TB Forum Secretariat paper TBF79
Source: FWi 20 February 2003

TBF79

Discussion paper on TB control policy options that might be adopted during 2003

Introduction

1. Defra, which was established on 9 June 2001, is the champion of sustainable development.  This rtle together with the publication of the Policy Commission report on the Future of Farming and Food, “Farming and Food, a sustainable future”, has focused attention on the economic, social and environmental consequences of Government policies including those in the animal health field.  In particular, the Policy Commission recommended that:
In view of England’s abysmal animal health record in recent years, Defra in consultation with the industry need to devise and implement a comprehensive animal health strategy. 
This recommendation was accepted in the Government’s response to the Policy Commission report, “The Strategy for Sustainable Farming and Food – Facing the Future”.

2. The Foot and Mouth Disease (FMD) epidemic of 2001 also had the effect ofhighlighting the significant consequences of animal disease not only on livestock farming,but also on the wider rural community and associated industries such as tourism. The mainreport of inquiries into the epidemic, the report of the Royal Society into the 2001 FMDoutbreak, “Infectious diseases in livestock” and the report of the Lessons to be LearnedInquiry into Foot and Mouth Disease 2001, both supported the recommendation of the Policy Commission. 

3. Defra is therefore in the process of developing an Animal Health and WelfareStrategy which we expect to publish in the summer of 2003. Although the PolicyCommission Report  referred to the animal health situation in England, the development ofan Animal Health and Welfare Strategy will be taken forward together with Devolved Administrations in Scotland and Wales.  This reflects the fact that GB constitutes a single epidemiological unit, and that the State Veterinary Service is a GB wideorganisation.  A joint consultation document was issued on 8 January.  During thedevelopment of the Animal Health and Welfare Strategy, the three GB environment and rural affairs departments will work in partnership with industry, specialists and the wider community to provide an overarching framework for the development and implementation of policies in all areas of animal health and welfare.  Clearly, any Animal Health and Welfare Strategy for Great Britain would be incomplete if it did not encompass bovine TB. This year Defra, with the Welsh and Scottish administrations will be developing a TB Strategy for GB in close consultation with the industry and stakeholders.

4. However, it is recognised that the process of developing a strategic approach which takes due account of the views of stakeholders will not be quick enough to satisfy all concerned that the Government is doing all that it can to address the immediate problem of bovine TB.  A number of policy options which might be introduced in the short term are therefore under consideration.  These might include:

• clearer implementation of EU legislative requirements;
• review of test frequencies to ensure compliance with EU minima;
• tailoring TB controls according to TB risk by area and/or herd health history;
• the introduction of pre movement testing;
• requiring on farm management action to reduce TB risk to cattle (for example, post movement testing with on farm isolation, herd health plans, excluding badgers from farm buildings); 
• review to identify possible need for test frequencies above the EU minima in certain areas;
• improvements in delivery of TB controls which might be made through the development of a new relationship between the SVS and LVIs;
• increasing the pool of people trained to test for TB and available to deliver testing (including the possible use of lay testers);
• streamlining service delivery processes within SVS in order to improve efficiency and reduce administrative delays;
• speeding up removal off farms of cattle that react to the tuberculin test (in part by reviewing and simplifying the compensation process).  
These are explored more fully in the following paragraphs.

Clearer implementation of EU legislative requirements.

5. Much of the framework for TB disease control in GB is set by European legislation governing trade in live cattle between member states (Council Directive 64/432/EC).  EU legislation is predicated on the classification of herds according to their TB status, and variation in the control measures necessary accordingly.  National rules have a similar effect, but the transparency of implementation would be much improved by translating EU rules into national legislation more clearly.  In addition, in some instances additional national requirements are set out under the respective national TB Orders.  Many in the industry are not clear where EU obligations end and national discretion begins. Defra would like to remake the English legislation to make clear which parts implement EU requirements and which parts implement additional national controls. 

6. Additional requirements might include:
• a prohibition on the marketing of live animals from herds with unknown TB status i.e. overdue tests (excluding marketing direct to slaughter);
• the power to ban the sale of milk or the despatch of cattle for slaughter from herds where the farmers refuse to carry out minimum TB testing (e.g. once a year);
• clear reference to the provisions in the Annex to Council Directive 64/432 on how appropriate testing frequencies are assessed and set; and
• pre movement testing and other requirements for the movement of cattle into areas of the country with EU recognition of “officially tuberculosis free region” status or being developed for that recognition.
They would definitely include the three main changes consulted on in 2001: a widening of the obligation to report M.bovis to the authorities, prohibition of the movement of cattle between the two days of testing, clarification of the Department’s power to impose movement restrictions on herds where the owner/ keeper refuses to have a test done by the due date.
 
Review and redistribution or increase of test frequencies in certain areas

7. The testing frequency of parishes is regularly reviewed by DVMs to take account ofthe latest disease situation.  However, the last full review of parish testing frequencies to ensure compliance with EU legislation was undertaken in 2000.  We need to carry out a review to ensure that the minimum standards set out in EU legislation are being applied in all areas.

Tailoring of TB controls according to TB risk by area and or herd health history.

8. Some areas of the country present a very low risk of bovine TB, and these areas should be protected against incursions of disease through the movement of cattle.  A zoning policy could be adopted in order to achieve this.  However, even in areas with higher numbers of TB incidents,  i.e. where 10 – 20% of herds might be placed under movement restriction in any one year,  there are a number of herds which have not suffered TB incidents in the recent past.  The problem with zoning where boundaries are set over large geographical areas is that all herds in the area have nominally the same risk of infection with TB even though the testing history of the individual herd would suggest otherwise.  A zoning policy which does not distinguish between herds on the basis of their individual history will therefore discriminate against some low risk herds.  We need to consider ways in which such discrimination might be avoided.  A working example might be the New Zealand arrangements, where each individual herd, regardless of the zonal controls which are applied, has a status for trading purposes based on the length of time since the last TB incident. 

The introduction of pre movement testing

9.  A requirement for pre-movement testing might be introduced for all cattle moving into areas either with or being groomed for EU recognition as OTF free regions (see paragraph 8 above).  The requirement for pre movement testing could be extended to all cattle being sold.  The veterinary resource available to deliver this and whether farmers or the state should bear the costs will be issues to consider here.  The test has known limitations in its ability to detect individual animals with infection and this also needs to be borne in mind.

Requiring on farm management action to reduce TB risk to cattle

10. There are measures that farmers can take when introducing cattle into the herd to reduce the risk of bringing in an infected animal.  If the option of pre movement testing is not adopted, isolation with post movement testing might be considered.  This could either be made mandatory or optional (with the incentive that a positive test in an animal brought into approved isolation facilities would not result in restrictions on the remainder of the herd).  In either case, there would be a need for the industry to equip itself with isolation facilities that meet requirements.

11. Defra would also like to explore whether legislation can be amended to make clear the responsibilities of individual farmers for disease control.  These might include requirements on farmers to:

• ensure that the TB testing of their herd is up to date;
• to nominate to the SVS the private veterinary surgeon they have chosen to carry out the testing (and to change and keep that nomination up to date should their chosen practice prove unable to deliver testing in time);
• draw up a herd health plan with the nominated private vet;
• provide evidence of the disease status (OTF or other) and last herd test results to buyers.

12. It might also include requirements on market operators to ensure that all cattle passing through markets are accompanied by proof of the recent disease history of the herd.

13. Advice on excluding badgers from farm buildings could be issued but there are already issues around livestock industry take up of advice.

Additional national testing in certain areas

14. Defra may consider whether, on the basis of veterinary risk assessments, a case could be made for increasing testing frequencies over and above EU minimum requirements in certain circumstances e.g. from quadrennial to biennial or biennial to annual.  For example, disease spread modelling or other predictive methods might be able to identify areas where TB is likely to spread in the immediate future.  It might be useful to increase testing frequency in areas identified as at risk of spread. 

Improvements in delivery of TB controls which might be made through the development of a new relationship between the SVS and LVIs

15. Current arrangements for the appointment of LVIs and delivery of LVI work on behalf of the Department are currently under review.  This review will need to take account of changes to the current arrangements which can be made in order to deliver more effective TB surveillance and control.  Consultation on any proposed changes is likely to commence this summer.

Increasing the pool of people trained to test for TB and available to deliver testing (including the possible use of lay testers)

16. The qualifications which should be required of a TB tester are a veterinary professional matter, and the CVO will be taking this forward with the veterinary profession. 

Streamlining service delivery processes within SVS in order to improve efficiency and reduce administrative delays

17.   The SVS are currently taking forward a project to map all processes connected with TB service delivery to identify and deal with duplication and bottlenecks.  The results of this work, which includes looking at the IT support need and the forms associated with service delivery, are likely to become available at the end of the year. 

This work is also informing development of a replacement IT system for VetNet with database and enhanced reporting and monitoring capabilities.  This is currently estimated to be some two years away from coming on stream.Speeding up removal off farms of cattle that react to the tuberculin test (in part by reviewing and simplifying the compensation process).

16. A major complaint of farmers affected by TB is that reactor cattle are not removed from herds swiftly enough.  Yet a significant proportion of farmers opt for the use of two valuers for the valuation of the cattle to be slaughtered.  In certain areas the valuer of their choice is not readily available thus prolonging the length of time affected animals stay on farm.  Considerable SVS resource, which might be directed to activities more closely concerned with disease control, is dedicated to organising valuation visits. 

Proposals for the rationalisation of compensation which will reduce dependency on individual valuations are being prepared, and will be issued for consultation in the summer.

TB Forum Secretariat
February 2003