Select Committee on Agriculture Appendices to the Minutes of Evidence


APPENDIX 11

Memorandum submitted by Dr Elaine King, National Federation of Badger Groups (J13)

1.  EXECUTIVE SUMMARY

  2.  The National Federation of Badger Groups (NFBG) represents many thousands of people in 80 badger groups across the UK, who are concerned for the conservation, protection and welfare of badgers and the habitats in which they live.

  3.  The NFBG addresses all issues relating to badgers and works with, and provides information and advice to, other conservation and welfare groups, the police, statutory Government bodies, MPs, the public and others. Although the NFBG's primary concern is to conserve and protect badgers in Britain, it is clear to us that this objective is inextricably linked to a farming future which unites rural communities and the natural environment through a holistic vision. To this end, our campaign goes beyond badgers, to increase pressure on the Government and vested agribusiness interests, to work towards a more diverse and sustainable rural economy.

  4.  Badgers are important cultural symbols in the fabric of the British countryside; they are protected by UK law because they are threatened by both legal and illegal human activity. Badgers are also protected by the international Bern Convention because they are declining across the wider European continent. Badgers also play a significant ecological role in the habitats in which they live.

  5.  The NFBG and its partners in the conservation and farming communities believe that the way to solve the bovine TB problem in cattle is not the widespread slaughter of wildlife. A solution will be found only through an integrated approach which incorporates measures including improved cattle testing and movement restrictions, an improved diagnostic test for TB in cattle, improved cattle husbandry and hygiene, a vaccine for cattle and research which investigates transmission, pathogenesis and immunology of the disease in cattle.

  6.  The NFBG therefore warmly welcomed the first inquiry by the Agriculture Select Committee in 1999. The NFBG submitted detailed evidence for the inquiry (NFBG, 1999) and also gave oral evidence. We were pleased that the Committee's report endorsed many of the NFBG's recommendations (HMSO, 1999) although we regret that the Committee supported the Krebs badger culling trial.

  7.  Since publication of the Agriculture Committee's report, the NFBG has monitored, as far as MAFF will allow, the extent to which the Government has implemented the Committee's recommendations.

  8.  The NFBG was therefore pleased to assist MPs prior to the debate on the subject in February 2000, by providing an assessment of the Government's performance in delivering the recommendations in the Committee's report (NFBG, 2000a). The paper identified the many recommendations which the Government has failed to implement.

  9.  The NFBG has published detailed papers on its recommendations for a sustainable strategy to control bovine TB in cattle (NFBG, 1999; CCW et al, 2000; NFBG 2000b, NFBG 2000c). We do not propose to repeat these here, but would instead urge members of the Agriculture Committee to refer to those papers, all of which are available from the NFBG office or the NFBG web site (www.nfbg.org.uk).

  10.  The NFBG has also explained previously the scientific, legal and ethical grounds for the NFBG's opposition to the trial. These concerns are still valid and we would refer Committee members to the NFBG paper submitted to the inquiry in 1999 (NFBG, 1999) and to the numerous news releases which the NFBG has issued on this subject (see www.nfbg.org.uk).

  11.  This paper presents the NFBG's assessment of the Government's progress in implementing its "Five-Point Strategy" for controlling bovine TB in cattle. It also reports on the Government's current progress in implementing the Agriculture Committee's recommendations.

  12.  This paper demonstrates clearly that the Government's strategy still contains an unacceptable range of flaws and loopholes in its futile search for a solution to the TB problem.

13.  IMPLEMENTATION OF THE GOVERNMENT'S FIVE-POINT STRATEGY

  14.  The UK Government has a five-point strategy to attempt to control bovine TB in cattle.

  15.  The five points of the strategy are stated as:

  16.  minimising the risks to public health;

  17.  continuing with regular cattle testing, slaughter of reactors and movement restrictions as required under EU legislation; and considering whether these arrangements can be strengthened;

  18.  development of a vaccine for cattle TB;

  19.  further research to understand better how infection is transmitted;

  20.  carrying out the badger culling trial recommended by the Krebs and Bourne Committees to find out what contribution badgers make to TB in cattle and whether badger culling is effective in reducing TB in cattle (DETR, 2000).

  21.  This paper presents the NFBG's assessment of the Government's progress in implementing this strategy. We outline and discuss the specific concerns which we have over each of the five areas. We also report on the Government's current progress in implementing recommendations made by the Agriculture Committee in its report last year (HMSO, 1999).

  22.  This paper demonstrates clearly that the Government's strategy still contains an unacceptable range of flaws and loopholes in its futile search for a solution to the TB problem. The focus of the Government remains on badgers, in part as a legacy of the limited remit provided by the Government to Professor Sir John Krebs.

  23.  Members of the Agriculture Committee will be aware that the Krebs review fell into the trap of previous reviews in that its terms of reference forced it to focus on TB in cattle and badgers. The remit was not to examine the whole issue. The terms of reference asked the Krebs team "To review, in the light of the scientific evidence, present Government policy on badgers and tuberculosis and to make recommendations" (Krebs et al, 1997). As a result, many of the recommendations were focused on badgers, and alternative strategies were ignored or not addressed in sufficient detail.

  24.  The Government has therefore taken forward some, but not all, of the recommendations in the Krebs report, while continuing to ignore other important measures to control TB in cattle. The NFBG therefore welcomes attempts by the Independent Scientific Group (ISG) to broaden the Government's research programme. However, we have serious concerns over delays in implementation and inertia in the Government arising from minds being closed to new ideas.

25.  Point 1. Minimising the risks to public health

  26.  The Government asserts that the current programme to control bovine TB in cattle is designed to protect human health.

  27.  In the earlier part of the twentieth century, thousands of humans died each year through infection with bovine TB. This was before milk was pasteurised and when a much larger proportion of the national herd was infected. However, current evidence suggests that the risk is now low and this is the stated view of the Government's scientific advisors (Krebs, 1997).

  28.  The risks to humans are considered to be low for a number of reasons. Firstly, the Government has a number of procedures in place which are designed to "make sure the risk of catching bovine TB is as low as possible" (MAFF, 2000a). Procedures put in place by the Government are the pasteurisation of milk, the inspection of cattle carcasses at slaughterhouses and a programme to test herds for TB.

  29.  The second reason for the risks being considered as low, is due to epidemiological data on bovine TB in humans, derived from a variety of sources, which show that the incidence and prevalence of bovine TB in humans is unrelated to the level of bovine TB in cattle.

  30.  For example, the Krebs Report (Krebs et al, 1997) concluded that: "Between 1993 and 1995 just over 6,000 cases of tuberculosis in humans have been notified annually in the UK . . . In 1995, 32 (1 per cent) of the 3,200 tuberculosis isolates cultured in the UK were attributed to M. bovis . . . There is, as yet, no evidence of an increased risk, of human infection with M. bovis associated with recent increases in disease in cattle". It went on to say "We conclude that the current risk of human infection with M. bovis in Great Britain is negligible".

  31.  The Krebs report also stated that the risk of contracting bovine tuberculosis in the UK is very small, both in terms of absolute risk, and in comparison to the risk of contracting other diseases. The Krebs report quotes UK Department of Health figures as a 1 in 2,000,000 annual risk of contracting culture confirmed bovine TB (M. bovis), compared to a 1 in 23,000 risk of contracting HIV; 1 in 20,000 risk of contracting meningitis and 1 in 600 of contracting food poisoning.

  32.  Further evidence of a negligible risk to the human population comes from a study which compared the numbers of tuberculin-positive children in an area of Ireland to the level of bovine tuberculosis in the local cattle population (Collins et al, 1992). The study found that children in areas where there is a relatively high incidence of tuberculosis in the local cattle population are no more likely to be tuberculin positive than are children in other areas of the country.

  33.  The evidence suggests, therefore, that the level of bovine TB in humans is not affected by the increasing levels of bovine TB in cattle. Moreover, existing evidence suggests that bovine TB in humans in the UK does not arise from contact with cattle or cattle products. Instead, it appears to be largely found in older people with recurrent infection or in people who have become infected abroad (MAFF, 2000a).

  34.  Despite evidence that the risks of infection are low, the Government continues to give mixed messages, depending on the forum and the point it wishes to make. When attempting to justify the badger culling trial, Government Ministers, MAFF officials and the ISG, imply that there is a health risk to humans. Despite being criticised by the Select Committee for "overplaying" the risks (HMSO, 1999), the Government continues to do so.

  35.  For example, MAFF states "TB in cattle does not present a major risk to human health, although the increase in cattle TB incidents in recent years means that it has the potential to become a problem. Because of this, and in the interests of the cattle, we are committed to reducing the level of infection as far as possible." (MAFF, 2000a).

  36.  There is no evidence to substantiate the UK Government's claims, which completely contradict the evidence cited above. The most current evidence from the Government's own PHLS shows the exact opposite. Recent data from the Public Health Laboratory Service show that M. bovis in humans is at low levels in the UK and is not increasing, despite the year on year increase in bovine TB in cattle (TB Forum, 2000a).

37.  Infection through the human food chain

  38.  Although the Government argues that human health could be put at risk if the level of bovine TB in cattle continues to rise, it is doing very little to address the most likely transmission routes of the disease. These are three-fold. Firstly, transmission may occur to farmers resulting from contact with infected cattle and cattle products. Secondly, transmission may occur to abattoir workers and meat hygiene inspectors through contact with infected cattle and cattle products. Thirdly, consumers may be at risk.

39.  Transmission to farmers, abattoir workers and meat hygiene inspectors

  40.  The Krebs report pointed out that bovine TB may be an occupational hazard, for example to farmers, abattoir workers and meat hygiene inspectors. The report therefore recommended that the data be collected on the occupation of humans identified with bovine TB infection (Krebs et al, 1997).

  41.  In October 2000, MAFF stated to the NFBG that it is "not aware" that it is conducting any assessment of the occupational risk of bovine TB infection. This is despite it being recommended by the Krebs report. The NFBG was informed that the extent of the Government's current action is that the Health and Safety Executive (HSE) provides general advice on a range of zoonoses (animal diseases which can infect humans) and that MAFF advice is being provided soon to abattoir workers. However, the HSE web site does not offer advice specifically relating to bovine tuberculosis.

  42.  The Government only recently provided advice on the public health consequences of bovine TB in cattle, in June 2000. The advice was produced by the Department of Health and the National Assembly for Wales, for Consultants in Communicable Disease Control and to Environmental Health Officers.

43.  Transmission to consumers

  44.  One of the Government's three measures to reduce the risks to humans is to inspect cattle carcases. However, this procedure is not without risks. The main problem is that some infectious cattle have non-visible lesions (McIlroy et al, 1986). The NFBG is therefore concerned that infective microlesions in cattle could find their way into the human food chain because they are invisible to the naked eye and therefore to meat hygiene inspectors.

  45.  We believe that the risk to consumers is likely to be extremely small. However, the NFBG believes that this issue should be investigated in detail by the Government, not least in the light of the BSE crisis and the public perception of any potential risks.

  46.  The NFBG's main concern is the fact that parts of cattle infected with bovine TB which do not show signs of visible lesions, are sold by the Government into the human food chain. In 1999-2000, the Government received £1.4 million through selling TB reactor cattle into the human food chain (TB Forum, 2000b). There is therefore a possibility that meat containing microlesions of live M. bovis bacilli, is being certified fit for human consumption, because infection is not detected by meat hygiene inspectors.

47.  Risk assessment of reactor cattle in the human food chain

  48.  As a result of the potential risk of transmission to humans through the food chain, the NFBG has been urging the Government for some time to conduct a risk assessment into the practice of selling carcases, or parts of carcases, of TB infected cattle, into the human food chain. The NFBG and others have also urged the Government to stop putting reactor cattle into the human food chain.

  49.  Nevertheless, the Government has appeared extremely reluctant to address the potential risk to humans of TB infected cattle entering the human food chain. The issue was raised at the first meeting of the TB Forum in September 1999. A lengthy discussion was held on the potential risks to humans and particular concern was voiced about the public perception of the procedure, in the light of the BSE crisis. A number of members called on the Government to stop putting reactor cattle into the human food chain. The possibility of conducting a risk assessment was also discussed and the Chief Veterinary Officer did admit that there is a "need to re-evaluate the risk and cost".

  50.  Despite the relatively lengthy discussion and the strong views presented, MAFF and some Forum members (largely from the farming and veterinary communities) refused to include reference to the discussion in the summary notes of the meeting. The main reason was to prevent public concern. MAFF officials also expressed reluctance to mention the issue in the summary notes of the meeting, because they would be posted on the MAFF web site.

51.  MAFF manipulates summary of TB Forum meeting

  52.  MAFF is the Forum Secretariat and produces the summary records of the meetings. No reference was therefore made to the discussion in the summary notes of that first TB Forum meeting (TB Forum, 1999a).

  53.  The NFBG expressed serious concern over this omission and insisted that the issue be included in the summary notes of the second meeting (TB Forum, 2000c). It was therefore agreed at the second meeting, somewhat reluctantly, to record in the summary that:

  54.  "MAFF reported on action points from the first TB Forum meeting: Heat Treatment Orders . . . Abattoirs refusing TB reactor cattle—it was noted that some abattoirs were even refusing to take TB negative cattle from herds under restriction. On reactor cattle, although the risks to public health from meat from such animals was considered very low, a number of members thought consideration should be given to excluding them from the food chain for reasons of public perception. MAFF agreed to discuss these issues with the embryonic Food Standards Agency as quickly as possible."

  55.  However, the NFBG has recently discovered that MAFF has altered the summary record of the second TB Forum meeting on its web site. The section now reads:

  56.  "MAFF reported on action points from the first TB Forum meeting, including Heat Treatment Orders and abattoirs refusing TB reactor cattle. MAFF agreed to discuss these issues with the embryonic Food Standards Agency as quickly as possible."

  57.  Although MAFF did not know the conclusions of the BSE inquiry, at the time it doctored the summary, we wish to draw to the attention of the Committee that MAFF continues to use devious means to avoid revealing commercially sensitive information to the public. We have this week written an urgent letter to our Ministerial contact, Baroness Hayman, asking her to enquire, as a matter of urgency, why her civil servants altered a summary record, agreed by members of the TB Forum, without alerting the Forum of their actions.

  58.  The TB Forum was informed by MAFF in March 2000 that it was negotiating a contract with the Royal Veterinary College, to conduct a risk assessment. However, no further information was provided on this initiative.

  59.  MAFF officials explained to Forum members in October 2000, that they had conducted a "rough and ready" risk assessment, but that a formal approach was needed to look at the issue in more detail. The Food Standards Agency (FSA) is therefore due to publish a research requirement document, to invite researchers to tender for the contract to conduct risk assessment of the practice of reactor cattle entering the human food chain. A detailed risk assessment has therefore not yet commenced.

  60.  In addition, MAFF informed the TB Forum in October 2000, that the Advisory Committee on the Microbiological Safety of Food is also investigating the matter.

  61.  We welcome the fact that studies are to be conducted and we hope that it is found that there are no risks. If that proves to be the case, we would like the Government to reassess its priorities and concede that human health is not the main aim of the culling trial and that the aim is in fact to protect an increasingly intensive food production industry.

  62.  MAFF's current advice is that provided meat is properly cooked, no transmission will occur (MAFF, 2000a). However, in a busy kitchen it is not inconceivable that bacterial residue from uncooked meat could be left on hands, on working surfaces and on kitchen implements, and later transferred to other food and ingested. It is also likely that the risks are higher in processed meat products, such as beef burgers, which contain a wide range of animal parts, and which are handled routinely in domestic environments before cooking.

63.  POINT 2. CATTLE TESTING, SLAUGHTER OF REACTORS AND MOVEMENT RESTRICTIONS

  64.  The NFBG is concerned that, in Britain, where cattle are moved around the country more frequently than in other European countries, a thoroughly rigorous TB testing regime is still not in place.

  65.  At the first meeting of the TB Forum, MAFF presented various proposals for the strengthening of cattle testing and movements (TB Forum 1999b, 1999c, 2000d and 2000e). Some involve a minimal cost and others involve greater cost. MAFF explained to Forum members that not all measures can be implemented due to limited funds and members have been invited to comment on the proposals and prioritise them.

  66.  The NFBG has been urging the Government to implement stricter testing regimes and stricter movement restrictions on cattle and therefore provided detailed constructive comment on the measures. The NFBG has endorsed the majority of measures.

  67.  However, the Government has still failed to implement the majority (and arguably the most important) of the measures. It has failed to secure funding for the most critical measures and still cannot confirm if or when they may be implemented in the future. Instead, MAFF has repeatedly provided Forum members with its proposals, members have commented but MAFF has continued to delay the process by bringing the proposals back to the Forum, instead of seeking ministerial approval for the measures, securing the funding and taking forward their implementation.

  68.  For example, the summary of the second meeting in December 1999, records MAFF stating that, "The next stage in taking forward the TBF 3 (revised/1) proposals would be to refine the costings, see if funds could be found, and prepare changes to the TB Order".

  69.  However, MAFF officials confirmed to the NFBG at the fifth TB Forum meeting in October 2000, that funding has still not been secured for the majority of measures and this will not happen before January/February 2001.

  70.  Below, we review the current position with the proposed package of measures to strengthen testing and movement controls, For ease of reference, the letters in brackets refer to the measures as presented in TB Forum paper TBF32 (TB Forum, 2000e).

71.  Review of TB testing frequencies and requirements (A)

  72.  In September 1999, MAFF asked Forum members for its views on the importance of conducting a review of TB testing frequencies and requirements. MAFF explained that the review is being conducted ". . . to ensure that EU requirements are being met." (TB Forum, 1999b).

  73.  The NFBG was staggered to learn that the review was being conducted simply to ensure that the UK is complying with the minimum standards set out in the relevant EU Directive. Indeed, we were concerned to be informed in March 2000 (TBF18) that on completion of the review, MAFF found that 126 parishes were below the EU minimum standards. Moreover, the review was to check only that at the end of 1998, Great Britain complied with the regulations.

  74.  MAFF has since stated that the necessary changes have been implemented, based on 1998 disease incidence figures (TB Forum, 2000f). It informed the Forum that it intended to conduct another review for 1999 figures and that a plan for implementing any changes would be agreed, implemented and announced by September 2000 (TB Forum, 2000f). It is not clear whether or not this has happened.

  75.  To conclude, while MAFF is acting to ensure testing frequencies comply with the minimum standards set by the EU, measures to allow for additional testing, are still only proposed and no funding is available for their implementation. This is in contrast to the impression given by Ministers and MAFF officials, that the Government is strengthening control beyond the minimum requirements.

  76.  The NFBG would ask the Agriculture Committee to enquire of Ministers, whether the Government will increase testing and movement controls beyond the minimum requirements? And, if so, what is the time-scale?

77.  Restrictions on herds not tested by the due date (B)

  78.  Some farmers refuse to allow their herds to be TB tested. One of MAFF's proposals with "minimal resource implications" (£5,000 per annum), submitted to the TB Forum, is that movement restrictions be imposed on herds not tested by the due date. The Forum endorsed this proposal and MAFF reported to the Forum in October 2000, "An amendment to the TB Order is in preparation". (TB Forum, 2000g.)

  79.  MAFF estimates that the cost to the farming industry will be £50,000 but has not responded to the NFBG's question as to how the figure was calculated.

80.  Movement of cattle only under licence between two stages of a tuberculin test (C)

  81.  Another of MAFF's proposals with "minimal resource implications" is that farmers be licensed to move cattle between two stages of a tuberculin TB test, so long as they are going direct to slaughter.

  82.  The NFBG responded to invitations to comment on the proposals, by recommending that cattle are not allowed to be moved between two stages of a test. This would save an estimated £20,000 per annum which would otherwise be spent on costs outlined by MAFF, such issuing licences, tracing and retesting cattle moved illegally and administration. Allowing movement between tests may also increase the risks of the spread of infection to new herds and to wildlife in new areas, if the licence conditions are breached.

83.  Isolation of M. bovis in any mammalian tissue (other than human) to be reportable to MAFF (D)

  84.  Another of MAFF's proposals with "minimal resource implications" is therefore to insist that isolation of M. bovis in any mammalian tissue be reportable to MAFF. Bovine TB can affect a wide range of domestic animals, livestock and wild animals, such as cats, dogs, ferrets and llamas and useful epidemiological data may be obtained through the reporting of these cases. Indeed, a significant association has been found between TB in cats and farms experiencing TB outbreaks (Snider and Cohen 1972, Ragg et al, 1995). Cats infected with bovine TB have also been found on farms in Cornwall (Monies et al, 2000).

  85.  The NFBG believes that such information may be important in assessing the source of a herd breakdown. The Forum endorsed the proposal and MAFF reported to the Forum in October 2000, "An amendment to the TB Order is in preparation". (TB Forum, 2000g.)

  86.  Consideration should also be given to imposing a mandatory test for farmed deer, especially in endemic TB areas. Currently, only a voluntary testing scheme exists for farmed deer and MAFF has informed the NFBG recently that ". . . the scheme has not taken off . . ." It is important to address bovine TB in deer as high levels of infection have been recorded in some herds (Phillips et al, 2000).

87.  Information for prospective purchasers of cattle (E)

  88.  For some years, the NFBG has been urging the Government to include TB test dates on the new cattle passport system, which was introduced in the UK in September 1998. However, MAFF still has no plans to comply with this request, despite being asked by the Agriculture Committee to reconsider this decision (HMSO, 1999). MAFF claims that the proposal will be too expensive and cannot be implemented because the Cattle Traceability System database is still not "fully comprehensive".

  89.  The result is that, when purchasing cattle, it is not possible for a farmer to know when an animal was last tested, or indeed if it has ever been tested. In contrast, the New Zealand Government stipulates that cattle are TB tested and proved negative before being moved to "clean" areas (Tweddle and Livingstone, 1994).

  90.  Instead, MAFF submitted proposals with "minimal resource implications" to the TB Forum that the current TB52 form (tuberculin test report and certificate of clinical inspection) be modified so that farmers can request a copy of the test certificate. The NFBG recommended that the certificate be provided routinely to farmers, to avoid the onus being put on the farmer to remember to ask for the form. Regrettably, the NFBG's advice was ignored by MAFF, we believe for reasons of cost.

91.  More frequent testing in low TB incidence areas following a confirmed TB incident (F)

  92.  MAFF has asked the TB Forum to comment on its proposals to conduct more frequent testing in low TB incidence areas following a confirmed TB incident. The aim would be to detect new foci of infection. The NFBG responded by recommending that this be considered a high priority.

  93.  This proposal is one with "significant resource implications" and MAFF estimates the cost to be £700,000 to £850,000 to the public purse and possibly over £1 million to the industry. The NFBG has queried how these figures were calculated, but has not received a response from MAFF.

  94.  The NFBG has suggested that part of the cost of increased testing be offset by applying to the EU Veterinary Fund. However, it is regrettable that MAFF has decided against applying for funding from this scheme, whose specific purpose is to provide funding for testing and compensation (MAFF, 2000b).

  95.  It is regrettable that MAFF still has no plans to increase testing frequencies beyond the legal minimum, despite the impression given by Ministers that such measures are being taken. It is also regrettable that MAFF has chosen not to apply for financial assistance for increased testing.

96.  More frequent testing in high TB incidence areas (not proposed by the Government)

  97.  As a result of the limitations of the tuberculin test, the NFBG believes that it is essential that cattle in both high and low risk areas be tested more frequently for bovine tuberculosis infection. We have been urging the Government to do this for some years. Testing more frequently in high incidence areas will allow the early detection of infected cattle.

  98.  Regrettably, the MAFF proposals for strengthened cattle control measures do not include measures to increase testing in high risk areas. This is despite evidence that annual testing has been effective in the past in reducing the incidence of TB in cattle (O'Connor, 1986).

  99.  In addition, it is known that infectious cattle shed bacteria in the early stages of infection, before they can be detected by the tuberculin skin test (Neill et al, 1992). The NFBG therefore strongly believes that all cattle in high incidence TB areas should be tested annually. This would enable infection in cattle to be detected earlier than at present and the animals removed from the herd to prevent spread to other cattle, other livestock, domestic animals and wildlife. Indeed, research has shown that annual testing results in the removal of most infected cattle before they reach the highly infectious visible lesion (VL) stage (McIlroy, 1986; Buddle et al, 1994 and Neill et al, 1992).


 
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