APPENDIX 21
Memorandum submitted by the British Veterinary
Association (L25)
1. The British Veterinary Association (BVA)
welcomes the opportunity to submit written evidence to the Agriculture
Committee inquiry into badgers and bovine tuberculosis. This is
an animal health issue that has long been of ongoing concern to
the veterinary profession as a whole.
2. In the past, the BVA has submitted evidence
to both the Krebs Independent Scientific Review of bovine tuberculosis
in catttle and badgers (March 1997) and the Bourne Independent
Scientific Group on cattle tuberculosis (March 1998). The BVA's
evidence is attached at Annexes A and B respectively. Together
these address a number of the points on which the Agriculture
Committee seeks comment.
3. In response to the Agriculture Committee's
request for the veterinary profession's views, the BVA has consulted
with its relevant divisions and now has the following comments
to make, as a supplement to the documents enclosed. In addition,
the Association is very willing to provide the Agriculture Committee
with oral evidence.
The design and likely effectiveness of the culling
experiment proposed by the Krebs report and any significant issues
which will have to be considered by the independent Expert Group
overseeing the experiment.
4. While the BVA is pleased that a proper
epidemiological study is at last to be set up and looks forward
to the eventual multi-variate analysis, it still has serious concerns.
The experiment is estimated to take at least five years to complete,
with additional time for analysis. In the meantime, the incidence
of herd breakdowns continues to increase and unless short-term
measures are taken to combat the spread of the disease, the UK's
"TB-free" status may be lost, with severe consequences
for trade. Therefore, the BVA requests that the Government carries
out a total badger cull in areas of new and existing breakdowns
which are not included in the trial.
5. The BVA is also disappointed by the Government's
slow implementation of the recommendations set down in the Krebs
report. The culling experiment is not yet functioning at full
strength, having only begun in two areas, and there is still no
definite indication of when the experiment will start in the other
proposed areas.
6. The original statement in the Krebs report
suggested that all badgers in the total kill areas would be culled.
However, it now seems that culling will cease at the end of January,
to avoid the removal of lactating sows, whose cubs may be left
underground. The BVA is of course concerned about the welfare
implications for the badger population, but serious consideration
must be given to whether this change in the experimental design
will affect the validity of the experiment.
7. It is also essential that steps are taken
to prevent the clandestine removal of badgers from the experimental
cull areas, prompted by badger welfare concerns. This would affect
the outcome of the experiment and more importantly may promote
the spread of the disease to previously unaffected areas.
8. The independent Expert Group is welcomed
by the BVA and once again it strongly recommends that a veterinarian,
with practical experience of bovine tuberculosis in the field,
is invited to join the Group. Please note the BVA's original comments
on the implementation of the Krebs report (paragraph 4, Annex
B).
Issues to be considered in the implementation
of the experimental comparison of different husbandry methods
proposed by the Krebs report
9. The BVA welcomes the recommendation to
carry out an experimental comparison of different husbandry methods,
as a means of reducing the spread of bovine tuberculosis outside
the "hotspot" areas. It will be necessary, however,
to clarify what the requirements will be, including the type of
husbandry methods, how they will be implemented and also how they
will be monitored (see paragraph 14, Annex B).
10. The BVA, in conjunction with its specialist
divisions, would like to collaborate with MAFF to develop some
practical guidelines for farmers. Emphasis must be placed on improving
the general "biosecurity" of farms, such as introducing
routine testing of incoming cattle from other areas, as a proactive
measure to help keep herds free from tuberculosis and other infectious
diseases. In the past, similar guidance, in the form of a leaflet,
was produced by the BVA on purchasing imported animals.
11. The BVA would also be in a position
to encourage the profession to work with farmers in the application
of alternative husbandry strategies. Given the severity of the
problem facing farmers, it is important that something is done
to alleviate the situation, before the outcome of the experiment
is known.
The Government's implementation of the changes
in the bovine TB research strategy proposed by Krebs.
12. The BVA supports the recommendations
regarding the bovine tuberculosis research initiatives, however,
this must not detract from the need to develop a short term strategy
to deal with this disease (see paragraph 32, Annex A).
Other issues relating to the question of badgers
and bovine tuberculosis, including the socio-economic effects
of bovine tuberculosis on cattle farmers, the animal welfare implications
of the proposed culling experiment and the public expenditure
implications of the Government's policy following the Krebs report.
13. The devastating socio-economic effects
of bovine tuberculosis on cattle farmers, have long been known.
In particular, the movement restrictions imposed on herds with
cattle testing positive for tuberculosis, can have severe economic
consequences for the farmer, as well as raising welfare concerns.
Controlling the disease will not only alleviate the problems experienced
by farmers, but it will also have the effect of reducing public
expenditure in due course.
14. The culling experiment, if properly
executed, should not have a significant effect on badger welfare,
since it is to be carried out under strict supervision and by
trained personnel. The BVA is sensitive to the concerns of conservation
groups, however, recent studies have confirmed that the badger
is not an endangered species. It is also important to emphasise
that it is in the interests of the health and welfare of both
cattle and badgers, that the spread of this debilitating disease
is halted.
12 January 1999
Annex A
Review of Tuberculosis in Cattle and Badgers
INTRODUCTION
1. The BVA is grateful for the opportunity
of submitting written evidence to the independent scientific review
of tuberculosis (TB) in cattle and badgers chaired by Professor
J R Krebs FRS. Whilst this paper represents a general overview
of the situation, the BVA would welcome the opportunity of giving
oral evidence to the review group and to providing the necessary
detailed scientific references.
2. The veterinarians' primary responsibility
is for the health and welfare of the animals under their care.
In this case, the profession is primarily concerned with the health
and welfare of the cattle. The profession is also concerned that
the farming community receives the best advice in the prevention
of disease spread amongst the animals they own. All this is not
to negate the profession's appreciation of the need to contribute
to and conserve the health and welfare of the natural fauna.
3. The BVA has become exceedingly concerned
about the very marked increase in the incidence of tuberculosis
in cattle, particularly in the South West. It is the most serious
disease problem facing dairy farmers in that part of the country.
In 1996 316 new cattle herds were confirmed as having TB and 2,431
cattle were slaughtered. There is evidence that the disease is
spreading to the north and east. If this continues, the "tuberculosis
free" status of UK cattle within the EU could be threatened.
4. The TB eradiction scheme for cattle has
been successful hitherto. The strategy for eradicating the disease
from badgers has failed. Whilst it is still not fully understood
how badgers transmit TB to cattle or whether cattle transmit TB
to badgers, there is little doubt that there is a link. The escalating
problems associated with TB in cattle need to be addressed.
5. The TB eradication scheme for cattle,
coupled with the pasteurisation of milk, has virtually eliminated
the zoonotic risk from bovine TB, a potentially severe chronic
bacterial disease usually acquired by drinking raw milk from cows
with an udder infection of Mycobacterium bovis. It is a
fact that TB in the human population is increasing but this is
due to the human organism, Mycobacterium tuberculosis, not
in any way connected with the disease in animals.
6. With the emphasis which is quite rightly
being placed on public health, the increase in bovine TB could
compromise the sales of milk from affected herds participating
in various quality assurance schemes being developed within the
food industry.
7. Nevertheless, the veterinary profession
is attempting to control an animal disease with possible implications
for human health. Monitoring for TB is a priority in the slaughterhouse.
It is a fact, however, that public confidence in food of animal
origin has been severely compromised in recent months and positive
action is required to control/eradicate this disease in both the
cattle and badger populations.
ERADICATION OF
THE DISEASE
IN CATTLE
8. Slaughter policies have been remarkably
successful in controlling major farm animal diseases, for example
brucellosis, foot and mouth disease, rabies and to a large extent
bovine tuberculosis. The reasons for success include:
(a) efficient, specific and sensitive tests;
(b) a thorough understanding of the epidemiology
of the disease;
(c) specific, identifiable animal populations
and the lack of wildlife vectors;
(d) commitment on the part of everyone to
eradicate the disease;
(e) public confidence in the policies.
9. In order to control the spread of TB
to cattle, there is a need for a policy which:
(a) stops the spread of new infections;
(b) reduces the incidence in established
areas;
(c) is simple and practical to carry out;
(d) satisfies public opinion;
(e) is acceptable to H M Treasury.
ERADICATION OF
THE DISEASE
IN BADGERS
10. The extension of the TB eradication
scheme to badgers has failed. This is because the parameters for
the successful eradication of disease in domestic farm animals
(see paragraph 8 above) cannot be applied to badgers in the wild.
There are a number of very different reasons for this including:
(a) the limited understanding of the epidemiology
of the disease in badgers and the assumption that there was a
common epidemiology for the disease in both species;
(b) an assumption that the disease was limited
to known and confined populations;
(c) the destruction of many healthy badgers
and strong public interest in the protection of badgers;
(d) the difficulties of detecting infection
in live badgers;
(e) failure to prevent recolonisation of
setts which have been cleared of infected badgers.
11. There have been three major policies
for dealing with the disease in badgers and over the last 25 years
the situation has deteriorated. Increased expenditure has had
little impact on the control of the disease.
(a) Gassing as a means of culling badgers
was inhumane and therefore unacceptable. It was effective, however,
and provided results when sustained in an area of infection.
(b) The clean ring strategy allowed for the
culling of all badgers in the area of an outbreak until a clean
ring around the area was established. The effectiveness of this
strategy increased with improvements in the ability to trap the
badgers. It was also effective as it applied not to herd breakdowns
but to areas. Public opinion was against this strategy.
(c) The interim policy has been the least
effective of the three. It is fundamentally flawed in that it
applies to herd breakdowns rather than badger groups. Thus badgers
are only removed when they enter the "reactor area"
of the farm of breakdown. If they live off the farm they are not
removed and recolonisation of setts can be rapid.
12. During the period of the interim policy,
the incidence of new breakdowns has increased significantly and
efforts to include adjacent farms in investigations have not materially
limited the areas in which the disease has occurred. All three
policies have been reactive. None of them has made a positive
attempt to tackle the source of infection before it spreads to
cattle.
13. There are a number of other contributory
factors which may have affected the incidence of disease:
(a) alterations to wildlife legislation have
increased the protection of badgers. Increases in the badger population
are widely reported but difficult to confirm scientifically;
(b) the widespread cultivation of maize has
provided an attractive new food supply for badgers on many farms;
(c) the increase in the testing interval
has provided longer periods within herds for disease to spread
before diagnosis. Open lesions can develop resulting in subsequent
infection of other cattle by the infected individual.
PROBLEMS WHICH
NEED TO
BE ADDRESSED
14. There are four problems which need to
be addressed:
(a) the control of the disease in cattle,
(b) the development of new and efficient
ways of testing cattle;
(c) the efficient diagnosis of the disease
in the badger population;
(d) an effective method of reducing or controlling
the level of infection within the badger population.
CONTROL OF
THE DISEASE
IN CATTLE
15. The veterinary profession's main concern
is for the health and welfare of the animals under their care.
If TB in cattle is not controlled the implications for animal
welfare are considerable. Herds are under restriction. The farm
resources are limited. Food shortage and inadequate housing may
be the consequence of additional numbers of animals on farm. The
welfare of badgers has to be reconciled with that of thousands
of cattle.
16. Farmers who have experienced TB in their
herds know first hand of the loss of income and expense arising
from movement restrictions, increased stocking density, secondary
diseases caused by overcrowding and time spent testing. Veterinarians
are involved in trying to reduce all these problems and believe
that to allow the epidemic to continue unchecked will negate all
the time, money and effort which has been spent in the past on
getting so close to complete eradication.
EXISTING HIGH
RISK AREAS
17. In existing high risk areas, farmers
have become accustomed to the problems. Although their ultimate
objective is eradication of the disease, they are aware of the
complexities of the issue and there is some sympathy for the continuation
of trials to develop controls other than those which can be achieved
through widespread culling. This is the case particularly around
the borders of the high risk areas. Nevertheless they seek to
minimise loss and to ensure their farms remain clear for as long
as possible. If the current problem continues to escalate, it
may become uneconomic to keep cattle in some parts of the country.
NEWLY AFFECTED
AREAS
18. In newly affected areas there is a strong
case for instituting a rigorous culling policy. In these outbreaks,
the numbers of the affected cattle are large and the incidence
of the disease in badgers is high. Rapid removal of the infected
population to provide a "clean ring" around the outbreaks
does seem to halt the spread. The Morbath area in Somerset is
an example of success in this respect.
19. Perturbation—a term given
to the possible disruptive dispersal of a badger groups following
the interference associated with a removal operation—has
been widely discussed but the hypothesis remains unproven. There
is evidence that odd infected badgers can escape from a removal
operation and that this may disturb populations around the area.
In turn this may cause further outbreaks.
20. There is a strong argument for an investigation
of the number of infected badgers before the commencement of a
removal operation, particularly in fringe breakdowns. The mini
panel has experience of instances where many badgers caught in
a breakdown area have all been fit and healthy. Perturbation of
the badger population may cause a dispersal of infection if the
badger responsible for the original infection escapes the cull.
NATIONWIDE
21. Serious outbreaks are occurring in Gwent
and West Wales. The level of infection in the South West is such
that it is likely to spread into the West Midlands. As many of
the new breakdowns are occurring in these areas, there is a case
for adopting rigorous culling both to deal with the individual
breakdowns and to try to contain the problem.
22. The Thornbury experiment in Avon still
stands as an area which has remained free from TB following extended
and widespread culling. By contrast the surrounding parishes have
all had repeated breakdowns throughout the subsequent 16 years.
Until a more effective way of controlling the disease in cattle
can be found, extended and rigorous culling of badgers in new
areas offers the best available control. Any culling operation
must include lactating sows.
THE DEVELOPMENT
OF NEW
AND EFFECTIVE
WAYS OF
DIAGNOSING TB INFECTION
IN CATTLE
23. The tuberculin test has been outstandingly
successful. It enables a veterinary surgeon to visit the herd
twice to test and then to assess the results. A clinical examination
of the animals is also required. It is reliable and it is also
economically viable. This should not preclude the development
of more efficient tests for the future. Furthermore, the feasibility
of using a vaccine in cattle in infected areas should be assessed.
Attempts to produce an effective vaccine for cattle should be
encouraged.
DIAGNOSIS OF
THE DISEASE
IN THE
BADGER POPULATION
24. In areas where the problem has been
continuing for some time, the live test provides a method of identifying
infected groups of badgers. The evaluation of the live test should
be completed and its use extended to define those infected groups
before removal. This is particularly relevant around the edges
of these areas where the numbers of infected badgers may be very
low and the possibility of perturbation or at least the destruction
of healthy badgers is most likely.
25. The BVA is of the opinion that the powers
of the "mini" panel of the Consultative Panel on
Badgers and Tuberculosis should be extended to provide a wider
range of options when assessing how a breakdown should be handled.
In many instances whilst it may be obvious that the breakdown
has arisen from an infected badger, it is difficult to decide
on the most effective course of action without knowledge of the
level of infection in the population. The panel should be able
to request testing of badgers both on and off the farm as well
as having powers to recommend removal or non-removal.
26. Whilst the total badger population is
difficult to assess, BVA supports the National Farmers' Union
view that there are unnaturally high populations of badgers in
some parts of the British countryside. BVA also believes that
the species is not endangered. Bovine TB is endemic in the badger
population and the health and welfare of the species is therefore
compromised. In the interest of the badger, the spread of the
disease has to be curtailed.
THE REDUCTION
OF THE
LEVEL OF
INFECTION WITHIN
THE BADGER
POPULATION
27. The availability of an effective vaccine
would be an enormous help in reducing the level of infection in
the badger population. It is accepted that the development of
a vaccine is likely to take many years both in its development
and before it has any significant effect on the problem. The fact
that so little is known about the way in which the disease develops
makes an effective vaccine part of a long term strategy for controlling
TB in badgers. Furthermore, because of the length of time the
infectious organisms can remain active in the environment, successive
generations of cubs in affected areas would have to be immunised
for several years.
THE NEED
FOR RESEARCH
28. The dilemma of how to deal with the
problem highlights the need for more research into the epidemiology
of the disease and in particular its diagnosis in badgers. Although
spread from one species to another is largely accepted, the method
of transmission is still not completely understood. Neither is
it understood why the incidence of the disease in badger populations
varies. The factors which affect the rate at which the infection
spreads to cattle are also matters for speculation.
29. More efficient tools, for example DNA
fingerprinting, must be developed to elucidate the epidemiology
of disease in affected areas. It is particularly important to
establish the means by which the infection cycles between and
within the cattle and badger populations.
CONCLUSIONS AND
RECOMMENDATIONS
30. It has been stated that, whilst being
mindful of the part it plays in conserving the health and welfare
of the natural fauna, the veterinary profession's primary responsibility
is for the health and welfare of the animals under its care. In
this case the profession's primary concern is for the health of
cattle. The number of reported cases of TB in cattle is continuing
to rise and the losses which are occurring in the cattle population
are unsustainable.
31. As our knowledge increases, we know
that the epidemiology of the disease is even more complex than
was at first thought. There are epidemiological variances between
outbreaks of the disease in different areas.
32. Given the current state of scientific
knowledge, the BVA believes there is no easy solution to this
problem and recommends that:
(a) in new breakdown areas, extended and
extensive culling of badgers should occur. It is with regret that
such action still offers the best prospect for the protection
of the animals under the veterinary profession's care. Extended
and extensive culling will provide the maximum period during which
cattle in these areas will remain free of the disease. Particular
attention should be paid to targetting infected animals only.
(b) in areas of continuing infection, further
use should be made of the live test in badgers and this should
be subject to further evaluation and development;
(c) the options available to the mini panel
should be extended particularly when dealing with breakdowns on
the fringes of chronically affected areas;
(d) further research should be carried out
to determine the epidemiology of TB in badgers and the ways in
which the infection cycles between and within cattle and badger
populations;
(e) further research should be undertaken
into the feasibility and effectiveness of vaccinating the badger
population;
(f) a review of cattle testing intervals—whether
annually, bi-annually or tri-annually should be undertaken;
(g) a review of the areas to which badger
control strategies are applied should be undertaken. The current
parish based system is not based on either the incidence of the
disease or the population spread of badgers;
(h) attempts should be made to explain to
conservationists the science behind the culling of badgers;
(i) the feasibility of using a vaccine in
cattle in affected areas should be assessed and attempts to produce
an effective vaccine for cattle actively encouraged.
6 March 1997
Annex B
Implementation of the Krebs Report into
tuberculosis in cattle and badgers
SUBMISSION BY
THE BRITISH
VETERINARY ASSOCIATION
1. The British Veterinary Association welcomes
the publication of the findings of the scientific review of tuberculosis
(TB) in cattle and badgers, chaired by Professor Krebs. Whilst
the review group is to be congratulated on undertaking a thorough
and complete evaluation of the past history of bovine TB (particularly
with reference to the badger) the British Veterinary Association
is disappointed that the report, like others before it, fails
to suggest an immediate solution to the TB problem. The situation
is urgent. In five years time it will be considerably worse.
2. While we realise that the current consultation
regards implementation of the proposals contained in the report,
we do have some general comments which we wish to reiterate, some
of which are acknowledged in the report.
GENERAL COMMENTS
3. The first paragraph of the Executive
Summary gives a false impression as the number of breakdowns per
annum is not the same as the number of affected herds.
4. The report details the epidemiology of
TB in the badger population very thoroughly, to the point where
it becomes a study of badger TB rather than bovine TB. The growing
problem in the national cattle herd would appear to be of secondary
importance, despite the fact that the disease is zoonotic. This
concern is borne out by the membership of the Expert Panel recently
announced. We believe a veterinary surgeon with practical experience
of the disease in cattle and access to microbiological expertise
would greatly strengthen the team.
5. The report states that the badger population
has increased over the past twenty years and it acknowledges that
the evidence strongly supports the view that badgers are a major
cause of herd breakdown. In light of this, it would seem logical
to expect that TB in cattle will continue to spread given that
the report is recommending that action to control badger numbers
will only be taken in twenty 10km x 10km areas. This could threaten
Great Britain's status as TB-free, resulting in increased costs
for TB testing and implications for potential exports if the current
export ban was lifted.
6. The proposals contained in the report
do not consider Great Britain's status as TB-free in the context
of the EU. This is an omission which must be addressed.
7. There is a wealth of knowledge in the
West Country regarding badger behaviour and ecology. This knowledge
should be tapped and used to the best effect.
IMPLEMENTATION OF
THE RECOMMENDATIONS
8. The Association is not convinced that
the experiment proposed will succeed since it ignores the experience
of Thornbury, where extended and widespread culling resulted in
a TB-free area being established. In addition, whilst the proposals
are scientific, they do not appear to be practical.
9. The report expects much from the farmers
whose herds are affected by TB, particularly within the no cull
areas. They may not appreciate the long term benefits which they
are expected to receive as a result of the recommendations, in
light of the short term costs they will face, ie the increased
threat of TB within their herds and from the employment of improved
husbandry techniques. If their goodwill and co-operation is to
be assured, it may be necessary to offer compensation for all
reactors and other incentives to prevent them taking matters into
their own hands and illegally culling badgers on their land. It
must be understood that if there is non-compliance in these areas,
the validity of the experiment will collapse.
10. The report recognises that in order
to be effective the experiment must contain a sufficient number
of areas of sufficient size. The greater the number of areas included
in the study, the less distorted the findings will be by atypical
results in any one area. We, therefore, recommend that the number
of experimental areas should be increased.
11. The areas in which the different control
strategies will be employed are to be located in "hot spots".
In order to identify these "hot spots" criteria will
need to be established to determine the parts of the country in
which these strategies will be implemented. This will also help
identify new "hot spots" which emerge during the anticipated
five year duration of the experiment.
12. Monitoring the re-colonisation of areas
from which badgers have been culled will be necessary. It will
also be important to monitor the TB status of any badgers recolonising
such areas.
13. The undertaking of the proposed experiment
requires the collection of a large amount of data. It is suggested
in the conclusion of the report that this is one way in which
farmers may contribute. However, we believe that using any party
with an interest in the outcome of the experiment, be they farmers
or badger groups, could introduce biases to the experiment. Instead,
independent parties should be used to collect any data required.
14. Improved husbandry practices are recommended
as a way of preventing the spread of TB from badgers to cattle
in those parts of the country where the culling of badgers will
not take place. In order for comparative results to be achieved
in the experimental control areas, similar husbandry practices
should be employed. Guidelines should therefore be established,
and their implementation monitored, by MAFF who could then advise,
rather than criticise, farmers. How effective these methods can
be in controlling the movement of badgers in these areas remains
to be seen. Perhaps, in the first instance, some form of trial
could be initiated in order to test the theory.
15. A further recommendation to come from
the report is the evaluation of alternative means of badger removal
including stop-snaring. This is a primitive means of capture which
can inflict a great deal of suffering on the caught animal which
may not necessarily be a badger.
16. The development of a vaccine for bovines
may appear to be the best option for the control of TB. However,
without support from the rest of the European Community this could
well become a further impediment to cattle exports. It is vital,
therefore, in this context to be able to distinguish between infection
and vaccination. The timescale of vaccine development is also
of concern. Ten years would appear to be an optimistic assessment
and the TB situation will be considerably worse by then. The BVA
would welcome more detail on the development work together with
an evaluation of its likely success.
17. There are a number of recommendations
within the report which the BVA supports:
(a) the taking of isolates of mycobacterium
bovis from each of the groups in the culling experiment and
applying modern molecular biological techniques to determine the
contribution which badgers (and other wildlife) make to TB in
cattle;
(b) the need for more resources to be made
available for research which should be better co-ordinated and
commissioned from the best available researchers. However, it
should not be forgotten that there is a great deal of expertise
within MAFF (at the Central Veterinary Laboratory) when commissioning
this work;
(c) the use of genome sequencing should be
encouraged as this could facilitate any study of the epidemiology
of the disease which could confirm (or repute) the relationship
between the disease in badgers and cattle.
18. In implementing the recommendations
of the report, the risk of bovine to bovine transmission of TB
should not be overlooked. The British Cattle Movement Database,
once it is implemented, should enable tracing of animals to be
carried out more quickly and efficiently.
19. Finally, the success of the recommendations
of the Krebs report will depend upon the proposed measures being
properly enforced. Without such enforcement the findings of the
culling and husbandry experiments may be seriously jeopardised
by farmers who are unlikely to see that the long term benefits
of the proposals could outweigh the short term costs.
4 March 1998
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