Governmental Responsibilities

While government is spending £1 billion to 'no good effect' and do not have a policy to eradicate let alone control bovine TB, as Lord Rooker explained to EFRAcom in December 2007, their statutory responsibilities are more clearly defined.

This paper is miles long so we will compress it for posting. Apologies that the posting is still extended. The document is a working paper issued late 2006, and clarifies protocol for the eradication of bTB within the member states of the European community. It's purpose is to review general principles of testing cattle, to propose short term measures in order to accelerate the progress of eradication programmes, to draw conclusions on perspectives on eradication and to stimulate discussion on future strategy.

The paper states that the "proposed measures must be explored and assessed based on the individual situation in each Member State (MS) running an eradication programme for bovine tuberculosis". It begins with the legal framework:

1.1. Definition
For the purpose of this document, the definition of bovine tuberculosis (TB) is: “Infection in cattle with any of the disease-causing mycobacterial species within the M. tuberculosis complex”.

1.2. Legal framework

The Community legal framework on TB is formed by legislation on trade of bovine animals:

(Directive 64/432/EEC), legislation on animal products for human consumption (Directive 64/433/EEC, Directive 92/46/EEC and Regulation No. 2004/853/EC) and legislation regarding Community co-financing of eradication programmes (Directive 77/391/EEC and Decision 90/424/EEC).

Background to these directives is given thus:

The first legal initiatives on TB at Community level were aimed at facilitating intracommunity trade among the EEC Member States by establishing comparable health requirements. Council Directive 64/432/EEC defined specific requirements for the trade of cattle in relation to TB and defined the officially tuberculosis-free (TBOF) status of bovine animals and herds. An important further step was Council Directive 77/391/EEC which introduced Community measures for the eradication of brucellosis, tuberculosis and leucosis in cattle. Member States were obliged to draft eradication programmes in order to accelerate, intensify or carry through the eradication of TB.

The paper then goes on to remind Member States, as have we on numerous occasions, that eradication of this most serious of zoonses is not negotiable. It is a statutory duty. And should any Member state ignore its statutory responsibilities the Commission has reserved the right to implement trade bans on its products. In these eradication protocols, after meetings held in 2002, the paper explains that "the Commission works closely to incorporate new methods and to align more with the Office Internationale des Epizooties (OIE) health standards".

Experts attending the Tb eradication workshops held during the 4th International Conference on Mycobacterium bovis provide well focused recommendations:

1. Epidemiological data analysis and monitoring of the progress of most programmes should improve. For this purpose more refined indicators to measure the level of infection and progress of the programme are required.

2. The tuberculin test performs well at the herd level but has limitations when used at the level of the individual animal. Its performance can be improved by increasing the extent of coverage of the total cattle population and the intensity at which the test is applied. Compliance with 64/432/EEC (trading rule) requirements alone does not provide for an optimal testing regime in order to eradicate the disease because of the diversity of situations in different MSs and regions in which it is used.

3. Extended use of IFN γ test on a strategic basis to supplement the tuberculin skin test.

4. Improve the efficiency of slaughterhouse surveillance by focussed training, improved supervision and ensuring effective communication between the meat inspection services and animal health services.

5. The reservoir of infection within wildlife populations should be effectively addressed.

.
The involvement of all sources of bTB is stressed again here:

d) Improvement of the management of infected herds, ensuring that all sources of infection have been removed (e.g. anergic and other non-reactors to tuberculin, including cattle identified on epidemiological grounds, and infected wildlife ) and that measures to avoid reintroduction are in place (wildlife-proof fences), by ensuring proper epidemiological investigation of outbreaks to identify the source of infection and the implementation of a well focussed action plan aimed at stamping out infection in these cases.

e) Improved management of wildlife by strategic removal of infected wild animals.

A system of "rewards and penalties" is floated to encourage stakeholders to take their responsibilities seriously. Fine, as far as it goes, but does that apply equally to governmental responsibilities? From this administration we have seen much of the latter and precious few of the former .... thus far.

Slaughterhouse surveillance is classed as 'vital' particularly in areas not undergoing regularly testing. The paper also recommends many measures which GB is already implementing:

- Use of severe interpretation of the tuberculin test in infected herds and herds at special risk

- Strategic use of the IFN-γ assay

- Increased frequency of herd testing

- Implementation of the pre-movement test in areas and regions of high prevalence

- Definition and application of the epidemiological unit of concern

- More extensive use of epidemiological data analysis: indicators

- Stamping out in infected herds: criteria, application and assessment

- Wildlife removal/alternatives.

- Re-appraisal of compensation schemes

- Re-define and strengthen restrictions on animal movements

The authors stress the efficacy of the intradermal skin test: "The tuberculin test in its various forms is the sole test prescribed in Community legislation. While the tuberculin test has been an effective tool when applied at herd level, a lack of sensitivity at the individual animal level is recognised to be a major limitation of the tuberculin test." They discuss severe interpretation, which is already applied in GB when TB is confirmed either by lesions or culture.

They flirt with the new toy, Gamma interferon assay, pointing out that its parallel use would increase faster removal of reactors over a shorter time scale. Defra parrot this line while ignoring the caveat offered:

However, if concomitant diseases (e.g. paratuberculosis) are present in the herd or cohort under test, this may affect the accuracy and reliability of either or both of these diagnostic tools. Accordingly, this factor should be taken into account.

and:

"Some drawbacks are the additional direct and indirect laboratory-related costs to perform the IFN-γ assay and also the logistic requirements linked to the collection of blood samples, their delivery to the laboratory within a specified period and the conditions of incubation of the samples with appropriate reagents which the assay requires represent a constraint in more remote areas."

... and given the carnage created by Defra's over injudicious interpretation of its new toy, the following may be of interest;

The IFN-γ assay should not be considered for use as a routine screening test in areas or regions where the herd prevalence is low. On the contrary, its use in parallel with the tuberculin test in highly infected areas is recommended as an effective means of attaining a higher Se for the diagnostic regime. Furthermore, in herds already deemed TB-positive, the IFN-γ assay should be considered for use at the first retest in parallel with the tuberculin test on such herds, after the index test, so as to remove the infection with the maximum Se.

We have no problem with that, once the wildlife reservoir has been addressed. But once that has happened, is there any need for the blood test, if testing is regular?
Pre-movement testing is discussed within the context of cost-benefit and/or cost-effectiveness ratio basis, which is recommended.

On whole herd slaughter, or 'stamping out' as the document quaintly sanitises the procedure, attracts the following criteria:

The decision whether to use stamping out or not should be based on a consideration of certain essential criteria that should be defined in advance. The prevalence in the area, the intra-herd prevalence, the persistence of an infected wildlife reservoir, contact with other cattle or susceptible species, the persistence of mycobacteria in the environment under local conditions, the interval before restocking, herd size, enterprise type and the type of husbandry, prevailing bio-security measures, farm security in relation to contiguous holdings (fences) and the ability and willingness of the herdowner(s) to conform with conditions pertaining to the stamping out protocol. Also, account should be taken of additional criteria assessed by the local veterinary services in relation to the decision to proceed with stamping out.

The bottom line to that little gem is contained below, in a phrase which describes the potential 'success' of the programme. The paper predicts:

.... effective eradication of TB provided other sources of infection, such as an infected wildlife reservoir, do not pose a major risk.

....... and if they do? The final decision would be made after consultation "in detail by local or regional veterinary officers when considering whether or not to
apply this option". So that's all right then.

And now to the core of GB's problems, and an elephant in the room which Defra seem unable to get to grips with. The paper describes any source of infection which

"enters into contact with cattle is a major obstacle to the eradication of TB. This obstacle should be addressed in tandem with the measures implemented in relation to the cattle population.

That's 'obstacle' as in badger or Badger Trust, and 'tandem', as in together, at the same time, concurrently and simultaneously. The paper continues that as [wildlife] vaccination is still a while away:

... in order to address the role of infected wildlife in the persistence of TB [measures] should be implemented without any delay so as to allow the progress of the eradication programmes. Removal of wildlife, either proactively or reactively following outbreaks, has proven to be an effective ancillary, and in certain situations necessary, measure to control and eradicate TB.

and:

The elimination or reduction of the risk posed by an infected wildlife reservoir enables the other measures contained in the programme to yield the expected results, whereas the persistence of TB in these wildlife populations impedes the effective elimination of the disease.

Major socio-political resistance (lobbyism) against any measure involving the removal of infected wildlife or interventions affecting the environment are to be expected. The additional costs associated with these actions are not likely to be negligible.

The costs of not removing an infected wildlife reservoir are infinitely greater, both in straight monetary terms or the long term transmission opportunities afforded to its spillover victims. The paper points out that if eradication of this disease is to be achieved then:

Control of infected wildlife species that is based on the strategic removal of members of a selected species in certain areas is nevertheless a necessary and probably unavoidable measure if eradication of TB is to be achieved.

The paper stresses again the use parallel cattle measures. But not one after the other in either direction. GB has the bulk of the cattle measures in place..

Now this next bit is interesting in that the commission paper seeks to 'modify farmer's behaviour' to encourage / discourage transmission opportunities. Interesting concept, and one which, if reference to removing 'obstacles' has snuck under Defra's radar, tweaking compensation will not have.

2.3.9. Re-appraisal of compensation schemes

The re-appraisal of compensation schemes and their alignment with the level of the
herdowner’s cooperation with the eradication programme is necessary. Once adequate compensation is approved, then its payment should be swift. Adequate compensation implies that the compensation does not, in any way, pose an obstacle for the progress and success of the programme.

The compensation scheme should be aimed at modifying the behaviour of the farmers in a way that they do their best to avoid the reintroduction of the disease in their herds. Consequently, a level of compensation that is perceived by the farmers not to be sufficient to allow them to adjust to their new circumstances following the loss of their stock and the imposition of animal restrictions, along with concern associated with the possible reintroduction of the infection, jeopardizes the progress of the programme by engendering an attitude of non-cooperation.

and furthermore - and this is the bit Defra will have picked up on:

Accordingly, it is extremely important to ensure that the level of compensation is the appropriate and serves to encourage farmers to respond to their situation in an appropriate manner that will prevent or considerably reduce future risk of infection. There is also a case to be made that the compensation is conditional on the herdowner’s compliance with stated conditions relating to the prevention of a further outbreak on the holding within a reasonable period. Otherwise, compensation may not be approved, or if approved, would be at a lower rate. Furthermore, compensation should always be at a level below (to a reasonable or, sometimes, significant extent) that of the current market price of comparable healthy animals.

Compensation depending on biosecurity? Against badgers which need a concrete fence sunk 15 feet into the ground at Weybridge to keep them IN?

The conclusions of the paper:

•

Eradication of TB is the target at EU level as laid down in Community legislation.
Eradication should be feasible in the long term despite the fact that different
epidemiological situations in the EU pose certain difficulties that should nevertheless be addressed through specific reinforced measures.

• Requirements of Community legislation are to be considered in the context of the
eradication programmes as the absolute minimum level of measures to be implemented.
Effective eradication programmes should include additional measures aimed at addressing the different constraints to eradication in each epidemiological situation.

• Full involvement of all stakeholders and optimum use of the abattoir as a surveillance resource that is more fully integrated in the eradication programme should be considered as necessary issues to be specifically dealt with in the context of eradication programmes.

• A set of ten specific short-term measures aimed at strengthening current programmes
have been identified. The implementation of some (if not all) of these measures in regions with high prevalence and in which little or no progress has been made in recent years should be addressed. In principle non-implementation of any of these short term measures in areas of high prevalence would require an epidemiologically sound reason, if such a position is to be accepted..

An announcement is expected very soon from Hilary Benn. We confidently expect this to duck the elephant in the room, and concentrate on more severe cattle measures. Equally, as his predecessors have found, and this paper confirms, such measures in isolation from controlling tuberculosis in wildlife, will comprehensively fail and at huge expense to the taxpayer and the industry.