Memorandum submitted by the Royal College
of Veterinary Surgeons
BOVINE TB
1. The Select Committee is well-informed
about the problem of bovine tuberculosis as a result of its past
inquiries, and it is aware of the concerns of the Royal College
of Veterinary Surgeons. This brief note therefore confines itself
to commenting on the issues in the light of the Government's consultation
paper, "Preparing for a GB strategy on bovine tuberculosis",
and the report of the Independent Scientific Review chaired by
Professor Charles Godfray.
2. RCVS found the consultation document
disquieting. The proposed short-term measures to reduce transmission
between cattle are reasonable but will do nothing to control transmission
between cattle and wildlife. The maps and chart in paragraph 3.3.8
present an unmistakeable picture of a disease which is out of
hand, but the document offers no convincing strategy for getting
it back under control. Indeed, the first question posed suggests
that the target for the next 10 years should be only "to
contain and progressively reduce spread, incidence and economic
costs of the disease and to continue to develop the science base
to inform future strategy". When a building is on fire, the
aim of the fire brigade is to put the fire out, not just to slow
down the rate at which it spreads. The Government's aim should
be to return to the position where most of the country is free
from bovine TB, with only sporadic outbreaks which can be contained
by movement restrictions and slaughter.
3. The consultation document addresses the
question of transmission between cattle and wildlife, but in terms
which seem to revert to an earlier stage in the debate. Seven
years ago, as the Select Committee knows, the Krebs report advised
that the evidence strongly supported the view that in Britain
badgers were a significant source of infection in cattle. The
report acknowledged that the evidence was indirect but said that
"in total the available evidence, including the effects of
completely removing badgers from certain areas, is compelling".
In August 1998 Ministers announced the decision to launch the
Randomised Badger Culling Trial "in order to find out when
culling is an effective approach and when it is not". Yet
now the consultation document asks whether "in the light
of current evidence, policies should be developed (including badger
culling) that seek to control transmission of bovine TB between
badgers and cattle". It also asks under what circumstances
a badger culling or management policy would be acceptable. It
makes no obvious sense to raise these questions when the culling
trial is at an advanced stage. The decision to mount the trial
implied that transmission between badgers and cattle had to be
dealt with, and that culling, if it worked, would be an acceptable
control measure. Professor Godfray's report has now confirmed,
if confirmation were necessary, that policy should be "based
on the assumption that badgers are involved in disease transmission
as a wildlife reservoir".
4. It is also a matter of concern that the
consultation document betrays a wish to distance Ministers from
responsibility for the strategy. Question 4 asks "Does Government
need to intervene in the control of bovine TB?". At some
point it may be worth considering this question, but it seems
strange to raise it at a time when a zoonotic disease is spreading
rapidly in livestock, farmers have no power to deal with the wildlife
vector except through husbandry measures, and the established
control system rests on the exercise of statutory powers. To return
to the earlier analogy, it is a bit like discussing the pros and
cons of privatising the fire brigade when there is a fire to be
put out. Similarly, the document asks questions about "effective
partnership" and "governance arrangements" for
a new strategy. Consultation and involvement of stakeholders in
the formulation and implementation of policy are of course desirable,
but the real need is for Ministers to make decisions and take
firm action.
5. Admittedly this is easier said than done.
Whatever Ministers do (or fail to do) is liable to be condemned,
and those who criticise ought to offer positive advice. The advice
which RCVS would offer is that the Government should reconsider
its strategy now on the assumption that the culling trial will
prove inconclusive. Reactive culling as carried out in the trial
has been abandoned, and it will not be surprising if proactive
culling turns out to be ineffectual. This is because it is not
thought to remove more than 80% of the badgers from the area.
Indeed, a Written Answer to Mr Owen Paterson MP on 29 April, col
1189, said that the efficiency of trapping might vary between
30% and 80%. Section 5.6 of the Krebs report made it clear that,
in both the reactive and proactive culling areas, the aim should
be to remove all badgers. If the object is to control a disease
by slaughtering potentially infected animals in a defined area,
it is optimistic to expect this to work when a substantial proportion
of them survive to spread the disease. It would therefore be rational
to work on the basis that proactive culling as practised in the
trial will not be effective. If it does work it will offer Ministers
a relatively comfortable policy option, but they would be ill-advised
to pin their hopes on this.
6. In setting up the culling trial Ministers
hoped to be able to make and defend policy decisions on the basis
of good science. If it becomes clear that the trial is not going
to prove anything there may be a temptation to call for further
evidence. Sometimes, however, it is necessary to act on the basis
of imperfect information. The advice already available to the
Government, most recently from Professor Godfray's report, is
that the transmission of bovine TB from the wildlife reservoir
must be dealt with. It would be good if transmission could be
controlled through husbandry measures, and Professor Godfray has
suggested a publicly-funded experiment in badger-proof farming.
A good idea, but such an experiment will inevitably take time
and husbandry may prove not to be an answer. The same comments
apply to vaccination to control the disease in badgers. In the
meanwhile there is clear historical evidence that the systematic
removal of all badgers in an area around an outbreak can work.
The evidence may not come up to the best scientific standards,
but as the epidemic continues to accelerate Ministers may not
be able to afford the luxury of further research before taking
action. The publication of the results of the Irish experiments
should in any case cast fresh light on the effectiveness of culling
which is designed to remove all badgers from an area.
7. RCVS hopes that the Select Committee
will encourage the Government to recognise that its present policy
of waiting for the outcome of the culling trial is not sustainable.
Royal College of Veterinary Surgeons
May 2004
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