Memorandum submitted by the Ministry of
Agriculture, Fisheries and Food (J15) (Continued)
". . . We are concerned about the logistical
aspects of reducing the statistical power but in no way could
we discover that the trial was scientifically flawed".
27. The Independent Scientific Group has
advised the Government that the trial is robustsee also
response to recommendation nn, on the statistical power of the
"We recommend that the number and age
of cubs and lactating sows caught in culling operations after
the closed season be monitored to assess the efficiency of the
closed season policy."
28. This aspect continues to be monitored
as part of the trial. In proactive culling operations in the first
five triplets lactating badgers were only trapped in one triplet,
Wiltshire where 51 were culled, less than 6 per cent of the number
of badgers culled in the initial cull in this triplet.
Co-operation with the trial
". . . the wider interests of the farming
community must be to co-operate fully with the trial . . . we
urge [the Wildlife Trusts] to consider what message their non-compliance
sends to others for whom non-compliance with the trial would take
different forms such as illegal culling of badgers."
29. The Government condemns interference
with badger culling trial operations and any illegal culling of
badgers. Participation and co-operation from landowners and farmers
is good generally, in excess of 80 per cent. There has been some
interference with trial operations by protesters opposed to badger
culling, mainly in the form of damage to cage traps and other
equipment. However, action by the police and by MAFF field staff
has limited the extent of this disruption and the trial is designed
to allow for such factors.
"We recognise the concerns expressed
by one badger group that 'unscrupulous individuals could well
take advantage of conveniently caged badgers' for use in badger-baiting
. . . we ask the Bourne Group through MAFF for reassurance that
all traps are checked sufficiently regularly to prevent this occurring."
30. As explained in the progress report
of February 2000 traps are checked as early as possible the next
day. Although some badgers appear to have been released from traps
by trial protesters, there is no evidence to suggest their use
in badger baiting.
"We agree with the recommendation of
English Nature that the Bourne Group gather what information it
can about the scale of illegal culling."
31. Regular unannounced spot checks of setts
are carried out in "Survey Only" triplet areas to monitor
for signs of illegal culling. We have no evidence to suggest this
". . . it is essential that the Bourne
Group can satisfy itself and hence interested observers that the
trial can be completed within a reasonable timescale and that
the results will be statistically sound."
32. The Independent Scientific Group has
confirmed to the Government that the trial remains on course to
produce valid results. The Group believes results may be available
by 2004, possibly earlier depending on the strength of the association
between badgers and TB in cattle. See also the response to recommendation
nn, on the statistical robustness of the badger culling trial.
"We recommend that MAFF publish its forward
projections of the number of staff it will need to complete the
trial within the five year period and how it proposes to meet
33. The projected complement of staff required
in the MAFF Wildlife Unit is 202. This ceiling will be achieved
through regular internal and external recruitment exercises to
fill vacancies. There are currently 171 staff in the WLU.
"We recommend that MAFF address the ability
of its laboratories to cope with the workload caused by the trial
as a matter of urgency and publish an analysis of the impact of
the culling trial upon the existing laboratory resources".
34. There are now five laboratories with
suitable facilities for carrying out badger post mortems and these
should provide sufficient capacity for the culling trial to be
completed. Work was carried out to forecast MAFF requirements
for badger post-mortems and VLA capacity to meet this is kept
"We recommend that MAFF publish an account
of how and when it met the requirements of each of the three monitoring
processes recommended by the Bourne Group for the first triplet
and how these processes will be applied in the second, third and
35. The Government expects to publish reports
from independent audits of the procedures for surveying for badger
activity and on the badger humane dispatch procedures in the Autumn
of 2000, together with its responses. The recommendations from
the auditors will be incorporated into the standard operating
procedures for the badger culling trial. A contract has been agreed
with the new humane dispatch auditor following the original auditors'
decision to stand down. A new contract is currently being negotiated
with the auditor for surveying.
"Although existing evidence suggests
that badger removal is unlikely to have adverse ecological consequences,
we support the environmental impact study that is now underway
and we recommend that it be made public as soon as it is completed."
36. A Central Science Laboratory project
to assess the ecological consequences of badger removal is now
in its second year. Areas subject to proactive, reactive and survey-only
treatments in four triplets will be monitored for one year before
and at least three years after treatment. Surveys will assess
the abundance and performance of selected bird and mammal species
in each triplet. Results are not yet available for this research
". . . we accept that it is not essential
to know exact densities of badgers, only that numbers have been
greatly reduced in the proactive areas."
37. Proactive culling has been carried out
in five triplets. It is estimated that about 20 per cent of the
badgers, which are available to be trapped in the "proactive"
culling areas, will be left after the initial trapping. This 80
per cent capture efficiency takes account of the use of cage traps.
Surveys carried out after culling in four of the five areas proactively
culled so far are consistent with this estimate of 80 per cent.
In one area, Gloucester/Hereford, the number of badgers trapped
was lower, possibly due to the fact that the field operations
took place in January, when badgers are less active. There may
also have been a lower population there due to previous official
culling operations in the area concerned.
The statistical power of the trial
". . . [The illegal culling of badgers]
could result in the trial failing to show that culling is a practical
way of reducing the incidence of TB . . . It is therefore extremely
important to encourage the co-operation of farmers in the control
areas and also to monitor the control areas periodically to assess
the incidence of killing, as we have recommended above. The use
of mortality tags to estimate the level of illegal culling should
be further investigated . . ."
38. Regular unannounced visits to survey
only areas have not revealed evidence of illegal culling of badgers.
Co-operation from farmers and landowners in these areas is very
good. The importance of not interfering with badgers in survey
only areas and elsewhere is a message the Government continue
to emphasise at every suitable opportunity.
". . . it is necessary for the Bourne
Group to undertake [quarterly] power analyses, which should be
verified independently by an expert, and to keep the Minister
informed of the relative strengths and weaknesses of the trial
. . . We also recommend that the original data behind the power
analysis conducted by Dr Donnelly from the Bourne Group . . .
be verified by an external expert and the results of this check
be made publicly available . . ."
39. Following the Committee's recommendation
the Government has agreed a contract with an independent statistical
expert. Professor Denis Mollison of Heriot-Watt University, Edinburgh
was appointed on 22 August 2000 to independently verify the original
data behind the power analysis conducted by the ISG. The Government
will publish his reports when these are presented.
Conclusions on trial
"We do not accept that the answers to
the questions posed by the trial are already known . . . We recommend
that the culling trial be implemented in full and strongly encourage
all interested parties to co-operate with it in order that reliable
results be attained in the minimum possible time and with the
minimum loss of life to badgers."
40. The Government agreed with this recommendation.
Answers are needed about the contribution badgers make to TB in
cattle and whether culling badgers reduces TB in cattle. The Government
believes that the badger culling trial and the associated research
programme are the best ways of finding the answers which will
help the development of a science based policy for the long term
control of TB in cattle.
Speed of implementation
". . . a prolonged trial would mean data
would be more difficult to interpret, the problem for the cattle
industry horrendous and the credibility of Government to find
a solution lost with unknown consequences."
41. The Government agreed with this conclusion.
The Independent Scientific Group expects results from the trial
by 2004, possibly earlier depending on the strength of the association
between badgers and TB in cattle.
"We recommend that MAFF together with
the Bourne Group examine ways in which the trial could be implemented
more speedily without impugning its scientific rigour. At very
least a target should be established for the full implementation
of all 10 triplets by the start of the closed season in February
2000 . . ."
"The Bourne Group will need to have the
strength and authority to ensure that the schedule for implementation
is met. At the moment, it is not evident that this is the case
or that the Group have any sanctions should the timetable slip.
This problem must be addressed by the Minister as a matter of
42. The timetable for the trial, set down
by the Independent Scientific Group, envisages seven triplets
being subject to initial proactive culling by the end of 2000
and all 10 by the end of 2001. The Government expects to meet
The Bourne Group
"We do not recommend that new members
be appointed to widen the Representation on the Group."
43. The Government agreed with this conclusion.
No further members have been appointed to the ISG.
Communication of data and information
"We recommend that the Bourne Group prepare
and release progress reports on a quarterly basis summarising
the progress of the trial and giving qualitative indications of
the preliminary results, with a strong warning as to the reliability
of conclusions based on the data."
44. Progress on the Government's TB Strategy,
including the Badger culling trial, is summarised in quarterly
reports which are made available to Members of Parliament and
the TB Forum and placed on MAFF's TB website. The annual reports
to the Independent Scientific Group contain more detailed information
on the trial and the related scientific research. MAFF also issues
news releases to cover particular events; for example, the announcement
of triplets and publication of reports such as the external auditors,
husbandry and vaccine advisor reports.
"We recommend that, in consultation with
an independent expert statistician, the Bourne Group carefully
consider what information can be made available, when and in what
form and that their decision be made known to the public well
45. This forms part of the contract of the
independent statistician whose reports will be published, see
response to recommendation nn.
"We recommend that once the trial as
planned is completed, the results be published as soon as possible
and all data be made as widely available as possible for analysis
by scientists or other parties."
46. The Government is committed to completing
the trial as quickly as possible and to making the results publicly
"We recommend that MAFF reassess its
PR strategy in relation to the implementation of the Krebs report,
with particular attention to improving public awareness of the
purpose of the culling trial."
"We recommend that the communication
strategy followed by MAFF in relation to informing vets and farmers
about TB incidents be reviewed."
47. The Government recognise the importance
of communications and is constantly looking for new and better
ways to explain the progress it is making in tackling TB in cattle.
At this year's Royal Agriculture Show in July there was a dedicated
TB in cattle stand where MAFF experts and Professor John Bourne,
Chairman of the Independent Scientific Group, were available to
answer questions. This initiative is to be repeated in 2001. TB
in cattle information was also available at other agriculture
shows. The MAFF TB website has been completely overhauled and
provides an informative source of information on the disease and
on the research and control work in place. MAFF has also produced
a set of factsheets that are freely available and there are regular
progress reports provided by MAFF to the Committee, MPs and the
TB Forum. However, the Government will continue to look at new
communication opportunities to explain its position and to listen
to feedback. In particular more information will be provided in
individual badger culling trial areas to explain the need for
the trial and progress on the wider research strategy. This effort
will be aimed at the general public as well as farmers, vets,
conservation and welfare groups.
The Bern Convention
". . . We find it astonishing that MAFF
placed their Ministers in such an embarrassing position . . .
we await with interest the outcome of the Government's defence
of its policy."
48. In December 1999 Bern Contracting Parties
agreed that the badger culling trial did not contravene the Convention.
The Government submitted an annual report on its TB strategy to
the Bern Convention in September 2000. Copies have been placed
in the Library of the House. The report will be considered at
the meeting of the Standing Committee to the Convention on 27
November to 1 December 2000.
"The withdrawal of its leaflet on farm
husbandry practices in connection with badgers and bovine TB demonstrates
MAFF's awareness of its shortcomings, but to do nothing to determine
what better advice should be offered to farmers is unacceptable".
49. In considering the report from the Independent
Husbandry Panel, the MAFF TB in Cattle and Farm Bio-security guidance
issued in July 1999 will be reviewed. This is expected to identify
where further guidance material covering different husbandry practices
may be useful.
". . . we are not convinced that the
industry as a whole has done enough in the past to address the
multifactoral nature of the bovine TB problem and the possible
role played by husbandry practices in finding a solution".
50. The TB Forum which includes representatives
from farming, veterinary, welfare and conservation organisations
is helping find new ways to tackle the TB in cattle problem. The
Forum has considered a number of proposals for changes to present
TB in cattle controls, including:
restrictions on cattle movements
between the two stages of the tuberculin test;
imposition of movement restrictions
if herds are not tested by the due date;
a requirement to report the isolation
of the M. bovis organism in any mammalian tissue (other
provision of better information for
cattle purchasers about the TB status of cattle.
51. Sub-groups of the Forum are looking
at the recommendations in the Husbandry Panel report and the use
of the gamma-interferon blood test to assist in the detection
of TB in cattle in Great Britain. A feasibility study on the use
of gamma-interferon as an adjunct to the tuberculin test is due
to commence in October 2000.
"We recommend that, in consultation with
the farming industry, MAFF and the Bourne Group simplify TB99.
The new questionnaire should then be subject to a rigorous pilot
exercise on farms and assessed for ease of administrative handling
before approval is given to a final version."
52. An amended TB99 has been drafted to
take into account comments received from SVS staff who administer
the questionnaire and those at the VLA who manage the database.
The revised form will gather a similar range of information; but
the order of questions has been changed to make it easier to manage
at the successive visits and some questions have been adapted
to make them clearer. The ISG is considering the proposed revision
along with comments from TB Forum members and other interested
parties. The new version should be ready for use in 2001.
Recommendation cccsee response for recommendation
"We commend to the Ministry the proposal
of the Soil Association for a comparison of the incidence of bovine
TB on organic farms with that on conventional farms".
53. TB99 epidemiological data has shown
that TB incidents have occurred in cattle kept on organic farms.
The initial analysis of data from the investigation of 688 confirmed
TB incidents in cattle herds which occurred during 1999, shows
that 25 (3.6 per cent) were herds on farms described as organic.
A more recent data output from the 1,195 herds entered on the
database by 15 September 2000 shows that 48 (4 per cent) were
herds on farms described as organic; 29 of these being registered
organic farms. The numbers are small but tend to suggest that
within the high risk areas, cattle kept under a range of farm
management systems can become infected with bovine tuberculosis.
Recommendation eeesee response for recommendation
"We recognise that within current spending
limits set for the Ministry in the Comprehensive Spending Review,
national levels of compensation cannot be raised to reflect consequential
loss. However, we also note that the Minister left open the possibility
that the situation may be reconsidered."
54. Under the 2000 Spending Review, no extra
money was allocated to extend compensation to cover the consequential
losses arising from a TB herd incident. The TB Forum has received
a report seeking to quantify the losses experienced by farmers
subject to movement restrictions as a result of TB in the herd.
The Forum is also considering ways in which the impact of the
imposition of movement restrictions may be mitigated without increasing
the risk of increased TB spread and incidence (for example by
being more flexible in allowing movement of cattle into herds
under movement restrictions). In the context of the recent Classical
Swine Fever outbreak, a Government-Industry working party has
been established to review ways in which the farming industry
can take steps to insure itself against the commercial losses
which arise from action taken to eliminate exotic animal diseases.
Although the terms of reference for this review do not cover bovine
TB, its conclusions may have wider relevance for commercial risks
faced by the farming industry.
Short term action by Government
"We recommend that, at present, no additional
action should be taken outside the trial area . . . We . . . urge
the government to give serious consideration to the NFU's case,
with a view to introducing a policy for the control of localised
bovine tuberculosis outbreaks in areas outside the trial within
the next 12 months."
55. A sub-group of the TB Forum, which included
representatives of farming and veterinary organisations, prepared
a preliminary discussion paper on a possible alternative strategy
for the control of bovine TB in cattle in areas away from the
badger culling trials. This paper included a suggestion for localised
badger culling under strictly defined circumstances. The paper
did not represent the official position of any of the organisations
represented on the TB Forum. The paper was discussed at a meeting
of the full TB Forum on 13 July 2000, and was strongly opposed
by conservation and animal welfare organisations. After an initial
discussion of the paper, Forum members were invited to submit
written comments on the paper ahead of the next Forum meeting
on 19 October 2000. At this time no decision has been taken to
introduce badger culling outside of the trial areas. The Government
is committed to seeing through the badger culling trials in order
to assess the impact of culling on the incidence of TB in cattle.
"We recommend that the Minister reconsiders
his decision on including the date of the last TB test in cattle
56. As explained in the Government's progress
report of February 2000 the TB Forum did not support the suggestion
of showing TB status on the cattle passport. Putting the information
on cattle passports would provide no guarantee to a buyer that
the animal was free from TB at the time of purchase. At best it
would show when the animal was last tested. It could also lead
to delays in moving cattle as passports would need to be passed
to BCMS to have the data entered. It would require passports to
be redesigned and re-issued to allow the new data to be included.
The Government is implementing procedures to provide cattle purchasers
with better information on the TB status of cattle. The procedure
takes the form of a voluntary system where copies of the last
TB test results are passed to buyers on request.
Future policy options
"We recommend that the Government specify
the criteria on which its sustainable policy on the control of
bovine TB will be judged and publish detailed objectives for the
policy in the short and the long-term. We also recommend that
MAFF undertake a statistical risk assessment of the possible policy
procedures, in conjunction with the Bourne Group and representatives
of all interested parties."
57. The Government is making progress on
all elements of its strategy to tackle TB in cattle. The main
focus remains on the regular testing of cattle herds and the associated
controls, which together with compensation payments will account
for about £26 million of the £45 million budget this
year. In addition, there is a comprehensive research programme,
overseen by the Independent Scientific Group, which includes work
on vaccines, on epidemiology, on disease transmission, on cattle
husbandry and on other wildlife species, as well as the badger
culling trial. The Government is determined to find the scientific
basis on which to build a lasting policy to control TB in cattle.
As stated in the progress report issued in February 2000, policies
will be judged according to the impact on public health, on animal
health and welfare, on the environment and on the economy, in
particular the farming industry and public expenditure.
31 October 2000