Memorandum submitted by the British Cattle
Veterinary Association (BTB 30)
1. The BCVA is a specialist division of
the British Veterinary Association comprising 1,500 members of
whom over 1,000 are practising veterinary surgeons working with
cattle in farm animal veterinary practice. In this respect a large
number of our members come into direct contact with TB control
policies as they affect their client's farms. BCVA have been represented
on the DEFRA TB Forum and are members of various stakeholder groups
affecting the industry.
2. BCVA welcomes the opportunity to respond
to this very important Inquiry on the potential role for badger
culling in the control of bovine TB (bTB) in the UK. The BCVA
response to the Defra Consultation entitled "Controlling
the Spread of Bovine Tuberculosis in Cattle in High incidence
Areas in England: Badger Culling" is currently being constructed
and as such is not yet finalised, yet the comments that follow
are likely to form the basis of this response. Additionally, as
the cattle specialist division of the BVA, BCVA has been closely
involved in the development of the BVA response to both the Consultation
and the Inquiry and so not surprisingly there are similarities
in our responses.
3. In light of the significant increases
in bTB incidence year on year in endemic areas this is perhaps
one of the most important consultations on bTB control in recent
years. The following quote from DEFRA's own Regulatory Impact
Assessment sets the scene well in terms of what is needed in these
problem areas.
"In the high incidence areas, where the
majority of costs of pre-movement testing and compensation will
fall, there is a reservoir of infection in the badger population.
Without tackling this exogenous infection reservoir, cattle based
measures alone may not be sufficient to have a significant impact
on the incidence of disease."
Mr Ben Bradshaw has also said:
"Experience from around the world shows
that strict cattle controls are essential if TB is to be contained
and eradicated. But it also shows that it is unlikely to be successful
unless in addition action is taken to deal with the disease in
wildlife."
4. The draft formal responses to the Consultation
questions are attached as an Appendix to this submission. BCVA
welcome the fact that that need for a regional approach has been
recognised and voiced within policy and consultation documents
from Defra and we would like to offer some observations which
may help enforce the need for a regional approach.
5. The relative importance of the spread
of bTB both within and between cattle and badger populations is
perhaps key to the regional importance of the various available
control options. It would seem logical that the emphasis should
be directed towards control measures most likely to result in
the reduction of disease disclosure rates in cattle herds (currently
rising at 18% year on year).
(a) Strong evidence for effective and rapid
badger to cattle spread of bTB.
(b) The data presented by the ISG from the
Randomised Badger Culling Trials (RBCT) and highlighted at both
the meeting at the Zoological Society of London (24 January) and
the ISG open meeting (25 January) showed very clearly that ineffectual
badger culling would cause disturbance to the normal badger behaviour
of those badgers remaining. This disturbance results in increased
"ranging" of badgers which, as a consequence, come in
to contact with more cattle herds resulting in increased herd
breakdowns. These effects were seen (perhaps surprisingly) within
the relatively short time span of the RBCT study which very clearly
highlights the efficient mode of spread of bTB from badgers to
cattle and would indicate that this badger to cattle spread will
happen in any situation where infected badgers come in contact
with cattle in these situations.
(c) Strong evidence for movement of bTB to
clean areas by movement of infected cattle. (Translocation of
infection).
(d) Practical experience and studies using
BCMS data has shown that not surprisingly the movement of cattle
with undisclosed bTB infection results in translocation of infection
from the herd of origin to the herd of destination. Usually the
number of infected cattle being introduced to herds is low and
this is backed up by the fact that many of the new herd breakdowns
in previously bTB free areas involve either single or small numbers
of reactors. More over the application of a test and cull policy
(often applying severe interpretation of the SICCT) results in
rapid control and a return to bTB free status for those infected
herds. This would indicate that the spread of bTB between cattle
in this situation is neither rapid enough to compromise disease
control or act as a barrier to the herd regaining bTB free status.
(e) Closed herds succumbing to bTB breakdowns.
Clearly bTB spread occurs within and between
badger and cattle populations but the strong message from the
RBCT data shows that the badger to cattle route is an efficient
one and this would help explain the numerous herds where cattle
movements can not explain a herd breakdown.
6. Although the extensive research from
around the world has improved our knowledge about this very complex
disease there are still significant gaps that exist; a situation
not unique to bTB. However despite this, the application of sound
veterinary principles can result in significant improvements towards
disease control in animals, clearly evident in the control of
Bovine Spongiform Encephalopathy (BSE) in the UK where the science
was clarified after much of the effective control measures were
in place.
7. In light of our current knowledge, the
key points in bTB control as BCVA see them are as follows:
(a) We need to tackle the spread of bTB in
the UK—this statement is supported by the majority of the
general public (see Defra survey).
(b) This disease is prevalent in two major
animal reservoirs—cattle and badgers.
(c) We need to control the disease in both
of these disease reservoirs by improving controls in cattle, and
starting to tackle the disease in badgers.
(d) BCVA wants to see a government co-ordinated
cull of badgers in high bTB incidence areas where badgers are
implicated in the disease picture.
(e) In the current situation, targeted culling
over specific areas linked to herd bTB incidence by shooting and
snaring of badgers is the most viable short-term option for control.
However it is acknowledged that there are significant practical
and welfare issues with these methods of control which need to
be addressed.
(f) Culling should only occur in high incidence
areas where there is sufficient evidence to show that there is
a high level of infection in the badger population. It is in these
areas, where cattle controls alone have not and will not work.
(g) In the longer term, culling badgers by
gassing should be further investigated as it could potentially
be the most efficient, cost-effective, and possibly most humane
method to employ once issues surrounding its application have
been resolved. Targeting of wildlife disease surveillance and
recording of culling activity would enable the effectiveness of
control methods to be properly evaluated.
(h) There is a need to continue research
into the application of control methods including culling strategies.
8. BCVA are concerned that there is too
much emphasis on cost which, whilst undoubtedly important, must
not override the effectiveness of any policy undertaken. The goal
must be a significant reduction in the number of cattle herd breakdowns
(CHB) that currently cost £26,762 each and are increasing
at 18% year on year. However apart from method 2a (cage trapping),
Table 9 on p 20 of the Partial Regulatory Impact Assessment implies
a similar reduction of Confirmed New Incidents (CNI) irrespective
of the culling method used. Calculating the breakeven point is
a good economic principle, but when the efficacy of each method
in terms of reduction of CNI is taken to be broadly similar, the
breakeven point will be lower for the cheaper option. The decision
should be based on the ability for the culling method to move
the Reproductive Index "R" value to <1 and so bring
the disease under control rather than requiring a smaller improvement
in CNI to achieve an economic break even.
9. BCVA also have serious concerns that
the estimates for reduction of CNI's with an uncoordinated farmer
based approach (Option 3) are likely to be an overestimate, not
only in terms of efficacy of the methods employed, but also as
a result of fear firstly of reprisal from badger groups against
those licensed to cull and their families, and secondly in terms
of negative attitudes of others within their local community.
10. In light of the obvious lack of successful
bTB control in these endemic areas (in part at least from previous
ineffectual control policies) there is a need for a fair, clear,
transparent and obvious partnership between Defra and farmers
to implement the more stringent cattle and badger controls that
are needed. Leaving farmers to take on the task of badger culling
alone would not be in the spirit of a partnership. Defra clearly
has the experience, personnel and ability to coordinate activities
on a wide scale and BCVA feels it is only with such a coordinated
approach that the efficiency will reach levels that would minimise
or avoid the concerns seen in the RCBT cull voiced by the ISG.
11. BCVA hope these comments, along with
the draft Consultation answers in the attached Appendix, are of
use to the Committee and would like to thank you again for the
opportunity to submit them. Representatives from the BCVA would
be only too pleased to attend formal evidence giving sessions
regarding this Inquiry should the Committee wish to explore our
position still further or, should this not be required, we would
be glad to answer any specific issues you may wish to ask us directly
by correspondence at the addresses above.
February 2006
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