Government response
Introduction
The Government welcomes this report. Following the
report of the Policy Commission on the Future of Farming and Food,
the reports of the inquiries into the FMD epidemic, and the publication
of the Strategy for Sustainable Farming and Food in England, the
Government is now developing an Animal Health and Welfare Strategy.
This will set the framework for a new bovine tuberculosis (TB)
Strategy. The Committee's report will be extremely helpful in
taking that process forward.
The Committee has rightly identified the need for
the Industry to be more involved in the control of TB, especially
in relation to improvements of husbandry practice.
The Animal Health and Welfare Strategy will seek
more stakeholder engagement in the protection of animal health
and the need to improve disease prevention measures on farm, including
measures against bovine TB. The Government will consult in the
summer on a draft Biosecurity Action Plan to address this need.
This response has been agreed with the devolved administrations
and incorporates the views of the Independent Scientific Group
on Cattle TB (ISG).
Where appropriate, related recommendations have been
considered together.
Conclusion and Recommendations
Recommendation 1: We welcome the fact that controls
on the movement of livestock have been tightened in high risk
areas. Nevertheless, we are surprised that stricter controls were
not imposed sooner (paragraph 9).
As explained to the Committee, Government considered
that a decision to place herds under movement restrictions with
little immediate prospect of being able to organise a test could
be open to legal challenge on grounds of proportionality.
In light of this, two risk based measures to minimise
the spread of TB through movements of infected cattle were announced
in January 2002:
With effect from 31 January 2002 immediate
movement restrictions on annual testing herds that had missed
a 6 or 12 month check test, pending a satisfactory test;
In conjunction with this, we provided guidance to
Divisional Veterinary Managers (DVMs) and Local Veterinary Inspectors
(LVIs) on the prioritisation of overdue TB tests, based on the
likelihood of finding reactors in each type of test;
As part of the 'Autumn package', further measures
were announced:
With effect from 1 February 2003: movement
restrictions in herds that are overdue their TB test by more than
12 months.
With effect from 1 April 2003: movement restrictions
in herds that are overdue their TB test by more than 6 months
Most recently, on 27 March 2003, Government announced
that, with effect from 30 September 2003, all herds with an overdue
TB test of three months or more will be subject to movement restrictions.
Recommendation 2, 3 & 8
Recommendation 2: We understand why the Government
wants to implement its Animal Health and Welfare Strategy as soon
as possible. However, we recommend that Defra take time to assess
what might be learnt from past responses to animal disease outbreaks,
including bovine tuberculosis. Such an assessment would reveal
the best ways for Defra to get its message across to farmers,
and so help in the delivery of the Strategy. It might also suggest
ways in which advice specifically relating to bovine tuberculosis
should be improved (paragraph 14).
Recommendation 3: The average cost of a TB breakdown
is £36,000. We are therefore surprised that farmers have
not more urgently sought Government help in testing better husbandry
methods, in line with the Krebs report. We urge the farming industry
to come forward with proposals for improved husbandry methods.
If it does so, we recommend that the Government provide suitable
financial support to help with their implementation (paragraph
15).
Recommendation 8: Although no single measure will
obviate the risk of a TB breakdown, investment in husbandry and
biosecurity measures will clearly help. We are therefore concerned
about limited progress in respect of improved husbandry. We have
suggested ( in paragraph 15) how farmers and the Government should
take responsibility for the issue. In addition, communication
by the Government and others of recommendations for better husbandry
must be improved (paragraph 21).
The Animal Health and Welfare Strategy will take
time to evolve and the Government plans to publish an outline
document this summer which sets out the guiding principles and
key messages. It will recognise that effective communication of
advice to farmers on the protection of their livestock is key
to achieving real improvements in animal health and welfare, including
the reduction of TB and other endemic and zoonotic diseases. A
key element of the Strategy will be a Biosecurity Action Plan,
which will set out how Government will work with stakeholders
to improve the way that advice and training are provided. Clearly,
the lessons learnt from previous disease outbreaks will need to
be taken into account.
The farming community will have a vital role in defining
how advice is best communicated and in ensuring that advice is
implemented. In the main, we already know what basic measures
can be implemented that can make a real contribution to reducing
the risk of introduction of TB. The challenge is to ensure that
the farming community understands and accepts the advice and brings
about real changes in the way they manage health risks that threaten
their animals. Incentives for improved farm health planning and
biosecurity need to be explored. It is possible that demonstration
farms and farm assurance schemes have a role to play in this.
The Government notes the Committee's statement on
the average cost of a TB breakdown, but wishes to make clear that
this is an industry estimate.
Government would welcome proposals from the farming
industry for improved husbandry methods to reduce prevalence of
TB. Government is keen to work in partnership with stakeholders
in providing advice based on practical experience from the farming
community. Government hopes that industry will develop its approach
to take account of the ISG's analysis of TB 99's. The Government
would be happy to facilitate discussions, but financial support
will depend on the availability of resources.
Recommendation 4: Defra should recognise the growing
concern within the farming industry about the spread of TB to
areas previously unaffected by the disease. It should therefore
ensure that all dairy farmers are regularly updated, via its website,
about the spread of disease and about the latest 'good husbandry
practice' that is available to counter the spread of the disease
(paragraph 16).
Government accepts this recommendation. Each month
Defra publishes provisional cumulative TB statistics for the calendar
year on its website, including the number of TB tests carried
out, the number of new TB incidents and the number of animals
slaughtered in each region. However, Government is undertaking
a review of the TB webpages of the Defra internet site and will
take full account of this recommendation in that. The review includes
plans to determine the feasibility of developing a TB interactive
map where farmers can easily access information about disease
incidence and test statistics.
Government has issued farmers with guidelines on
good husbandry practices to try to minimise the transmission of
TB. The booklets 'TB in Cattle - Reducing the Risk', 'Golden Rules
for a Healthy Herd' and 'Farm Biosecurity - Protecting Herd Health',
have all been issued to farmers free of charge. The publications
are also available via the Defra internet site.
At the end of June 2002, Defra issued a press notice
emphasising the wisdom of minimising direct contact between wildlife
and cattle. This followed publication by the Royal Society of
research by Central Science Laboratory (CSL) scientists on the
"use of farm resources by badgers and the risk of bovine
TB transmission to cattle".
Recommendation 5: We expect Defra to explain more
fully developments relating to pre- and post-movement testing.
We also ask that it consider:
Whether 'tuberculosis-free' regions should be
defined, and what rules should govern the movement of animals
into such areas;
What the implications of a positive test of an
animal held in isolation following a movement should be both for
its herd of origin and the herd it was to join; and
What would be the costs and benefits of compulsory
pre-movement testing (paragraph 18).
Government will be exploring these issues in detail
with stakeholders as part of the development of a TB Strategy.
EU rules govern the definition of 'Tuberculosis-free' regions
and movement of animals in and out of such regions.
Recommendation 6: For the time-being, the SVS
must concentrate on clearing the backlog of tests. In the longer
term the Government should consult interested parties about the
merit of introducing flexible, 'on-request' testing for tuberculosis
(paragraph 19).
Government agrees that the SVS must continue to concentrate
on clearing the backlog of TB tests, as it has been the case for
the last 14 months. The latest statistics available indicate that
on 31 March 2003 the overall number of overdue tests stood at
4,511, representing a 27% improvement on the position at 28 February
2003, when 6,139 tests were overdue. This brings down the national
TB testing backlog roughly to the level at the onset of the FMD
outbreak of 2001. Tests overdue by 6 months or more now only account
for 12% of the total backlog, compared to 64% in August 2002.
The SVS, private veterinary practitioners industry bodies and
herd owners alike should be credited for this ever improving situation.
The threat of impending movement restrictions on overdue herds
has also acted as a powerful incentive to clear the backlog. Herds
with a TB test overdue by more than 6 months are now routinely
placed under movement restrictions, pending satisfactory completion
of the test. As already mentioned, TB tests overdue by 3 months
or more (29% of the backlog) will also result in the imposition
of movement restrictions with effect from 30 September 2003.
Government will consider with the farming industry
how to make private or 'on-request' TB testing more appealing
in the longer term. At present, private TB tests can be carried
out by local veterinary inspectors (LVIs) outside the routine
testing programme for a herd, usually on individual animals or
specific groups of cattle at the owner's request and expense.
Those tests have to be authorised by the DVM and their results
must be notified to the DVM. When reactors and/or inconclusive
reactors (IR's) are disclosed at a private test the LVI carrying
out the test must inform the DVM immediately by telephone. Such
reactors and/or IRs should be dealt with as if they had been disclosed
at an official test and the LVI should serve a notice enforcing
TB movement restrictions as usual.
Despite encouragement from Government, the uptake
of private testing by herd owners in the post-FMD era has been
disappointing. The Government regards private TB testing as a
key element for improving TB herd biosecurity. A key issue for
discussion with industry in relation to this will be how the costs
of any such testing should be borne.
Recommendation 7: We welcome in principle the
proposal to use 'lay' testers to clear the backlog of outstanding
tests. Such testers may have a role to play in respect of diseases
other than bovine TB. However, it is vital that lay testers are
properly trained. We therefore recommend that the Government publish
more detailed proposals about the qualifications it will require,
taking into account the views particularly of the veterinary profession.
The proposals should also outline the role combined lay testers
and animal health officers based in Animal Health Offices might
play in overcoming the shortage of veterinarians (paragraph 20).
The Government is planning a full public consultation
exercise in the summer of 2003 on a proposal to introduce an Exemption
Order, under the Veterinary Surgeons Act 1966, to permit trained
and competent lay people to perform tuberculin skin testing of
cattle. The consultation will publish proposals for (i) training
and a period of supervised testing prior to becoming an 'approved
tester'; (ii) the role of the lay tester; and (iii) the role of
the veterinary surgeon. We propose that there should be a continuing
need for quality assurance of the work of the approved lay tester,
by veterinary surgeons accompanying the tester for a proportion
of the visits.
Recommendation 9: We understand the concerns of
farmers. But we believe that the continuation of the culling trial
is necessary to establish once and for all whether killing badgers
has any impact on bovine tuberculosis in cattle. We therefore
welcome the Minister's clear statement that the Government will
not sanction culling outside the trial areas whilst the trial
continues (paragraph 28).
Government notes this recommendation.
Recommendation 10: We recommend that, as soon
as practically possible in 2004, the ISG publish the number of
TB99 forms collected in the current calendar year and an assessment
of their suitability for analysis (paragraph 30).
The Government accepts this recommendation.
Recommendation 11: We acknowledge that the TB99
form is complex. But its value in providing definitive information
to complement that found in the culling trial and other scientific
work would be diminished if it was peremptorily changed (paragraph
31).
Government notes this recommendation. The TB99 form
is indeed long and complex, but the level of detail is important
if the study is to tease out those aspects of beef and dairy farming
that might have a role to play in pre-disposing livestock to,
or protecting them from M.bovis infection. For any such
approach to work, the net has, first, to be cast as wide as possible
to catch any potential factor of importance.
The ISG has made clear its intention to carry out
analysis of TB99 data as soon as the Department can deliver sufficient
datasets for a realistic and representative analysis to be carried
out. After initial analysis it may well be possible to narrow
the scope to focus on key areas that might emerge as being of
greater importance. This would lead to a shorter, more focussed,
and hence easier, form to complete.
Recommendation 12: We support the road traffic
accident survey. If it is found over time to provide a good indication
of the prevalence of bovine tuberculosis in badgers an extension
to the survey should be considered (paragraph 34).
Government accepts this recommendation, subject to
availability of funding.
The value of the Road Traffic Accident Survey, if
found by validation, to be a good predictor of background to M.bovis
infection in wildlife (specifically badgers) is not underestimated.
The ISG has predicted that sufficient badgers will have been collected
to carry out an initial analysis of the first full year's data
from the RTA Survey this summer. It is possible that this analysis
may indicate that further sampling is required in order to carry
out the validation.
Recommendations 13 and 14
Recommendation 13: If it requests advice Defra
should obviously allow the ISG adequate time to provide it. But
Defra is not obliged to follow the ISG's advice: Defra is responsible
for the decisions made. However, the importance of a harmonious
relationship between the ISG and Defra is such that in this instance
it would be helpful for Defra to clarify the differences between
the protocol it adopted and the advice it received from the ISG
and provide some commentary on the reasons for the difference
of approach (paragraph 36).
Recommendation 14: We ask that Defra now provide
an update on recruitment to the pilot, detailing both the anticipated
recruitment for each three month period of the trial and recruitment
to date. Defra should also detail any changes it has made to the
protocol since 9 October 2002, in response to the ISG's comments
(paragraph 37).
Defra officials and the ISG are continuing to discuss
the suggested changes to the gamma Interferon pilot study. In
particular, the ISG proposals have significant resource implications
which need to be addressed. It is estimated that the ISG suggestion
would cost an additional £3.5 million for a study comprising
150 herds. (The current pilot will cost £667,000 for the
first 150 herds, although it is proposed that the pilot be extended
to include 660 herds in total.) The ISG proposals would also impinge
on the resources and facilities which are currently used both
for ongoing high priority research studies, and for routine surveillance,
monitoring and disease control purposes. It has not yet proved
possible to reconcile these issues. No changes to the protocol
have therefore been made to date although discussions are continuing.
The aim at the start of the Gamma Interferon trial
was to recruit 660 herds over a period of two years. This equates
to approximately 28 herds a month, or 84 herds a quarter. The
pilot study began on 28 October 2002 and as at the end of the
second quarter, 27 April 2003, 39 herds had been recruited. This
equates to shortfall of 129 herds against plan. A review point
for the trial has been set for when a total of 150 herds have
been recruited.
Recruitment of herds to the study is on a voluntary
basis and as such requires a Veterinary Officer from the State
Veterinary Service (SVS) to visit individual cattle-keepers. Not
all farmers approached choose to join the trial, for various reasons
including potential impact on their business. As such, recruitment
is proving to be very demanding on SVS resources.
Recommendation 15: It is apparent that all interested
parties would be willing to endorse the use of an effective
bovine TB vaccine. Therefore, despite the long time-frame, research
into the development of vaccines should continue. Moreover, other
important lessons about the disease are likely to be learned from
the vaccine research programme. However, the long time-frame means
that Government and others cannot afford to pin all their hopes
on the development of a vaccine. It would be helpful if Defra
could provide a statement summarising the present state of work
worldwide on the production of a vaccine by the veterinary medicines
industry. Finally, the private sector should be encouraged to
play a part in the development of a vaccine (paragraph 42).
The Government is continuing to fund collaborative
research into the development of vaccines for both cattle and
badgers. In 2002, a scoping study to look at the feasibility of
pursuing a TB vaccination strategy for either cattle or wildlife
was set up as a sub group of the ISG. This group included members
of the ISG, Defra officials, representatives from industry and
eminent scientists in the field of human and bovine TB. The present
state of work on animal TB vaccination in other countries, particularly
New Zealand and Republic of Ireland was also considered by the
sub group. The report is due to be published shortly.
The Chief Veterinary Officer (CVO) has set up a Vaccine
Steering group to identify the administrative and legal processes
that need to be followed to enable a vaccine to be used with minimum
delay, once a suitable candidate vaccine is identified.
Recommendation 16: We would therefore encourage
the ISG to indicate why specified topics which have been drawn
to its attention are not recommended for further study (paragraph
44).
The ISG consults widely with members of the scientific
community and others to continually review scientific requirements.
It considers all scientific research proposals which Defra and
others present to it and advises Government on their scientific
validity and priority. In the specific instance raised by the
Committee - the effect of trace elements such as selenium on the
disease status of cattle and badgers - the ISG is aware of the
background scientific information available, but it has not been
asked to consider any worked-up research proposals relating to
this area.
Recommendations 17, 18 and 19
Recommendation 17: We recommend that the Government
publish the terms of reference of and the plan of work for its
review as quickly as possible (paragraph 45).
Recommendation 18: We therefore reiterate the
call made by the Agriculture Committee that a "Plan B"
be developed to address a situation in which the results of the
culling trial are inconclusive (paragraph 47).
Recommendation 19: It would be reassuring for
farmers and others if the Government would re-confirm what is
the overriding aim of its TB Strategy (paragraph 48).
Government is developing, in consultation with stakeholders,
a TB Strategy. This will cover a period of up to 10 years. Government
expects to issue a consultation document later this year. A number
of shorter term measures, as announced on 20 February, are also
under consideration.
The Strategy will address what will need to be done
when the randomised badger culling trial is complete, whatever
the results of the trial may be.
The Strategy will include a draft vision - a picture
of where we would wish to be in 10 years time. The views of stakeholders
will be sought on what that vision should be.
Recommendation 20: Members of the TB forum should
re-assess what role it should play and Defra should consider redefining
its remit accordingly. It may have a particularly important role
to play, for example, in communicating the results and validity
of the current scientific research programme (paragraph 50).
Government recognises that some parties have been
frustrated in the way the TB Forum has operated and will be re-assessing
its future with members. The TB Forum is currently the main stakeholder
group for the consideration of matters relating to bovine TB.
Relationships between Government and stakeholders will need to
be addressed in the light of the Animal Health and Welfare Interim
Strategy, and in the discussions on the TB Strategy.
Department for Environment, Food and Rural Affairs
June 2003
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