Consultation Response

Transcription

1 Consultation Response Improving TB cattle controls, including a proposal for statutory post-movement testing Defra Consultation Date: Introduction The CLA is the membership organisation for owners of land, property and businesses in rural England and Wales. We help safeguard the interests of landowners and those with an economic, social and environmental interest in rural land and the rural economy. Between them our members own and manage about half of the rural land in England and Wales, including edge of settlement locations and some urban portfolios. We have been looking after the interests of our members, as well as promoting the positive aspects of land ownership, land management and rural business activities for the past 100 years. The quality of the countryside, and its natural resources, is of vital importance to our members. Most objectives for the countryside - economic, social and environmental - rely on landowners and managers for their success. Equally, a healthy environment relies upon a thriving rural economy and financially viable agricultural businesses. 2. Responses to the Consultation Questions Question 1: Do you agree or disagree with statutory post-movement testing of cattle entering the Low Risk Area 1.1 We agree with a risk based approach to controlling bovine tuberculosis (btb). The decision to require statutory post movement testing should be balanced with the cost to the farming sector, not least as farmers in the Low Risk Area (LRA) will be responsible for arranging and paying for the test and the effect post movement testing will have on stopping the spread of btb. 1.2 Statutory post movement testing for cattle being brought into the LRA will mean that it is compulsory for all farmers to test cattle, unless they fall under an exemption; hence there would be a common set of rules for all livestock farmers. The estimated cost of the post movement test to farmers in the LRA is 1.5 million per year or 500 per business (Defra economic assessment). This is not insignificant to a sector subject to price volatility. 1.3 The option to place all LRA herds in annual surveillance testing would cost 19.8 million per year, which from the assessment does not appear to be a beneficial use of controlling the disease for the cost involved. Page 1 of 6

2 1.4 The Defra economic assessment does not break down the costs to individual business types. The CLA would like to see more evidence on the costs which will affect individual producers who are suckler, dairy or beef. This information is important to enable businesses to plan for the increased costs their business may face. The 148,000 annual movements into the LRA should be broken down into breed and age so farmers can be better informed which types of farmers will be affected the most. 1.5 Defra must be aware of the increased cost farmers will face due to the potential increase in testing, which will be required under this statutory requirement in the LRA. Farmers will have to upgrade/ improve their cattle handling facilities and this will come at a time when several sectors of the cattle industry are under increased financial pressure. Most accidents on farms occur when TB testing takes place and avoiding harm to both animal and humans must be a priority. 1.6 Previous early voluntary pre movement testing was not taken up by farmers in the High Risk Area (HRA), and suggests bringing in the post movement test as a voluntary measure may not fully achieve the desired result. 1.7 The risk of transmitting btb from the HRA to the LRA can increase due to the ability to keep cattle on a holding in the HRA, which have been subject to a clear pre movement test for up to 60 days. In that 60 day period, cattle can mix with other cattle brought by the farmer and transmission can take place. It could be the 59th day of the pre movement test the cattle are sold, and in that time they have potentially mixed with infected cattle. Transmission can also occur during transport. 1.8 Currently, under this scenario, the holding in the LRA which the cattle are moving to may not be due another four yearly btb test for say 3.5 years, and in that time the cattle brought on to the holding from the HRA may infect the herd and remain undetected for 3.5 years; and during that time, could infect a large proportion of cattle in the LRA. 1.9 Cattle moving from high infection rate areas, such as the South West of England to the Eastern Counties, mean that farmers who choose to trade in these areas are taking a huge risk. Limiting this risk is currently uncontrollable, hence a compulsory post movement test would enable government to control better the cattle movements which take place, and investigate new outbreaks quickly and efficiently The type of livestock producer will dictate how they are affected by the introduction of the post movement test. Dairy farmers in the LRA with flying herds will purchase replacements from the HRA, and so will incur the cost of doing so. Cattle sold in the HRA may decrease in value due to the extra cost incurred, and may change buyer behaviour. HRA suckler herds, breeding heifers and steers for sale to finishers in the LRA may have a reduction in value in their stock, as a large proportion of finishing units are in the LRA counties. This must be considered, as it could cause harm to their businesses. Beef finishers in the HRA who purchase store cattle will incur the costs of testing cattle not finished in 120 days; again this will impact on what price they pay, and the added cost they may have to incur in making their holding equipped to deal with btb testing, if it is not already equipped The CLA is concerned whether there is sufficient veterinary capacity to deal with a post movement test regime, and would want government assurance. As vets are required to Page 2 of 6

3 carry out the test, it must be made clear that the veterinary practices in the LRA have the capacity to take on this testing regime, and that the location of the holding and size of the batch test does not incur added cost because of this. Farmers in the LRA should not be put to anymore expense than their annual testing area counterparts Statutory post movement testing in the LRA will mean stopping the multiple movements of cattle from one holding, once they are brought from the Annual Testing Areas (ATA - the high risk and edge area combined) currently permitted under the 60 day pre-movement rules. This will enable the disease to be found on the holding they are brought onto in the LRA, and it will not risk the spread of the disease in the transport period. Post movement testing will not stop farmers from purchasing cattle in the ATA and delivering them to multiple holdings within the LRA on the day of purchase. What that does do is mean the cattle are on the holding and the 120 day starts from the day of arrival not after the 60 premovement test has ended The participation of cattle exhibitors at Agricultural shows may be reduced due to the restrictions of post movement testing. Question 2: Do you agree or disagree that for the post-movement testing proposal the tuberculin skin test should be supplemented with the interferon gamma (IFN-γ) blood test? Please let us have your views. 2.1 The CLA agrees that the tuberculin skin test should, where appropriate, be supplemented with the interferon gamma blood test. Giving farmers the option to choose which test to be carried out is important for the purposes of post movement testing. 2.2 We would also ask Defra why it has not yet commented on the research undertaken by Professor Liz Wellington at the University of Warwick, published in the Journal of Clinical Microbiology (July 2015, Vol.53, No.7, pp ). This work was commissioned by Defra in 2012 and ended in January The research team has developed an M bovis test that can be used on badger faeces, and believe the test can be used to identify potential TB hotspots. It could also help target badger culling within a cull zone and within the overall TB eradication strategy. We would urge the Government to review the results of this 18 month project, and extend funding to further develop the efficacy of the M bovis test developed by Professor Wellington. This could offer a most cost effective method of the control and spread of btb. Question 3: Do you agree or disagree with a more robust approach to dealing with btb breakdowns in the High Risk Area 3.1 The CLA agrees that a more robust approach is needed in dealing with btb outbreaks in the HRA. Adopting the approach applied in the Edge Area and implementing that in the HRA will mean a more robust approach to dealing with btb outbreaks. 3.2 Continuing with the LRA approach of one clear short interval skin test is acceptable. The approach on btb breakdowns, which are contiguous to another breakdown still requiring two clear short interval tests, should continue. Page 3 of 6

4 3.3 Implementing stricter rules in the HRA will mean a more robust approach for dealing with any residual infection, and the long term benefits of this will be felt by farmers, if this approach is taken sooner rather than later. 3.4 The CLA agrees with the removal of the terminology OTFS and OTFW. Question 4: Do you agree or disagree that cattle should be able to move to/ from rented grazing within a 10 mile radius of the herd owner s home premises without pre-movement testing 4.1 The CLA agrees that cattle should be allowed to move 10 miles to and from rented grazing, without the need for a pre movement test. Where the cattle keeper is not under restriction, the rules under which he moves cattle need to remain flexible, so that they do not have to incur the added cost of post movement testing. Allowing the 10 mile area limit will mean farmers can rent grazing without the fear of having to incur costs of pre movement testing. The removal of creating a Single Occupancy Authority has limited farmers who move cattle to and from premises, which this enables them to do with some of the benefits the SOA had. Question 5: Do you agree or disagree with the proposal to phase out Exempt Finishing Units in the Low Risk Area 5.1 The CLA agrees with the proposal to phase out Exempt Finishing Units (EFUs). 5.2 Out of 75 EFUs in England, five are located in the LRA. Allowing EFUs in the LRA undermines the purpose and reason for the Government s TB policy in making the LRA officially btb free status (OTF). The risk which the unit poses is not acceptable, equally neither is the current rules of allowing cattle to move without a pre movement test to the EFU in the LRA. This undermines the policy to attain OTF status by Question 6: Do you agree or disagree with proposal to reduce the TB risks from Approved Finishing Units 6.1 The CLA agrees with the proposal to reduce the btb risk from Approved Finishing Units (AFUs). 6.2 The risk of infection from cattle from an AFU with grazing, which is non-contiguous, is high and that goes against the policy of what an AFU must be. Allowing an AFU to send cattle to graze on land not contiguous is creating a risk of spreading the disease to holdings away from the AFU. This is not acceptable and is counterproductive. 6.3 The CLA agrees with the grace period of six months, and that no new AFU s will be approved with non-contiguous land. Page 4 of 6

5 Question 7: Do you agree or disagree with the proposal of a voluntary scheme to help reduce the TB risks from the sale of cattle originating from 4 yearly testing herds 7.1 The CLA agrees with the proposal for a voluntary scheme to help reduce the TB risk from the sale of cattle originating from four yearly tested herds. Securing the desired levels of take up will be key to its effectiveness. 7.2 The CLA has been an active consultee in the development of a proposed scheme. We believe a scheme should be funded by Defra, and be on a pilot basis for a set period of time. The scheme must be promoted by vets, auctioneers and national farming organisations to support good practice and reduce the risk of the spread of dormant TB from four yearly testing herds to potentially all parts of the country. The results of the pilot scheme can be assessed and analysed in order to see whether btb is, or is not, being found. Then the decision can be taken to continue or cease the scheme. 7.3 This type of voluntary scheme should not be funded by farmers, but the publicity should come from all areas of the industry to promote good practice by farmers. 7.4 The Cumbria dairy herd dispersal sale was an example of how the spread of the disease can have a huge affect on farm businesses. Giving farmers an option to limit this, and in doing so increase the saleability of their stock because of a pre movement test, can only be to the benefit of the industry. 7.5 APHA will need a streamlined approach to dealing with volunteer applications and the numbers to warrant a test should be in the region of 20 head of cattle. Question 8: We are seeking your views on the proposal to take forward plans for enhanced btb surveillance in the Edge Area. 8.1 The CLA believes there is a need for enhanced btb surveillance in the Edge Area. Stopping the spread of btb from the Edge Area to the LRA and HRA is imperative. High incidents of btb in Cheshire have meant the introduction of a six monthly testing regime. The data analysis and results from this need to be looked at to see if the increased testing is having an effect on controlling the disease. This information needs to be shown to have had an effect. Radial testing could be introduced in the Eastern parts of the Edge Area, which is where most new infections are occurring. 8.2 The CLA would like to see Defra undertake further full analysis of the proposals and be involved in any subsequent consultation. Question 9: We are seeking your views on the circumstances in which a private interferon-gamma (IFN-γ) blood test (BovigamTM) could be useful. There are currently two TB diagnostic tests used (on any scale) in England: the single intradermal comparative cervical tuberculin (SICCT) test (the skin test) the supplementary interferon-gamma (IFN-γ) blood test (Bovigam TM ). 9.1 The CLA would support the private use of the interferon-gamma blood test as another tool in promoting good practice by farmers, to show that the pre or post movement testing of Page 5 of 6

6 cattle are clear of TB. Farmers will be expected to pay for the test, and we imagine in a lot of cases will accept the charge for it. If farmers wish to see cattle with high herd status, then the ability to prove the TB test is completed with a blood test may help the sales and marketing of the cattle. 9.2 The possibility of having a positive test would see the OFT status removed from the holding, but this is a normal procedure if the skin test were to prove positive. The normal slaughter and compensation procedure should apply. 9.3 We would, however, want Government assurance that if a farmer sends an animal for slaughter and is found to have btb, as a result of a voluntary test paid for by farmers, compensation will still be paid by Government. Some of our members have advised us of instances where this has not been the case, because the farmer ordered the animal to be slaughtered rather than the Government. 9.4 The CLA would recommend Defra/ APHA have the capacity and ability to provide this service, if it were to become available. For further information please contact: Damian Testa Head of Land Use Policy CLA, 16 Belgrave Square, London SW1X 8PQ Tel: Fax: damian.testa@cla.org.uk Richard Goodwin Rural Surveyor CLA Midlands, Knightley, Woodseaves, Staffordshire ST20 0JW Tel: Fax: richard.goodwin@cla.org.uk Page 6 of 6