VAWM publishes a critical response to the recent Bovine TB strategy review from DEFRA (The Godfray review)
The Association was moved to respond to the latest review published by DEFRA (October 2018) chaired by Sir Charles Godfray.
One is driven to the conclusion that the two assumptions on cattle to cattle transmission and vaccination are driven more by political expediency than science and one must question therefore the value of a report and strategy based as it is largely on these two assumptions.
We urge Government therefore to take direct hold of the problem and resume research into identifying humane fumigants coupled with precise identification of infected badger setts by molecular PCR testing so that a more efficient, humane and targeted strategy of culling badgers underground might be pursued. Such an approach that targeted only infected/diseased animals would clearly be more acceptable to the public in general and to the profession.
Oue full response to the Godfray review can be [downloaded here].
The case for culling badgers to control bovine TB is irrefutable
The disease was almost eradicated in the 1980s by a combined strategy of tuberculin testing of cattle and culling of badgers. But following the Zuckerman report of 1980 culling was scaled down and entirely abandoned following the Krebs report in 1997 by the in coming Labour Government. Since when, as may be seen from the chart below, the disease has escalated out of control:
Clearly it won't be controlled by killing more and more cattle as recommended by the so called Independent Scientific Group in 2006! 39,389 cattle were slaughtered in 2016. The current inefficient, labour intensive, strategy of farmer led badger culling is simply holding the disease at a wholly unacceptable level. Nor is it likely to be controlled by vaccination (see above)
Dealing with the consequences of badger protection legislation a Position paper
Bovine TB in cattle has escalated out of control since 1997 when the incoming Labour government introduced a moratorium on all badger culling in England and Wales excepting the Randomised Badger Culling Trials which ended in 2005. The following position paper is therefore prompted by the failure of DEFRA to research, formulate and implement a realistic strategy for the control of bovine TB since then.
Summary of VAWM's conclusions
- VAWM regrets the introduction of badger protection legislation. It was introduced to protect a species whose conservation status was not threatened, nor likely to become so. Badgers have no natural predators within the UK and their numbers have increased many-fold with disastrous consequences. The spread of high bTB prevalence areas to one third of the country is but one. Furthermore, as they reach carrying capacity, individual badgers are living highly stressed lives and their welfare is inferior to that which their predecessors would have experienced before they were “protected”.
- The malign effects of protection were not a necessary consequence of the legislation per se. There always was and continues to be the provision for farmers to apply for licences to cull nuisance social groups and destroy their setts. The problem has been Natural England's (NE) reluctance to issue them.
- No significant reduction of badger-associated problems can be expected without acceptance for the need to cull. This is not to suggest that improved cattle measures and oral badger vaccination in edge areas might not also play a role in bTB control, merely that, without culling, they would largely be a waste of time and money. Further bTB transmission is far from the only problem created by the uncontrolled population.
- It is recommended that, in high disease prevalence areas, culling should be sett-based. A prerequisite of sett-based culling is the prompt licensing of an effective and humane fumigant. Once available, sett fumigation will allow a more efficient and much cheaper means of control. Undertaken at appropriate times of year, it should minimise any problems of perturbation. However, it is recognised that, in summer, most infected badgers tend to spend a high proportion of their days in outlying holes or even above ground.
- In high disease areas, selectivity would either require the use of qPCR (quantitative polymerase chain reaction test) to identify infected social groups or would be based on cattle sentinels (reactive culling) or both.
- Should no fumigant be identified as suitable for licensing, culling would need to be based on trapping and free shooting. Under the latter circumstances, the percentage of animals killed per social group would be likely to be lower and consequential perturbation higher. However, this has not been enough to prevent a very significant reduction of bTB breakdowns in the Republic of Ireland, which has been undertaken by means of selective culling without fumigation of setts. Nevertheless, given the much higher badger densities in England, the absence of licensed fumigant may suggest that proactive culling would be more appropriate.
Recommendations pertaining to the NE's approach to licensing
- NE should adopt different policies as regards to licensing for bTB- free areas on the one hand and high disease prevalence and edge areas on the other.
- In the former, NE should assume that the nuisance criterion will always be met when a) landowners of shooting estates can demonstrate that they are releasing ground roosting birds such as partridges and b) whenever landowners can reasonably assert that they are attempting to manage habitat to conserve those species of conservation concern which are likely to suffer from the presence of badgers. In other situations, it should be necessary to prove nuisance or damage before licences are issued. Methods of culling (e.g. trapping or shooting) should be agreed, but avoidance of perturbation need not be of concern.
- In high disease or edge areas, NE should issue licences automatically and without equivocation at the behest of officers of the State Veterinary Service. Should a fumigant be licensed, it is recommended that it should be mandatory to cull any badger social groups on land grazed by recent breakdown herds when badgers are judged to be the most likely sources of transmission. Veterinary officers should, in addition, be able to obtain licences to cull social groups that are shown to be infected by qPCR, provided that the farmer agrees. If a sett fumigant is not approved, licensing would best be restricted to circumscribed areas of minimum size of, say, 100 sq. km minimum, provided the overwhelming majority of farmers within it endorsed the decision to cull. In other words, licences would require similar conditions to those that currently apply to existing proactive trapping and free shooting trial areas.
- Farmers should meet the majority of cull costs, but not the associated policing costs, made necessary by anti-cull protestors. Licenses should be issued free of charge to qualifying farmers and landowners.
Criticisms of existing policy or implementation thereof.
VAWM's position is fully consistent with current Government policy in respect of M.bovis control (culling in high prevalence areas, oral vaccination around edges, assuming an effective vaccine becomes available, and improvements in cattle testing and movement regimes). It goes further in recommending that culling should become easier in currently disease-free areas.
VAWM is not however enthusiastic about the widespread deployment of the Badger BCG vaccine in England and Wales, which appears to be driven rather by public opinion than scientific evidence. Experimental evidence of vaccine efficacy is equivocal, safety for the target species is questionable and evidence of efficacy has not been forthcoming from the field over 3 years, indeed several herd breakdowns have been reported from different areas where the vaccine has been deployed.
VAWM's principal criticism relates to implementation of what it regards to be the most important aspect of the policy, namely culling.
While there may be a declaration that culling is part of a control programme, there would seem to be little enthusiasm for its implementation. The very limited culling trials that are taking place are being undertaken and financed by farmers. Meanwhile, erstwhile Government expert advisors are mounting a vocal public campaign against the trials, inciting violent protests against those attempting the culling. Further, the cullers have been faced with an array of bureaucratic hurdles which make their task unnecessarily difficult and costly. One is tempted to wonder whether the apparently half-hearted approach to implementation is the result of Government's fears over the unpopularity of culling or whether it is a sign that some of its civil servants and civil-servant appointed outside expert advisors are deliberately being obstructive and delaying progress.
In fact, VAWM, as the name suggests, concerns itself with the welfare, husbandry and conservation of a balanced wildlife population in the context of a largely man-made environment. As such, its members are uncomfortable with the proactive cull approach because it is indiscriminate. Failing a satisfactory licensed alternative, it can and does accept the necessity for proactive culling while regretting the necessity for such a crude approach. To this extent, VAWM members have some sympathy with the views of those objecting to the culls as currently carried out. It seems obvious that culling should be sett-based for reasons of efficacy, efficiency and economy. This also enables the targeting of social groups of badgers that are, themselves, most likely to be infected. Of itself, cull selectivity should reduce public hostility to culling. However, it must be recognised that the best method to cull selectively is sett fumigation. The idea of gassing animals underground may be so repugnant to some that it outweighs the public relations advantage of selective over indiscriminate culling. However, it remains VAWM's position that sett fumigation has the potential to provide more humane deaths for badgers than the alternatives of trapping and free shooting. This, of course, presupposes that an appropriate fumigant is identified by testing and subsequently licensed for use.
Sett fumigant testing and licensing
It is the VAWM view that failure promptly to replace cymag with a more humane alternative when use of the former was banned was the single most important factor contributing to loss of control of M.bovis. This led to culling by trapping and the ill-fated RBCTs, which were poorly conducted, badly interpreted and which, in the public mind, led to the belief that culling was largely ineffective because of perturbation effects.
Defra's approach to sett-fumigant research has been snail-like. A committee reporting in 2005 had been deliberating at length on various culling methods. The view was expressed that sett fumigants were very unlikely to prove satisfactory because it would probably be impossible to achieve sufficient gas concentrations throughout complex setts. However, the committee concluded that it might be worth looking at carbon monoxide while rejecting carbon dioxide out of hand. Subsequent carbon monoxide-based research initially suggested that the committee's earlier views were correct. However, by 2006, researchers were reporting good results and recommended that their method was ready to be tested in occupied setts. Since then, there has been very little publically-available information on the subject. Defra officials suggest that research into sett fumigation is ongoing, but refuse to divulge any details until it is completed. At one stage, there was mention of high expansion nitrogen foam becoming a candidate fumigant, but, shortly thereafter, came the announcement that the foam was no longer a candidate, despite the fact that VAWM has independent evidence that there was no testing of nitrogen foam before the decision to drop it was taken. A VAWM enquiry to a Defra official a couple of years ago did elicit a response that occupied-sett testing of carbon monoxide would have to be preceded by monitoring in empty setts and that nobody had worked out how to do this. It was also stated that no independent research organisations appeared willing to work on fumigation of occupied setts for fear of potential threats from animal rights terrorists. Further enquiries, including offers to take responsibility for organising an appropriate research programme into the subject, from VAWM, both to Defra civil servants and, directly, to the Chief Veterinary Officer were met with unhelpful responses. VAWM was informed that its offer to take responsibility for the relevant research was unnecessary because Defra already had an active research programme looking into both carbon monoxide and high expansion nitrogen foam. A VAWM member subsequently wrote to the CVO to question whether there existed the possibility that he was being misled by his civil servants, given the prior announcement that nitrogen foam had been discussed but that research had been discontinued before any trials had been undertaken. No response was received. Attempts to glean information on interim research results (if, indeed, there are any) and requests to meet and discuss the subject with the relevant researchers have been totally rebuffed. VAWM was informed that the research was ongoing, but that no information would be divulged until the project was completed. VAWM would be delighted to think that there was, indeed, an active research programme. However, lack of reported progress since 2006 leads some members to the suspicion that there is no intention to complete, assuming the research programme exists all.
Having gained nothing of value from correspondence with Defra officials and the CVO, VAWM's secretary, Dr Lewis Thomas, wrote directly to the Secretary of State and requested a meeting. His letter received no personal response, but, instead, was diverted back to the same officials who had previously been so unhelpful and who responded in the same unhelpful manner. Is this a case of officials stonewalling on behalf of their Minister or, alternatively, are they deliberately misleading her?
VAWM has members who have long and detailed knowledge on the subject of M.bovis and its control and its collective expertise matches or exceeds that of many of the expert advisors that Defra has appointed. Members have enjoyed friendly and frank discussions with researchers working on all aspects of M.bovis control except those who work on culling (if, indeed, they exist at all).
VAWM sets out its proposals for M.bovis control in this document. The background for its stance is explained in the appendices listed below. VAWM would welcome discussion with other relevant scientists and is willing to be challenged over its views and modify them should any of them be shown to be incorrect. It would also welcome the opportunity to challenge the views of some others. To the extent that VAWM's approach could be said to be novel, it would seem reasonable, at least, for the Government to allocate and fund a trial area for demonstration purposes. It is not intended that VAWM members should undertake the research, merely have joint planning and advisory roles.
VAWM, once again, requests a meeting with the SoS so that the issues raised can be discussed. It is the organisation's wish to work “within the big tent” rather than to campaign and fight from the outside.
The detailed arguments underpinning VAWM's position above are provided in appendices with the following titles, which can be provided on request:
- Effects of badger protection legislation on damage to other wildlife and to human interests (excluding the subject of tuberculosis).
- Animal welfare effects of badger protection legislation.
- Badgers, cattle and the concept of Ro.
- Thoughts on badger culling and alternative strategies for control of tuberculosis in cattle.
- A consideration of badger culling methods and strategies.
- Pros and cons of three potential sett fumigants.
VAWM publishes a position statement on control of bovine TB
The Badger protection acts of 1973 and 1992 are identified as the major constraint to effective control of the badger population and bovine TB. The Association calls therefore for a broadening of the criteria whereby Natural England grant licences for culling of badgers and calls on DEFRA to identify as a matter of urgency an effective and humane fumigant for the culling of badgers underground. The statement was submitted to the Secretary of State, Liz Truss in November 2015.
The full statements may be read [on this link].
The scientific basis for the Badger BCG vaccine is questionable
A recent critical assessment of the scientific basis for the Badger BCG vaccine reveals serious shortcomings.
Although the vaccine has been shown to provide some protection against experimental challenge it fails to protect against infection and all vaccinated animals shed M.bovis post challenge. Furthermore it has no proven efficacy against bovine TB in the field. The likelihood therefore of the vaccine giving protection in the face of the massive infection out there in the badger population is therefore highly improbable. The vaccine has only a Limited Marketing Authority. For more information please see our letter to the AHVLA questioning the efficacy and safety of the Badger BCG vaccine (2014b).
Badgers and the countryside
Since the badger was made a protected species in 1973 the population has been expanding out of control until it is now, due to overpopulation, having an increasingly deleterious effect on the countryside both by digging and as a relentless predator of vulnerable wildlife.
It is now a serious agricultural and domestic pest in many parts of the country simply from the damage that it does by digging. Many farms and estates, gardens, golf courses, buildings, waterways, graveyards and archaeological sites across the country are now suffering substantial damage simply because of the massive damage caused by excavating badgers. The Llangollen canal in North Wales, for example, suffered major damage to its banks and loss of water in 2005, the cost of repair was estimated at £500,000. A national survey by DEFRA in 1997 of 1800 agricultural properties in England and Wales put the annual damage at £25.7m.
The major diet of badgers is earthworms but the animal is an opportunist feeder and if availability of their preferred diet is removed, as in times of drought, they will eat almost anything - hedgehogs, frogs, toads, grass snakes, free range lambs and piglets, bumble bees, ground nesting birds and their eggs - are all vulnerable. Numbers of skylarks and lapwings have for example plummeted in the last two decades. And as the number of badgers rises inexorably so will this impact on the countryside be increasingly felt .
A response to the Governments consultations on bovine TB and badger culling 2010, 2013 and 2014
Vaccination of badgers is probably futile and certainly hugely expensive
See below/attached copy of letter submitted to the Daily Telegraph 28.8.13 Vaccination of badgers is not just “simply impractical in the immediate term” as stated in a leader in the Daily Telegraph (27.8.13) in support of the badger cull, it is probably futile and certainly hugely expensive (the welsh CVO estimates over £650 a badger in 2012). What the National Trust, the Welsh Government, the RSPCA and others that advocate vaccination as an alternative to culling should know is that the Badger BCG vaccine, which was granted only a Limited Marketing Authorisation in March 2010, has no proven efficacy against bovine TB in the field. And even in challenge experiments with naive, uninfected badgers in the laboratory it fails to protect solidly against the infection. To expect such a vaccine to protect against the huge burden of infection currently present in large parts of the badger population can therefore only be described as highly speculative, driven largely by perceived public opinion rather than scientific reality.
The band wagon for vaccination against bovine TB is going nowhere
What the Bow Group of Tory MPs, the Welsh Environment secretary and other organisations such as the RSPCA and National Trust that are climbing onto the band wagon of vaccination should know, is that a proven vaccine against bovine TB currently does not exist for use in the field either for cattle or for badgers.
For the full text of our response to EFRACom's Inquiry on vaccination against bovine TB [click here].
A response to the Governments consultation on bovine TB and badger culling 2010
Please download our full response to the Government's 2010 consultation on bovine TB and badger culling on this link (PDF Format)
A response to the Welsh Consultation on bovine TB
Please download our full response to the Welsh Consultation on bovine TB on this link (PDF Format)
A supplement on the Badger BCG vaccine to the Government's Consultation 2010
Please download our supplement to our response to the Government's consultation 2010 on bovine TB and badger culling on this link (PDF Format)
Vets applaud Welsh badger cull
VAWM joins with the British Veterinary Association (BVA) in welcoming the recent announcement (January 13, 2010) by the Government of the Welsh Assembly of a pilot badger cull and stricter cattle measures, located mainly in north Pembrokeshire, in the bid to tackle the spread of bovine tuberculosis.
Comment by Dr. L.H.Thomas MRCVS on DEFRA's England Wildlife Health Strategy
"Amongst the mindnumbing 37 pages of DEFRA speak (what an earth does "a variety of cross cutting initiatives" (para 7.10) mean?) and the plethora of acronyms - NEEG, SPIRE, HAIRS, UKZADI, to name but a few, there is the interesting proposal for a National Wildlife Disease Surveillance Partnership. Little information is given as to how it might be achieved and who the partners with the VLA might be but the aspiration seems worthy. And this largely sums up this latest strategy document from DEFRA. It is essentially an enabling report, a catalogue of worthy intentions.
Rational determination on bovine TB from Wales - speculative vaccination from DEFRA
The recent announcement by the Welsh minister for rural affairs, Elin Jones, to set up an Intensive Action Pilot Area in Pembrokeshire is in stark contrast to the announcement by DEFRA that they plan to start vaccinating badgers next year with BCG.
DEFRA cops out on controlling bovine TB
Predictably, coming as it does from this feeble Government, the Secretary of State for the Environment, Mr. Hilary Benn, announced on Monday, July 7, 2008 that DEFRA will continue to pursue the policies that have, over the last decade, led to a tenfold increase in bovine tuberculosis in cattle. In spite of statements by the Chief Scientist, Sir David King last October and the more recent report in April by the Environmental, Food and Rural Affairs Committee of the House of Commons that the wildlife reservoir of bovine TB, namely badgers, will have to be culled in order to control the disease, DEFRA have stuck their heads firmly back in the sand in the hope that the situation will get better if they just go on killing more and more cattle (some 28,000 in 2007 and rising already in 2008).
Support for the Welsh CVO
Support for the recent decision by the Chief Veterinary Officer for Wales and the Welsh Rural Affairs Minister to carry out strategic badger culling in those parts of Wales affected by endemic bovine TB.
EFRACom recommends a multifaceted approach in their recent report on bovine TB
Given the conflicting conclusions on how to tackle bovine TB in this country from the Independent Scientific Group and the former Chief Scientist, Sir David King it is perhaps hardly surprising that a committee of MPs has recently produced a comprehensive, 67 page report that encompasses all the options for tackling the disease (Fourth report of the Environmental, Food and Rural Affairs Committee, 2007-08). However at least it brings the most important option into play the necessity of tackling the huge reservoir of infection in the badger population. But it is a pity that it has been fogged by all the other options such as more and more cattle testing, biosecurity and vaccination, two of which together, cattle testing and biosecurity, have been shown to be wholly inadequate in tackling the disease to date. And there are good reasons set out in our last statement why vaccination of cattle is unlikely ever to be a realistic option.
In spite of what some, including EFRACom, would have one believe bovine TB is not a complex disease. It is caused by a single organism Mycobacterium bovis and the major wildlife reservoir of infection in this country is the badger. It was almost eradicated in the mid 80s by a sustained policy of cattle testing using the intradermal skin test and slaughter of reactors, accompanied by a policy of culling infected badger populations. And there is no reason why the same approach cannot succeed two decades later in spite of the hugely increased scale of the problem that has been allowed to develop. As the Irish have shown where theres a will theres a way.
We have already given our support to the 7 point plan recently set out by the NFU and other farming interests but it is now hard to envisage how this has much chance of success given all the constraints recommended by EFRACom on any badger culling and the knowledge, revealed in the report, that the Government has abdicated all responsibility for logistical support hardly the commitment by Government to fight the disease, declared elsewhere in the report.
Finally we are astonished to note that the committee does not appear to have consulted any veterinary organisation outside of DEFRA and the VLA. Instead they have sought the opinions of two non veterinary, single issue organisations the Badger Trust and RSPCA, who have no apparent concern for the insidious disease that is endemic in parts of the badger population, one of which, the RSPCA, was censured by the Advertising Standards Authority in 2006 and the Charity Commission in 2007 for publishing misleading information on the transmission of bovine TB.
Statement on bovine TB by chief scientist is to be welcomed
The recent statement by the chief scientist Sir David King that badgers will have to be culled in order to control bovine tuberculosis is a welcome breath of scientific fresh air and common sense to be contrasted with the politically compromised recommendations of the so called Independent Scientific Group earlier this year.
The task will not be an easy one since the disease has effectively been allowed to run out of control for the last 20 years during which time the badger population has escalated and the disease has spread in both in badgers and cattle to involve large areas of England and Wales. But it is to be hoped that the Government will now grasp the nettle and put into place effective measures for eradicating the infection in badgers alongside the current programme for tackling the disease in cattle. These measures should also include eradication of bovine TB in other wildlife species such as deer into which the disease has spilled over in the last decade.