Select Committee on Merits of Statutory Instruments Eighth Report


SI 2005/2015  Veterinary Surgery (Testing for Tuberculosis in Bovines) Order 2005

Paper submitted by Royal College of Veterinary Surgeons


The Royal College of Veterinary Surgeons (RCVS) has debated with DEFRA and its predecessor the Ministry of Agriculture, Fisheries and Food over many years the question whether it would be appropriate for lay technicians to carry out TB testing in cattle. This note summarises the recent history and issues.


On 4 July 2003 DEFRA consulted on the proposal "that trained and competent non-veterinarians should be permitted to carry out tuberculin testing of cattle". RCVS responded on 7 November 2003 offering advice on which parts of the testing procedure could properly be delegated to trained lay people. RCVS also sought clarification of the proposal. A discussion took place on 17 February 2005 and the issues were debated further in subsequent correspondence.


The test entails injecting tuberculin and, 72 hours later, checking for an increase in skin thickness at the injection site. A significant thickening of the skin may be evidence of an immune response, implying that the animal has been exposed to infection. An immune response may also be evidenced by certain clinical signs such as oedema or exudation, so it is necessary to note such signs even if there is no clear increase in skin thickness.

Official TB tests are normally carried out in England and Wales by private practitioners acting for the Department under contract as Local Veterinary Inspectors (LVIs). The LVI reports the outcome of the test, including any clinical signs observed, to the DEFRA Animal Health Divisional Office for interpretation.

Issues over the conduct of the test

RCVS sees no objection to the use of a trained technician to inject tuberculin and measure skin thickness but considers that the observation of clinical signs is a matter for a veterinary surgeon. DEFRA's response is that technicians would be trained to identify cases which called for veterinary examination. RCVS questions whether a lay tester could reliably spot the presence of the relevant signs.

An EU Directive specifies how the test is to be carried out, including both the measurement of skin thickness and the observation of clinical signs. Most of the TB tests carried out in the UK do not need to comply with the Directive, but DEFRA have confirmed following consultation with the Commission that those tests which do need to comply with the EU requirements will have to be carried out by a veterinary surgeon.

It is unclear how lay testing would work in practice. It is not envisaged that the technician would be accompanied by a veterinary surgeon, since this would jeopardise the desired resource savings. LVIs are, however, required to inspect all the cattle to be tested and carry out a clinical examination of any suspect animals. A veterinary surgeon would therefore need to carry out the clinical inspection and, where necessary, examination, before the technician administered the test. The technician would also need to be able to seek help from a veterinary surgeon at the second stage of the test if the animal was suspected of showing relevant clinical signs. Such signs ought, however, to be observed 72 hours after the initial injection. It might not be possible to arrange for a veterinary surgeon to examine the animal reasonably promptly.

The pilot scheme

The SI is designed only to enable DEFRA to carry out a pilot scheme using lay testers employed within the State Veterinary Service. The Department has said that, if the pilot is successful, LVI practices would be offered the option of employing lay testers and that there is no present intention to use Departmental staff for the purpose. RCVS questions, however, whether a pilot scheme using experienced non-veterinary members of the State Veterinary Service would be a valid demonstration of how it would work if practices used lay testers.

Viability of farm animal veterinary practice

There is a wider issue. The difficult financial situation of many livestock farmers in recent years has made farm animal veterinary practice less viable in some areas. The EFRA Select Committee of the House of Commons reported in October 2003 on "Vets and Veterinary Services" (sixteenth report of the 2002-2003 Session), noting concerns about the adequacy of veterinary cover and the need for "a greater on-farm presence of veterinary surgeons" in order to deliver the Government's strategies for animal health and welfare and veterinary surveillance. The present TB testing system has the incidental benefit of getting local veterinary surgeons on to farms, and it supports the viability of those practices which deal with farm animals. RCVS does not oppose the intelligent use of trained non-veterinary staff for appropriate tasks but questions whether it is expedient to introduce lay TB testing at this time.

Royal College of Veterinary Surgeons

10 August 2005

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