106. The pattern of TB incidents shows that there are local variations in risk with two almost identically situated farms experiencing very different levels of TB breakdowns. As has been noted earlier, Professor Krebs identified one factor in this variation as farm husbandry. He did not explore this possibility any further but this suggestion has received support from many witnesses to our inquiry. Several cited a research paper from Ireland which concluded that the practices associated with increased risk were failure to provide mineral licks, rough grazing areas, purchase of bulls, spreading of slurry and the intensive management of cattle.[316] The NFU questioned the validity of this particular piece of research,[317] although they were generally supportive of work to identify beneficial husbandry practices.[318] The difficulty, as witnesses agreed, is that at the current time "no-one has been able to say this is a high risk, that is a low risk and that is of quantitative significance".[319] Professor Bourne added that "at the moment it is very much a guessing game and I have great sympathy for farmers saying:`Well, okay I will do it but is it really going to provide any benefit to me' and the answer is we do not know."[320]

107. In any case, the advice received by farmers on husbandry practices has been inadequate. In the past, MAFF's policy on the role of husbandry in the control of bovine tuberculosis has been to disseminate advisory leaflets to the farming community, and to exhort farmers to follow this guidance. However, among witnesses this policy was widely seen as having little or no influence on livestock management practices.[321] The NFBG pointed out that it was aimed only at keeping cattle and badgers apart (a phrase used as the title of the leaflet) and did not address the wider potential risks to cattle,[322] while the CLA suspected that "the existing advice has not been widely heeded because it is impractical and substantial costs are involved."[323] We were also told by Mr Gill of the NFU that these advisory leaflets had been withdrawn by MAFF five years ago, pending a review by the Ministry, and not yet replaced.[324] We understand that new leaflets are to be issued shortly,[325] but in the meantime, as the Wildlife Trusts told us, farmers are confronted by a "lack of information and advice" from MAFF.[326] The withdrawal of the leaflet demonstrates MAFF's awareness of its shortcomings, but to do nothing to determine what better advice should be offered to farmers is unacceptable.

108. There is little evidence that the farming community itself has acted to compensate for this lack of advice from the Ministry or to develop their own ideas of husbandry practices which might assist in the control of bovine TB in cattle. We were concerned by the negative attitude expressed by many towards the various suggestions made for changes in husbandry methods. The NFU dismissed "a lot of the ideas that have been put forward" as "utterly impractical" but were not prepared to make their own recommendations.[327] At least two other witnesses from the farming sector called for individuals to be allowed to cull badgers on their own land, thus underlining the firm belief of many that the badger alone is to blame.[328] There is some evidence that general trends in farming such as intensification are having a detrimental effect on the incidence of certain animal diseases, including bovine TB, and that specific cropping practices such as increased maize growing encourage the presence of badgers. Professor Krebs spoke of the industry needing to take "ownership" of this issue.[329] As a result of the publication of the Krebs report, the industry has now acted through the Milk Development Council to commission research into husbandry practices, the results of which are expected by the end of April 2000.[330] We welcome this development but while we accept that farmers cannot be expected to implement expensive management changes of unproven benefit, we are not convinced that the industry as a whole has done enough in the past to address the multifactoral nature of the bovine TB problem and the possible role played by husbandry practices in finding a solution.

109. The Krebs report proposed two approaches to the identification of effective husbandry practices: collecting data on existing practices in order to correlate variables to incidence of TB breakdowns, and proactive experiments to test likely practices on matched farms. Both Krebs and Bourne favoured the statistical approach, the latter arguing that "there are so many variables that [field experiments] simply would not give, in our view, any sensible results." He believed that "the only sensible approach to this is through risk analysis which can analyse a whole range of effects which are just not accessible to ordinary scientific investigation".[331] Data for this purpose is to be collected through an epidemiological questionnaire, known as the TB99 form. An earlier version, TB49, was discontinued following Krebs' conclusion that it did not satisfactorily take into account local correlates of risk other than the badger. The new form has been drawn up by the Bourne Group in consultation with the industry.[332] There are two versions, one for use on farms which have experienced breakdowns and one on control farms. TB99 is therefore seen by MAFF as a tool for management, epidemiology and data collection purposes.[333] There has been some confusion over which farms are to be included in the survey, particularly over whether low risk farms or those outside the trial areas were to be used as controls. Mr Scudamore of MAFF told us that, now that the form has been piloted on 29 farms, it will be used both in the trial areas where there will initially be one control to each affected farm, rising eventually to three controls, and outside the trial areas on all farms experiencing breakdowns in the whole of the country.[334] The data from this could then be analysed to identify potential risk factors, not just in husbandry, but also local variables.

110. We have seen the finalised versions of the two forms and appreciate the effort that has gone into producing them. The NFU greeted TB99 as "a major step forward".[335] However, we have reservations about its use in the field. The main form is over 30 pages long, with the control only slightly shorter. Although it is to be filled in by MAFF staff, we believe few farmers would find the time necessary to assist in its completion. We also doubt that vets or Animal Health officers, despite the best endeavours of the Ministry to provide training and guidance, could attain the necessary degree of objectivity, given that the form is still biased towards the assumption that badgers are the chief cause of bovine TB in cattle, if only in the size of the space available for answers. It appears to us that without significant revision TB99 will be too lengthy and complicated to be administered easily and effectively. Administrative costs arising from the widespread application of TB99 as drafted could be prohibitive and it is likely that if TB99's complex structure is retained, it will increase the probability of serious errors being made at the data input stage, which might undermine or invalidate experimental results. We are also concerned that with so many variables, invalid correlations could be drawn, leading to further problems. We recommend that, in consultation with the farming industry, MAFF and the Bourne Group simplify TB99. The new questionnaire should then be subject to a rigorous pilot exercise on farms and assessed for ease of administrative handling before approval is given to a final version.

111. Subject to these reservations, we agree that the collection of data on existing husbandry practices by means of the TB99 form or a variant of it constitutes a useful way forward and should be implemented as soon as possible. However, results from the questionnaire are not expected for some time. The second approach - that of designing anexperiment or series of experiments to test different practices - offers a more proactive and directed strategy. Krebs had suggested in his report that "outside the hot-spot areas the farming industry itself should take the lead in carrying out a proper experimental comparison of the impact of a small number of simple husbandry techniques". MAFF should offer advice and analysis.[336] As we have argued earlier, we agree that farmers should take more responsibility for acting in their own best interests but we are not convinced that they are well placed to take advantage of the latest scientific research on husbandry practices, to design experiments based on these practices, or to put these experiments on the necessary scientific footing. The BVA has offered its services in developing new practical guidelines for farmers to improve biosecurity on farms and in encouraging its members "to work with farmers in the application of alternative husbandry strategies".[337] MAFF too has a role to play and has made a cautious start in opening dialogue with farmers' representatives on husbandry issues. However, we recommend that, in addition, MAFF appoint a small panel of experts to undertake a fast track review of the available scientific evidence on husbandry, taking evidence from the industry and the veterinary profession as appropriate. This expert panel should report to MAFF within three months with recommendations as to whether husbandry experiments are justified at this stage and if so which experiments would be most promising in terms of their likelihood of controlling disease outbreaks. These experiments would then be allocated at random and implemented on holdings identified by the industry outside the trial areas, as recommended by Krebs.[338] In this way, husbandry issues would be given the priority they deserve without distracting attention or resources from the culling trial.

112. The Soil Association raised with us a particular area which we believe would provide a worthwhile starting point for investigation. They suggested a comparison of the incidence of bovine TB on organic farms with that on conventional farms.[339] As they point out,"the strict husbandry standards and detailed record-keeping followed by organic producers, the improving geographical spread of organic farms and the increasing rate at which producers, especially dairy farmers, are converting to organic production provides a unique and extremely low cost opportunity for comparative analysis to be undertaken by MAFF."[340] We agree, and commend the proposal to the Ministry.

113. The NFU and other groups raised the question of who should pay for husbandry experiments and concluded that it should not be the farmers.[341] We have several reasons for agreeing that the Government should underwrite the cost. Investigation into the effect of husbandry practices on the transmission of bovine tuberculosis is no less valid a component than other elements of Krebs' disease control strategy, which are all MAFF funded. To suggest that the costs of husbandry research should be borne by the industry would therefore not only be inconsistent: it would also downplay the importance of the husbandry issue, which we consider at this stage cannot be justified scientifically. As experiments involve risk, it is unreasonable to expect an individual farmer to undertake husbandry experiments which may reduce his income and increase his expenditure, at a time when farming incomes remain seriously depressed. Since MAFF would be responsible for identifying practices, it is fair that they should underwrite the cost of implementation, which would also help ensure that all trials are undertaken to the same standard. We recognise that the expenditure implications could be substantial, but by restricting the research to the most promising practices, these costs could be mitigated. Furthermore, the information yielded from these experiments could result in the identification of practices which lead to a sharp reduction in bovine tuberculosis outbreaks, leading to a corresponding reduction in levels of compensation paid by MAFF. On this basis, we recommend that the Government finance the cost of accelerated research investigating the most promising husbandry practices likely to assist in the control of bovine tuberculosis. This is a different issue from that of whether farmers should receive compensation to implement good husbandry practises, an idea vigorously rejected by the Minister,[342] or alternatively should be fined for not implementing them.[343] Such questions will only arise when appropriate measures have been identified and their cost-effectiveness evaluated.

Compensation for farmers

114. We heard from the NFU[344] and the TFA[345] of the plight of farms afflicted by herd breakdowns, and how present compensation arrangements did not adequately reflect the often catastrophic consequential losses attached to these events. It was suggested that this could cause particular grievance in the no-cull areas where farmers had "the worst of both worlds", a "purely negative role in the scheme".[346] The RSPCA and the CLA, among others, were concerned that this could lead to illegal culling in these areas and hence disrupt the experiment.[347] In a reply to an Adjournment debate on 22 February 1999, Mr Rooker made clear that MAFF recognised that compensation covered only 16% of total costs borne by farmers, but also emphasised that financial constraints on the Ministry prevented compensation being raised above the current level "at present".[348] While compelling individual cases were brought to our attention during the course of this inquiry which could with justice be deemed 'special cases', our view is that it would be profoundly unfair for certain producers to benefit from higher levels of compensation than others. Such monies as were used for this purpose would also inevitably decrease the funds available for research, the introduction of new triplets, and the implementation of the research into husbandry we have recommended. Reluctantly therefore, we recognise that within current spending limits set for the Ministry in the Comprehensive Spending Review, national levels of compensation cannot be raised to reflect consequential loss. However, we also note that in his reply, the Minister left open the possibility that the situation may be reconsidered. We repeat that, if farmers are to bear the costs and stress associated with a herd breakdown without increased compensation, then they must be convinced that all elements of the Krebs report are being implemented speedily and effectively.