Memorandum submitted by Wildlife and Countryside
1. Wildlife and Countryside Link (WCL) brings
together voluntary organisations concerned with the conservation
and protection of wildlife and the countryside. Our members practise
and advocate environmentally sensitive land management and food
production practices and encourage respect for and enjoyment of
natural landscapes and features, the historic environment and
biodiversity. Taken together, our members have the support of
almost seven million people in the UK.
2. WCL believes that the Government must
adopt a science-based, strategic approach to disease control.
Disease outbreaks in Britain, such as foot and mouth (FMD) and
BSE, have had a disastrous effect on the rural economy including
the farming industry and tourism. Many diseases also cause significant
animal welfare problems. For example, in 2002, 90,000 cows were
slaughtered due to mastitis and 31,000 due to lameness1. WCL therefore
supports Government plans to introduce an Animal Health and Welfare
Strategy. A vital part of such a strategy must be to address the
growing problem of bovine TB in cattle.
3. Bovine TB has increased in the national
herd by 88% since 19902, 3 and in 2003, 23,546 cattle were slaughtered4.
WCL believes that bovine TB can be brought under control and reduced.
The challenge for the Government is to implement a control strategy
that both enhances farm animal welfare and conserves wildlife.
WCL believes that this will only be possible with improvements
to the scientific basis of animal health and welfare strategies.
This requires improved disease surveillance that facilitates epidemiological
analysis of data and the implementation of a wide-ranging and
rigorous research programme that can inform Government policy.
4. WCL is concerned that a misplaced focus
on badger culling to try and reduce the incidence of bovine TB
has misdirected efforts to control the disease in the past.
5. WCL believes that a future bovine TB
control strategy must be based on four key principles:
5.1 effective disease surveillance;
5.2 targeted and rigorous scientific research;
5.3 development, implementation and monitoring
of policy; and
5.4 rigorous analysis of economic, social,
and environmental considerations.
6. However WCL notes that there is already
sound evidence to indicate that the spread of bovine TB between
cattle is significant5. Therefore, controlling the spread of disease
between cattle must be the first priority of a bovine TB control
strategy. WCL believes that, in the short term, bovine TB could
be brought under control and reduced through the implementation
of the following measures:
6.1 improved cattle testing, including use
of the gamma interferon test;
6.2 stricter movement restrictions; and
6.3 improved husbandry and biosecurity.
7. IMPROVED CATTLE
7.1 The tuberculin skin test is increasingly
recognised to be unable to detect a significant number of infected
cattle. However, the gamma interferon test is able to identify
infected cattle that the skin test misses6, 7. WCL is concerned
by the Government's failure to implement a gamma interferon TB
testing strategy which could revolutionise bovine TB control in
the UK. EU regulations allow for the introduction of more advanced
TB testing regimes, such as the gamma interferon test, but so
far the Government has not properly assessed either the benefits
of an improved testing regime or the advantages of the gamma interferon
test over the current skin test. Gamma interferon has been extensively
researched and utilised in other countries, including Ireland,
for more than a decade. The Government's own gamma interferon
field trial is progressing very slowly and is not being carried
out as recommended by the Independent Scientific Group. The trial
will not assess the test's specificity and sensitivity and, therefore,
the trial will not effectively inform policy options.
7.2 WCL believes that the following measures
would more quickly and accurately identify cattle infected with
Improved cattle testing, including more frequent
testing in high risk areas and low risk areas in the event of
a TB breakdown, and compulsory pre- and post-movement testing;
Improved diagnosis using the more reliable gamma
interferon test, in conjunction with the skin test; and
Incentives and penalties for farmers, including
penalties for failing to have cattle TB tested.
8. STRICTER MOVEMENT
8.1 EU regulations mean than cattle must
be routinely tested for bovine TB. Cattle testing positive"reactors"are
slaughtered and movement restrictions are placed on affected farms
until they are clear of the disease. However, due to the FMD crisis,
most TB testing was suspended and the number of overdue TB tests
peaked at 26,936 herds. In breach of EU regulations, DEFRA failed
to impose movement restrictions on these herds while they were
overdue for a test, resulting in TB being spread to new areas
as farmers restocked after FMD.
8.2 The UK remains in breach of EU regulations
because herds that are overdue for their TB test do not have movement
restrictions imposed on them immediately, but only after they
have been overdue for three months. WCL believes that it is critical
that cattle which could have contracted TB from other cattle should
be traceable and tested. WCL proposes that this could be achieved
through improved regulation and recording of livestock movements,
including TB test dates on cattle passports.
9. IMPROVED HUSBANDRY
9.1 There is a positive correlation between
the incidence of bovine TB and herd size, possibly because existing
testing regimes do not identify all reactors in larger herds,
allowing the disease to persist8. Reform of the Common Agricultural
Policy (CAP) is likely to lead to significant changes in the structure
of the dairy and beef industries in the UK with implications for
the spread and persistence of bovine TB amongst cattle. The number
of farms larger than 100 hectares in size is forecast to increase,
leading to a corresponding increase in herd size9. Improved husbandry
and biosecurity on farms is therefore critical to reducing cattle
to cattle transmission, within and between herds.
9.2 WCL believes that this could be achieved
Improved husbandry and biosecurity, to include
better cattle welfare standards and inspections, compulsory herd
health plans and adequate isolation facilities; and
Grants to support expensive husbandry and biosecurity
measures such as isolation facilities and properly ventilated
10. BOVINE TB
10.1 WCL believes that a vaccinefor
cattle, wildlife or bothmay represent a long-term measure
in reducing and controlling bovine TB in Britain. A vaccine scoping
study published in 2003 reviewed the progress made to date with
bovine TB vaccines10. However, it concluded that a suitable candidate
vaccine is not yet available for use in cattle, due to scientific
questions and policy issues needing to be addressed first. It
was recommended that research in this area continues to be funded.
10.2 Similarly, the authors concluded that
significant scientific hurdles need to be overcome before a badger
vaccine may be used. One key issue is that a vaccine would only
be effective if most cattle TB is derived from badgers. This is
being investigated by the Krebs trial. Other issues that need
to be resolved with a badger vaccine relate to safety, efficacy,
ethics, economics and practicalities.
10.3 WCL therefore agrees with the authors
of the vaccine scoping study that the option of the use of vaccines
be retained. We also urge the Government to ensure that the research
and development of vaccines is properly funded.
11.1 WCL is concerned by the widespread
belief that badger culling reduces the incidence of bovine TB.
Historic bovine TB control strategies in the UK, which combined
the testing and slaughter of cattle with killing badgers, have
been re-analysed by the Government's Independent Scientific Group
on Cattle TB (ISG). It found that killing badgers gave no demonstrable
benefits11. A further analysis of research data has cast serious
doubt on the efficacy of targeted badger culling: it is not possible
to identify infected badgers, culling has a disruptive effect
on badger social organisation and badger populations can rapidly
recover12. More recently, the "reactive" randomised
badger culling experiment (the "Kreb's trial") has shown
an average 27% increase in the incidence of cattle TB13. Although
the recent Godfray review sought to question the statistical validity
of this particular figure, even their interpretation made it clear
that there was strong evidence that the number of herd breakdowns
in reactive areas was greater than in control areas14. This may
be further evidence that badger culling is not an effective control
policy, although the data have not been comprehensively analysed.
11.2 It is claimed that the "Four Areas
Badger Study" in Ireland has shown that badger culling can
reduce bovine TB in cattle by up to 90%15, other sources have
stated that the effect is a 50% reduction. However, it is known
that badger removal operations also took place in the scientific
control areas of the study (the so-called "Reference Areas")
and that varying levels of badger culling had taken place in the
study areas before it began. It remains to be seen how reliable
results can be drawn from the study, given these apparently limited
scientific controls and large variables. The results of that study
have not yet been published.
11.3 The UK is a major stronghold for the
European badger, which is in serious decline in much of its range16.
Badgers play an important role in the environment as a predator
and seed disperser. They also modify the landscape at a local
level through excavations that can be extensive. Badger setts
provide hibernacula for great crested newts, which are also protected
by legislation. A badger culling strategy would be obliged to
disregard the existence of highly valued nature conservation designations,
such as Sites of Special Scientific Interest and National Nature
Reserves. Extensive badger culling would breach the UK's commitment
to its international nature conservation obligations. The Bern
Convention, to which the UK is a signatory, prohibits the "widespread
disappearance" of a protected species and "indiscriminate
methods of trapping" such as snares17. Although derogations
can be made for the control of disease, this is only permissible
when there are "no other satisfactory solutions". It
should also be noted that the use of snares to kill or take badgers
is prohibited by the Wildlife and Countryside Act (WCA) 1981 as
amended. The use of snares is of concern to WCL as there is evidence
that non-target species are regularly caught in snares, including
otters, wildcats, pine martens, red squirrels, mountain hare,
owls, black grouse and capercaillie18, 19, 20. In 1968 MAFF (Humane
Traps Panel) conducted a trial to compare the efficiency of types
of snare. Results of snaring included 155 foxes and 132 non-target
animals21. The Burns Inquiry also reported ". . . about half
of the captures made by snares are of non-target species . . ."
11.4 Bovine TB control must be seen in the
context of a wider range of stakeholders than farmers and conservationists
alone. Badgers are one of Britain's most popular mammals. Indeed,
in a country where most large predatory mammals have been eliminated,
the badger remains one of the few animals widespread enough to
excite people about "wild" places. WCL believes that
extensive badger control, particularly involving snares, would
prove immensely unpopular and risks harming important rural industries
such as tourism. Badger culling would also erode public confidence
in farming at a time when closer relationships between farmers
and consumers are increasingly important.
Environmental Investigation Agency
Herpetological Conservation Trust
National Federation of Badger Groups
Royal Society for the Prevention of Cruelty to Animals
The Wildlife Trusts
World Society for the Protection of Animals
R (2003). Rethink health strategies. Farmers Weekly. 28 February
2 HMSO (1990). Animal Health 1990. Report of
Chief Veterinary Officer. Ministry of Agriculture, Fisheries and
3 DEFRA TB statistics at www.defra.gov.uk/animalh/tb
4 DEFRA (2004). Overview of national bovine TB
statistics for 2003. TB Forum paper TBF 101. February 2004. www.defra.gov.uk/animalh/tb/
5 ISG (2001). An epidemiological investigation
into bovine tuberculosis. Third Report of the Independent Scientific
Group on cattle TB. July 2001. www.defra.gov.uk/animalh/tb/
6 Wood, P R and Jones, S L (1998). Bovigam an
internationally accredited diagnostic test for bovine tuberculosis.
United States Animal Health Association. 1998 Proceedings.
7 Monaghan, M L, Doherty, M L, Collins, J D,
Kazda, J F and Quinn, P J (1994). The tuberculin test. Veterinary
Microbiology, 40, 111-124.
8 Green, L and Cornell, S (2002). Investigations
into risks of bovine tuberculosis breakdowns in cattle outside
the badger trial areas. TBF73. "As herd or test size increased,
the risk of a positive test and the number of reactors also increased".
9 Silcock, P et al (2003). A long-term
policy perspective for sustainable agriculture: the potential
environmental impacts of CAP Mid-Term Review proposals. Final
Report for DEFRA. 22 August 2003. www.gfa-race.co.uk
10 Development of vaccines for Bovine Tuberculosis.
Report of the Independent Scientific Group Vaccine Scoping Sub-Committee.
July 2003. www.defra.gov.uk/animalh/tb/publications/index.htm
11 EFRA Committee (2003). Badgers and Bovine
TB. Seventh report of session 2002-03. April 2003. Professor John
Bourne: "We also revisited old data from previous BROs (badger
removal operations) to see if this would shed any light on the
potential for culling in a localised situation outside trial areas.
We found we could not add to what Krebs had said that there was
no evidence that localized culling had any impact on cattle TB
12 Delahay, R J et al (2003). Bovine tuberculosis
in badgers: Can culling control the disease? Conservation and
Conflict, pp 165-171, Westbury Publishing.
13 Donnelly, C A et al (2003). Impact
of localized badger culling on tuberculosis incidence in British
cattle. Nature, 426, 834-837 Letters to Nature (18 Dec 2003).
14 Godfray, H C J et al (2004). Independent
Scientific Review of the Randomised Badger Culling Trial and Associated
15 Leigh Corner, BBC Radio 4 Farming Today, 31
16 Griffiths, H I and Thomas, D H (1997). The
conservation and management of the European badger (Meles meles).
Nature and Environment, No 90. Council of Europe.
17 Convention on the Conservation of European
Wildlife and Natural Habitats. www.nature.coe.int/english/cadres/bern.htm
18 SSPCA 2002, Scottish Society for the Prevention
of Cruelty to Animals (2002) Field experience and information
provided for the NFBG report on snares 2002.
19 RSPCA 2000, Royal Society for the Prevention
of Cruelty to Animals (2000) Submission to the Hunting Inquiry.
20 Cosgrove P & Oswald J (2001) Western Capercaillie
in snares. Scottish Birds. Vol 22: Part 1.
21 Forestry Commission (1997) Foxes and Forestry.
Technical paper 23.
22 Burns et al (2000) Final Report of
the Committee of Inquiry into Hunting with Dogs in England and
Wildlife and Countryside Link