TB Strategic Partnership Group Interim Report

TB Strategic Partnership Group Interim Report Comments by Northern Ireland Environment Link 4 th September 2015 Northern Ireland Environment Link (NIEL) is the networking and forum body for non-statutory organisations concerned with the environment of Northern Ireland. Its 62 Full Members represent over 90,000 individuals, 262 subsidiary groups, have an annual turnover of 70 million and manage over 314,000 acres of land. Members are involved in environmental issues of all types and at all levels from the local community to the global environment. NIEL brings together a wide range of knowledge, experience and expertise which can be used to help develop policy, practice and implementation across a wide range of environmental fields. These comments are made on behalf of Members, but some members may be providing independent comments as well. Please note that Ulster Wildlife who gave evidence to the TB Strategic Partnership Group has been involved in constructing this response and do not intend to provide a separate submission. If you would like to discuss these comments further we would be delighted to do so. Dr Stephen McCabe Northern Ireland Environment Link 89 Loopland Drive Belfast, BT6 9DW P: 028 9045 5770 E: jonathan@nienvironmentlink.org W: www.nienvironmentlink.org Northern Ireland Environment Link is a Company limited by guarantee No NI034988 and a Charity registered with Inland Revenue No XR19598

NIEL is grateful for the opportunity to engage with the DARD Strategic Partnership Group on the issue of bovine TB, and to comment on their Interim Report. We welcome the positive and transparent nature of the report, and look forward to continued engagement in these difficult issues. Culture and communication A) What do you consider to be the main barriers to TB eradication facing all stakeholders e.g., attitude knowledge, culture, resignation to the current TB situation. NIEL believes that it is crucial to foster openness and cross-sectoral partnerships going forward. An obvious barrier to progress is that various groups hold strong views on the issue of bovine TB and wildlife, and stakeholders need to come together in a non-confrontational and constructive way under the leadership of the Strategic Partnership Group. Another barrier to success remains the science gap on the means of both disease spread and containment. For example, AFBI research has not proven any definitive cause and effect in the spread of btb to date via the badger population other than establishing that they carry similar DNA strains of btb. In fact, there was no significant contact evident between cattle and badgers either at grass or when housed. The recent QUB study recently published is also a significant cause for concern. This report highlighted that approximately 5% of badger setts showed signs of recent illegal damage. The study suggested that this practice could contribute significantly to new bovine TB breakdowns in nearby cattle. As a result of uncertainty in the science, there is often inconsistency in message. Another study on the effects of badger culling showed that localised, reactive culling is ineffective and can actually increase btb infection levels in cattle. Culling can disrupt the territorial organisation of badger communities leading to greater movement of individuals, and an increased likelihood of disease transmission in adjoining areas. However, the study did show that a well-co-ordinated, simultaneous cull of badgers over a substantial area (at least 150 square km) over a protracted period (at least four years) would in theory reduce btb in cattle in and around the cull area by approximately 16%. That said, NIEL would not support a widespread cull. There is a significant risk that culling on this scale would not be practicable or cost effective. A poorly co-ordinated cull that was not synchronised could lead to an increase in TB outbreaks. We emphasise that sound policy will arise out of stakeholder engagement (not only with the Strategic Partnership Group, but facilitated engagement between stakeholders) and increased information based on sound science, perhaps especially around the involvement (or otherwise) of wildlife/badgers in the spread of btb.

B) Do you agree that developing a local partnership approach as outlined at 3.9 is the most effective way to develop the constructive engagement necessary to overcome these barriers. Yes, NIEL agrees that local partnership working should be implemented. A wide range of stakeholder groups need to come together, potentially under the guidance of the Strategic Partnership Group, including environmentalists, to share their ideas in a non-confrontational way for sound policy, based on objective science. There is, however, a risk that such groups could become talking shops and that deep preconceptions could distort the key messages so we would suggest that Government, AFBI and QUB have a very important role to play in this process. C) In terms of the options presented at 3.8, how might farmers and private vets take greater responsibility for TB eradication? NIEL stresses the need for the full implementation of biosecurity measures on-farm doing simple things well (for example, double fencing, secure housing and meal stores, tagging and notification procedures around the movement of cattle) will, we believe, yield significant benefits. Farmers, vets and DARD advisors should work closely together to ensure good practice. D) Thinking about option 3.11, how should we develop stronger engagement, raise awareness and create a more proactive culture around TB eradication. NIEL fully supports a vigorous publicity campaign around farm bio-security measures and procedures. There is a spectrum of strongly held views, assumptions, and interests that different groups bring to the table. NIEL recommends that any research undertaken is closely linked to an honest broker or knowledge broker (neutral third party or a dedicated worker with this role) to help communicate potentially difficult or controversial ideas in understandable and acceptable ways. The value of such a role should not be underestimated in the context of these emotive issues. Information could be disseminated through the local animal health committees outlined in 3.8. Governance and Delivery A) Taking into accounts the options presented at 4.4 to 4.7, do you consider that a new system of governance is needed to successfully eradicate TB? We would hope that a variation of the current governance is likely to be suitable, and we would rather encourage change on the ground through making funding

available for bio-security measures on farms and through bio-security audits to ensure standards are being met than locking up funds in additional formal structures. B) Do you consider that increased industry involvement at a strategic level should be accompanied by cost and responsibility sharing with government? Part of the solution will be in industry enforcing a level of compliance amongst operators. Cost should not fall solely on the public purse. Industry will benefit from improved practice and thus should take some shared responsibility and cost. Given that tax payers already subsidise agriculture through CAP and the Basic Area Payment, it would seem appropriate that some of the cost be shared between industry and government. One potential way forward would be an industry levy that could help fund research into knowledge gaps. Existing tools and processes A) Do you consider that the parallel testing regime with INFG as suggested at 5.4 would speed up disease control and reduce the potential for disease spread? INFG may be able to speed up disease control and reduce the potential for disease spread. Blood sample based diagnostics would remove some practical difficulties associated with the skin test SICTT. B) Do you consider that the responsible person making a diagnosis should DNA tag the animal to reduce the risk of inadvertent substitution as suggested at 5.5 Yes, NIEL agrees that this would be good practice. C) Do you see a role for lay testers under appropriate supervision? Testing should be done by trained individuals and accompanied by a robust system of quality assurance to international inspection standards EN4501 / ISO 17065. If completed by local vets, part of this role could be up-skilling the farmer by informing him of any recent research and best practice guidelines, since prevention is better than cure. This could also include a simple biosecurity audit of the farm with recommended actions that farmers should follow. If this advice is not taken on board within a realistic timeframe, a reduced level of compensation could apply if a subsequent herd breakdown occurs.

D) In terms of the option presented at 5.9, do you consider that herds should be designated on basis of risk? Designating herds on the basis of risk to include disease history and assessment/ rating of on-farm measures to limit infection risk both within and between herds would be beneficial. Using a risk-based approach makes logical sense and facilitates informed decisions by those who are purchasing stock, although certain requirements relating to biosecurity, cattle testing and movement need to be rigorously applied (and audited) across all areas in order to ensure the overall success. As a risk based approach is likely to impact upon value of the animal, there needs to be consistency of implementation to ensure a fair and equitable system. E) Should a system of pre-movement testing as outlined at 5.10 be introduced? A system of pre-movement testing would be beneficial. This should be as comprehensive as is practical and should be accompanied by effective monitoring of movement compliance protocols. Pre-movement testing was successfully undertaken in Wales and is now compulsory. F) Do you consider that the agriculture industry should pay for the pre-movement test? From a public perspective, it would seem logical for any pre-movement test to be paid by the agriculture industry. It is in effect a quality assurance system prior to sale. Other quality assurance systems are financed by the industry e.g. FQAS. G) What are your views on the value of inspection of animal testing being carried out to international inspection standards as suggested at 5.11 NIEL supports inspection being carried out to international standards. Wildlife A) Which of the following do you consider as the best option to help reduce the reservoir of TB infected badgers A programme of badger vaccination A programme of vaccination and removal of infected badgers

A programme of badger removal We would again raise a concern over the assumption of a clear link between a reservoir of TB infected badgers and the transmission of the disease to cattle which has not yet been conclusively scientifically proven, and emphasise the need for evidence-based policy. The view of NIEL members is that a programme of vaccination would be the best option. Feedback from NIEL members suggests that badger vaccination provides a satisfactory alternative solution to culling that does not risk making the situation worse (as culling may do). Detailed field trials of an injectable badger vaccine showed that it reduces the number of badgers testing positive to btb by 74%. This vaccine is available now and we believe that the Government should be doing more to proactively support and encourage its use. A study carried by Queen s University Belfast has highlighted that 5% of badger setts had recent illegal disturbance. This concluded that interference with badger setts (through, for example, blocking entrances with soil, boulders and branches, or pumping full of slurry) may increase risk to local herds. See http://www.bbc.co.uk/news/uk-northern-ireland-33958608. There is therefore a need to re-educate the industry regarding interference with wildlife. Current peer-reviewed scientific research suggests that, based on numerical computer modelling, investment in increasing the frequency of cattle testing would be a more effective strategy than badger culling in dealing with the spread of btb. Ultimately, cattle vaccination will have an important contribution to make in tackling the risk to herds if eventually approved by the European Commission. B) Which of these options do you consider outlined at a) about would help to prevent disease exchange between cattle and badger populations. While it is not clear that any of the above would definitely prevent disease exchange, a programme of badger vaccination may ensure that disease is not moving from badger to cattle. We would encourage development of the cattle vaccine. The results from the TVR study may provide an additional evidence base for consideration, however at this point its impact is unknown and ability to upscale will be an issue for Northern Ireland given its cost.

C) The trapping and injection of individual badgers is costly and can be in excess of 600 per badger. Given the significant cost of any badger intervention how such an initiative might be funded? Ancillary activities (trapping etc.) could potentially be carried out by lay persons, which would help to reduce the cost. TVR could be co-funded and the approach adopted on high risk herds as part of a wider programme of action to reduce the risk of btb or where a breakdown occurs. We would stress that where social groupings of badgers have major disruption, perturbation is likely to occur. While TVR is an expensive process, simply vaccinating all badgers would be much less costly as they would not need to be transported off site something that is a key part of the Welsh Government s TB eradication strategy, and appears to be yielding positive results (see, for example, http://www.westerndailypress.co.uk/bovine-tbbadger-vaccination-working-welsh/story-20707412-detail/story.html). Either government or local vets could carry out the vaccination/tvr. D) Taking into consideration the information at 6.2 and 6.8, what evidence would be required to support such an initiative as limited controlled culling of infected badgers? Before targeted culling takes place it would be important to know the percentage of any social group that is infected with TB and the likely evolution of the disease within the group. Euthanizing badgers with advanced TB is something we would support as humane and responsible. Vaccination A) Do you consider the vaccination of badgers to be an acceptable approach to assist in the eradication of TB in the badger population and cattle? We agree that vaccination of badgers is an acceptable approach. B) Considering 7.9 to 7.14, if badger vaccination were to be deployed what way would it be best to deploy this and why? It would be best to be deployed in areas identified as high risk, or where a herd breakdown has occurred.

C) Should badger vaccination be carried out in conjunction with a target cull of diseased badgers as outlined at 7.11 and 7.13? While we would rather avoid a cull, specific targeted culling (with agreed criteria and guidelines) combined with vaccination is an acceptable way to proceed. We would not support a widespread cull similar to that in England. D) Do you agree that if a vaccination programme were to be deployed that it should be focused on specific areas, if so, which? As above, we suggest that high risk areas be identified and vaccination be progressed in these areas first. E) Who should administer/deliver a badger vaccination strategy? A vaccination strategy can only be delivered with buy-in from, and in partnership between, all relevant stakeholders (including government, land owners and engos). Farm Practice and Bio-Security A) In terms of the bio-security measures outlined at 8.4 to 8.11, which of these in order of preference do you think would give the greatest TB control benefit and why? Although we believe that all the biosecurity measures outlined from 8.4 to 8.11 should be actioned, and would have a positive impact, in order of preference: Farmers own vets providing advice on a range of bio-security issues, including animal movements, cleaning and disinfectant procedures, housing conditions. Associated with implementation of advice i.e. routine cleaning and disinfecting. Reducing nose-to-nose contact between herds through simple biosecurity measures and working with neighbouring farmers. Informed purchasing. Animal movement registration on APHIS. Investigating longer-term conacre leasing to encourage better land and livestock management practices.

Research and Policy Development A) What are your views are sought on the suggested research areas and the approach to taking these forward? We support all of the research areas outlined. Knowledge gleaned from sound science is crucial to an effective evidence-led strategy. Funding TB Eradication A) Do you consider that the current position in relation to 100% compensation as outlined at 10.4 is a disincentive and requires change? Compensation should remain at 100% as an incentive to farmers to support TB measures. However, this should be related to compliance in on-farm biosecurity measures testing, best practice and infection control. Failure to meet standards, adhere to best practice, or implement adequate measures to mitigate risk should result in reduced compensation as this is a cost that is borne by the tax payer.