Memorandum submitted by Dr Elaine King,
National Federation of Badger Groups (J13)
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
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
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
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
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.
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
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
18. development of a vaccine for cattle
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
26. The Government asserts that the current
programme to control bovine TB in cattle is designed to protect
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,
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
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
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 cattleit 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
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.
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
71. Review of TB testing frequencies and requirements
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,
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
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
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,
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).