Memorandum submitted by the Badger Trust
EXECUTIVE SUMMARY
1. The Badger Trust welcomes this invitation
to present written evidence to the Environment, Food and Rural
Affairs Select Committee. There is now a greater body of sound
scientific evidence about the epidemiology of bovine TB than ever
before. We hope that the Committee will base its recommendations
on this sound science, much of which has been published in the
world's leading peer-reviewed journals[1-3].
2. The Badger Trust seeks constructive,
positive solutions to the problem of bovine TB, all of which must
be based on sound science. We support the Independent Scientific
Group's conclusion that badger culling cannot make a "meaningful
contribution" to bovine TB control.
3. Instead, the science makes it clear that
it is perfectly possible to bring bovine TB under control using
cattle-based measures alone, such as gamma interferon TB testing
and whole herd slaughter for problem herds.
4. It is imperative that a badger cull is
not offered to farmers as a political quid pro quo for
implementing the strong, cattle-based TB control measures that
the science shows are required. There is speculative evidence
that this is Lord Rooker's intention.
5. We make the following recommendations:
6. Recommendation 1: The establishment
of an Epidemiology Research Unit that is fully independent of
Animal Health. It will use lay staff under the supervision of
independent scientists to gather useful epidemiological data to
support the battle against bovine TB—and potentially against
other diseases, too.
7. Recommendation 2: The Government
should appoint an independent scientific panel to ensure that
new TB policies are based on sound science and, crucially, that
the benefits of the policies are properly monitored after their
introduction.
8. Recommendation 3: The Government
should establish an incentive system for people involved in the
slaughter and inspection of cattle and deer, to maximise the reporting
of suspicious lesions.
9. Recommendation 4: The Government
should: introduce annual bovine TB testing across England; whole
herd slaughter for problem herds; urgently review the progress
of gamma interferon testing and upgrade laboratory facilities
accordingly; and, improve the use of resources by involving trained
lay personnel rather than vets in bovine TB testing.
10. The Badger Trust accepts the scientific
findings of the ISG and notes that the ISG has provided scientific
and economic arguments, which eliminate the culling proposals
advocated by farming unions.
11. We advocate the urgent introduction of a
case-control study to assess the benefits of taking steps to keep
badgers out of farm buildings.
INTRODUCTION
12. The Badger Trust welcomed the invitation
from the Committee Chairman, the Right Honourable Michael Jack
MP, to present further written information, if we wished, in the
wake of our appearance before the Select Committee on 20 June
2007. In this submission, we provide additional evidence that
we hope the Committee will find useful.
13. There is now a greater body of sound
scientific evidence about the epidemiology of bovine TB than ever
before. We hope that the Committee will base its recommendations
on the sound science which has been published in the world's leading
peer-reviewed journals[1-3]. If bovine TB is to be effectively
controlled, it is essential to avoid policies based on speculative
and intellectually weak "what if?" interpretations of
the science, made by state vets rather than by independent scientists.
14. The Badger Trust provides centralised,
specialist scientific, legal and communications advice to badger
groups. It also liaises with relevant organisations across the
UK and Ireland. Its partners include the many land-owning nature
conservation organisations that have recognised that badger culling
cannot make a meaningful contribution to controlling bovine TB,
including: the National Trust, the RSPB, the Wildlife Trusts and
the Woodland Trust.
15. The Badger Trust seeks constructive,
positive solutions to the problem of bovine TB, all of which must
be based on sound science. We support the Independent Scientific
Group's conclusion that badger culling cannot make a "meaningful
contribution" to bovine TB control. We hope that the Select
Committee will acknowledge that badgers are a protected species
and that the UK is a stronghold for this species in the EU. Taken
together, these two arguments mean that demands from farming unions
for the extermination of badgers in substantial areas of the UK
are, at any scale, scientifically, politically and economically
unacceptable. These demands must be rejected.
16. Instead, the science makes it clear
that it is perfectly possible to bring bovine TB under control
using cattle-based measures alone, such as gamma interferon TB
testing and whole herd slaughter for problem herds. The question
that the Select Committee needs to answer, we suggest, is the
extent to which taxpayers should be expected to help farmers implement
such measures.
17. It is imperative that a badger cull
is not offered to farmers as a political quid pro quo for
implementing and paying for the strong, cattle-based TB control
measures that the science shows are required. At this stage, the
Badger Trust very much fears that the quid pro quo is exactly
what Lord Rooker, in whose hands the decision rests, is inclined
to offer.
18. The Farmers Guardian, for example which
likes to give the impression that it has direct contact with Lord
Rooker, today reports: "Although Food and Farming Minister
Lord Rooker does not share the ISG's views on the futility of
badger culling, Defra has made it clear that farmers would have
to accept some form of enhanced cattle controls in exchange for
the licensed culling policy he wants to introduce.[4]"
19. Such a decision will not based on sound
science but on cheap politics.
20. The Government stands at a crossroads
in bovine TB policy. It has the choice to help farmers address
not only bovine TB but also a wider range of farm animal health
and welfare objectives, with carefully targeted funding aimed
at reducing the transmission between infected animals. This would
be a sustainable, win-win approach, helping to improve the economic
viability of farming without alienating the wider public who are
prepared to support farmers, but not at any cost. Alternatively,
the Government could permit a futile, vindictive campaign of badger
killing which will make the disease situation worse and alienate
farmers in the eyes of the public, whilst handing farmers the
total financial burden for other bovine TB measures.
21. We prefer the former option and, in
this document, the Badger Trust offers positive solutions that
will help to address the problem of bovine TB in a sustainable
way.
RESPONDING TO
THE SELECT
COMMITTEE
A. Ministers, state vets and scientists
22. David Taylor MP commented: "You
said that [the Minister] would be in a science vacuum at the mercy
of state vets, as if he is some poor, simple sap baffled by scientists
with a hidden agenda."
23. Whilst the Badger Trust would not go
so far as to describe any Minister as a "simple sap",
we have been deeply worried by the fact that a succession of Ministers
has spent a great deal of time listening to state vets' interpretation
of the ISG's research, rather than listening to the ISG itself.
24. The Select Committee will be aware from
its previous hearings in 2005 that the Government launched its
consultation on badger culling without taking advice from the
ISG. When the Badger Trust Cymru and the Badger Trust recently
met ISG chairman Professor Bourne, when giving evidence to the
Rural Development Sub-Committee at the Welsh Assembly on 20 September,
we were astonished to learn that Lord Rooker had still not met
the ISG.
25. We feel that this is a shameful dereliction
of duty by the Minister. Tax payers have invested in excess of
£50 million in the work of the ISG and, at the very least,
Lord Rooker should have taken the time to discuss with the ISG
any uncertainties that he may have about their research. He should
have done this early on, given the pressing nature of the bovine
TB problem.
26. More recently, Lord Rooker has indicated
to us that it is not for him to accept or reject the recommendations
of the ISG. We disagree. It is exactly the role of Ministers to
make clear decisions about the validity of the advice that they
receive and that tax payers have paid for. We believe that it
should be relatively easy for Lord Rooker to accept the ISG's
findings, given that they have been subject to very robust peer
review at the highest international level. The failure of Lord
Rooker and his predecessor to do so begs the question: why?
27. We believe that the answer lies in the
policy-making structure of Defra. Despite being renamed in the
wake of the foot and mouth disease fiasco of 2001, the Department's
policies with regard to animal health and welfare are still driven
by state vets, with scientific advice very much on the sidelines.
28. We have seen consistent evidence of
civil servants undermining the work of the ISG. This is apparent
in the minutes of the ISG[5] and the erosion of scientific expertise,
by civil servants, continues. During a recent meeting with Lord
Rooker, for example, a senior member of Defra's TB unit defended
Professor Simon More's critique[6] of the ISG's work, insisting
that the critique had been peer-reviewed. The Veterinary Record
has told the Badger Trust that Opinion pieces are not normally
peer-reviewed and the RSPCA has stated, as a matter of fact, that
this Opinion was not peer-reviewed[7].
29. More significantly, however, is not
where More's critique has been published, but where it has not.
On 10 October, at a seminar organised by Ireland's Department
for Agriculture, Professor More confirmed in response to a question
from the Badger Trust that the critique had been submitted to
Nature, where the ISG's results were first published. Nature had
declined to publish the submission, following peer review.
30. We find it perverse, to put it mildly,
that Defra officials are actively involved in undermining research
of the highest quality and commissioned by Defra itself, particularly
when the research has been published in journals of the highest
international standing.
31. In conclusion, we believe that whilst
Ministers must make clear decisions about future strategies for
bovine TB control, those decisions must be expressly supported
by genuinely-independent scientific experts. Defra's Science Advisory
Council has provided an excellent model suggesting how such a
system might work. Yet to the best of our knowledge, the Minister
has done nothing to implement it.
32. David Taylor MP also suggested that
in criticising Animal Health (formerly the State Veterinary Service)
we were passing a verdict without a trial. In fact, our report
on Animal Health contained a detailed analysis that fully supported
our primary conclusion: namely, that claims made by State Vets
about badgers as a cause of bovine TB—either on a farm basis
or regionally—are not supported by valid epidemiological
evidence. More details are given in Appendix A.
33. In July 2007, Defra effectively confirmed
the Badger Trust's lead finding. It published research that has
been in the Government's possession since 2000. The research included
a review, by the Veterinary Laboratories Agency, of the qualitative
information gathered by TB49[8]. TB49 was the questionnaire used
by state vets to document TB outbreaks between 1986 and 1998.
It was the only source of evidence available to state vets on
the epidemiology of bovine TB.
34. Yet the researchers found `a minimum
quality standard in operation' with regard to completion of the
forms and concluded that "TB49 is not adequate for use in
detailed epidemiological analysis of risk factors for bovine tuberculosis".
In short, the data gathered by state vets up to the end of 1998
could not be used to explain the causes of bovine TB cases or
to explain the spread and persistence of the disease.
35. Since 1998, there has been no consistent
strategy to ensure that useful epidemiological data on the causes
of bovine TB is gathered. This leads to a serious problem at farm
and regional level. State vets routinely tell farmers that badgers
are the likely cause of a TB breakdown, when in fact they lack
the level of information required to pass such a judgment. Farmers,
not surprisingly, get angry and frustrated, and this fuels the
pressure on Ministers to kill badgers.
36. Thus, it remains our position that state
vets cannot be relied upon to provide Ministers with sufficiently
robust scientific or epidemiological advice. Yet within the corridors
of Defra, state vets rather than scientists take a primary role
in influencing policy and they have the ear of the Minister.
37. We urge members of the Select Committee
to read our report on Animal Health which has been submitted to
the Committee and is available on our website at www.badgertrust.org.uk
B. Bovine TB in Ireland
38. Sir Peter Soulsby MP asked why, in our
estimation, Ireland's Agriculture Minister—Mary Coughlan—was
wrong to defend the role played by badger culling in controlling
bovine TB in Ireland.
39. In Appendix B, we provide a graph that
details the recent history of badger culling in Ireland. What
is clear from this graph is that whilst badger culling has been
consistently practised for decades, bovine TB levels have soared
and fallen independently of the killing strategy. Instead, rather
more clear parallels can be seen with shifts in cattle testing
policy.
40. A further important point to be drawn
from our graph is the more recent situation. Far from showing
a sustained drop in bovine TB, the number of slaughtered reactors
in the Irish national herd has been stable for the last three
years, despite continued badger culling.
41. A key question which the Irish researchers
are currently unable to answer is this: Why is it that bovine
TB strains are clustered in cattle herds, but are not clustered
in badgers within two or even five kilometres of those herds?[9,
10]
42. We believe that the persistence of bovine
TB in the Irish national herd is the result of localised cattle
movements in a patchwork of fields, none of which are double-fenced,
leading to cyclical infection amongst herds. Ireland's surviving
badger population, meanwhile, is so perturbed that animals roam
very widely, acquiring different bovine TB strains from different
clusters of infected cattle.
43. We respectfully ask the Select Committee
to ask the Minister why it is that Defra officials (who attended
the seminar in Ireland) place so much weight on findings in Ireland,
even though they do not remotely approach the scientific robustness
of the findings of the ISG in England.
44. Reliable data from Ireland is sparse
at the best of times, but two things are clear: twice the proportion
of the national herd in Ireland is slaughtered with bovine TB
compared to Britain; and, nowhere in Ireland's major centres of
disease has bovine TB been eradicated. Furthermore, bovine TB
declines in Northern Ireland—where there is no culling but
where controls on cattle have been tightened—match those
in the Republic of Ireland, suggesting that cattle controls are
the instrumental factor.
C. Badger welfare
45. Patrick Hall MP asked about the implications
of bovine TB for badger welfare. We would like to stress three
points.
46. First, bovine TB in badgers is not a
significant cause of death, as indicated by long-term research
at Woodchester Park[11].
47. Second, in paragraph 4.25 the ISG's
report[12] notes that "the number of such severely lesioned
infected badgers was very low (only 166 animals out of 9,919 scored
in 1998-2005, Jenkins et al, in review-a; Woodroffe et
al, in review)". That only 1.67% of badgers were severely
lesioned strongly suggests that bovine TB is not a significant
cause of suffering to badgers. Woodchester park research has found
that badgers with TB live and breed normally for many years, with
no sign of ill-effects[11].
48. Third, and most importantly, the fact
that a minority of badgers suffer from bovine TB does not, ethically,
justify killing them when they are infected but not sick. It certainly
does not justify killing the vast majority of badgers that are
perfectly healthy and unaffected by the disease, as would be the
consequence of any culling policy.
D. Bovine TB at the local level
49. In responding to question 181 from Patrick
Hall MP, the Badger Trust made the point that when bovine TB maps
are looked at in detail, even in parishes subject to annual testing
the majority of farms are not affected by bovine TB. We noticed
one or two Committee members appearing to disagree with this statement.
But it is vital that its significance is grasped and understood.
50. Bovine TB maps published by Defra suggest
that vast swathes of the countryside are under bovine TB restriction.
In fact, this is not true. Defra's map shows parishes subject
to TB testing, but within those parishes the majority of farms
are rarely affected. This is important, because it means that
in most parishes the majority of farmers have nothing to gain
from a badger cull and indeed they have more to lose, because
it puts them at greater risk of acquiring the disease.
51. We understand that the Select Committee
visited Devon on 18 October to meet farmers and vets. It is unfortunate
that the Committee was unable to find time to meet those who do
not advocate badger culling as a means to control bovine TB. But
now that Members are familiar with the lie of the land, this provides
us with an opportunity to illustrate the huge dangers posed by
a badger culling policy.
52. Our example centres on the parish of
Beaworthy in West Devon, where local farmer Bryan Hill has long
claimed that a policy of killing "sick badgers", adopted
by himself and colleagues, has kept the parish "99%"
free of TB[13]. Unfortunately, these claims do not stand up to
scrutiny.
53. The following graph, using data provided
by Animal Health, shows what has actually happened in Beaworthy
and the parishes immediately adjacent to it (Ashbury, Bratton
Clovelly, Halwill, Northlew, Okehampton and Sourton). If Mr Hill
and his friends have indeed been killing badgers, then either
they have had no effect (since the general upward trend in bovine
TB is the same nationally). Alternatively, if illegal killing
is taking place nationally, then it might be argued that farmers
are generally making matters worse. Either way, the statistics
do not present an argument for killing badgers.
54.
55. The first important factor to note is
the declining number of herds. This does not mean that land is
no longer grazed. Instead, farmers who continue to manage livestock
are now grazing their cattle on land that formerly held cattle
from other herds. If the land is registered under a single holding,
Animal Health will have no records to show that the livestock
have been moving ten or 15 miles away to graze and, possibly,
coming into contact with another herd.
56. The second important factor is that
even in these parishes, where a minority of farmers demand the
right to kill badgers, the vast majority of herds are not under
bovine TB restriction. Those under restriction are very much the
minority. A badger culling policy, by triggering increased perturbation,
would put the majority of herds at risk.
57. The third factor to note is that bovine
TB had persisted at the same level for many years. This is consistent
with the ISG's point that a persistent minority of `problem herds'
are at the heart of the bovine TB problem. Given the even distribution
of badgers, this rather suggests that a factor within the management
of the herd rather than within the local badger population is
the cause of the problem.
58. The fourth and final factor to note
is that the disease only increased sharply and consistently in
the wake of foot and mouth disease. We lay the blame for this
firmly at the feet of Defra and the NFU. Under pressure from the
NFU, Defra allowed the restocking of slaughtered herds with untested
livestock, triggering the most dramatic increase in bovine TB
for years. This catastrophe was predicted by the Badger Trust
and by the ISG, yet badgers have been blamed instead.
59. The following graph indicates the progress
of bovine TB in a group of parishes centred on Coppenhall in Staffordshire.
The other parishes are Acton Trussell and Bednall, Bradley, Castle
Church and Dunston. We draw this example to the Committee's attention
because Coppenhall's only infected herd is owned by Bill Madders,
a member of Peter Jinman's Bovine TB Advisory Group.
60.
61. Mr Madders' herd went down with bovine
TB in 2006 and he told Farmers Guardian: "The local SVS view
is that it is almost certainly badger contamination of the pasture
last spring... . The consistent view coming out of the State Veterinary
Service is that until we do something about the disease in the
wildlife it will get worse. It is the politicians that we're up
against.[14]"
62. Yet for the last 10 years no herds in
Mr Madders' parish have had bovine TB. In the surrounding parishes,
only one herd had been affected by the disease for most of the
period. Only since foot and mouth disease has that number risen
to four cases, but the affected herds are scattered, with one
in each of two parishes and two in Bradley. This scattered distribution
is not easily explained if, as state vets and Mr Madders claim,
a localised "infected badger sett" is to blame.
63. Again, note that the vast majority of
herds in this area are not affected by bovine TB. And again note
that the disease only increased significantly in the wake of foot
and mouth disease.
64. In conclusion, the Badger Trust takes
the view that a badger cull at any scale would be a grossly disproportionate
response to the bovine TB problem. Instead, we believe that the
Committee should urge the Government to instead adopt positive
solutions that will be supported by everyone concerned and, in
particular, by tax payers.
POSITIVE SOLUTIONS
E. Reforming Animal Health
65. Recommendation 1: The Badger
Trust recommends the establishment of an Epidemiology Research
Unit that is fully independent of Animal Health. It will use lay
staff under the supervision of independent scientists to gather
useful epidemiological data to support the battle against bovine
TB—and potentially against other diseases, too.
66. For 40 years, state vets have been responsible
for advising on the best policy strategies for bovine TB control
and for determining the course of scientific research in this
field. State vets were behind the narrow terms of reference imposed
on historic enquiries into bovine TB, from Zuckerman[15, 16] to
Krebs[16], all of which focused attention on badgers rather than
on bovine TB itself.
67. The ISG, to its credit, rejected this
dogmatic approach in favour of a broader research base. As a result,
the evidence now clearly shows that bovine TB is still very much
maintained and spread by cattle[3]. It is transmitted rapidly
to badgers who are the unwitting victims and consequential scapegoats.
68. Nevertheless, state vets and retired
state vets continue to make public claims that they know best
and that badger culling is essential. Yet despite their claims
to be authoritative, state vets do not have any epidemiological
evidence to support their argument. In fact, the opposite is true.
69. Animal Health (formerly the State Veterinary
Service) is not currently able to effectively manage the bovine
TB epidemic in Wales or in Great Britain because it lacks adequate
data and its IT systems are, in the words of Animal Health itself,
"archaic"[17].
70. In June 2007, the Badger Trust published
a report demonstrating that state vets do not possess any evidence
to explain the epidemiology of bovine TB or, as a result, to manage
the problem of bovine TB. Their claims are, instead, based on
supposition and anecdote[18]. This is not a satisfactory way to
determine policy.
71. The report found that:
(i) State vets do not collect sufficient
evidence to explain the underlying epidemiology of bovine TB events.
Furthermore, the limited data that is gathered is held on paper,
not data processed and never statistically analysed.
(ii) State vets rely on unreliable farmer
evidence about where livestock have been held on farms with multiple
land parcels. Consequently, state vets cannot say with any authority
where a TB outbreak was acquired. This, in turn, means that it
would be impossible for state vets to determine where badgers
should be killed, in the event of the Government approving such
a policy.
(iii) Animal Health (formerly the State Veterinary
Service) does not hold records on badgers, collected by state
vets from farms, for post mortem examination.
(iv) A wide range of failings in the state-run
bovine TB testing programme was identified by the European Union
in 2005. Many of these allow for undetected cattle-to-cattle,
herd-to-herd transmission of TB.
(v) State vets have not been kept up-to-date
with new scientific research on bovine TB. The Introduction to
the online bovine TB practise manual (VIPER) had not been updated
for a decade.
72. The full report is available online
at http://www.badgertrust.org.uk/content/w-campaign.asp.
73. Our analysis of subsequent data gathering
by state vets (Appendix A) confirms that they still have no epidemiological
evidence to support their demands for badger culling or to support
the implementation of a badger culling strategy. Nor do they have
data with which to comment on cattle management and other possible
risk factors. They are effectively in the dark.
74. In summary:
(vi) The SVS has never had a system for collecting
and analysing epidemiological data on bovine TB.
(vii) When TB99 (TB49's successor) was implemented,
the SVS consistently failed to obtain adequate scientific controls
to complement the case studies. This greatly weakened the potential
for sound scientific analysis.
(viii) Disease control emergencies including
classical swine fever and foot and mouth disease totally disrupted
the collection of epidemiological data by state vets. Future outbreaks
of disease will have the same effect.
(ix) With the current Disease Report Form,
Animal Health is failing to gather epidemiological evidence to
inform the battle against bovine TB and the EU's 2005 findings
suggest that the DRF might be a futile exercise even in addressing
the particular breakdown in hand.
(x) State vets only gathered adequate data
for the Case Control Study 2005 when a specific person was assigned
to maintain internal pressure for its delivery.
75. When its report on Animal Health was
published, the Badger Trust advised the then Secretary of State
for the Environment, David Miliband, to treat state vets' advice
with caution. The Badger Trust urges the Select Committee to take
the same approach. Whilst we do not dispute state vets' good intentions,
claims that are not supported by a robust evidence base should
be rejected.
76. What is the alternative approach? Animal
Health must play a central role if bovine TB is to be controlled.
But resources are stretched and are likely to be stretched still
further by inevitable, future outbreaks of animal diseases arising
from intensive farming practices and large-scale animal movements.
More efficient use must be made of resources.
77. The Badger Trust's report found that
in 2005 and 2006 alone, state vets spent the equivalent of between
11 and 15 working years collecting paper-held data on bovine TB
outbreaks. This is not an effective use of the time of skilled
professionals, particularly given that the data contributes nothing
to our epidemiological knowledge.
78. The archaic paper-based approach by
Animal Health must be replaced with a new and independent Epidemiology
Research Unit (ERU) with its own budget and team of lay researchers
whose function is to gather epidemiological data on a digital
system. The costs of investing in such a system could be balanced
by reducing the number of state vets, who will no longer need
to spend hours of time recording data on paper that is never to
be analysed. Data gathering does not require the skills of a state
vet, since it is essentially an administrative service.
79. Giving the ERU its own budget will protect
it from the impacts of disease control emergencies faced by Animal
Health. Decisions concerning what data are to be gathered, and
the methodology used, should be made by an independent panel of
scientists who can then update the data gathering protocol in
the light of initial findings. The appointments to this panel
should be independent of the chief vet and made, instead, by Defra's
chief scientific adviser.
80. Whilst our focus is on bovine TB, it
is also likely that the Epidemiology Research Unit will be able
to gather data for use in combating other serious livestock diseases.
F. Utilising independent scientific advice
81. Recommendation 2: The Badger
Trust believes that the Government should appoint an independent
scientific panel to ensure that new TB policies are based on sound
science and, crucially, that the benefits of the policies are
properly monitored after their introduction.
82. In 61, above, the Badger Trust describes
how state vets have maintained a focus on badgers in the search
for a solution to bovine TB—and failed. In fact, it is now
clear that cattle are the primary source of the problem and the
supposed "gold standard" skin test is inadequate to
the challenge of tackling bovine TB in a livestock economy that
involves large, intensively managed herds, substantial numbers
of animal movements over short and long distances and a testing
regime that is not frequent enough.
83. At the root of state vets' failure to
address bovine TB has been the misunderstanding that having a
scientific background equates to having scientific expertise in
the epidemiology of a disease. As illustrated in Recommendation
1, above, it is patently clear that Animal Health suffers from
a lack of epidemiological knowledge, not a surfeit of it.
84. The Badger Trust believes that the time
is right for a genuinely independent and scientific approach to
formulating bovine TB policy.
85. State vets and the existing TB Action
Group (TBAG) will, of course, still play a role in advising on
the practical implementation of policy. But the formulation of
policy must be science-based and removed from the bias and baggage
associated with state vets and stakeholders.
86. The Badger Trust's preferred option
is that advocated for a Science Advisory Board (SAB). The SAB
was proposed by Defra's Science Advisory Council (SAC) in 2005
and accepted by former animal welfare Minister, Ben Bradshaw,
in 2007[19]. Unfortunately, progress in establishing the SAB has
been painfully slow, revealing a lack of enthusiasm in Defra where
state vets wish to protect their positions as the main source
of advice to ministers[20].
87. The Badger Trust respectfully draws
the Committee's attention to the advice of Defra's SAC, which
has provided a detailed proposal for the structure of the SAB.
The SAC recommended that the SAB should have "the clear remit,
breadth of expertise and coverage to enable it to have oversight
of all available bTB science, both from within and external to
Defra, bringing it all to bear in providing advice to the Department;
such advice should include the identification of gaps in the evidence
base... it was essential that bTB SAB had a chair who was independent"[21].
88. The SAC also warns of the dangers of
confusing stakeholder input with independent scientific advice.
As the SAC advised: "TBAG should not be seen, or used, as
an alternative source of scientific advice to Ministers... the
remit and role of TBAG needs to be clearly identified as distinct
from the scientific advisory roles played by the [Chief Veterinary
Officer] and the [Chief Scientific Advisor]."[21].
89. An additional role for the SAB—whatever
form it takes—should therefore be to provide farmers, state
vets and private vets with independent, clear advice on the science
underlying bovine TB policy and the benefits that the policy is
expected to bring. This will counter the speculative misinformation
put about by farming organisations and help to minimise discontent
and an unwillingness to co-operate with improved TB controls.
90. An independent scientific panel would
be able to comment on the accuracy or otherwise of claims made
about bovine TB control strategies, helping to ensure understanding
of the issues within the farming community.
G. Improved slaughterhouse surveillance
91. Recommendation 3: The Badger
Trust believes that the Government should establish an incentive
system for people involved in the slaughter and inspection of
cattle and deer, to maximise the reporting of suspicious lesions.
92. Before bovine TB can be controlled in
cattle, it needs to be detected. The identification of bovine
TB lesions at slaughter makes a modest contribution to the effective
monitoring of the disease in cattle, even though only around 14%
of infected animals have visible lesions[22]. Research also shows
that deer, particularly high density farmed and park deer, show
TB infection even more readily than do cattle, yet the Badger
Trust notes that very few infected deer are ever reported, even
though research has indicated a number of localities where the
disease is clearly a problem in deer[23].
93. A study of the minutes of ISG's meetings
reveals consistent concerns about consistency and objectivity
of slaughterhouse surveillance for bovine TB[24]. High variability
in the consistency of slaughterhouse identification of bovine
TB has also been found in the Republic of Ireland[25]. And in
the United States, a bonus scheme has long been in operation for
slaughterhouse inspectors, to improve standards of reporting.
This has resulted in 38 of the 40 slaughterhouses which deal with
94% of the cattle in the US "meeting or exceeding targeted
surveillance levels".[26] (Michigan in the USA has a known
wildlife reservoir for bovine TB in the form of white-tailed deer.
These are fed illegally by hunters resulting in high densities
that are susceptible to infection—not unlike deer parks
and farmed deer in the UK. Virtually all other cases of bovine
TB infection dealt with at federal level have been traced to cattle
movements from Mexico).
94. The Badger Trust concludes that an incentive
scheme for those involved in the slaughter and processing of cattle
and deer should be tested, to see whether the consistency of slaughterhouse
reporting improves.
H. Annual testing, gamma interferon and resource
efficiency
95. Recommendation 4: The Badger
Trust believes that the Government should: introduce annual bovine
TB testing across England; apply whole herd slaughter for problem
herds; urgently review the progress of gamma interferon testing
and upgrade laboratory facilities accordingly; and, improve the
use of resources by involving trained lay personnel rather than
vets in bovine TB testing.
96. In 2001, the ISG noted that "annual
testing of all herds will give a true measure of annual incidence
whereas testing at two, three or four year intervals will not,
because some of the infections detected could have been initiated
in previous years"[27]. One of the consequences of this is
that the apparent "increase" currently being recorded
in bovine TB is in large part the product of increased testing.
As more infected herds are found, the number of parishes subject
to annual and biannual testing increases, leading to further discoveries
of infection.
97. In July 2006, the ISG's Chairman advised
Defra officials that "a four-year testing regime was not
appropriate. He and the Group believed that pre-movement testing
was an important surveillance tool but that annual testing for
the whole country was necessary. Resource for this should be found,
some of which could be released by eliminating problem herds since
52% of tests were carried out on only 4% of herds". Defra
officials rejected this proposal on the grounds that: "the
Department would not operationally be able to undertake uniform
annual testing; a proportionate and measured response was required
focussing on pre-movement testing with consideration of a new
hotspot policy and greater use of the gamma interferon test. He
said that annual testing for the National Herd would represent
a disproportionate approach, and was not practicable to deliver
with the veterinary resource available"[5].
98. It is not clear whether the ISG's advice
on annual testing was ever communicated to Ministers at Defra.
However, the failure to implement an annual testing policy suggests
that Ministers were unaware of this scientific advice. Given both
scientific and farming support for annual testing, the Badger
Trust believes that the Government should apply annual testing
across England.
99. Also in 2001, the ISG observed that:
"Given the increased incidence of cattle herds affected with
TB, and the incomplete sensitivity of the tuberculin test, it
is likely that increasing numbers of infected cattle are remaining
undetected". As more evidence emerged of the failure of the
tuberculin test and as Defra dragged its feet on assessing the
gamma interferon test, the ISG became increasingly frustrated:
"We have consistently questioned the effectiveness of the
conventional tuberculin test in situations of high disease incidence.
Its value as a herd test is fully accepted, but as a test to identify
individually infected animals it is far less dependable. The opportunities
for disease transmission from infected animals at all stages of
the disease process, and the difficulties of diagnosing some of
these animals using the established skin test, have been demonstrated
in laboratory and field studies on the pathogenesis of TB in cattle.
We believe, therefore, that the case for developing improved techniques
of diagnosis is overwhelming, and have repeatedly advised that
far more emphasis be placed on this particular objective. It is
for this reason that we have given continuing support to the development
and field evaluation of the gamma interferon (IFN) test (although
as yet not perfect) as offering the best prospects for more effective
identification of TB-infected cattle. We have advised that complementary
use of this test with the tuberculin test is the only realistic
way of tackling the substantial reservoir of disease in cattle
that appears to be present in some areas, and also to reduce radically
the risk of transmission of disease to new areas of the country.
Defra's unwillingness to accept our advice on the design of a
field trial of the IFN test which would be rigorous enough to
yield the kind of data on its performance that are essential to
provide an informed basis for its use in a range of control options,
has been disappointing and extremely worrying".
100. The value of the gamma interferon test
should not be underestimated. Between 1 January and 31 July 2007,
18.3% of the cattle tested with gamma interferon in Wales were
positive to the test. Inexplicably, the proportion in England
was lower. In Wales, this resulted in the removal of more than
250 dangerous contacts that would otherwise have remained in the
herd to infect other cattle. Yet as of 31 July 2007, Defra and
the Welsh Assembly Government were still well short of the target
of 50,000 cattle due to be subject to gamma interferon this year.
101. It is not clear why the implementation
of gamma interferon is not taking place as rapidly as it should.
The Badger Trust would welcome an assessment of the slow progress
on this front by the Rural Development Sub-Committee. One problem
is thought to be the lack of laboratory facilities to rapidly
process the blood samples. The Badger Trust therefore believes
that the Government must establish a suitable infrastructure for
testing blood samples.
102. Finally, the Badger Trust believes
that bovine TB will only be effectively controlled and reduced
if the current infrastructure for dealing with it is subject to
reform. The ISG has already suggested that removing the 4% of
herds that currently consume more than 50% of the TB testing effort,
thus releasing funds, could save resources.
103. In addition, we believe that lay personnel
would be able to deliver the administrative functions of bovine
TB control more cost-effectively than state vets. We have already
cited the example of epidemiological evidence gathering. Other
key functions that could be dealt with by administrative, lay
personnel rather than qualified vets include:
(i) Organising the removal of test-positive
cattle from farms—something which farmers believe is taking
place too slowly;
(ii) Organising the valuation of cattle and
compensation, to ensure fairness for both farmers and tax payers;
(iii) Undertaking detailed checks of farm
records and the British Cattle Movement Service, to ensure compliance
with the relevant legislation (this task currently falls to Trading
Standards Officers, but often in the wake of reports of possible
non-compliance by state vets).
I. The politics of the issue
104. Following the publication of the ISG's
final report, farming groups have argued that more intensive culling
and/or culling over very large areas (ideally with some "hard"
boundary) would make badger culling feasible. The Badger Trust
notes that the ISG rules out these options[12] for scientific,
practical and economic reasons. We also note that farming groups
have failed to make an economic case for such a strategy; they
have not made clear how it could be delivered in practice with
humaneness and rigour. Nor have they made clear how the huge range
of practical problems, such as limited access to land, could be
addressed. We would be surprised if farming lobbyists have provided
convincing answers to these questions when they met members of
the Select Committee on their recent visit to Devon.
105. The Badger Trust rejects claims by
farming groups (and, it is alleged, by Lord Rooker) "that
the ISG has gone outside its remit"[28] with the cost-benefit
analysis in its report. A detailed examination of the ISG's minutes
confirms that effective cost-benefit analysis (CBA) has long been
part of the ISG's remit. Ministers were kept fully informed of
progress on this front through the ISG's regular reports. The
ISG's work on cost-benefit analysis was detailed at some length
in 2000, in the ISG's second report to Ministers.[29]
106. The Badger Trust notes tensions between
Defra and the ISG over the issue of cost-benefit analysis. Although
Defra was well aware of the ISG's work on this front, it nevertheless
pursued its own CBA (Research Project SE3117) and `the project
was to proceed regardless of any scientific review procedure and
[Professor McInerney, the ISG economist] considered this an abuse
of the system. The [ISG] Chairman agreed'. In the event it made
little difference, since Defra's own partial CBA failed show any
economic justification for badger culling.
107. Farming groups have complained that
the ISG undertook a "partial" cost-benefit analysis,
in focusing only on badger culling and not on the costs of cattle
controls.
108. The Badger Trust points out that badgers
are a public good. The public response to consultations on badger
culling has shown that they are highly valued by the public. It
was essential that the ISG considered the cost-benefits of badger
culling. In contrast, cattle are a private good. The cost-benefit
analysis for protecting this private asset falls to the owners,
the farmers, although inevitably Government has an interest in
this cost benefit analysis since bovine TB is a zoonosis and since
taxpayers are currently subsidising the private economic interests
of farmers through compensation for TB losses.
109. Farming groups have suggested that
the ISG should have considered "the economic, social and
ecological cost if cattle farming were to be made unviable in
some areas of the country".[30] This a classic example of
muddled thinking from the unions, in which a range of private
and public goods are lumped together and treated as one. It suggests
that the farming unions continue to believe that the cost of addressing
bovine TB is an issue for the public purse rather than for the
industry.
110. In fact, the viability of the livestock
industry is more significantly influenced by the shift away from
production subsidies in a global marketplace, where economies
of scale will inevitably squeeze smaller producers out.
111. The Badger Trust believes that the
Select Committee would greatly help matters if it were to make
it clear where it feels the responsibility for controlling bovine
TB lies. Significant global forces are changing the structure
of the beef and dairy industry and the Government must avoid falling
into the trap of confusing these global shifts with the impacts
of a disease that affects a relatively small proportion of herds
as a direct result of farmer behaviour.
112. Given that tax payers are currently
subsidising the livestock industry with compensation for a disease
which could be 70% eliminated if farmers agreed to participate
in effective testing regimes, deciding who should pay is an issue
of critical importance.
113. We make the following observations:
70% of the bovine TB problem is attributed to cattle-cattle transmission;
cattle infect badgers, a protected species, with bovine TB in
the first place; public health is protected by the disposal of
milk from reactors, by pasteurisation and by cooking meat properly.
Therefore, the cattle-based benefits of bovine TB control are
effectively a "private good" and the economic responsibility
of farmers, who are the primary beneficiaries. But since taxpayers
are delivering compensation, the Government needs to take responsibility
for taxpayers by compelling farmers to comply with a stricter
testing regime.
114. It has been suggested by some farming
lobbyists that placing the economic responsibility of bovine TB
control on farmers would destroy the industry. The Badger Trust
observes that livestock auctioneers claimed that pre-movement
testing would have a similar effect and this was clearly wrong.
Nevertheless, if the costs of delivering effective standards of
farm animal health and welfare are beyond some sectors of the
industry, that is not the fault of badgers and badgers should
not be scapegoated for those shortcomings.
115. The Badger Trust is also concerned
at the limitations of the ISG's cost-benefit analysis, but for
different reasons. We note that farming lobbyists are obsessed
only with the cost-benefits of badger culling. No consideration
is given to the cost-benefits of other possible measures that
would minimise the risk of bovine TB transmission from cattle
to badgers, and back again.
116. The ISG's final report notes that more
than 90% of bovine TB-infected cattle present with pathology that
"implies that such infections are acquired as a consequence
of close contact with other animals (cattle or wildlife)".
The ISG also concludes that the pathology of bovine TB in badgers
also "suggests that most infections are acquired via the
respiratory route".[12]
117. In the field, there is little opportunity
for close contact between cattle and badgers: badgers rarely approach
within four metres of cattle. In farm buildings, however, CCTV
footage has now shown that badgers come into very close contact
with cattle when foraging in cattle feed.
118. The Badger Trust finds it extraordinary
that no-one in either the farming community or in Government has
yet produced a cost-benefit analysis of keeping badgers out of
farm buildings. We suggest that before the Government even considers
badger culling, it should fund a case control study of preventing
badger access to farm buildings, feed stores, cattle sheds and
troughs, to see what effects are achieved in minimising bovine
TB transmission between cattle and badgers.
119. This would, in effect, be the Plan
B that the former Agriculture Select Committee called for way
back in 2001.[31] For minimal investment—by the taxpayer,
if the Government deems it worthwhile—it is possible that
the majority of the small amount of negative feedback from badgers
could be eliminated in this way, to the satisfaction of farmers
and taxpayers alike.
October 2007
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