APPENDIX 21
Memorandum submitted by the RSPCA (P21)
1. INTRODUCTION
1.1 Despite the terms of reference of the
trial and the accompanying work of the TB Forum, the focus of
bTB control still remains largely focused on killing badgers.
This is despite the establishment of the TB Forum and its husbandry
and biosecurity subgroup, the commissioning of a livestock husbandry
report and the release of a number of publications to farmers
relating to herd management and biosecurity measures designed
to help to control the disease.
1.2 There has also been pressure from some
agencies to initiate a culling policy outside of the trial areas.
In its second report to the Minister, the Independent Scientific
Group (ISG) documented in Appendix E, the reasons why pre-emptive
culling outside trial areas would be inconsistent with the objectives
and methodology of the trial programme.
1.3 Recently commissioned DEFRA research
by the Universities of Warwick and Cambridge into the risks of
bovine tuberculosis breakdowns in cattle outside the badger trial
areas concluded that there were six possible reasons why TB could
have spread to these areas. One of these included that there was
evidence but not proof, that wildlife may be acting as a reservoir
host for bovine tuberculosis in these areas. Hence pursuing the
idea of culling outside of trial areas would appear to be an untenable
position, given the evidence.
1.4 There are still fundamental questions
which remain unanswered, for example,
— why one cow in a herd reacts to the
tuberculin test and another does not?
— is the advice given by DEFRA effective?
— has the advice given by DEFRA been
effectively implemented?
— the influence of diseases such as
Bovine Viral Diarrhoea (BVD) on the immune systems of animals
and the implications for them becoming TB reactors;
— why is it that on two adjoining farms,
where the sett spans both farms, one herd will get some reactors
and the other herd will not.
1.5 A contract to formally audit the uptake
of existing TB advice in order to determine the best way of getting
advice across to farmers was put on hold as a result of foot and
mouth disease. It is unclear whether this contract has been carried
out since the end of the foot and mouth outbreak. One criticism
is that farmers cannot afford to wait until the end of the trial
before any action is taken.
1.6 There are however a number of things
which farmers can do before the end of the trial, for example:
— prevent the introduction of disease
onto the farm by purchasing/selecting disease free animals as
much as possible;
— minimising the contact between wildlife
and cattle, for example, by changing grazing patterns;
— ensure that on-farm biosecurity is
given due consideration;
— minimise the contact between cattle
of neighbouring farms.
2. THE IMPACT
OF THE
GOVERNMENT'S
AUTUMN PACKAGE
OF MEASURES
FOR THE
CONTROL OF
BOVINE TB IN
CATTLE ON
THE SPREAD
OF THE
DISEASE AND
ON FARMERS
AND FARMING
2.1 The ability of non-reactor cattle to
move off of farms which would normally be under movement restrictions
has to be welcomed as it has enabled farmers to operate more efficiently
and reduces the risk of cattle to cattle transfer occurring on
that particular farm. However, the relatively poor sensitivity
of the intradermal test means that the risk still remains on the
receiving farm. This coupled with long periods between tests,
could mean that some bTB infected cattle remain undetected.
2.2 There also has to be a planned strategy
for every animal coming onto the farm. This must be made a priority.
This strategy must include isolating the animals and testing and
vaccinating them for a range of diseases. Such a policy should
be a part of a farm specific written animal health plan. On-farm
biosecurity is also important, although there is evidence to suggest
that it is not always given the attention which it deserves.
3. PROGRESS ON
THE DEVELOPMENT
OF A
VACCINE
3.1 The issue of vaccine development is
extremely complex and should not be seen as a short -term remedy
in terms of disease control. However, even though success cannot
be guaranteed in this area of research, it does need to be pursued
as a legitimate policy option. Deciding whether to vaccinate cattle
or wildlife is just one of the factors which has to be taken into
consideration, remembering that a wildlife vaccine will only be
effective if most cattle TB infections are derived from wildlife.
4. THE IMPLICATIONS
OF THE
DELAYS TO
THE KREBS
TRIAL
4.1 Foot and Mouth disease in 2001 has played
a significant role in creating a backlog of herds which have not
been routinely tested for TB. This is particularly serious in
areas which are known to be TB hotspots. The effect of this would
be that as testing has resumed, there has been an increase in
the number of breakdowns, which is not unsurprising. At the 10th
TB Forum in October 2002, Professor Bourne stated that the reactive
element of the trial was being delayed because of the delays in
the TB testing programme and he anticipated that this delay could
not be completely recovered. The proactive culling element of
the trial was going as planned.
4.2 It has been reported at previous Forum
meetings that the TB99 questionnaire work was not being completed
as required, and that it was also necessary to get the Road Traffic
Accident (RTA) survey back on track. Previously, the Independent
Scientific Group (ISG) had highlighted the importance that they
attach to the information on farms with TB breakdown.
4.3 The overall implications of delays in
obtaining data from the various aspects of the trial could lead
to insufficient data to analyse. Having a partial data set may
impinge upon the interpretation of the data.
5. GAMMA INTERFERON
5.1 The RSPCA welcomes the trial of the
Gamma Interferon Test, which has a higher sensitivity and a lower
specificity than the conventional tuberculin test. The RSPCA would
strongly urge the government to use this test in conjunction with
the single intradermal skin test which is estimated to be only
75-90% effective.
6. CONCLUSION
6.1 There appears to be a paucity of up-to-date
information on the DEFRA website, and so it is difficult to know
the current situation with regard to the various aspects of the
trial. A number of questions need to be asked with regard to this
in order to clarify the situation.
6.2 The results of the trial may yield much
in the way of ambiguity. Hence, it is vitally important to have
a plan to manage the disease, based on a veterinary risk assessment.
This needs to be up and running before the end of the trial. At
Ministerial level it has been previously stated that there will
not be any mass culling of badgers, whatever the outcome of the
trial results, and hence pursuing such a policy will only serve
to undermine the trial.
31 January 2003
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