The NFU has welcomed the Defra consultation which details proposals for future TB policy. The suggested introduction of a TBI (targeted badger intervention) policy and simplified licensing procedure offers sound principles for disease control, which we hope can be implemented to continue building on the great benefits industry have achieved in reducing bTB.
The NFU is aligned with the overarching aim of the cattle measures set out in the consultation.
The proposals to enhance accessible information on ibTB follow recommendations made by the TB Partnership.
How would TBI be delivered?
The guidance to applicants included within the consultation document is similar to the guidance for current SBC (supplementary badger control) areas. Operationally we would therefore expect methods, operating procedures, and licence conditions to remain broadly the same as that policy.
Badger vaccination delivery
There is no defined expectation within the consultation regarding who will be the badger vaccination delivery body.
Similarly, we don’t know at this stage what the requirements will be to demonstrate the ability to vaccinate after culling when applying for a licence. The consultation suggests this could be a field force of individuals to undertake training, or via securing the services of an existing supplier.
Change of licensing organisation
Natural England currently work closely with cull companies, creating detailed reports which are submitted to the Chief Veterinary Officer and Secretary of State. We anticipate that the proposed change of licensing organisation would therefore be similar to the current structure which offers the Secretary of State powers for decision making under the Protection of Badgers Act, regardless of the licensing body.
Defining clusters and eligibility for culling
We support the proposal for Chief Veterinary Officer’s decision making to be in collaboration with expert advisers, but also believe that there should be mechanisms in place to allow farmers and vets in and around clusters to feed into this process.
We are awaiting further information from Defra and the APHA on details of clusters, including how they are identified and the regularity of the identification, but we can agree with the broad principles for identifying localised disease issues and reducing disease.
We also need further information on their size and geographical spread which is currently not available to have confidence they will achieve the desired outcomes.
It can be anticipated however that clusters will not align to existing cull areas so there will be a need for ongoing local engagement and industry representation.
The networks that have been developed have been a key part of successful wildlife control to date and these must be maintained in order to deliver effective culls in eligible clusters.
Organisational licence – what would it look like and who would be responsible?
There may be an opportunity to streamline costs and the administrative burden by centralising tasks under one organisational licence issued annually. This could also permit industry to react faster once a cluster is identified and deemed eligible for culling.
Whoever takes this on will, as stated in the consultation, have a greater level of responsibility for operations on the ground so a strong network of contacts across a cluster will be vital.
We understand the huge amount of work and dedication that has gone into delivering industry-led culling over the last decade, and it is vital the investment is maintained.
The NFU will continue supporting industry to deliver any future wildlife control policy successfully.
Who will pay for culling and vaccination?
It is proposed that culling will continue to be industry-led and industry funded, however we would expect any badger vaccination to be supported financially by Defra.
Given the lack of evidence on its effectiveness at reducing bTB within cattle there cannot be an expectation for farmers to pay.
We would strongly recommend that any savings made by the government through licensing changes are invested in successful delivery of culling as a proven disease control measure.
NFU position on cattle measures
The NFU endorses initiatives that empower farmers with disease information, enabling them to make informed individual purchasing decisions tailored to their herds, thus mitigating TB risk and minimising disease transmission.
However, we are mindful that these measures must not impact trading opportunities or result in diminished stock values with the potential of creating a two-tier market.
ibTB data
The ibTB map is currently updated every two weeks; we do not yet have details of whether the information relating to animal data will be real time, however, we believe that it should be to be of use to farmers.
Benefits of publishing additional disease information on ibTB
Cattle movements are a recognised TB risk pathway with the potential to introduce disease into herds. Publishing additional animal and herd level TB information will enable potential buyers to assess the associated TB risk – especially relevant for breeding stock.
If CPH and tag numbers of potential source cattle are known in advance buyers will be able to cross reference ibTB to access key information to ensure the purchase fits with their business model.
The date and type of an animals’ most recent pre-movement TB test provides reassurance that an animal moving to a new herd has a low TB risk of spreading residual infection.
TB testing has limitations and risk factors are variable; information such as the length of time in a herd, number of years that herd has been TB Free, and the date and type of the last TB test are key indicators of the level of disease exposure.
Increasing accessible routine information gives greater transparency and promotes responsible purchasing within the cattle industry.
How will bTB risk information on source stock herd be displayed?
The level of detail is yet to be confirmed but we expect this to be developed once the principle to display it is established. Updates to the ibTB website will be part of a three-year improvement project.
Currently, herds locations are the registered address of the CPH; bTB history for all herds ('the health rating view') for the last 10 years displays as a traffic light system.
Cattle vaccination
The Veterinary Medicines Directorate has not approved the cattle BCG vaccine for use in the UK because it can cross-react with the approved tuberculin skin test used for national bovine TB surveillance.
An effective DIVA test that can tell infected animals apart from vaccinated animals is vital. Defra recently announced a future third phase of the UK cattle vaccine field trials to further assess the specificity of the DIVA test and options to maximise performance.
How will the changes be funded and delivered?
The consultation states that proposals to enhance ibTB will not result in increased costs or burdens to the industry.
Funding for the proposed enhancements to the ibTB website is expected to be through the Government’s bovine TB control programme and implementation will require resource from the APHA.
It will be imperative that there is no impact upon their existing commitments.
Livestock information service
The NFU supports the delivery of the livestock information service for cattle which has the potential to deliver additional TB information at the point of sale to support a voluntary risk-based trade approach.
Enhancing ibTB information at the animal level is not comparable to the potential to give cattle keepers information through the livestock information service which we urge Defra to introduce as soon as possible.
