CATTLE BASED MEASURES
Defra should initiate a cost-benefit analysis
of the options based on cattle controls recommended by the ISG
in order to inform its decision on future policy on cattle TB
(paragraph 116).
24. The ISG made a number of recommendations
about cattle control measures that could have a positive effect
on bovine TB incidence, but without offering any indication as
to whether these measures would be cost effective to the taxpayer
or to farmers. Initial cost benefit analysis of increasing the
frequency of cattle testing or making more extensive use of the
gamma interferon test suggests that they would come at a high
cost with limited benefits—and so would be difficult to
justify in terms of Government expenditure. Decisions about the
value of such measures, and how they might be funded, are as much,
if not more, a question for industry as for Government and will
need to be discussed by the Bovine TB Partnership Group. We agree
that cost-benefit analysis or other appropriate economic assessment
is important for informing these decisions.
It is important that research continues to fill
the gaps in the scientific knowledge on bovine TB identified by
the ISG and others and Defra must ensure that funding for this
research is found. In particular, the Government must decide in
the next 6 months whether further research on establishing exact
means of transmission is necessary (paragraph 117).
25. The Government has invested over £109
million over the past 10 years in research, including the Randomised
Badger Culling Trial, and the research budget for the next three
years is approximately £26 million. The gaps in the scientific
knowledge identified by the ISG and others have been carefully
considered and prioritised against policy needs. These are used
as the basis for conducting open competitions for commissioning
research published in the annual Defra Research Requirement documents.
This will continue, and the newly formed independent bovine TB
Scientific Advisory Body will also play a role in this process.
26. We now have enough evidence to decide that
further research is unlikely to yield conclusive answers on the
exact means of transmission between cattle and badgers; however,
we will continue to consider new ideas. The RBCT has demonstrated
that it is not possible to quantify the possible routes of transmission
and although there is evidence that transmission to cattle is
primarily through the respiratory route, the pathology of bovine
TB in badgers, cattle and other species suggests indirect infection
of cattle through badger excreta is a considerable risk. The relative
importance of the routes of infection will therefore remain an
unknown, and it should be assumed for control purposes that both
direct and indirect transmission of TB between badgers and cattle
may occur in farm buildings and at pasture. Our bovine TB control
strategy mitigates the risks around the uncertainty concerning
exact routes of transmission by seeking to ensure that, in relation
to as many routes of transmission as possible, disease spread
is minimised.
TB SAB should be given clearly defined roles in
how it should provide advice to the Government (paragraph 134).
27. Defra's Bovine TB Science Advisory Body does
have a clear role and a structure is already in place for organising
its provision of advice to the Government. This has been developed
on the basis of advice from Defra's Scientific Advisory Committee.
The Bovine TB Science Advisory Body was established in January
2008 to provide expert oversight of Defra-funded bovine TB research,
identify gaps in its evidence base and to provide independent
advice on the strategic direction of, and priorities for, all
Defra-funded bovine TB-related research. It is not within the
Body's remit to advise on questions of policy, nor inform and
monitor the effects of policy decisions.
28. The Bovine TB Science Advisory Body has four
working subgroups focusing on specific areas of Defra's bovine
TB research portfolio: vaccines; epidemiology and wildlife risks;
diagnostics; and economics and social science. The Chairman of
the Bovine TB Science Advisory Body, Professor Quintin McKellar,
will take a strategic overview of the activity of the sub-groups
and identify any gaps in their coverage. The Body reports to Defra's
Chief Veterinary Officer and Chief Scientific Adviser.
Defra should discuss the introduction of post-movement
testing in respect of cattle moved from high risk areas to low
risk areas with the farming industry, veterinary experts and Animal
Health (paragraph 143).
29. The Government advises farmers to take all
responsible precautions to prevent introduction of infected animals
into their herds. Pre-movement skin testing combined with post-movement
testing would provide greater protection from bovine TB than pre-movement
testing alone. We continue to advise farmers to post-movement
test animals on a voluntary basis, as best practice in protecting
the health of their herd.
30. The option of introducing compulsory post-movement
testing was considered as part of the strategy consultation in
2004. However, it was decided not to go ahead with post-movement
testing at that stage. Analysis showed that post-movement testing
cattle moving into a 3 or 4 yearly testing herd in England and
Wales, in addition to pre-movement testing as currently implemented,
would give the greatest disease control of the options assessed
but at the highest cost. That approach was shown to have a lower
net benefit than pre-movement testing as currently implemented.
Based on the information then available, the addition of post-movement
testing was estimated to prevent a further 70 bovine TB incidents
per year at a cost of about £50,000 each, which appeared
to be high in relation to the benefits.
31. Nonetheless, the Government agrees with the
Committee that it would be worth revisiting this decision, but
would want to do so as part of the discussion in the Bovine TB
Partnership Group of future control options.
An assessment should be made of the performance
and functionality of the current National Cattle Tracing System
(paragraph 143).
32. In England, the British Cattle Movement Service
(BCMS) is responsible for keeping records of all cattle movements
through its Cattle Tracing System, which is fit for purpose. Vetnet
is the current IT system used by Animal Health to keep records
of bovine TB testing and control measures, and it is to this that
Lord Rooker referred (q538, transcript of 10 December 2008) when
giving evidence to the Committee, rather than to the BCMS Cattle
Tracing System.
33. Animal Health is responsible for the administration
of the bovine TB control programme, and has recognised the problems
associated with having several separate outdated systems to deliver
the programme, which include Vetnet and TBIS. As part of their
Business Reform Programme they are introducing a new, more cohesive
IT system which will fulfil the functions currently performed
by several different systems. The first version of this new system
('SAM') will be rolled out shortly, with bovine TB functionality
introduced at a later date.
34. The systems used in England for recording
cattle movements and other information relevant to managing bovine
TB breakdowns are not directly comparable with the APHIS cattle
tracing system operating in Northern Ireland.
The gamma interferon test should be strategically
directed in both routine and pre-movement testing (Paragraph 143).
Defra must examine carefully the benefits of the
introduction of the parallel use of gamma interferon testing alongside
the tuberculin skin test. (paragraph 193).
35. The Government recognises that the gamma
interferon test (a laboratory-based blood test) is a valuable
additional tool for detecting and controlling bovine TB, and this
is why more gamma interferon tests are carried out in Great Britain
every year than in any other country in the world. Research shows
that the skin and gamma interferon tests identify different populations
of infected animals - so maximum testing sensitivity is achieved
when they are used together (parallel testing).
36. The current gamma interferon policy, adopted
in 2006, increased the circumstances in which the test is used,
and was designed to target the test where it would yield the highest
benefits. The decision as to where to focus its use also reflected
the high cost of the test, and practical constraints such as laboratory
capacity and the need for blood samples to reach the laboratory
in a viable condition within 24 hours of being taken. The test
is currently used in the following circumstances, and targeted
on those herds where reactors have already been identified by
a parallel skin test, and disease has been confirmed at post-mortem
inspection or through culture:
- all confirmed new incidents
in 3 or 4 yearly tested herds, including those that fail to resolve
through repeated skin testing or where complete or partial de-population
is contemplated;
- confirmed bovine TB incidents that have failed
to resolve through repeated skin testing or where complete or
partial de-population is contemplated;
- at the first inconclusive reactor (IR) retest
in unresolved IRs in herds in 1 and 2 yearly tested herds.
37. Between 23 October 2006 and 30 April 2008,
this approach identified 3651 reactors in England. These gamma
interferon test reactors were likely to be infected with bovine
TB, but had failed to produce a reaction to an earlier (or contemporaneous)
tuberculin skin test.
38. During development of the gamma interferon
policy, consideration was given to whether it should be used in
pre- and/or post-movement testing. However, practical, legal and
cost issues have ruled this option out for the present. Currently,
blood samples for gamma interferon testing are only taken by Animal
Health staff because of the complicated logistics of despatching
these samples quickly to the laboratory in temperature-controlled,
specialist packaging. Pre- and post-movement tests are carried
out by private vets and it is not currently practical to extend
the system so as to allow them to take samples for gamma interferon
testing. There would also be significant cost implications. Pre-
and post-movement testing is paid for by farmers, whereas gamma
interferon testing is currently funded by Government. Using the
gamma interferon test for pre-movement testing is likely to cost
significantly more per animal tested than the current cost using
the skin test, a cost which would be borne by industry, who have
little appetite for such a change. Although this approach could
be expected to disclose more reactors, it is far from clear whether
the benefits would justify the substantial costs.
39. The slightly lower specificity (its ability
to differentiate between true and false positives) of the gamma
interferon test (in relation to the skin test) might also result
in significant farmer opposition if it was used as a surveillance
test rather than, as at present, in herds where disease has already
been identified. The gamma interferon test has a specificity of
97%, which although high, still carries a risk of producing three
false positives per hundred animals tested. It is for these reasons
that the gamma interferon test use is currently targeted in herds
where infection has already been confirmed at post mortem examination
and/or culture, or where the likelihood of the animal truly being
infected with bovine TB is high (e.g. 2 time inconclusive reactors).
40. The tuberculin skin test is currently the
only one approved by the EU as the primary diagnostic test for
bovine TB i.e. to determine the disease status of cattle herds.
The gamma interferon test is recognised by the EU, as an ancillary
test. To routinely use the gamma interferon test in parallel with
the skin test would bring with it significant difficulties and
very high costs. An initial high-level cost-benefit analysis shows
that routinely using the gamma interferon test as the primary
diagnostic test for bovine TB is likely to produce small benefits
when compared to the extremely high cost (possible benefits of
around £125m over 20 years, with a cost of £1 billion
over 20 years). Using the gamma interferon test routinely in parallel
with the skin test would cost still more.
41. A review of the first full year of the use
of the gamma interferon test since its roll-out in October 2006
is currently underway. The circumstances in which the gamma interferon
test is used, including the Committee's recommendations and whether
the test should be made available for private use, are being considered
as part of this work. Further roll-out of its use in the future
will depend on a number of factors including availability of resources,
testing/laboratory capacity, the effectiveness of the policy and
the level of stakeholder buy-in to the test.
42. Government will continue to work to increase
understanding of the gamma interferon test and build confidence
in the role it can play in tackling disease.
Defra must examine carefully the benefits of increasing
the frequency of testing (paragraph 193).
43. Increasing the frequency of bovine TB testing
in some areas was recommended by the ISG. However, doing this
would have significant financial and practical implications—an
initial cost-benefit analysis does not suggest that the case for
this sort of change is strong. Increased testing would result
in more animals slaughtered and, as the Committee acknowledges,
this would also increase the cost of compensation for the taxpayer.
Our current approach to determining the minimum levels of routine
testing for cattle herds is risk-based and consistent with the
requirements of EU Council Directive 64/432/EEC. Parish Testing
Intervals reflect the local level of bovine TB prevalence, and
are reviewed each year to take account of any change in the disease
situation. An increase in the levels of disease in an area triggers
more frequent testing. Divisional Veterinary Managers (Animal
Health) are already empowered to increase testing if local circumstances
indicate that such action is required.
44. The current approach is risk-based and, as
already discussed, any changes to the current package of cattle
controls would only be considered if supported by industry. This
will be another issue that will be on the agenda for the Bovine
TB Partnership Group.
Defra must continue to support research into evaluating
the effects of employing different animal husbandry measures on
farms. Defra should adopt a more pro-active approach using vets
based in local communities creating biosecurity "partnerships"
with farmers (paragraph 166).
45. The Government recognises the role good husbandry
and biosecurity measures can play in reducing the risk of a herd
experiencing a bovine TB breakdown. In 2006-2007 the Bovine TB
Husbandry Working Group reviewed the available evidence and provided
farmers and vets with practical, evidence-based information to
help them make informed decisions. However, as the Committee recognises
in its report, the relative lack of knowledge on the exact method
of transmission of disease from badgers to cattle means that it
is difficult to determine the effectiveness of biosecurity and
husbandry measures. The mechanisms of cattle-to-cattle disease
spread are better known, and the surveillance and slaughter programme
which Defra and Animal Health enforce includes biosecurity measures
to reduce this risk, for example compulsory isolation of reactors,
pre-movement testing and the disinfection of buildings used to
house reactors.
46. An analysis of farm-level herd breakdown
risk factors for bovine TB was conducted by the ISG during the
course of the RBCT. They concluded that it is not possible to
identify single factors that increase the chance of a herd suffering
a bovine TB breakdown. It is therefore not possible to recommend
a single measure that farmers could take to mitigate these risks,
but by introducing a number of measures and following best-practice
advice the cumulative effect may result in a reduction of bovine
TB incidence.
47. The Government continues to fund research
into the feasibility of practical husbandry measures reducing
the disease risk posed by badgers to cattle. Between 2003 and
2005 a husbandry project carried out by researchers at the Central
Science Laboratory (CSL) (project SE3029: An investigation of
potential badger/cattle interactions and how cattle husbandry
methods may limit these, total cost £556,851) investigated
badger-to-cattle contact in and around farm buildings and found
that badgers did visit farmyards to a higher degree than was previously
thought. Since November 2005 Defra has funded a follow-up project
with CSL (project SE3119: An experiment to assess the cost-effectiveness
of farm husbandry manipulations to reduce risks associated with
farmyard contact between badgers and cattle, total cost £1,042,493),
which is investigating practical adaptations which can be made
to farm buildings and equipment such as feeders and gates in order
to keep badgers out while not significantly interfering with the
day-to-day running of the farm. This research will also include
an analysis of the costs and benefits of the husbandry interventions
tested. The results of this research are due in early 2010.
48. The Government recognises that many farmers
currently have reservations about accepting its advice on issues
such as husbandry. It is for this reason that the Bovine TB Husbandry
Working Group was established, to work with industry representatives
and other interested groups to develop and distribute advice in
which farmers would have confidence. We would also encourage industry
bodies to continue to promote best practice husbandry and biosecurity
measures to their members as a way in which they can reduce their
chance of experiencing a bovine TB breakdown. The Bovine TB Partnership
Group may wish to consider how we communicate biosecurity measures
and how we could work together to assist parts of the farming
sector in managing the impact of living in high risk areas. We
would be prepared to consider making additional funding available
to support such initiatives if the group puts forward a strong
business case for doing so.
49. Defra works closely with the Welsh Assembly
Government to combat bovine TB in both England and Wales. The
Welsh Assembly Government was represented on the Bovine TB Husbandry
Working Group and keeps us closely in touch with the progress
of their Husbandry Intensive Treatment Area. We have not ruled
out trialling a similar approach in England and are awaiting the
outcome of this research with interest.
Defra should issue a culling licence to NFU applicants
in the South West if they can satisfy conditions agreed by Sir
David King and ISG, and put into a framework by Defra and NE (paragraph
181).
50. As the Committee recognises, the scientific
evidence shows that the way a cull is delivered is critical. It
would be very difficult to deliver an effective large area cull
in practice; it would be a costly operation that would need to
be continued for a number of years. Public opposition to culling
would increase the challenge of delivering an effective cull.
The Government agrees with the Committee that there is a risk
that patchy, disorganised culling could make matters worse. Having
considered the evidence on the practicality of culling, and discussed
the issue with farming, veterinary, wildlife and police organisations,
the Government has concluded that its policy should be that licences
for farmers to cull badgers over a large area to prevent bovine
TB in cattle will not be issued. The Government does, however,
remain open to revisiting this policy under exceptional circumstances
or if new scientific evidence were to become available.
The Government must make the development of its
vaccine strategy a priority in order to guide the scientists involved
in the development of vaccines for cattle and badgers. There is
a case for further funding for vaccine research on an 'invest
to save' basis (paragraph 189).
51. The Government agrees that effective vaccines
could make an important contribution to its bovine TB control
programme including by addressing the bovine TB reservoir in badgers,
and will therefore commit increased funding to develop vaccines
and prepare for their deployment. We fully endorse the Committee's
recommendation of an "invest to save" approach.
52. We have a programme in place to explore the
options for the use of vaccines with the scientists involved in
their development, and with stakeholders. Vaccine development
has been a priority for a number of years in line with the recommendations
in the 1997 Krebs Report. We have invested £18 million over
the past ten years in research and development on badger vaccines,
cattle vaccines and associated diagnostic tests. We have now also
decided to commit to spending a total of £20 million over
this CSR period. The continued and additional funding will help
us further develop oral badger vaccines and investigate ways in
which they could most effectively be deployed. It will also enable
us to continue with the work on cattle BCG-based vaccines, developing
tests to differentiate infected from vaccinated animals, evaluate
the duration of sensitisation of cattle to the tuberculin skin
test and boost work looking at non-sensitising vaccines for cattle.
53. We will also invest additional funding in
setting up and running an injectable badger vaccine deployment
project to prepare for deploying vaccines in the future. The injectable
badger vaccine will be used in the deployment project with the
aim of building stakeholder confidence in the long term contribution
badger vaccination could make to tackling bovine TB, and to provide
valuable information which can help us move towards the longer
term goal of an oral badger vaccine. This will not be a rigorous
scientific trial but a practical demonstration in collaboration
with stakeholders and researchers on how a vaccine might be used,
in order to gain confidence in the use of badger vaccination.
54. The Government is also working closely with
researchers in Ireland and New Zealand to share any developments
across the bovine TB community internationally and draw on worldwide
expert advice. Bovine TB vaccine research is an extremely complex
area but this integrated approach places us in the best possible
position to share knowledge and target research funding appropriately.
55. A Vaccine Scoping Study Sub-Committee was
set up by the Independent Scientific Group on Cattle TB (ISG)
in 2001 to review progress and reported its advice on future research
requirements to Ministers in 2003. Most of the recommendations
from the Study have been taken forward by the Department and are
overseen by a bovine TB Vaccine Programme Advisory Group composed
of independent scientists and chaired by the Departmental TB Vaccine
Programme Adviser, Professor Douglas Young, an internationally
recognised expert in human TB vaccines from Imperial College.
56. There are a number of different ways in which
vaccination could be used to tackle bovine TB in cattle and/or
badgers, each with associated benefits and issues. At the core
of these is the balance of costs versus benefits in terms of disease
control, but there are also wider issues that need to be taken
into account and balanced such as acceptability, practicality,
trade issues and legal constraints. Government has been working
closely with scientists and stakeholders to consider these issues
and develop a strategy for the potential use of vaccines for bovine
TB by:
- ascertaining whether the benefits
of vaccines will be sufficient to ensure uptake and justify their
use when balanced with the costs associated with developing and
using them;
- identifying any barriers to the potential use
of vaccines that need to be overcome e.g. any legal restrictions;
and
- understanding the properties required of the
vaccines to influence further development.
57. This work has shown that vaccines can potentially
make a contribution to the control of bovine TB as part of a wider
package of controls. However, it has identified a number of significant
issues both scientific and policy which will need to be addressed.
The options and issues have been summarised in two papers, one
considering cattle vaccines and the other badger vaccines. Both
have been endorsed by industry and stakeholder groups as a sound
basis for moving the vaccines programme forward. The papers are
available online at http://www.defra.gov.uk/animalh/tb/vaccination/index.htm.
58. Vaccination is a long term policy option.
Research by its nature takes time and a successful outcome cannot
be guaranteed. Taking into account the scientific, policy and
legal issues, oral badger vaccines are unlikely to be available
before 2014 and cattle vaccines not before 2015. A licensed injectable
badger vaccine may be available by 2010 and although unlikely
to be practical for widespread its small scale use in the deployment
project is important to understand what may be possible with an
oral badger vaccine.
Defra needs a clearly defined compensation policy
for dealing with TB in species other than cattle (e.g. llamas)
(paragraph 35).
59. The Government recognises the need to develop
a formal policy on bovine TB in species other than cattle, such
as llamas. An interim compensation policy is currently in place,
with compensation of £750 to be paid for each camelid reactor
slaughtered. We are currently considering our wider policy on
bovine TB in species such as camelids, arrangements for the test
and slaughter of infected animals, and whether, and if so how,
to provide compensation for them. There have been discussions
with the camelid industry to ensure the review is informed by
industry concerns.
Defra must review the current table valuation
system for compensation of cattle (and other farmed animals) slaughtered
for cattle TB. It is currently unfair to farmers of pedigree animals
(paragraph 191).
60. The Government does not agree that the current
table valuation system is unfair to owners of pedigree cattle.
The decision to introduce table valuations for both pedigree and
commercial categories of cattle in February 2006 was not taken
lightly, but the large body of evidence that the previous compensation
system (based on individual valuations) resulted in significant
and widespread over-compensation could not be ignored. The current
arrangement provides better protection for the taxpayer, and provides
significant compensation given that bovine TB reactor cattle are,
in commercial terms, only worth salvage value.
61. We recognise that table valuations are unpopular
with some cattle farmers, and we would emphasise that:
- table valuations are an entirely
objective way of determining compensation;
- a large amount of sales data is collected to
support table values (i.e. for around 1.25 million cattle a year)
from a large number and wide range of sources;
- table values are only used if sufficient data
has been collected. The decision as to what constitutes 'sufficient'
data is based on an annual objective analysis (by statisticians)
of the variability of sales data within each category; and
- table valuations are not new - they have been
used previously in GB and are currently used (for bovine TB purposes)
in other parts of the world.
62. The Government has not ruled out the possibility
of making changes to the table valuation system but our view remains
that any such changes must be fully and objectively justified
and must also protect the interests of all parties - including
the taxpayer.
63. The Committee will be aware that the NFU
have supported a judicial review of the table valuation system
and that we are currently awaiting the Court's judgement.
We would encourage a dialogue to continue between
the former members of the ISG and the new Government Chief Scientific
Adviser (paragraph 75).
64. Sir David King was asked to provide the Secretary
of State for Defra with an independent assessment of the
scientific evidence relating to badgers and bovine TB in cattle.
He therefore sought advice from experts who had not been involved
in the ISG report. As his report was to the Secretary of State,
Sir David gave him an opportunity to consider the report before
making it more widely available. Sir David and former members
of the ISG met subsequently and reached agreement on the measures
that would be needed if badger culling were to have an overall
beneficial effect on levels of bovine TB in cattle.
65. The new Government Chief Scientific Adviser,
Professor Beddington, has also spoken to Professor John Bourne,
who confirmed the points of agreement. Given this agreement, no
further dialogue is planned between Professor Beddington and former
members of the ISG. However, Professor Bob Watson, Defra's Chief
Scientific Adviser, will continue his interest in bovine TB and
involve other experts as necessary.
Department for Environment, Food and Rural Affairs
4 July 2008
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