26th Aug 2015

Consultation on TB Strategic Partnership Group Interim Report,

TB Strategic Partnership Group,

Department of Agriculture and Rural Development,

Room 650, Dundonald House,

Ballymiscaw,

Upper Newtownards Road,

Belfast

BT5 3SB

Response to consultation on TB Strategic Partnership Group Interim Report

To whom it may concern,

Tuberculosis has long been a thorn in the side of the Northern Ireland cattle industry and the Ulster Farmers' Union (UFU)welcomes this opportunity to help steer the industry towards a long term eradication policy.The UFU is the largest farming organisation within Northern Ireland representing over 11,500 farming families. The structure of the UFU ensures that policy positions are formed from the bottom up as each of the 25 groups have representatives on each commodity committee, who in turn have representatives on each of the specialist committees (in this case, the animal health and welfare committee). Views are then fed up to the executive committee where final policy positions are established. This consultation response therefore represents the views of a large proportion of farmers within Northern Ireland.

UFU response:

3a) 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?

The UFU is aware that there are many on-going factors that act as a barrier to the effective eradication of TB within Northern Ireland. These include:

  • The lack of a suitably accurate test to effectively screen for TB.
  • Inability to remove all sources of local TB infection following a breakdown (be these within cattle or the wildlife population).
  • A high density of livestock and wildlife within Northern Ireland, which leads to frequent disease transfer between the two.
  • The lack of an effective means of communication to spread knowledge and scientific research to farmers on the ground.
  • There is a perception within the farming community that DARD culture is more concerned with budget reduction and ensuring that EU funding for the Northern Ireland TB control policy is maintained,as opposed to a willingness to make hard decisive decisions and invest the resourcesnecessary to effect TB eradication.
  • Livestock farmers appear to have a significant level of distrust in DARD that leads to farmers discounting the information the department is providing them with/a reluctance to take on-board their suggestions.
  • Thereis significant frustration within the livestock farming community that politicians appear to take more consideration of the opinions of environmentalist groups than the opinions of farmers and scientific advisors.

3b) 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?

At this stage, the UFU agrees that there needs to be more effective communication between farmers and veterinary officials. However, the membership is not convinced that the current proposal is the most effective way to complete this. There is a concern that such groups would become a means for DARD to force its policies on farmers as opposed to offering an effective channel for information dissemination. If this policy was to progress, communication must be two-way with vets and DARD taking farmer suggestions and concerns on-board as opposed to forcing further on-farm inspections and biosecurity measures on farmers.

3c) In terms of the option presented at 3.8, how might farmers and private vets take greater responsibility for TB eradication?

At this stage, the UFU believes that if farmers and vets had greaterinput into the national TB policy, this would encourage better a understanding, a greater sense of industry ownership and that all stakeholders are working together to eradicate TB. However, the UFU is concerned that as DARD will remain the competent authority for TB within Northern Ireland, they will ultimately remain in control of the eradication policy. As such, there is a fear that DARD may simply reject proposals put forward by the industry and that any new stakeholders group/board/champion will simply add to bureaucracy and cost and provide a focus for farmer criticism and deflect attention away from DARD’s failure to act to eradicate TB.

3d) Thinking about option 3.11, how should we develop stronger engagement, raise awareness and create a more proactive culture around TB eradication?

The UFUanimal health and welfare committee appreciates that through this consultation process their own understanding of TB and the many complexities surrounding its eradication have increased substantially. As such, it is evident that current knowledge transfer surrounding TB from DARD/AFBI/CAFRE to farmers on the ground is poor. Furthermore, whilst the current consultation provides an excellent brief of the information and complexities surrounding TB, its length has sadly resulted in a very limited number of farmers fully reading its contents. Where information has been most successfully disseminated, this has occurred via face to face meetings and presentations from DARD/AFBI/IFA/UFU. As such, the UFU believes that a greater emphasis needs to be placed on education and effective communication with farmers. This may well be best accomplished by the establishment of the suggested local animal health committees or by having one expert individual whose sole job is to attend farmer meetings to give presentations on TB. This would include providing clear information on the accuracy of the current testing regime, long term disease trends to show progress made, disease transfer within cattle and wildlife, concurrent infections, the cost of TB, farming practices in other parts of the world, local options available for control. Furthermore, the committeebelieves that livestock courses at CAFRE could include a detailed module on TB covering the same areas to better educate new entrants to the farming community. Additionally, a suggestion was made that a series of newspaper articles breaking the final consultation document into smaller ‘bite-sized’ chunks for weekly reading may be a better way of disseminating information to the wider farming community and encourage broader industry discussion.

4a) Taking into account the options presented at 4.4 to 4.7, do you consider that a new system of governance is needed to successfully eradicate TB? i. If yes, do you support any of the options outlined and why? ii. If not, why not?

At this stage, the UFU would like to see greater leadership and willingness from within DARD, veterinary staff and scientists to comment publically and engage with the farming community and the general public in regards to TB eradication. The UFUsees benefit in creating an oversight board or electing a TB eradication champion (preferably from overseas to provide a fresh insight). However, the UFUis concerned that as long as DARD remains the competent authority on TB within Northern Ireland, any change in governance is likely to add bureaucracy and cost as any suggestions will ultimately still be approved or rejected by DARD. As such, the new body or champion would be hamstrung before it started, becoming a focal point for criticism for failure of DARD to act, whilst having no power to force change.

4b) Do you consider that increased industry involvement at a strategic level should be accompanied by cost and responsibility sharing with Government? i. If yes, on what basis? ii. If not why not?

5a) 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?

The UFU believes that this means to improve the identification and removal of infected animals within a herd would be welcomed by the industry provided a suitable cost/benefit analysis deems it to be worthwhile.

5b) 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.

5c) Do you see a role for lay testers under appropriate supervision?

The UFU believes there may be a role for lay testers, provided they are suitably trained and allowed the power to confirm a reactor without having to call a vet to confirm. Furthermore, they must be willing to work beyond a 9-5 day and on Saturday’s to minimise testing inconvenience for farmers.

5d) In terms of the option presented at 5.9, do you consider that herds should be designated on the basis of risk? i. If yes,  what risk factors should be taken into consideration?  how should the information be made available to those purchasing cattle? ii. If no, why not?

Whilst the UFU does see merit in enabling farmers to make more informed purchasing decisions in the future. There is a concern that we are not far enough along the disease eradication pathway to do this without creating intolerable trading conditions for farmers within Northern Ireland. As such, the UFU is not in favour of herd risk classification at this time.

5e) Should a system of pre-movement testing as outlined at 5.10 be introduced? i. If yes which herds should it apply to? ii. If no, why not?

At this stage, the UFU is not in favour of pre-movement testing. Based on the current accuracy of the TB testing, the UFU feels that this method would be ineffective in controlling the spread of TB, serving only to add more inconvenience and cost to farmers.

5f) Do you consider that the agricultural industry should pay for the pre-movement test? i. If yes what factors should be taken into consideration? ii. If no, why not?

The UFU is against pre-movement testing until the test accuracy can be significantly improved.

5g) What are your views on the value in the inspection of animal testing being carried out to international inspection standards as suggested at 5.11?

In the absence of more information on how much this process would cost/what benefit it would bring to the industry, the UFU does not wish to comment on this question at present.

6a) 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 (like TVR)?  a programme of badger removal?

At this stage, no scientific evidence has been presented to the UFU that wildlife vaccination or vaccination and removal leads to a significant reduction in TB in the local wildlife population. As such, we wish to hold our opinion on this topic until the results of the TVR study are made available to the committee. In light of there being no available evidence that vaccination is a suitable or cost effective approach, the UFU is in favour of the targeted removal of infected wildlife from TB hot spots or areas with persistent infection to improve the health status of the local wildlife population and cattle.

6b) Which of these options do you consider outlined at a) above would help to prevent disease exchange between the cattle and badger populations?

We believe that if a suitable, cost effective, oral vaccine can be developed, any of the above strategies would reduce disease spread between cattle and wildlife populations.

6c) 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 might such an initiative might be funded?

Due to the costs associated with trapping and vaccinating badgers, the UFU does not deem it provides a suitable cost/benefit to the industry. At this stage, the UFU would prefer to see the development and use of an oral vaccine for the wildlife population. If it is necessary to progress with the use of trapping and vaccination, we deem that animal welfare and environmental groups should bear any costs over and above what it would cost for a targeted removal of infected wildlife within a TB hot spot. Further to this, the UFU believes that farmers may be willing to support such action in the form of paying for one annual herd test per year (similar to ROI), provided that the money raised is ring fenced and only used to address the removal of TB infected wildlife.

6d) Taking into consideration the information at 6.2 to 6.8 what evidence would be required to support such an initiative as limited controlled culling of infected badgers?

The UFU deem that targeted removal of infected wildlife should be supported under the following conditions:

  • Situations where two or more herd breakdowns of neighbouring herds occur (a hot spot).
  • Situations where a herd has been persistently infected for over 1 year. The committee deem this necessary as local wildlife are likely to have also become infected during this time and without addressing all local TB sources the herd is likely to suffer a subsequent reinfection.
  • Situations where an infection has been introduced to a closed herd. As such, the only possible route for introduction will have been through infected wildlife in the surrounding area and as such, infected wildlife needs to be removed.

7a) Do you consider vaccination of badgers to be an acceptable approach to assist in the eradication of TB in the badger population and cattle?

The UFU deems vaccination of wildlife to be acceptable in assisting in the eradication of TB. However, this must be accompanied by a suitable cost/benefit analysis that shows that such an approach would bring a benefit to the industry. In the absence of such an analysis, officials must be willing to take actions to removal infected wildlife from hot spot areas as listed above.

7b) Considering 7.9 to 7.14, if badger vaccination were to be deployed what would be the best way to deliver this and why?

The UFU believe that oral vaccination of badgers could be carried out effectivelyby local farmers. This would deliver maximum uptake and deliver significant savings.

7c) Should badger vaccination be carried out in conjunction with a targeted cull of diseased badgers as outlined at 7.11 and 7.13?

Logic would suggest that such an approach would bring about the fastest reduction of TB in the local wildlife population. However, a suitable cost/benefit analysis would need to be conducted to see if the cost would outweigh simply vaccinating for a longer time period or removing infected wildlife in the area.

7d) Do you agree that if a vaccination programme were to be deployed that it should be focused on specific areas and, if so, which?

The UFU believe thatvaccination should be focused on hot spot areas, areas of pedigree herds and areas of reoccurring/persistent infection as this would lead to a reduction in the total cost of TB compensation. This would allow resources to be diverted to further control TB in other areas. There seems to be little rational in vaccinating the wildlife in areas where there is little/no cattle or TB present. These areas should be addressed when moving towards final eradication.

7e) Who should administer / deliver a badger vaccination strategy; private vets, licensed persons, environmental bodies, DARD?

The UFU believe that oral vaccination of badgers could be carried out effectivelyby local farmers. This would deliver maximum uptake and deliver significant savings. In the case of injectable vaccines, the UFU believe that administration could be completed by a licensed individual provided they were also capable of interpreting the TB status of the animal and removing it if infected. In the absence of such ability, the UFU believe that vaccination and/or removal should be completed by a vet as the removal of infected badgers provide a conflict of interest for some environmental groups.

7f) Given the potential significant additional cost of any badger intervention as outlined at 7.6, how would such an initiative be funded?

At this stage, livestock farmers within Northern Ireland have a serious mistrust of DARD. As such, there is a concerned that any move to obtain money from the farmer would be used to reduce the DARD TB budget and the money would not be reinvested in TB control. However, if assurance could be given that the money provided would be ring fenced to address the removal of infected wildlife, the UFU believes that farmers would be willing to support the department through paying for one annual herd test (similar to ROI).

8a) 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?

At this stage, the UFU does not believe that any changes need to be made to on-farm biosecurity. The current on-farm biosecurity protocols have proven robust enough to remove brucellosis from Northern Ireland. As such, the UFU believes that they should therefore be robust enough to remove TB. Furthermore, ROI has seen a significant reduction in its TB incidence since 2002 simply by addressing TB in the local wildlife population and by introducing increased use of the Gamma Interferon test to remove infection from a herd quicker.

8b) Should pre-movement testing as detailed at 8.9 be introduced and, if so, for what movements and why? 37 i. If not, why not?

The UFU does not believe that pre-movement testing should be introduced as the current test for TB is not robust enough to prevent the sale of infected animals or the spread of TB.

8c) Should farmers pay for pre-movement testing? i. If yes, what factors should be taken into consideration? ii. If no, why not?

At this stage, the UFU does not believe that pre-movement testing should be introduced. As such, they are opposed to farmers being asked to pay for its implementation.

8d) As outlined at 8.15, should farmers be required to notify DARD if moving animals within their farm over a certain distance; e.g. 10 miles or 5 miles in the case of restricted herds? i. If yes, do you think the distances are right? If not, what distances would be right? ii. If no, why not?

The UFU is not opposed to a requirement of farmers to notify DARD if animals are moved over longer distances, especially in the case of a restricted herd. However, farmers would need assurance that this notification would not add to an animal’s number of herd movements as this could reduce the animal’s value. Without access to more information on typical animal movement data, the UFU can not comment on the suitability of the suggested movement ranges. However, we would suggest using a much larger distance (perhaps 25/50 miles) in early initiation of such a proposal to see how such a protocol would workpractically and then gradually reduce the range. This would allow farmers to plan ahead, give time to identify and fix flaws in the system while the number of farmers impacted is still small and allow farmers time to gradually restructure the land they are renting in anticipation of forthcoming changes.