.
21. In the wake of the foot and mouth crisis,
the NFBG warned that TB would spread and increase in the national
herd as farmers restocked with cattle purchased from TB hotspots.
We asked then that the Government tighten movement restrictions
on cattle in TB hotspots.
22. The Government failed to act and, in
September 2001, started to allow the licensed movements of livestock.
Four months later the Government imposed movement restrictions
on only 1.5% of herds, leaving other at-risk herds free to be
moved countrywide.
23. There is now evidence that bovine TB
has been introduced into counties previously unaffected by the
disease.
24. The NFU has made little effort to encourage
its members not to restock from TB hotspots. The unions even had
the gall to blame badgers for the rise in TB, which was clearly
the result of the Government's failure to restrict cattle movements.
25. In 1996, Professor Sir John Krebs stated
that, "It is essential that the industry recognises the role
husbandry may have to play and that they fully take ownership
of the issue."
26. The consequences of the foot and mouth
catastrophe have been played out against a backdrop of other failures
in policy implementation and stakeholder negotiations.
27. INEFFECTIVE
TB FORUM
28. The TB Forum has not been effective
in advising Ministers on the full range of views as to how bovine
TB should be addressed.
29. The Government now appears to be to
circumnavigating the TB Forum altogether. In November 2002, it
announced that it had formed a separate "industry group"
without consulting the TB Forum. The rationale for this decision
and the role of the TB Forum is now unclear.
30. THE OBSESSION
WITH BADGERS
31. The Government's research programme
has seen the publication of a number of papers and reports focussing
on badgers, whilst research on alternative TB control strategies
remains unpublished.
32. Other research of far greater significance,
such as a project on the development of TB hotspots through cattle,
is still not published or publicly available.
33. We respectfully urge the Committee to
consider the process by which DEFRA-funded research is commissioned
and published, and the agreements on publication, if any, that
are set up between DEFRA and its contractors.
34. Failings in DEFRA's TB research strategy
35. DEFRA clearly has no grip on its research
programme into bovine TB. In July 2001, the NFBG requested a comprehensive
list of the Government's research projects into bovine TB. We
wanted to ensure that research was being undertaken to support
a "Plan B".
36. Eighteen months later, we still do not
have a comprehensive list of the current research programme.
37. We wonder how the Minister can be aware
of the cost and direction of the current programme when a comprehensive
list of current research cannot be compiled.
38. DEFRA also does not appear to have a
grip on research that has been completed. Eight months ago, the
NFBG asked DEFRA for the results of eleven research projects completed
since 2000. But DEFRA has been unable to provide us with the results
of this research, allegedly because of an "intermittent IT
problem".
39. How can the Minister assess the results
of research and consider policy options when his officials appear
incapable of locating the information?
40. The NFBG respectfully urges the Committee
to ask DEFRA when it will publish full details of current and
completed research, including the results and raw data of completed
work. After all, the research is being funded with public money.
41. THE IMPACT
OF THE
GOVERNMENT'S
AUTUMN PACKAGE
OF MEASURES
42. We believe that this package of measures
will not help to slow the spread of TB and may make it worse.
The TB Forum had been consulted about tightening cattle movements
and it was clear in its support for tighter, rather than weaker
movement restrictions.
43. LICENSED
MOVEMENT OFF
FARMS OF
NON-REACTOR
CATTLE
44. This measure will not improve the control
of TB in cattle and may even make it worse.
45. The licensed movement of cattle off
farms is clearly designed to ease the effect of movement restrictions
on farmers' businesses, and not to control the spread of bovine
TB.
46. The TB Forum was not consulted over
this proposal which was simply presented as a fait accompli at
the tenth TB Forum meeting on 10 October 2002.
47. IMPOSITION
OF MOVEMENT
RESTRICTIONS ON
HERDS WITH
OVERDUE TESTS
48. This measure is too little, too late.
49. In 2001, the NFBG warned that allowing
the movement of cattle with overdue TB tests would have a disastrous
effect on farmers and spread the disease countrywide.
50. On 31 January 2002 the Government announced
limited movement restrictions that applied only to the 1.5 per
cent of herds tested annually for bovine TB. DEFRA also already
knew that high numbers of reactor cattle were being found in some
of the remaining 98.5% of herds.
51. Of the 1.5% of herds mentioned above,
20% (166) were found to be infected with TB. Hence, DEFRA allowed
thousands of infected cattle to be moved all over the country
during the surge of post-FMD restocking.
52. Bovine TB spread to new areas of the
country. Many of these new cases have been linked to the purchase
of infected cattle from TB hotspots.
53. The NFBG also urged the Government to
extend the annual test countrywide and place movement restrictions
on all cattle with overdue tests. The Government failed to act,
claiming that, "more severe restrictions would not be proportionate
to the risk".
54. The NFBG respectfully suggests that
the Committee asks DEFRA to justify this statement. For example,
did it conduct a risk assessment and/or a cost-benefit analysis?
55. The reason for the failure to apply
rigorous movement restrictions was DEFRA's inability to clear
the backlog of overdue tests. DEFRA admits that the backlog of
tests peaked at 27,000 herds. DEFRA does not expect the backlog
to be cleared until summer 2003.
56. The continued failure of DEFRA to clear
the backlog of TB tests is likely to have devastating effects
on many farmers who will have undisclosed infected animals in
their herds.
57. GAMMA INTERFERON
PILOT PROJECT
58. In its current form, the gamma interferon
project is unlikely to assist in controlling bovine TB in cattle.
59. The NFBG recognises that the current
tuberculin skin test is unreliable and we support measures to
develop an improved test.
60. In 2000, the Government started a pilot
trial to examine the cost effectiveness of using the gamma interferon
blood test in herds with multiple reactors. The research indicated
that: it is practical to carry out the test in Britain; the test
detects infected cattle missed by the tuberculin skin test; and
it is able to detect those cattle earlier than the tuberculin
test.
61. The researchers recommended that further
work be carried out to improve the sensitivity and specificity
of the test and to conduct a cost-benefit analysis. But the ISG
has expressed concern that the new DEFRA-designed trial will not
have scientific rigour; will not maximise the scientific data
gathered; will not answer key questions; and, will not allow Ministers
to consider a range of options for future TB policy.
62. DEFRA appears to be incapable of implementing
rigorous research and we fear that this will be another lost opportunity
for TB control.
63. INDUSTRY
GROUP
64. We regret the establishment of the industry
group without prior consultation with the TB Forum. It is the
industry which has consistently opposed and weakened cattle-focussed
TB control measures.
65. PROGRESS
ON DEVELOPMENT
OF A
VACCINE
66. The NFBG believes that the development
of a cattle vaccine must be part of a strategy to control bovine
TB in cattle. However, it should not be considered a panacea.
67. DEFRA appears to be increasing its focus
on a badger vaccine rather than a cattle vaccine. Progress in
molecular techniques means that a cattle vaccine remains a more
practical option if there is the political will to see it developed
and to have it approved by the EU.
68. IMPLICATIONS
OF DELAYS
TO THE
KREBS TRIAL
69. The FMD crisis resulted in the trial
being suspended for over a year. We are not convinced by the ISG's
reassurances of the consequences. For example, what is the effect
of culling 7% of herds in trial areas, as a result of FMD?
70. We are worried that there is no independent
verification of the work of the ISG when large amounts of public
funds are being invested over a long period of time, in a piece
of scientific research that is supposed to influence all policy
decisions.
71. Many field-based research projects,
unrelated to the Krebs trial, were also suspended due to FMD.
Will DEFRA ensure that this work is completed?
72. Also, will the results of all the non-Krebs
trial research be available for Ministers and others before or
at the same time as the Krebs trial results?
73. THE GOVERNMENT
RESPONSE TO
THE AGRICULTURE
COMMITTEE'S
RECOMMENDATIONS
74. Animal welfare in Krebs trial
75. The NFBG remains concerned over animal
welfare aspects of the trial.
76. The independent welfare auditor raised
a number of concerns and made recommendations to improve animal
welfare in the trial. DEFRA has failed to make information available
on whether it has implemented all the auditor's recommendations.
77. Badger road traffic accident (RTA) survey
78. This survey is a pilot and aims to discover
whether the prevalence of bovine TB in badger populations can
be assessed from examining badger RTAs. DEFRA has finally contracted
the survey to one of its agencies, the Central Science Laboratory,
and results are not expected for some time. This is a cause of
great concern to the ISG.
79. CATTLE HUSBANDRY
80. DEFRA has failed to implement Select
Committee or Husbandry Panel recommendations. Of seven key areas,
one related to badgers and the others were largely cattle-focussed.
The only recommendation to have been implemented fully—and
already published—is the project on badgers.
81. TB99 QUESTIONNAIRE
82. DEFRA has focussed the TB99 questionnaire
on farms with TB outbreaks and has not rigorously applied it on
"control" farms without TB outbreaks. A scientifically
valid comparison between the two types of farm is impossible and
negates the entire purpose of the questionnaire.
83. This situation has not improved, despite
concerns having been raised repeatedly by the ISG. We have concerns
of our own. TB99 is too focussed on badgers and is ridiculously
subjective. One question asks farmers how often they see wildlife
and, if alive, do the animals appear sick. Such muddled research
defies credibility.
84. DEFRA's failure to deliver on this research
betrays a fundamental problem: it is incapable of managing science.
85. TB FORUM
86. The NFBG has played a constructive role
on the Forum, but has become increasingly concerned at its ineffectiveness.
The NFBG has not received any indication from DEFRA that its comments
and ideas are taken into account.
87. For example, on five consultations,
we have received no feedback. Subsequent policy announcements
"produced in consultation with industry group representatives"
have been made without consulting or advising the Forum. It is
clear who DEFRA does and does not listen to.
88. The only area where DEFRA may have taken
Forum members' views into account is on its proposals to improve
cattle control measures. Ironically, none of these have been implemented
due to the FMD outbreak.
89. We are also concerned at the persistent
focus on badgers by DEFRA and other groups on the Forum. Others
have also expressed concern, such as the RSPCA.
90. FREQUENCY
OF CATTLE
TESTING
91. DEFRA has failed to increase cattle
testing frequency. The NFBG believes that DEFRA should increase
test frequencies in both high and low risk areas.
92. TESTING IN
HIGH RISK
AREAS
93. The Government has stated that all herds
in high-risk areas are subject to annual testing. However, a review
of TB testing frequencies and requirements found that, at the
end of 1998, 126 parishes were below the EU minimum standards
for TB testing frequencies, as set out in the relevant EU Directive.
94. In the wake of FMD, many herds on annual
testing may be overdue for a test by up to two years. In addition,
TB outbreaks have been discovered in new areas, many of which
are unlikely to have been on annual testing. It is critical that
DEFRA ensures that the backlog is cleared quickly and that all
high-risk herds are placed on annual testing regimes.
95. TESTING IN
LOW RISK
AREAS
96. Increased monitoring in areas of lower
TB incidence is likely to prevent the local spread of infection
as well its spread to new areas.
97. The Government's plans to increase testing
in certain low risk parishes were delayed in 2001. This means
that the work cannot begin before clearance of the continued testing
backlog, which will be in summer 2003 at the earliest.
98. INFORMATION
ON CATTLE
TEST RESULTS
99. DEFRA has failed to make test data readily
available when cattle are sold. MAFF refused to include TB test
data on cattle passports. DEFRA still has no plans to implement
this measure.
100. DEFRA has introduced a "buyer
beware" system whereby farmers can request the current tuberculin
test report (TB52). It would be interesting to ascertain how many
test reports have been requested as a proportion of livestock
sold on from TB hotspots.
101. The onus is on farmers to isolate any
bought-in cattle, to consider private TB testing for all bought-in
cattle, to arrange pre-movement testing and to buy cattle from
non-TB areas. But there is clear evidence that many farmers do
not take responsibility for disease control.
102. The lack of information about the TB
status of cattle is a serious threat to good farm biosecurity.
103. MORE ACCURATE
TB TEST
104. The Committee has expressed concern
about the lack of progress on developing a more accurate test
for TB in cattle.
105. DEFRA appears to have made little progress
in this area (see 57, above).
106. FUTURE POLICY
OPTIONS
107. The Committee recommended that Ministers
ensure that a "Plan B" is developed in the event that
the Krebs' badger culling trial does not provide clear results.
108. We expect that the Krebs trial will
find badger culling not to be effective, economically viable,
publicly acceptable or practical. It is essential that Ministers
have the research needed to formulate an alternative "Plan
B" for the management of bovine TB in cattle.
109. A major part of this research programme
must be to shift the focus to cattle controls, especially in the
light of increasing evidence that cattle to cattle transmission
is more significant than previously thought.
110. The ISG must be commended for its efforts
to introduce a holistic research programme. However, we regret
the obstructive behaviour by DEFRA officials that we have witnessed
at TB Forum meetings.
111. We are particularly concerned at DEFRA's
persistent focus on badgers and its apparent unwillingness to
resource and support research on cattle-based solutions. Badger-culling
dogma is alive and well at a senior level in DEFRA, and it is
our view that this is slowing progress on developing a truly effective
TB research and control programme.
Dr Elaine King
31 January 2003
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