Memorandum submitted by Dr Elaine King,
National Federation of Badger Groups (J13) (continued)
100. Staggering of the test date of herds
within a parish (G)
101. In 1993, the TB testing frequency for
most of Great Britain was reduced from three to four yearly. To
ensure that some herds in each parish were tested each year, the
changes were phased but MAFF admits that, ". . . in some
cases there would be no TB testing within a particular locality
for up to three years" (TB Forum 1999c).
102. MAFF even admits, "This would
be of particular concern in areas which have become new foci of
infection". TB Forum (1999c). The NFBG believes that there
may be far worse implications for the potentially large numbers
of cattle remaining undetected in high incidence TB areas.
103. Despite these admissions, this appalling
situation has remained the same for the past seven years.
104. The proposal to remedy this situation
is another high cost proposal from MAFF (an estimated £540,000-£1.2
million to bring herd tests forward) and funding has not been
secured. The NFBG has recommended that this be a high priority
105. Pilot trial of the gamma interferon test
106. The Government is currently investigating
the gamma interferon blood test as a potentially more reliable
test than the tuberculin test. Although the test produces a higher
number of false positives than the tuberculin skin test, it is
the more sensitive test, and is able to detect some infected cattle
which are missed by the tuberculin test.
107. The study is another of MAFF's proposals
with "significant resource implications" and is endorsed
by the NFBG, which is a member of the Forum sub-group involved
with investigating the test.
108. However, the NFBG is concerned that
the pilot trial may repeat similar research on the gamma interferon
test, such as that conducted in the US, New Zealand and Australia,
which has found that the gamma interferon test is not completely
reliable (see Neill et al, 1992; Griffin and De Lisle,
1995; Thoen and Steele, 1995). The NFBG therefore asked MAFF,
at a meeting of the gamma interferon sub group, to provide group
members with details of published research on the test. MAFF failed
to do so.
109. The NFBG supports the trial only on
the premise that the Government is not "reinventing the wheel"
by conducting this pilot trial, when other measures to strengthen
testing and movement still require the necessary funding.
110. Notwithstanding the point made above,
in view of the urgent need for a reliable test for bovine TB in
cattle, it is regrettable that the Government is spending only
£170,449 each year for three years on developing a new test
(MAFF, 2000g). In addition, it is regretable that it has started
so late and is only a pilot study, rather than a full-scale trial.
The NFBG understands that the one-year pilot trial is estimated
by MAFF to cost £100,000 (testing and compensation) and that
funding has not yet been secured for a full-scale trial.
111. This is in contrast to the badger culling
trial which was fast-tracked by the Government and started over
two years ago in August 1998. Moreover, no pilot trial was conducted,
despite the controversy and the inevitable practical problems
which were predicted at the time and which have now become a reality.
The Government has committed over £34 million to the culling
trial (MAFF, 1999), compared to a fraction of that for the gamma
interferon pilot trial, despite the latter presenting a far more
likely candidate for being part of a package of measures to control
bovine TB in cattle effectively.
112. Isolation and testing of incoming cattle
113. This is a proposal originating from
the British Cattle Veterinary Association (BCVA) and is supported
by the NFBG. As the incidence of bovine TB in cattle increases,
there is an increased risk of purchasing infected cattle and these
proposals specifically aim to reduce the risks to farmers of purchasing
infected cattle and to reduce the risks of incoming cattle infecting
the existing herd.
114. The paper recommends a plan whereby
incoming cattle are TB tested and isolated from the existing herd
until a clear result is obtained. NFBG has recommended that grants
be made available to farmers to help them comply with the isolation
requirements, such as improving existing facilities or building
new facilities. However, MAFF officials and Ministers have consistently
ignored these proposals.
115. MAFF has estimated the cost to have
"significant resource implications" (£250,000-£300,000
per year) but has still not made the funding available. It has
also failed to explain how the estimate of cost was obtained.
116. Conclusion on proposals to strengthen
cattle testing and controls
117. The NFBG is particularly concerned
that the Government emphasises its commitment to improved testing
and movement controls, but has still not implemented the major
measures discussed above. In particular, the NFBG believes that
the following measures should be approved, funded and implemented
immediately: more frequent testing in low TB incidence areas following
a confirmed TB incident (F); staggering of the test date of herds
within a parish (G) and isolating and testing incoming cattle
118. The NFBG proposal not recommended by
the Government, to conduct more frequent testing in high TB incidence
areas, should also be implemented immediately.
119. The four measures above represent essential
elements of a disease control package and, despite support from
most Forum members, the Government has taken no action but to
create further delays by repeatedly referring back to the TB Forum,
even after comments have been submitted.
120. We are concerned that the lack of funds
means the Government is forcing the TB Forum to choose between
control measures, all of which are vital in reducing the spread
of bovine TB in cattle. We are also concerned that funding has
still not been allocated to implement these vital disease control
121. The NFBG would invite the Agriculture
Committee to ask the Minister when these vital control measures
will be implemented.
122. Evidence of MAFF delays
123. The Government appears to be unacceptably
delaying the implementation of control measures. For example,
in September 1999, at the first Forum meeting, MAFF described
Point 4 of the five-point plan, the "Prevention of cattle
to cattle spread", as the "main plank" of the strategy.
MAFF goes on to state that " . . . existing testing, slaughter
and movement restriction arrangements continue, at a cost of around
£17 million in 1998 . . . Possible strengthening of these
arrangements under consideration (sic)". (TB Forum, 1999d.)
124. Since that time, little progress has
been made by the Government. In March 2000, at the third TB Forum
meeting "MAFF pointed out that implementation of the package
was subject to Ministerial agreement and to the availability of
resources". (TB Forum, 2000h.)
125. Over one year later, at the TB Forum
meeting on 19 October 2000, the NFBG asked MAFF what funding will
be available to implement these control measures and when it would
be available. MAFF explained that it would know how much money
the department has to spend in January/February 2001, but then
there will be competition for the money from other departments
and Ministers must decide on how it is spent.
126. There is therefore still no guarantee
of obtaining the necessary funding to implement these vital measures,
despite first being proposed to the TB Forum over a year ago and
despite the NFBG and others having made these recommendations
long before that. In contrast, over £34 million has been
committed to the culling trial, which started over two years ago.
127. Additional testing and movement control
measures which are not being considered by Government
128. The NFBG has proposed control measures
to the Government which are important measures to control bovine
TB in cattle. However, the Government has not taken any positive
action on the following points.
129. No routine testing of cattle
130. In its report to the Agriculture Committee
in January 1999 (NFBG, 1999) , the NFBG expressed its concern
over the fact that some cattle are never TB tested. This often
occurs when cattle are sold prior to a routine TB test. The loophole
in the testing system has been admitted by MAFF, "The tuberculin
test is normally used as a herd test, so the movement of individual
animals are not normally relevant for this purpose. For various
reasons, some cattle are never tested for TB" (statement
from MAFF press office, dated 10 September 1998).
131. The NFBG has urged the government to
ensure all cattle are routinely TB tested but the loophole remains.
Indeed, the situation is likely to have worsened in recent months,
as more farmers give up farming and sell entire herds at one time.
132. No pre-movement testing
133. The proposal to test cattle herds prior
to dispersal was proposed by MAFF in the TB Forum paper TBF3/revised
(TB Forum, 1999c) and was endorsed by the NFBG and others. However,
the proposal was dropped due to opposition from farmers and vets.
The weaker system in place is "buyer beware" where the
onus is on purchasers to check the disease status of cattle (which
is not always possible) and to isolate and test incoming cattle
134. The NFBG is concerned that current
advice to farmers considering a whole herd dispersal sale is to
sell before a routine TB test is due, in case bovine TB is found
in the herd. If this were to be the case, the value of the herd
would be reduced and it would be placed under costly movement
restrictions. In 1999, an article in Farmers Weekly recommended
that farmers sell before a TB test, in case a positive test resulted
in devaluation of the herd.
135. This advice was confirmed at a meeting
of the TB Forum on 19 October 2000, where one of the veterinary
representatives admitted that many vets advise farmers to sell
cattle once they receive their TB test dates, particularly if
TB movement restrictions would result in cattle needing to be
housed, which is costly. The vet admitted that, "financial
advice is counterproductive to disease control advice".
136. The NFBG believes that all cattle should
be TB tested prior to movement and/or sale, particularly entire
herd dispersals. This used to be the case in Ireland until 1998,
after which the incidence of bovine TB in cattle increased dramatically.
We urge the Agriculture Committee to ask the Minister to insist
that this vital control measure is considered as part of the Government's
strategy to strengthen testing controls.
137. Hired bulls spread bovine TB
138. Hired bulls are not always TB tested
as they are rarely "at home". Forum members at the Husbandry
sub group meeting in September 2000 raised this issue. Concern
was expressed at the potential of hired bulls to be sources of
TB spread between herds. MAFF admitted that no provision is made
to ensure that hired bulls are tested regularly and MAFF officials
undertook to investigate closing this loophole.
139. The NFBG would urge the Agriculture
Committee to ask the Minister when this loophole will be closed,
to ensure all hired bulls are tested routinely.
140. Tuberculin skin test is unreliable
141. The current comparative intradermal
tuberculin skin test, used in Britain to detect bovine TB in cattle,
is the only test recognised by the EU. The test has been effective
in virtually eradicating bovine TB from most countries in the
world but has been ineffective in reducing the disease in parts
142. One of the shortcomings of the test
is that its sensitivity can be as low as 68 per cent, resulting
in 30 per cent of infected animals passing the test undetected.
At best, assuming a sensitivity of 91 per cent, almost one in
10 infected animals will pass a test undetected (Phillips et
al, 2000). The result is false positives, but more significantly
in terms of disease control, the test produces false negatives.
Other problems with the test include the fact that it relies on
the subjective interpretation of a skin reaction by a veterinary
143. When infected cattle are missed by
the tuberculin skin test, no movement restrictions are imposed
and the animal will remain in the herd to infect other cattle,
cattle in contiguous herds and cattle in a new herd if sold or
moved without a pre-movement TB test.
144. It is therefore vital that an improved
test for bovine TB is developed and, in the meantime, all herds
in endemic TB areas are placed on annual testing regimes.
145. The movement of cattle from endemic TB
areas to the rest of Britain is not restricted
146. The obvious result of the tuberculin
test missing infected cattle, and of the fact that some cattle
are never TB tested, is that infected cattle remain undetected
and likely to spread infection into new herds. Undetected infected
cattle may be the cause of the spread of bovine TB into cattle
in new areas of Britain, in addition to presenting a disease risk
to domestic animals, livestock and wildlife.
147. The NFBG believes that the risk of
undetected cattle spreading TB into new areas should not be under
estimated. Indeed, bovine TB still affects less than 1 per cent
of the national herd and most parts of Britain do not have TB
in either badgers or cattle. It would be a tragedy if bovine TB
were to be spread to new areas of the country simply because the
Government has not imposed strict controls on the testing and
movement of cattle.
148. The NFBG has long recommended that
the Government prohibits the sale or movement of cattle from endemic
TB areas to "clean" areas. Despite evidence that movement
bans do protect TB-free areas, the Government has taken no action
and cattle movements continue at an alarming rate.
149. Indeed, the report of the Husbandry
Panel (Phillips et al, 2000) states that, in the absence
of a wildlife reservoir, most transmission of bovine TB in cattle
in Britain is thought to derive from cattle movement. Indeed,
15 per cent of outbreaks in the southwest region of Britain are
attributed to cattle movement and the report states that it is
higher outside this area.
150. However, while the impression is given
that wildlife are the main cause of infection in cattle in the
south-west of Britain, the report concludes that the "localised
occurrences of the problem in disparate regions", suggests
"the involvement of cattle movement . . . rather than gradual
spread through a wildlife vector" (Phillips et al,
2000). This observation is not surprising, as it is cattle, not
badgers or other wildlife, which travel large distances across
151. The report also cites evidence from
Italy, that imported infected cattle can maintain the disease
in the absence of a wildlife vector. This may occur in the UK,
where TB infection persists in cattle, while not existing in the
local wildlife population. Indeed, in these circumstances, infected
cattle may infect local domestic animals, livestock and wildlife.
152. POINT 3.
153. The NFBG believes that the development
of a cattle vaccine must be part of a strategy to control bovine
TB in cattle. However, in view of the numerous obstacles in the
path of developing an effective vaccine, delivering it to cattle
and obtaining approval from the EU, the NFBG believes that it
should not be considered a panacea.
154. The NFBG is also mindful that 10 to
15 years ago, the Government claimed that a vaccine would be available
in 10 to 15 years time. But a vaccine is not available and the
Government is saying that it may require another 10 to 15 years.
When an effective vaccine has still not been developed for human
tuberculosis, it appears unlikely that one for bovine tuberculosis
will be available soon, when far fewer resources are available
for the latter. Government figures show that only £6.5 million
over five years is being directed towards developing a bovine
TB vaccine (TB Forum, 1999d).
155. The NFBG supports the recommendation
in the Krebs report that a badger vaccine continues to be developed
alongside a cattle vaccine, as the early stages in the development
of the two vaccines will be very similar. However, we believe
that there are serious practical and ethical issues to be overcome
before a vaccine can be used for badgers. These concerns are outlined
in answer to a supplementary question provided to the Agriculture
Committee in March 1999.
156. In its report on this issue (HMSO,
1999) the Agriculture Committee recommended that the Government
should keep the EC informed of developments in this field. It
is not clear whether or not MAFF has yet made contact with the
EC on this issue.
157. POINT 4.
158. The NFBG regrets the persistent Government
focus on badgers in its funding of TB research.
159. The Government has stated that the
trial would cost £34.3 million over five years (MAFF, 1999).
More recent figures show slightly lower figures, but this is likely
to be due to delays, resulting in the trial taking at least seven
or eight years, instead of the five proposed by the Krebs report.
160. The trial is still by far the single
most expensive part of the Government's "Five Part Strategy",
despite being listed as number five. Recent Government figures
show that badger-related projects, including the trial, still
amount to almost £44 million over five years, compared to
a total research budget of £55.2 million (DETR, 2000). This
amounts to almost 80 per cent of the entire TB research budget.
Put another way, the trial is expected to cost over £34.3
million over five years, compared to only £20.9 million being
spent on all other TB research during that period (DETR, 2000).
161. The NFBG welcomes the additional research
initiatives recommended by the ISG and which go further than those
in the Krebs report. In particular, we believe that research into
the transmission, pathogenesis and immunology of M. bovis
in cattle will provide information essential if the disease in
cattle is to be understood and controlled effectively. However,
the NFBG regrets that these projects were delayed in starting
and that some have still not commenced.
162. There is a very real danger in the
Government relying so heavily on the trial to provide a solution
to the TB problem. When, as we expect, the current Krebs' experiment
finds that badger culling is not humane, efficient, economically-viable,
publicly-acceptable or practical, Ministers will have no alternative,
considered strategy for the management of bovine TB in cattle.
This will be catastrophic for farmers and for badgers.
163. The NFBG would urge the Agriculture
Committee to satisfy itself that the Government is directing sufficient
funds into alternative measures which will provide a real an lasting
solution for farmers, but which will also be humane for livestock,
caring for wildlife and acceptable to the public.
164. POINT 5.
165. Despite the Government's protestations
to the contrary, it is clear that the badger culling trial is
the main priority in the Government's "five-point strategy".
Even though the trial started late in terms of the Krebs report's
recommendations, the trial still started long before most other
research started. The trial has also been provided with funding
at the expense of other, deserving research. Indeed the trial
commenced before much of the other research had even been conceived.
It is clear that, over the past two and a half years, the Government
has prioritised its resources (funding and staff) into the trial.
166. Here we demonstrate that the trial
is wasting valuable resources, that the science is fundamentally
flawed, that the trial is proving practically difficult to conduct
properly that the trial seriously compromises animal welfare.
167. Wasting money
168. In addition to fast-tracking the trial,
the Government has repeatedly confirmed that money would be made
available for the trial. At the same time, it claims that vital
measures such as strengthening the testing and movement controls
on cattle may not be implemented due to the lack of available
169. The NFBG believes that the cost of
the trial is escalating due to circumstances which have arisen
during the course of the trial. These circumstances include the
extra costs of complying with the Health and Safety Executive
prohibition order, freezing and storing badger carcasses before
the HSE requirements were met and additional training for staff
after the BBC filmed operatives not killing badgers humanely.
170. We urge the Agriculture Committee to
request information on the exact costs and to seek confirmation
that these will not compromise other, valuable research.
171. A number of vital measures to strengthen
testing and movement of cattle still require funding. Using the
Government's own figures, the annual cost would be £1.6 million
to £2.4 million. This could be funded easily by money currently
being wasted on the trial and is likely to significantly reduce
the incidence of bovine TB in cattle.
172. Wasting police resources
173. We invite the Agriculture Committee
to establish what additional burden the trial is imposing on already
stretched rural police forces. We understand from a variety of
sources that MAFF has:
(1) made arrangements for police support only
to let the service down, literally at the last minute;
(2) started a culling operation without providing
the police with adequate advance notice; and
(3) conducted surveys without notifying the police
that staff are likely to be found wandering private land at all
hours of the day and night.
174. For example, MAFF appears to be failing
to communicate with the police at the highest level. The NFBG
understands that the Staffordshire Police were concerned about
legal aspects of the trial and met with MAFF officials in London.
We understand that the police intended to seek legal advice before
allocating MAFF police for the trial on Staffordshire. However,
we understand that MAFF started working in Staffordshire in early
October 2000, before the police had resolved its concerns.
175. In addition, the NFBG understands that,
in May 2000, MAFF met with officers from the Devon and Cornwall
Constabulary to discuss the policing of the trial. The police
expressed concern at the request to provide officers during the
summer months, when police resources are already stretched due
to the influx of tourists. MAFF was, apparently, determined to
carry out the trial during the summer months, regardless of concerns
raised by the police.
176. At MAFF's request, the police therefore
arranged for CID and Special Branch to be available in the first
weeks of May, when badger culling was due to take place in Cornwall.
However, the NFBG understands that one week prior to the scheduled
start of the culling, MAFF informed the Devon and Cornwall Constabulary
that it had completed survey work for only 75 per cent of the
area and it instead started killing in Wiltshire in early May.
This wasted valuable police time and resources.
177. The NFBG would invite the Agriculture
Committee to seek information on the cost of policing the trial
and to question whether MAFF is managing the trial properly and
informing all the relevant authorities.
178. Flawed science
179. Access to land
180. Before the trial started, the NFBG warned
that landowners denying access to their land would undermine the
trial. We believe this has become one of many serious flaws associated
with the trial.
181. The Government cannot compulsorily
gain access to land in order to kill badgers. The Wildlife Trusts,
the Woodland Trust, the RSPB and other nature conservation organisations
have not allowed culling (or surveying) on their reserves. Neither
too has the Countryside Council for Wales. The NFBG has also been
contacted by a large number of private landowners who have denied
MAFF access to their land.
182. The NFBG would like to draw a worrying
trend to the Committee's attention. A number of landowners have
contacted the NFBG for more information on the trial and have
complained of intimidating behaviour by MAFF officials, when seeking
approval for the trial. Individuals have felt pressurised to comply
and have complained at the lack of information provided to them
by MAFF staff. In some cases, MAFF has arrived on their property
with vans containing cage traps, expected to set them on the land,
without having first sought permission. MAFF officials have also
not made it clear to landowners that participation in the trial
is voluntarythis is one of the reasons why many people
have sought advice and information from the NFBG.
183. The NFBG has also received reports
from farmers and landowners, that do not support the trial, and
have been subject to intimidation by other farmers.
184. We regret that the Government is keen
to point out that the trial has received an "average of 80
per cent support . . ." (MAFF, 2000c), but is less keen to
tell us what percentage of the land area is available for culling,
or, for that matter, what is meant exactly by "support"
of the trial. Figures could be provided easily without revealing
personal details of landowners and the NFBG can see no reason
why the information cannot be made available.
185. Ministers are also keen to give the
impression that rural communities support the trial. We understand
that the Government will be commissioning further public attitude
surveys from the University of York to back up this claim. However,
we believe the pilot research was seriously flawed. The surveyors
found that the public were more inclined to support the cull when
told of the growing threat of bovine TB, the risk to people and
the primary role played by badgers in the transmission of the
disease. But the survey failed to explain how low the health risks
are likely to be, that the role of the badger has never been proven
ormost importantlythat there may be alternative,
wildlife-friendly solutions to solving the problem.
186. We are pleased to see that rural communities
who are fully informed of the issues are often inclined to reject
badger culling. For example, Penwith District Council, in Cornwall,
recently voted to oppose the trial. We also hear on good authority
that while many farmers are allowing the surveying of their land
for badgers, they are refusing to allow culling to go ahead.
187. It is not at all clear that MAFF operatives
are able to access a statistically robust proportion of the culling
area. In addition, we have been unable to ascertain how the trial
is to take statistical account of insufficient compliance from
188. Illegal killing of badgers by farmers
189. The NFBG has repeatedly warned that
one of the major factors likely to undermine the trial is the
killing of badgers illegally by farmers and landowners in trial
areas. The illegal killing of badgers in the "no cull"
areas of the trial will result in there being no scientific controls,
which are needed to validate the trial.
190. Illegal killing of badgers in trial
areas is rife and the number of reported incidents is increasing.
191. The NFBG has evidence that farmers,
especially those in the TB areas, have been killing badgers illegally
for some time. Evidence comes from MAFF reports, press reports,
badger groups, the police and conversations with farmers in the
TB areas. For example, when invited to speak at a meeting of farmers
in Staffordshire, a farmer informed the NFBG that he, and others,
had killed all the badgers on their land. This was admitted to
the full meeting and in the presence of the local MAFF officials.
Other farmers have made similar admissions at meetings with Ministers
when the NFBG has also been present, but the Government has taken
192. More recently, the NFBG has received
reports of farmers shooting badgers at night, using poison mixed
in food put out for badgers, pumping slurry into setts and bulldozing
active setts containing badgers. In one area of Staffordshire,
a landowner informed the NFBG that a MAFF official surveyed his
land for badgers and expressed concern at the lack of badger activity
at setts on his land, and suggested that this was a result of
193. Farmers have also informed the police
that they are killing badgers. A Police Wildlife Liaison Officer
who attended the Royal Show this year, expressed concern to the
NFBG at the large number of farmers who admitted to him that they
kill badgers on their land. They even gave examples of their methods.
194. Despite evidence that badgers are being
killed illegally, the Government appears not to be taking this
issue seriously. The Government is, apparently, carrying out,
unannounced, walkover spot-checks of only 10 per cent of known
setts in trial areasbut only in "survey only"
areas. However, farmers themselves have admitted to the NFBG that
most methods used to kill badgers leave no outward signs. Such
methods include poisoning and shooting.
195. The Government has still not explained
how the extent of illegal killing will be assessed properly and
built into the statistical analysis of the trial.
196. The NFBG would urge the Agriculture
Committee to press the Government and the ISG on how this problem
is being addressed.
197. Direct interference with trapping operations
198. The NFBG predicted that local opposition
to the trial would result in badgers being released from traps
and traps being destroyed and/or removed. The NFBG does not support
or condone any action which is illegal, but nevertheless believes
that this kind of action is undermining the trial.
199. The NFBG has asked the ISG how it will
account for this action in the statistical analysis of the results,
but it has persistently refused to provide an explanation.