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 Added by  Sally (Guest)
 27 May 2010, 5:09 PM


Has a cost benefit analysis ever been undertaken to justify the existing programme of eradication in the UK? The UK, in common with many European countries, is in dire financial straits and cut backs are expected in many areas. What about bovine TB? We put this question to Ministers and DEFRA in March 2010 and sent them a copy of the report 'Public health and bovine tuberculosis: what's all the fuss about?' by Paul R and David J Torgerson. The response is below.
 
CCU Ref: DWOE178656 
 
 
April 2010

 
BOVINE TB
 
Thank you for your email of 26 March regarding bovine TB (bTB) and the copy of the opinion paper by Torgerson & Torgerson to which you refer. I have been asked to reply.
 
Whilst the paper may have a point in pure monetary terms of human lives saved (or clinical cases of TB prevented) by the bTB control programme, we should not lose sight of the fact that the costs of an existing disease control intervention are often easier to quantify than the benefits, some of which may be rather intangible.
 
As stated in the paper, under EU Animal Health legislation (not only Council Directive 64/432/EEC), there is a legal obligation on every Member State to draw up and implement a plan for the eradication of bTB from their respective territories. The UK plan is approved and co-financed by the European Commission. It is simply not a realistic option for the UK Government to seek derogation from Directive 64/432/EEC (which applies to all Member States), or to expect that the Commission would grant it. Were the bTB surveillance and control programme to be terminated, the Commission would probably impose an automatic ban on all live cattle exports from the UK and instigate costly infraction proceedings against the UK government. The trade of cattle between England, other parts of the UK and especially with Scotland (designated as an officially TB free [OTF] region last September) would be severely disrupted.
 
Additionally, Mycobacterium bovis infection would be expected to spread out of control not only within the national cattle herd, as implied in the paper (and evidenced after just a one-year suspension of testing during the 2001 epidemic of Foot and Mouth Disease), but it would also spill over more frequently to other domestic and wild mammals (including pets) at a much higher rate and over a wider geographical range than at present.
 
Furthermore, the absence of a national bTB surveillance regime on UK cattle farms would have knock-on effects on OTF guarantees for meat and (especially) dairy products. The wholesomeness and safety of UK beef and dairy products would likely be called into question by importing countries (both EU and rest of the World), regardless of any meat inspection and milk pasteurisation procedures in place. The current drive in food safety regulation is also to produce uncontaminated, safe products at source, rather than apply chemical or physical treatments to render them safe. Although pasteurisation of milk and dairy products is generally considered an effective and efficient way of eliminating the risk of foodborne human M. bovis infection, pasteurisation failures are also known to occur and the procedure is not universally applied to all milk sold in England and Wales. It would be impossible to impose or enforce a ban on the personal consumption of raw milk and dairy products on farms, etc.
 
To address your reservations regarding the relevance of bTB control to public health I must point out that the majority of M. bovis infections in humans are chronic and latent. Clinical cases of TB confirmed by culture represent only a fraction of the total population infected. The majority of human M. bovis infections diagnosed in the native UK population involve reactivation of old infections in elderly persons who contracted them before the advent of compulsory bTB testing of cattle herds and the widespread adoption of pasteurisation by the dairy industry. Whilst the incidence of clinical human M. bovis infections has been low for several years due to a combination of control measures, a sudden rise in the prevalence of M. bovis infection in cattle and other animals in the UK would lead in turn to a marked increase in the risk of zoonotic TB due to milk, airborne or cutaneous transmission. This would affect farmers and other sectors of the population most likely to come into contact with infected animals. Many of those human infections would remain subclinical for the time being, but a proportion of those would be expected to emerge as cases of TB disease several years after the exposure.
 
The current test and slaughter regime is helping to contain the prevalence and geographical spread of bovine TB at a relatively low level. Hilary Benn announced in the House of Commons on 25 March that the Veterinary Medicines Directorate (VMD) issued an authorisation for Badger BCG vaccine on 24th March 2010. This vaccine provides another tool in the box of measures for tackling bovine TB. Development of cattle vaccines continues. The earliest projected date for the use of a BCG cattle vaccine with a differential diagnostic test to Differentiate Infected from Vaccinated Animals (a so-called 'DIVA test') is 2015.
 
Vaccination on its own would not be sufficient to eradicate the disease and even less so if the prevalence of infection is high and widespread in a range of species when the vaccine becomes available. We need a holistic approach.
 
I hope I have provided sufficient clarification of the Government’s position on this issue.
 
Yours sincerely,
 
 
Lee Hodkinson
Defra - Customer Contact Unit
 

Customer Contact Unit 
Defra

becky
According to the Independent (/www.independent.co.uk/environment/nature/police-we-wont-be-able-to-cope-with-badger-cull-protests-6265124.html) Ministers have been warned that police forces will struggle to cope if plans to shoot badgers trigger a dangerous stand-off between armed farm workers and animal rights protesters.
 
In a memo obtained by The Independent on Sunday, the head of the police unit dealing with domestic extremism warns of the "clear potential for harm to public safety" if protesters clash with farmers carrying out a cull. Caroline Spelman, the Environment Secretary, is expected to make an announcement within weeks on a cull of badgers, which could see tens of thousands of badgers killed. Two trials could begin next year.
 
In an email to the Government, Detective Chief Superintendent Adrian Tudway, the national co-ordinator for domestic extremism, warned that forces could be overwhelmed by protests. Officers already face budget cuts, he said,.
 
"Given the difficult nature of policing this initiative, the steps forces are taking to respond to new financial pressures and the proximity of this initiative to other competing priorities... forces will find themselves under huge pressures to manage even small but sustained campaign activity, particularly where that includes unlawful direct action and subsequent criminal investigations."
 
Police in Devon and Cornwall, one of the areas worst affected by bovine TB, have written to MPs to assure them the force has "plans in place to respond to protests". Forces are able to claim for a special or extraordinary grant from the Home Office if costs to police protests exceed 1 per cent of their annual budget.
 
Each cull is expected to cost farmers £1.4m. Labour's Mary Creagh has condemned the plans as " bad for farmers, bad for badgers and bad for the taxpayer".
 
"Any option that includes farmers and landowners culling badgers with firearms has potential to place armed farm workers in the near vicinity of protesters and activists, typically during the night-time," Det Ch Supt Tudway warned. "We regard this as a scenario with clear potential for harm to public safety. We see particular challenges where farm workers with little or no experience of trapping badgers in order to shoot them (while still caged) are attempting to do so under the gaze of activists."
 
A Defra source insisted that no final cull decision has been taken, adding: "We have taken on board all interested parties' concerns and will make sure that the granting of licences will be based on the advice that we have received."
 
Sally
MG has sent us a string of emails relating to questions he raised under Freedom of Information Act about misleading Defra figures. He says 'MORE MISLEADING DEFRA STATS. You can see from the email exchange below that the "herds under restriction" given in Defra's monthly Btb stats includes those herds which are '"overdue their test" This gives a totally misleading picture of the actual herds under restriction due to Btb.'
 
Email 1
Sent: 03 September 2011 21:28
To: TB Statistics (FFG-EKBES)
Subject: Bovine tb stats
Hi Can you please answer the following questions which relate to the monthly Btb stats that you publish.
Re
Line 2 Does this show number of new herds (as per line 5) plus repeat breakdowns or ???
Line 15 Total TB tests overdue. Does this refer to herds or cattle?
 
Response
From: TB Statistics (FFG-EKBES)
Sent: Tuesday, September 06, 2011 12:29 PM
Subject: RE: Bovine tb stats
 
Regarding line 2 of the regional stats notice.
“2. …of which were under TB2 restrictions because of a TB incident at some time during the reporting period”.
The figures on this line include herds that had a breakdown and were still subject to restriction going into the reporting period and new herd breakdowns some of which could be repeats within the time of the reporting period.
Line 15 refers to herds.
 
Email 2
Sent: 01 November 2011 13:42
To: TB Statistics (FFG-EKBES)
Subject: Re: Bovine tb stats
Hi
Re. Bovine Tb Stats.
Can you please confirm that line 15 (Total TB tests overdue ) is included in Line 16 (Herds Under Movement restriction on...)
My reading of the reports is:
In the Jan to July 2011 report the
Total GB Herds under movement restriction = 5359 (Line 16)
The Total tests overdue = 4308(Line 15)
Is it correct that :
The total herds under restriction due to failing the TB test is
5359-4308 =1051
 
Response
From: TB Statistics (FFG-EKBES)
Sent: Tuesday, November 01, 2011 3:04 PM
Subject: RE: Bovine tb stats
 
The figures contained within line 15 are not included within line 16.
Regards
TB statistics
 
Email 3
Sent: 01 November 2011 15:11
To: TB Statistics (FFG-EKBES)
Subject: Re: Bovine tb stats
Thanks. However:
What does the "heading" between line 15 and 16 Mean?
It appears to be a heading for line 16 and includes "(due to a TB incident,overdue TB test etc)
Hence my reading that line 16 included the overdue tests in line 15.
Please help clarify
 
Response
From: TB Statistics (FFG-EKBES)
To: Mick Griffiths
Sent: Tuesday, November 01, 2011 5:09 PM
Subject: RE: Bovine tb stats
 
Dear Mick
Many apologies made a mistake earlier, very busy here, so just to clarify.
The overdue tests at line 15 do form part of the total ‘Herds under movement restriction’ at line 16.
Yes the heading is for line 16.
Regards
TB Statistics
 
becky
Email from P dated 14/11/11
 
More props from Defra to support their negative reporting but the astute observations from Dr Gareth Enticott give us hope that it's not so easy for government departments to deceive in this day and age.
 
Sally
Misleading Data Visualisation: Defra’s TB Maps - is the title of the latest blog by Dr Gareth Enricott http://biosecurityresearch.blogspot.com/2011/11/misleading-data-visualisation-defras-tb.html
 
It is clear from what he says that the maps published by Defra are misleading. They are not consistent regarding their reporting of confirmed and unconfirmed bTB cases, thereby giving out confusing and misleading data, which misrepresents the true situation.
 
Gareth says; "Personally, I think this whole debate about confirmed/unconfirmed reactors is not handled very well. Sometimes Government likes to treat unconfirmed reactors in the same way as confirmed cases (as is the case here), all go under TB restriction, and even when no visible lesions are found, Government likes to tell farmers that doesn’t mean they don’t have TB. At other times, they are treated separately – for example, the work on badger culling ignores unconfirmed cases, AHVLA only visit farms to conduct epidemiological investigation on confirmed cases, and the rules for going clear are different. If one of the purposes of the change to the OTF jargon was to help farmers understand the difference between confirmed and unconfirmed cases, then I think that misses the point about the reasons why farmers distrust science and the government."
 
Sally
FREEDOM OF INFORMATION REQUEST FOR INFORMATION Ref: RFI 4275 dated 18/10/11: number of carcasses from reactors that enter the
food chain and number that are condemned as unfit for human consumption.
 
Thank you for your request asking how many carcasses from bovine TB reactors or inconclusive reactors enter the food chain and how many are condemned as having too many lesions for human consumption. As you know we have handled your request under the Freedom of Information Act 2000 (FOIA).
 
Defra does not hold or record the number of TB reactors (or inconclusive reactors) that enters the food chain or the number condemned as having too many lesions to go for human consumption.
 
The decision as to which TB reactor carcases processed in abattoirs may or may not enter the human food chain is ultimately the responsibility of Food Standards Agency (FSA) inspectors and official veterinarians as part of their public health protection duties. However, Defra’s understanding is that the information is not currently held centrally by the FSA (or another public authority) in an easily retrievable format.
 
If you wish to contact the FSA, please write to:
 
Food Standards Agency
Aviation House
125 Kingsway
London WC2B 6NH
 
You may find the Agenda, Papers and Minutes of the FSA’s Board Meeting of 20 July 2010 interesting, an FSA paper (ref 10/07/12) setting out the advice from the Advisory Committee on the Microbiological Safety of Foods (ACMSF) regarding the very low risk posed by Mycobacterium bovis to consumers of TB reactor meat was discussed and noted. The papers are published on the FSA website at: http://www.food.gov.uk/aboutus/ourboard/boardmeetings/
 
becky
Questions by email 30/6/11
 
The Bovine TB test data published by Defra (http://archive.defra.gov.uk/foodfarm/farmanimal/diseases/atoz/tb/stats/documents/10/2010gb.pdf ) combines Single Intradermal Comparative Cervical Tuberculin and Ganma Interferon tests in one figure. I would be grateful if you could provide data allowing the number and results for the two tests to be distinguished.
 
Secondly please could you provide figures for the sensitivity and selectivity of the Gamma Interferon test as used currently, indicating the source of the information provided.
 
Response from Defra by email 11/7/11
 
We do not currently differentiate the number of IFN-gamma test reactors (and tests carried out) from the skin test reactors in the monthly TB statistics that are published on the Defra website.
 
However, statistics are available on the Defra website on IFN-gamma testing since the introduction of the policy:
http://archive.defra.gov.uk/foodfarm/farmanimal/diseases/atoz/tb/stats/gamma-stats.htm
 
Please also see the link below, again from the Defra website, regarding the specificity of IFN-gamma testing:
http://archive.defra.gov.uk/foodfarm/farmanimal/diseases/atoz/tb/documents/gifn_specificityreport.pdf
 
Sally
Reading through the many Defra papers and web reports on the subject of Bovine TB, it is interesting to see the different reasons for the existing policy. Some examples are set out below. The Rethink bTB discussion document at www.rethinkbtb.org looks at these reasons and concludes that not one stands examination. UK policy is driven by the EU requiring member states to eradicate bovine TB. For government to intervene in private or business affairs, and in particular to take and kill livestock, there must be sound justification rooted in the common good. No such justification has been advanced.
 
1. Extracted from Defra’s report “Options for Vaccinating Cattle Against Bovine Tuberculosis”
 
‘Protection of public health - historically this has been the main reason for Government intervention on bTB, based on risks to consumers from milk and meat. There are also minimal occupational health risks.’
 
‘International trade – the presence of bTB on a farm is potentially an impediment to EU trade in live cattle and cattle products.’
 
‘Protect/promote animal welfare – cattle are currently exposed to a level of disease which is resulting in the slaughter of around 22,000 animals each year.’
 
‘To protect the interests of wider society/economy – the existence of a reservoir of infection in wildlife, particularly badgers, is a significant factor in our ability to control the disease in cattle. However, badgers are protected by law and are valued by wider society.’
 
2. Extracted from Defra’s “Bovine Tuberculosis Evidence Plan 2011/12”
 
‘Protect the health of the public and maintain public confidence in the safety of
products entering the food chain.’
 
‘Meet our international (in particular EU) and domestic legal commitments and
maintain the UK‟s reputation for safe and high quality food’.
 
‘Maintain productive and sustainable beef and dairy sectors in England securing
opportunities for international trade and minimising environmental impacts.’
 
‘Protect and promote the health and welfare of animals.’
 
‘Reduce the cost of TB to farmers and taxpayers’.
 
3. Extracted from Defra’s original web site www.web.archive.org/web/20080804000056/http://www.defra.gov.uk/animalh/tb/control/index.htm
 
‘To protect public health.’
 
‘To prevent bTB spreading to other cattle or other animals.’
 
‘To make sure that cattle do not suffer because of bTB.’
 
 
 
becky
Updated cattle export figures (email 9/2/11 and 10/2/11 from Gardiner, Joanne (FFG-EKBES, DEFRA)
 
Table 1: GB exports of live bovine (cattle and calves) 2006 - 2010
 
2006 91,462
2007 85,840
2008 52,152
2009 1,121
2010 723
Crown Copyright
Source: RADAR (Rapid Analysis and Detection of Animal-related Risks) dataset
 
2010 data is subject to amendments
 
Table 2: Value of UK exports of live bovine, 2006 - November 2010 (cattle and calves)
 
£000s
2006 3,332
2007 3,332
2008 2,548
2009 1,457
Jan-Nov 2010
Live Cattle and Calves 152 57
 
Crown Copyright
Source: H M Revenue and Customs
Data prepared by Trade Statistics, Economics and Statistics Programme, DEFRA
 
2010 data is subject to amendments
 
Background notes
 
The notable drop in number of cattle exports in 2008, 2009 and 2010 is due to the reluctance of EU member states to import from the UK with the current TB situation.
 
The notable drop in number of cattle exports in 2008 and 2009 is due to the reluctance of EU member states to import from the UK with the current TB situation. The reasoning behind this footnote is that calf numbers accounted for a high percentage of all cattle exports from the United Kingdom, with the two main destinations being Holland and Belgium (as the data indicates). In 2008 live calf exports were disrupted due to the informal ban on UK imports by the Netherlands and Belgium following the discovery of bovine tuberculosis in calves exported from the UK. Therefore export numbers dropped significantly.
 
This ban was well publicised at the time with reports suggesting other EU member states became uneasy.
 
http://news.bbc.co.uk/1/hi/uk/7594625.stm
http://www.timesonline.co.uk/tol/news/uk/health/article4656330.ece
http://www.fwi.co.uk/Articles/2008/07/16/111208/EXCLUSIVE-UK-calves-boycotted-after-Holland-is-infected-with.htm
http://www.farmersguardian.com/thousands-more-calves-shot-as-farmers-search-for-a-market/19898.article

 
becky
Last year (email dated 8/6/10) we asked vital questions to which we have never received a response. We have resubmitted these by email today (21.3.11) as follows.
 
To: "Henderson, Tom (RA - OCVO)" <Tom.Henderson@Wales.GSI.Gov.UK>
Subject: Re: Bovine TB Eradication Programme
 
Dear Mr Henderson
The University of Exeter TB report that you referred to (and provided copy) is really nothing about the economic losses caused by TB (such as decreased production, cost of treatment etc), but the economic consequences of implementing the control programme. You have clearly stated that it is not known how many animals are clinically affected by TB and that it is an insidious disease with a long incubation period. Perhaps the incubation period is so long that the average productive life of a diary cow is already over by the time she starts showing clinical signs (hence no data on clinical cases, and hence minimal productive losses)....?
 
As the eradication programme is so costly and presumably MUST now be fully justified, bearing in mind the huge public debt and imminent drastic cuts, please explain why the small minority of farmers who wish to export live animals or sell unpasteurised milk should not be allowed to undertake their own progamme and remain “attested” and leave the rest of the industry (the other 95%) to get on with business and control through vaccination and biosecurity?
 
derek
I wrote to the Wales Audit Office. Here are the question and responses.  There was no indication that I should not forward the replies. Disappointing but worth a try.  However it does question the diligence in scrutiny as operated by the WA. Heads should roll but they won't.Thank you for your e-mail of 9 January about the Welsh Assembly Government’s bovine tuberculosis eradication programme, in particular its proposals for a badger cull.
 
Email dated 7 Feb 2011 from Audit office
As Auditor General for Wales, my remit does not allow me to comment on the merits of policy decisions. As such, I cannot comment, nor otherwise intervene, in relation to a decision the Minister has made – or might make – on the basis of the information and advice available to her. I note that the formal consultation on the Assembly Government’s proposals closed in December and that the Minister expects to make a decision later this year, when she has had an opportunity to fully consider the responses. In these circumstances it would be inappropriate for me to conduct a study in this area since doing so could be seen as intervening in the decision-making process.
 
I appreciate that this is a sensitive issue and recognise that you may be disappointed with this reply.  However, I hope I have made clear the restraints inherent in the statutory basis of my role.
 
Huw Vaughan Thomas
Auditor General for Wales
 
I replied as follows by email on 7 Feb 2011
 
Bovine TB
Thank you for your reply.  I agree that the issue is sensitive but I would like to point out that I have approached this issue from a scientific not an emotional viewpoint.  I have also been fortunate in being in contact with others in Wales (and the UK) who have significant scientific and other relevant experience.
 
I am not disappointed with your response.  I am only disappointed that there has been a lack of lack of scrutiny (in this case at least) and that
 
1 A pamphlet was issued to 26000 householders with a blatant error that should have been picked up.
2 The correction to this error was erroneous in itself.
3 A mathematical error that of course supported a badger kill was left unchallenged.
 
And yet the consultation was allowed to go ahead.
 
I doubt if any action will be taken against personnel involved with the above to put it mildly incompetence.
 
It is a sad reflection of scrutiny as it operates within the Welsh Assembly that ordinary members of the public had to draw these inaccuracies to the attention of the Rural Affairs Department.
 
The one disappointment I had reading your email is that you did not advise me how I could proceed with what I see as a genuine grievance.
 
Emailed reply dated March 17 2011
The Auditor General has asked me to thank you for, and respond to, your e-mail of 7 February. I am sorry for the delay in getting back to you.
 
In terms of the action you can take to challenge the Assembly Government’s decisions and the process by which it reaches them, I understand that you are already corresponding with the First and Deputy First Ministers and the Minister for Rural Affairs as well as a number of Assembly Members.
 
In addition, and if you have not already done so, you may want to consider petitioning the National Assembly, either in writing or by using the e-petitions system at:
 
http://www.assemblywales.org/gethome/e-petitions.htm
 
Subject to the Presiding Officer’s confirmation that a petition is admissible, the Petitions Committee would consider it and decide on any action. I understand that an e-petition seeking a review of the decision to undertake a badger cull pilot scheme in North Pembrokeshire attracted almost 1,500 signatures last year although any subsequent action was overtaken by the successful legal challenge. The ultimate challenge is via the courts.
 
Regards
Bernadette Daley
Auditor General’s Office
Wales Audit Office
 
My response dated 17 March 2011
 
Thanks for your and the Auditor General's time Bernadette. I'm not to sure that the e-petition was overtaken by the successful legal challenge. My recollection is that the committee were very tardy in coming to any decision on how to move forward with the petition (that gained hits in 4 figures - not known before or since).
 
I will forward the latest PAC Bulletin that expresses great concern how the WA comes to a conclusion in a consultation. Certainly detail on responses (important) are hidden well away. We are awaiting to see if the Badger Trust or PAC will take legal action. This will of course cost the man in the street money while the costs to the WAG of a challenge are also charged to the man in the street. Hardly fair!!!!!
 

 
Sally
RFI 3725 & RFI 3749 Freedom of Information Request response emailed 19/01/11
 
Bovine TB: specificity of the tuberculin skin test.
 
Thank you for your request for further information about the specificity of the tuberculin skin test for bovine TB, which we received on 23d December 2010. We are dealing with your request under the Freedom of Information Act 2000. This response also covers your Freedom of Information request RFI 3749 of 17th January 2011.
 
The series of studies performed by Lesslie and co-workers and later published in the Veterinary Record underpinned the changeover in 1975 from ‘mammalian’ (M. tuberculosis) to ‘bovine’ (M. bovis) tuberculin produced by VLA Weybridge. This became, along avian Weybridge tuberculin, the only antigen used in the detection of cattle infected with Mycobacterium bovis in Great Britain until October 2005 (see below). Those studies also enabled the estimation of the specificity of the single intradermal comparative cervical tuberculin (SICCT) test used in the UK bovine TB control programmes.
 
The formulation of tuberculins at VLA Weybridge remained essentially the same since 1975, i.e. using the same strain of M. bovis, same basic tuberculin production method and broadly the same nominal potency as stipulated in the European legislation and Pharmacopoeia (small variations in performance are a normal feature of biological products such as tuberculin, including variation between different production batches).
 
In the summer of 2005, after difficulties with the production of tuberculin at VLA Weybridge, Defra began to source paired stocks of bovine and avian tuberculins from ID-Lelystad in The Netherlands. These stocks started to be used in herds across GB from October 2005 and were alternated with Weybridge tuberculins for release to veterinarians on a strict temporal basis, dependent on the shelf life of the available stocks from each manufacturer. The alternate use of both tuberculins continued in GB until the production of Weybridge tuberculin at VLA ceased and stocks eventually ran out in September 2009. Since then, Dutch tuberculin from ID-Lelystad (now owned by Prionics) has been the only antigen used in the UK bovine TB testing programme (and it had also been in use in Ireland for many years before it started to replace Weybridge tuberculin in the UK).
 
Comparative statistical analyses of field test reactor data from British cattle herds tested between January 2005 and June 2009 were carried to monitor the relative performance of Weybridge and Dutch tuberculins. Although the classic test characteristics of sensitivity and specificity could not be compared with surveillance data (because only test reactors are slaughtered and we have no contemporaneous information on TB infection prevalence in test-negative cattle), the analyses indicated that the overall rate of disclosure of reactors and TB herd breakdowns were slightly higher in herds tested with Weybridge than with ID-Lelystad tuberculins. By contrast, confirmation of TB infection by post-mortem examination or culture was higher in reactor animals tested using ID-Lelystad tuberculin. However, the differences between the two tuberculins were small and unlikely to have observable effects in overall trends in bTB surveillance data.
 
Empirical (field) data from the bovine TB surveillance programme in Great Britain also show that the specificity of the SICCT test remains very high, despite the change of tuberculins. The specificity of a diagnostic test is the converse of the proportion of false positive results. Since (i) the number of false positives cannot exceed the total number of positive test results and (ii) between January and September 2010 (the most recent set of TB test data available) there were 4.1 TB reactors per 1,000 animal tests in GB, this means that, in the worst-case scenario, the SICCT test specificity in GB would be at least 995.9 per 1000 or 99.59%. Given that the majority of skin test reactors detected in GB originated from endemic TB areas of England and Wales and were likely to be infected (regardless of post-mortem findings), a better estimator of the true test specificity would be the converse of the proportion of test reactors observed in a very low TB incidence area such as Scotland, where the majority (but not all) of the test reactors could be expected to constitute false positive test results. Since we had a rate of 0.8 tuberculin skin test reactors per 1,000 animal tests in Scotland in the first nine months of 2010, this means that the test specificity was about 999.2 per 1,000 (or 99.92%).
 
Therefore, in addition to the field trials carried out by Lesslie et al. in the mid-1970s, the current field data continues to indicate a very high specificity of the SICCT test, despite the gradual replacement of Weybridge tuberculins with ID-Lelystad (Prionics) tuberculins between 2005 and 2009.
 
Comments on above from MJ (email 20/1/11)
The letter does not answer question which was in summary: “What is the source of the specificity figure.”
 
I think a fair appraisal would be:
 
According to Defra the only place the specificity of 99.9% using Weybridge tuberculin can have come from is the Leslie paper. No one is certain if it did, and if so who calculated it, as the figure and calculation do not appear in the paper.
 
Defra have no clear idea of the specificity using Dutch tuberculin but assume it is similar to Weybridge as no discontinuity in overall national test data was evident over the prolonged changeover period. A dangerous assumption.
 
Defra finally fall back on the truism that the number of false positives cannot exceed itself added to the number of true positives.
 
None of this is good enough.
 

 
Sally
On 23 December we responded (see below) to DEFRA's reply as set out in the previous posting. We are currently awaiting a response.
 
We have now read the papers you referred to. The only manuscript from which there is actual data from which the specificity of the SCITT test can be calculated is the Leslie et al paper from 1975. All the other manuscripts refer either directly (or more usual indirectly, via the Monaghan paper – and the Monaghan paper is not original data but a review paper) to this data. In none of these references does ANYONE actually calculate the specificity of the skin test. With the exception of the Leslie paper, they all refer to other work, which usually refers back to the Leslie paper. The Leslie paper does have data from which the specificity could be calculated, but they did not actually do this. Only the Leslie paper gives raw data – all others refer to other articles. Please could you therefore indicate how the specificity was actually calculated and where the data came from. We understand that the international standard for tuberculin (used in the SCITT test) was adopted in 1986 (copy of relevant OIE manual attached). So if you are using the Leslie data for test specificity can you also confirm that the formulation of the tuberculin in the skin test has not changed since 1975. If it has, then using the Leslie data is surely invalid as the test has actually changed?

 
Sally
On 10 December 2010 we emailed DEFRA under the Freedom of Informstion Act asking; 'Defra has published the figure of 99.9% as the specificity of the skin test. Please provide the basis used for this figure.'
 
The following response was received on 16 December under ref: RFI 3706
REQUEST FOR INFORMATION: Single intradermal comparative cervical tuberculin (SICCT) test
 
Thank you for your query about the specificity of the single intradermal comparative cervical tuberculin (SICCT) test currently in use in Great Britain. We received your request on the 10th December 2010. Your request has been considered under the Freedom of Information Act 2000.
 
You may find some background information about the test interesting. The SICCT test is an effective test for bovine TB when correctly performed. National campaigns involving systematic skin testing of cattle herds and slaughter of test reactors have eradicated bovine TB, or reduced it to very low levels, in the majority of industrialised countries where cattle is the only maintenance host of infection.
 
The SICCT test applied to cattle in bovine TB-free herds in GB is estimated to have a specificity of 99.9% at standard interpretation, which is equivalent to a 0.1% probability of false positives or a one in 1,000 chance that a non-infected animal will be wrongly classified as a reactor. In other words, the SICCT is a moderately sensitive and highly specific screening test for TB in cattle.
 
Nevertheless, it is important to appreciate that the sensitivity and specificity values quoted above are indicative working averages. The actual performance of a bovine TB screening test in a particular herd under field conditions will depend on a range of variables, such as the degree of adherence to the correct testing procedure, the within-herd prevalence of cattle sensitised to other non-tuberculous environmental mycobacteria and any factors that may alter the delayed-type hypersensitivity response of an individual animal to tuberculin (e.g. nutritional status, pregnancy, stress levels, concurrent infections, etc.). Additionally, for every diagnostic test with a readout given in a quantitative or ordinal scale, there is a trade-off between sensitivity and specificity so that different interpretations (cut-offs) of the tuberculin skin test can be used under different disease incidence scenarios. The sensitivity of the SICCT test can be enhanced in herds with post-mortem or cultural evidence of TB infection by application of the so-called severe interpretation, but this is at the expense of lowering its specificity.
 
The basis of the 99.9% figure for the specificity of the skin test is obtained from estimates published in scientific review papers. A non-exhaustive list of references to the sensitivity and specificity values we are working to include the following papers:
 
• Monaghan, M.L. et al. (1994), Veterinary Microbiology 40, 111–124.
• De la Rua-Domenech R. et al (2006), Research in Veterinary Science 81, 190–210.
• De la Rua-Domenech R. (2006), Government Veterinary Journal 16(1), 65-71.
• Vordermeier M. et al. (2008), Government Veterinary Journal, 19(1), 38-43.
• Lesslie, W. and C.N. Hebert, Comparison of the Specificity of Human and Bovine Tuberculin Ppd for Testing Cattle. 3. National Trial in Great Britain. Veterinary Record, 1975. 96(No.15): p. 338-341.
 
 

 
Sally
On 20th October 2010 we emailed DEFRA under a Freedom of Information request. We asked 'are you able to let me have any figures that reveal, over the last three years, how many cattle in England and Wales have been found to have actual clinical symptoms of bTB?'.
 
An email response was eventually received on 21 December 2010 (from DEFRA's TB Communication Unit, Bovine TB Programme, Food and Farming Group). The response was; 'Apologies for the delay in responding to you. Unlike the numbers of reactors, slaughterhouse cases, etc, information regarding actual symptoms of bTB is not systematically recorded on the Animal Health central database (VetNet). Clinical signs of bovine TB are not very specific and we are therefore not in a position to answer this question.'
 
 
Sally
Formal response to the following consultations from www.bovinetb.co.uk, 'looking for the reform of a costly and misguided system':
 
England's 'Bovine Tuberculosis: The Government’s approach to tackling the disease and consultation on a badger control policy' and Wales' 'Consultation on Badger Control in the Intensive Action Area'
 
Emailed to Defra tbbc@defra.gsi.gov.uk on 3/12/10 and 8/12/10 and to WAG bovinetbconsultations@wales.gsi.gov.uk on 12/12/10, together with all the questions raised under 'Bovine TB - Is a Change of Direction Needed?' at www.bovinetb.co.uk/article.php?article_id=27
 
 
Why do we need an eradication programme? It is clear from the research we have done that the current strive for eradication will not work because the skin (and blood) test used, which forms the basis of the eradication programme, is not accurate enough. Countries that claim to have eradicated the disease using the skin test (which is not accurate enough to be anything other than a herd test) have only done so by the complete depopulation of all herds where any animal reacts to the test and re-stocking is then delayed (not done in the UK).
 
It is therefore somewhat disturbing that the majority, including politicians and the NFU, are so obsessed with the badger culling debate that the fundamental, long-term failures and problems of the existing inflexible, costly eradication policy are being totally disregarded. There are many questions regarding the existing system (see www.bovinetb.co.uk). If these cannot be answered then the existing policy is suspect and a re-think is needed.
 
One of the aims of the policy is to protect public health, yet the very real health and safety risks from so much cattle handling are being ignored. Another aim is to make sure that cattle do not suffer because of bTB, yet the consequences of the policy, not the disease, are raising serious welfare issues. It is not disease that is crippling those involved - it is the policy. For examples see the growing number of case studies at www.bovinetb.co.uk/articles.php?category_id=32). Furthermore, UK government officials tell us that we are still years away from eradication, so the suffering for those farmers affected will continue and, both cattle and wildlife will continue to be culled needlessly and at great public cost.
 
Why all this fuss about bovine TB? There is not the same concern given to the human form, which is on the increase (ref 1) - humans are not being tested and culled; those effected are not even segregated. Bovine TB represents less than 1% of human cases of TB and is no longer considered the human health risk (ref 2) it once was now that virtually all milk is heat-treated. The ‘eradication’ policy appears to exist mainly to protect a dwindling livestock export, (in 2009 just 11,050 cattle were exported, with a value of £152,000).
 
The few reports undertaken regarding cost effectiveness of badger culling have shown it to be very poor value for money. There is little evidence given anywhere for the continued justification of the current draconian and expensive eradication policy, either on the grounds of costs, human or animal health! In fact it is now more about meeting political deadlines and targets. 60 years of test/cull in the UK and pockets of TB have always remained, and probably always will, as the bacteria are so widespread across the world. Even in so-called bTB-free areas cases spring up with surprising regularity.
 
Interestingly DEFRA does reveal, in the latest consultation documents, that a vaccination for cattle will be available in 2012 (with a DIVA test). The BCG vaccine is not perfect – but then neither is the existing skin (or blood) test! Bearing in mind the average lifespan of most cattle, vaccination could be used as a successful control, rather than eradication, policy. However, the EU procedures will not be completed until 2015! This is not good enough and derogation should be sought so a vaccination programme can be started for cattle as a matter of urgency (already successful in Ethiopia where they cannot afford to keep culling cattle needlessly). Then surely wildlife reservoirs will no longer be a problem!
 
Ref 1 Health Protection Agency report, ‘Tuberculosis in the UK: Annual report on tuberculosis surveillance in the UK 2010’. The trend of a gradual rise in the number of tuberculosis cases observed over the last 20 years continued in 2009, with a 4.2% rise giving an overall rate of 15 cases per 100,000 population in the UK. A total of 9,040 cases of tuberculosis were reported in 2009 with the majority of disease concentrated in urban centres. All 19 primary care organisations with a rate of 40 per 100,000 or more were in major urban areas. London accounts for 38% of cases, with a rate of 44.4 per 100,000.
 
Ref 2 ‘Public Health and bovine tuberculoisis: what’s all the fuss about?’ They propose that the continuing bTB programme in the UK is economically unacceptable as a public health intervention. Furthermore, they believe data is lacking with regards to the positive economic effects to animal health. There should be a shift away from prevention in cattle, whilst continuing with the regulation of milk and meat. This should provide adequate public health protection at relatively modest costs.

 
Sally
Email 15/4/10
In view of the huge amount of money spent on tackling this disease that you claim is a health and welfare issue for cattle and badgers, could you please confirm if any data is available with regards to the positive economic effects to animal health, given that the main costs are currently implementation expenditure.
 
Response 19/05/10
 
Thank you for your e-mail of 15 April 2010 sent to the bovine TB mailbox. Please accept out apologies for not replying sooner.
 
Trade of cattle within the European Union is solely possible by virtue of the fact that UK herds are attested and cattle traded are clear tested from unrestricted herds. Because of the long term bovine TB testing programme in Wales we intercept and remove infected animals long before they have the opportunity to develop severe clinical disease. Bovine TB is a slow, insidious disease with a long incubation period, although there are a few exceptions in heavily infected herds where cattle as young as unweaned calves can become unwell and die as a result of the disease. However, no official database exists that quantifies the numbers of clinically sick animals seen in the UK.
 
During the foot and mouth disease (FMD) outbreak in 2001 testing for bovine TB ceased for a period. The statistics for bovine TB reactors slaughtered before 2001 and after FMD, when testing recommenced, emphasise the sudden increase in infection that can arise as a result of suspension of the TB testing programme.
 
The following paper on the economics of bovine TB may be of interest:
 
Sheppard, A. & Turner, M. 2005, An Economic Impact Assessment of Bovine Tuberculosis in South West England, Centre for Rural Research, University of Exeter, 9.
 
If you would like more information about the bovine TB Eradication Programme, please visit the Welsh Assembly Government’s bovine TB webpages: www.wales.gov.uk/bovinetb or www.cymru.gov.uk/tbmewngwartheg
 
Yours sincerely
TB Team
Office of the Chief Veterinary Officer
 
On 8/6/10 the following email was sent to TB Team, Office of the Chief Veterinary Officer, WAG. A response has not yet been received and was chased on 1/12/10
 
Dear Mr Henderson
The University of Exeter TB report that you referred to (and provided copy) is really nothing about the economic losses caused by TB (such as decreased production, cost of treatment etc), but the economic consequences of implementing the control programme. You have clearly stated that it is not known how many animals are clinically affected by TB and that it is an insidious disease with a long incubation period. Perhaps the incubation period is so long that the average productive life of a diary cow is already over by the time she starts showing clinical signs (hence no data on clinical cases, and hence minimal productive losses)....?
 
As the eradication programme is so costly and presumably MUST now be fully justified, bearing in mind the huge public debt and imminent drastic cuts, please explain why the small minority of farmers who wish to export live animals or sell unpasteurised milk should not be allowed to undertake their own progamme and remain “attested” and leave the rest of the industry (the other 95%) to get on with business and control through vaccination and biosecurity?
 
 
Keith (Guest)
PROVISION OF REQUESTED INFORMATION
Ref: AH0535,536,546 dated 10 August 2009
 
Thank you for your requests for information relating to bovine TB and TB Policy. Your requests have been considered under the Freedom of Information Act 2000. Please find the following replies to each of the requests for information that you made.
 
• Apart from the “Shambo Case” could you advise (and provide details) if there have been any other prosecutions or court cases in connection with the bovine TB policy?
 
Each year Defra is required to lodge a summary of all prosecutions made under the Animal Health Act in both Houses of Parliament. This document is in the public domain and will include TB related prosecutions. The link is provided here for your convenience.
 
http://defraweb/animalh/ahws/deliver/health_act-1981_year2008.pdf
 
In recent years, in England, there has been a Judicial Review against certain aspects of Defra’s gamma interferon test policy (which Defra successfully defended) and a Judicial Review against Defra’s table valuation system for TB affected cattle (which Defra won on appeal) – both of these were heard in the High Court.
 
• DEFRA/Animal Health are quoting the following
 
On one hand, the comparative tuberculin test can be expected to detect approximately 80% of all the infected cattle in a herd at any one test. This is known as the test’s sensitivity. On the other hand, reactions to the tuberculin test can sometimes be caused by exposure to other mycobacteria. In Great Britain, when the test is applied to cattle without TB there is a 1 in 1,000 chance that a non-infected animal will be wrongly classified as a reactor. This is known as the test’s false positive rate. Because it is impossible to find out in living animals whether the reaction to the test is due to M. bovis or another mycobacterium, all reactors have to be regarded as infected and must be slaughtered according to national and European Union regulations in order to eliminate any risk of
infection to other cattle. Please provide the evidence which is being used to back up these claims.
 
The evidence backing these claims comes from the various studies published in the veterinary scientific literature over the years, which have been reviewed and summarised, among others, by:
 
de la Rua-Domenech, R., Goodchild, A.T., Vordermeier, H.M., Hewinson, R.G.,
Christiansen, K.H., Clifton-Hadley, R.S., 2006. Ante mortem diagnosis of tuberculosis in cattle: A review of the tuberculin tests, gamma-interferon assay and other ancillary diagnostic techniques. Research in Veterinary Science 81, 190-210.
 
Monaghan, M.L., Doherty, M.L., Collins, J.D., Kazda, J.F., Quinn, P.J.,1994. The tuberculin test. Veterinary Microbiology 40, 111–124.
 
Vordermeier, H.M., Whelan, A.O., Ewer, K., Goodchild, T., Clifton-Hadley, R., Williams, J.,
Hewinson, R.G., 2006. The BOVIGAM® assay as ancillary test to the tuberculin skin test. Government Veterinary Journal 16, 72-80.
 
All these papers are in the public domain and therefore accessible through libraries, online search engines, the journals’ websites, etc. should you wish to go straight to the original sources.
 
In responding to this FoI request, it is important to make the point that the quoted sensitivity and specificity estimates are indicative averages. The actual performance of a TB screening test in a particular cattle herd under field conditions is, of course, dependent on a range of variables, such as the diligence of the tester in adhering to the correct testing procedure, the within-herd prevalence of cattle sensitised to other non-tuberculous environmental mycobacteria and factors that may alter the
allergic response of individual animals to tuberculin (e.g. nutritional status, pregnancy, stress levels, concurrent infections, etc). Additionally, for all diagnostic tests there is a trade-off between sensitivity and specificity, so that different interpretations of the tuberculin skin test can be used under different disease situations. Sensitivity of this test can be enhanced in herds with post-mortem or cultural evidence of TB infection by application of the so-called severe interpretation, but this is at the expense of lower specificity.
 
• Please advise if the audit commission has looked into any aspect of expenditure on TB policy in the last 3 years and if so provide details?
 
At year end the National Audit Office pick random lines to investigate from across Defra, this has included lines on TB expenditure. In terms of specific audit, TB expenditure has never been looked at for any reason.
 
(by Email)
 
David Simms
Animal Health Information Manager
 
Keith (Guest)
PROVISION OF REQUESTED INFORMATION RECEIVED FROM ANIMAL HEALTH, WORCESTER DATED 20 MAY 2009 REF: AH0458
 
Thank you for your request for information about TB statistics and costs in GB, which we received your clarification on 23 April 2009. Your request has been considered under the Freedom of Information Act 2000.
 
You raised 13 questions requiring a response under the FOIA 2000.
All of the requested statistics or figures below are provided for GB covering financial years 2007/08 (April–March) and 2008/09 (April-March) where available.
1. Number of cattle identified as TB reactors and slaughtered.
The number of cattle identified as TB reactors and slaughtered as at 30th April 2009 is:
2007/08 (April–March) - 26,959
2008/09 (April–March) - 38,580
2. Number of Reactors that on post-mortem were found to have TB lesions.
The number of Reactors that on post-mortem were found to have TB lesions (visible lesions) as at 30th April 2009 is:
2007/08 (April–March) -10,026
2008/09 (April–March) -12,643
3. Number of cattle identified as Inconclusive Reactors (IRs) and slaughtered.
The number of cattle identified as Inconclusive Reactors (IRs) and slaughtered as at 30th April 2009 is:
2007/08 (April–March) - 518
2008/09 (April–March) - 1311
4. Number of Inconclusive Reactors that on post-mortem were found to have TB lesions.
The number of Inconclusive Reactors (IRs) that on post-mortem were found to have TB lesions (visible lesions) as at 30th April 2009 is:
2007/08 (April–March) - 57
2008/09 (April–March) - 74
5. Total annual cost of TB testing cattle, including payments made to, direct and indirect staffing costs, infrastructure, management etc.
6. Total cost of compensation payments to farmers for cattle slaughtered as a result of the TB controls.
7. Cost of implementing the existing TB eradication policy, including policy making expenses, management/staff costs, indirect and direct costs for GB and the TB Eradication programme in Wales.
5, 6 & 7. The total annual cost of TB ‘Testing Cattle’ and ‘Compensation’ is available within the ‘Breakdown of bovine TB expenditure in GB 1998/99-2007/08’ report on the Defra website at: http://www.defra.gov.uk/animalh/tb/stats/other.htm under the TB expenditure heading.
The GB TB expenditure figures for 08/09 are currently being processed and it is anticipated these figures will be published on the Defra website (http://www.defra.gov.uk/animalh/tb/stats/index.htm) this Summer, and therefore these figures have been not been released under FOIA Qualified Exemption 22 (see: http://www.opsi.gov.uk/Acts/acts2000/ukpga_20000036_en_3#pt2-l1g22).
The TB Eradication Programme in Wales was not in place in 2007/08, therefore, costs for implementing TB policy in this year and previous years are included in the ‘Breakdown of bovine TB expenditure in GB 1998/99-2007/08’.
 
Additional expenditure on the TB Eradication Programme for 2008-09, over and above the costing for normal surveillance activities, will be made available on the Welsh Assembly Government’s bovine TB website www.wales.gov.uk/bovinetb following the publication of the GB figures for 2008/09.
8. Total number of imported cattle tested and found to have TB lesions on post-mortem.  Please also advise if all imported cattle are tested before they enter the UK.
All cattle imported into Great Britain from other EU Member States must comply with the TB certification conditions set out in Council Directive 64/432/EEC (as amended).; for cattle over 6 weeks of age originating in non-officially TB free (OTF) states, this includes pre-export tuberculin testing in the 30 days before departure.
 
Post-import check tests for TB are required for cattle from Northern Ireland, Republic of Ireland (ROI), the Isle of Man and any non-OTF (non Officially TB Free) EU Member States. The number of imported cattle post-import tested (excluding post-import exemptions) and found to have TB lesions on post-mortem as at 5th May 2009 is: 
2007/08 (April–March) - 3
2008/09 (April–March) - 5
 
9. The income received for the selling of carcasses of certain reactors back into the food chain.
 
Please see Meat Hygiene Service (http://www.food.gov.uk/multimedia/pdfs/mhsmanualch2part4rev28.pdf#page=32) for protocols on considering the fitness for human consumption of meat and offal from animals in which tuberculosis is suspected or confirmed with clinical tuberculosis.
 
Salvage income received for the selling of carcasses of certain reactors back into the food chain as at 5th May 2009 is: 
2007/08 (April–March) - £2,541,425.85
2008/09 (April–March) - £4,812,205.86
10. Number of beef cattle exempted from TB testing in beef fattening units.
Animal Health does not hold this information.
 
11. The value of the market regarding UK beef exports.
 
12. The value of the market regarding UK milk exports.
 
13. The value of breeding stock exports (cattle).
 
11, 12 & 13. Animal Health does not hold this information. Perhaps the NFU could help you here?
 
Sally
The TB Team, Office of the Chief Veterinary Officer sent the following response on 2nd July 2010.
 
'In our response to your e-mail of 15 April 2010, we made reference to the fact that, in heavily infected herds, cattle as young as un-weaned calves can become unwell and die as a result of bovine TB. Additionally, we made reference to the sudden increase in infection that can arise as a result of suspension of the TB testing programme, as happened during the foot and mouth disease outbreak in 2001. Our long term bovine TB testing programme in Wales allows us intercept and remove infected animals long before they have the opportunity to develop severe clinical disease. The TB Health Check Wales in 2008-09 and the current annual testing regime is further improving our ability to identify TB infection sooner and thus reducing the potential for disease transmission by cattle.
 
 
Bovine TB must be tackled on all fronts, and limiting opportunities for the infection to spread will make an important contribution to eradicating the disease from Wales. Biosecurity is an important aspect of our multi-pronged approach to tackling bovine TB, but the adoption of biosecurity measures alone will not eradicate this disease. Our TB testing programme must continue.
 
 
The Welsh Assembly Government is committed to supporting the development of effective badger and cattle vaccines for use in the control of bovine TB.
 
 
The injectable Bacillus Calmette-Guérin (BCG) badger vaccine has now received a Limited Market Authorisation. This means the Badger Vaccine Deployment Project (BVDP) in England can go ahead which will allow for the training and accreditation of lay vaccinators, whilst also providing a better understanding of the practicalities of using an injectable vaccine in the field. An oral badger vaccine is also being developed, but this is unlikely to be available until at least 2014.
 
 
We have started discussions with various organisations and experts on how we could introduce badger vaccination as part of the strategy for Wales. These discussions will involve wildlife, veterinary and farming interests. We will monitor the progress of the BVDP and other vaccination trials including the vaccination of possums in New Zealand in order to inform our own decisions with respect to vaccination.
 
As with the badger vaccine, the lead candidate for a cattle vaccine in the short to medium term is the injectable BCG. The ongoing research and legislative issues which need to be addressed before the widespread use of a cattle vaccine were set out in our e-mail to you on 8 June 2010.
 
 
Yours sincerely
 
 
 
TB Team
 
Office of the Chief Veterinary Officer'
 
Sally
On the 7/6/10 we wrote to the TB Team, Office of the Chief Veterinary Officer.
 
Could you please advise what progress is being made for a vaccination porgramme for cattle. It would appear from the links below that significant progress has already been made and the BCG vaccine could be used immediately.
 
http://www.iah.bbsrc.ac.uk/research/BovCelImm/BovCelImm_jh.shtml
 
http://www.iah.ac.uk/press_release/2007/JHope_Nov07.htm
 
It would appear that the main reason for the reluctance to start a vaccination programme for cattle means that the existing skin test would have to be phased out, as vaccinated cattle would show up as positive reactors. HOWEVER it must be remembered that the skin test is not a perfect test, and yet the overall TB status off an area is based solely on the results of this test, ie the test defines the TB status of an area. The test indicates that the animal has mounted an immune response capable of recognising M. bovis and does not conclude actual infection. It means that animals may have been exposed to a bacterium that can cause TB at some point in their life (or have been vaccinated!).
 
Current EU regulations mean that vaccinated cattle could not be exported to the rest of the EU, as current tests cannot distinguish between infected and vaccinated animals. In reality this does not matter for meat and dairy products as pasteurisaion and cooking kills the bacteria that causes bTB.The only products at risk would be those used in their raw state. Indeed many countries, where bTB is endemic or only controlled, export products to the UK.
 
We must therefore conclude that the real reason for the existing eradication policy is to protect the market for live exports of cattle, and to comply with existing EU regulations which insist on its countries achieving TB-free status. Obviously countries which do not have bTB are unlikely to want to risk importing any infected cattle, how ever small the risk. However, if one looks at the export figures for Great Britain (ref 1)) over the last few years it is difficult how such a decision can be justified in cost terms for the UK.
 
In 2006 89,567 cattle were exported with a value of £3,332,000
In 2007 85,487 cattle were exported with a value of £2,548,1457
In 2008 52,129 cattle were exported with a value of £1,457,000
In 2009 11,050 cattle were exported with a value of £152,000
 
The numbers and value is falling year-on-year and, even more surprising, is the fact that the value of this market is considerably less than the annual costs of the existing eradication policy for bTB. Surely this makes a vaccination programme for cattle viable and an appropriate case should be made to the EU in this respect?
 
Ref 1 Access to Information requests - email response from DEFRA dated 12/10/2009 and 14/6/10
 
The response received on 8/6/10 was as follows:
 
'Thank you for your e-mail of 7 June 2010. You comments have been noted. The Welsh Assembly Government is committed to supporting the development of effective badger and cattle vaccines for use in the control of bovine TB and is working closely with Defra on research into vaccines. The importance that is attached to vaccine development is clearly demonstrated by the fact that, in July 2008, Defra announced they would be committing a further £20 million to the TB Vaccines Programme, over the next three years, to the development of usable Bacillus Calmette-Guérin (BCG) vaccines.
 
This additional funding will help to further develop vaccines and investigate ways in which they could most effectively be deployed. It will also enable the necessary work to continue in the application for a license for a cattle BCG vaccine and boost work looking at non-sensitising vaccines for cattle. Non-sensitising vaccines can be used without a differential diagnostic test to Differentiate Infected from Vaccinated Animals (DIVA).
 
You have correctly identified in your e-mail that, in its current form, EU legislation prohibits the use of a TB vaccine for cattle. EU legislation would have to be amended to allow cattle vaccination, particularly with a vaccine which sensitises cattle to the tuberculin skin test, without trade restrictions being imposed on live animals. A DIVA test would have to be used alongside the skin test to confirm the ‘status’ of the animal. This represents a significant obstacle which would need to be overcome prior to any widespread use of a cattle vaccine. Work has begun to identify and address this issue.
 
Research on the efficacy of a vaccine for cattle is ongoing. The earliest projected date for the widespread use of a BCG cattle vaccine with a DIVA test is mid to late 2015.
 
The development of a vaccine for cattle will be monitored closely with a view to introducing it into Welsh policy as and when it is available and appropriate.'
 

 
Sally (Guest)
On the 15th April 2010 I wrote to the WAG TB Team t to ask the following question.
 
'In view of the huge amount of money spent on tackling this disease that you claim is a health and welfare issue for cattle and badgers, could you please confirm if any data is available with regards to the positive economic effects to animal health, given that the main costs are currently implementation expenditure.'
 
On the 19th May 2010 I received the fllowing response.
 
Thank you for your e-mail of 15 April 2010 sent to the bovine TB mailbox. Please accept out apologies for not replying sooner.
 
 
Trade of cattle within the European Union is solely possible by virtue of the fact that UK herds are attested and cattle traded are clear tested from unrestricted herds.
 
Because of the long term bovine TB testing programme in Wales we intercept and remove infected animals long before they have the opportunity to develop severe clinical disease. Bovine TB is a slow, insidious disease with a long incubation period, although there are a few exceptions in heavily infected herds where cattle as young as unweaned calves can become unwell and die as a result of the disease. However, no official database exists that quantifies the numbers of clinically sick animals seen in the UK.
 
During the foot and mouth disease (FMD) outbreak in 2001 testing for bovine TB ceased for a period. The statistics for bovine TB reactors slaughtered before 2001 and after FMD, when testing recommenced, emphasise the sudden increase in infection that can arise as a result of suspension of the TB testing programme.
 
 
The following paper (which was attached) on the economics of bovine TB may be of interest:
 
Sheppard, A. & Turner, M. 2005, An Economic Impact Assessment of Bovine Tuberculosis in South West England, Centre for Rural Research, University of Exeter, 9.
 
If you would like more information about the bovine TB Eradication Programme, please visit the Welsh Assembly Government’s bovine TB webpages: www.wales.gov.uk/bovinetb or www.cymru.gov.uk/tbmewngwartheg
 
Yours sincerely
TB Team
Office of the Chief Veterinary Officer
 
The paper that was attached to the response concentrates on the financial consequences for farmers and compensation levels paid. It was commissioned by the South West Regional Development Agency and a sub-group of the Strategy for Sustainable Food and Farming – Regional Implementation Steering Group to provide a firm evidence base of the economic and social impacts of the disease in the region. It recognises that bovine TB has both economic and social impacts for farmers, rising principally because of restrictions imposed on the movement of animals, part of the standard procedures for the control of notifiable diseases in livestock. Although the precise estimation of the full economic impact of a bovine TB breakdown is acknowledged to be impossible (University of Reading, 2004; NAO Wales, 2003), there is little disagreement that the total cost of a TB incident generally exceeds payments for the livestock slaughtered.
 
Email comment from Prof. PT on 8/6/10
The University of Exeter TB report that is alluded to by Tom Henderson- you will see that on close inspection it is really nothing about the economic losses caused by TB (such as decreased production, cost of treatment etc), but the economic consequences of implementing the control programme. This is not pedantics. I believe it is the control programme that is causing the damage, not the disease and farmers are widely supportive of ever more aggressive action because they believe that successful elimination will result in cessation of the control programme. Perhaps if farmers were more aware of this they might be less supportive of the present action. Indeed Mr Henderson admits it is not known how many animals are clinically affected by TB and that it is an insidious disease with a long incubation period. Perhaps the incubation period is so long that the average productive life of a diary cow is already over by the time she starts showing clinical signs (hence no data on clinical cases, and hence minimal productive losses)....
 
Perhaps you could also ask Mr Henderson why the small minority of farmers who wish to export live animals or sell unpasteurised milk should not be allowed to undertake their own progamme and remain “attested” and leave the rest of the industry (the other 95%) to get on with business and control through vaccination and biosecurity. “Never has been so much given by so many for so few”.
 
 
 

 
Sally (Guest)
We replied to DEFRA on 27/05/10 as following:
 
To: Lee Hodkinson
Defra - Customer Contact Unit
 

Customer Contact Unit 
Defra
 
Your Ref: CCU Ref: DWOE178656
 
Dear Lee
 
With regards to your response I wish to respond as follows.
 
With regards to the second paragraph relating to finances. Can you please define what benefits are actually being derived from the existing UK programmes which aim to eradicate TB and quantify, in terms of cost, such benefits? It would seem that no proper cost benefit analysis has ever been undertaken.
 
With regards to the third paragraph, relating to exports. Please explain exactly why it is not a realistic option for the UK Government to seek derogation from Directive 64/432/EEC and why you are not prepared to make a special case to the Commission? Why do you think the Commission would not grant such a dispensation? I understand that the export market in live animals is actually worth considerably less than the cost of the eradication programme, so please explain just why is this such a relevant issue? Infraction proceedings are unlikely and it would appear this is scaremongering.
 
With regards to your third paragraph, I can accept it may spread but then farmers may like to work on a farm-by-farm basis, based on local epidemiology and bio-security. This would be cheap and highly cost effective. It may even be more effective than the existing programme, which is time consuming for farmers, disruptive, stressful and very costly. There are lots of other diseases that spill over into domestic pets and yet there is no system in place for dealing with these. Echinococcus, for example, is far more dangerous to humans than bovine TB. It is endemic in Wales, there are human cases (requiring major surgery to treat – human bTB can be treated with antibiotics) but virtually nothing is done about it. Other diseases which are currently include Toxoplasmosis, Q fever. Why is bovine TB treated so differently?
 
With regards to your fourth paragraph. Lots of countries (eg many in Latin America) can export beef, despite the fact that bTB is endemic in these countries, so why can’t the UK? There is no risk to humans as cooking destroys any of the bacteria that cause TB so even in the UK the carcasses of reactors enter the foodchain. With regards to the dairy industry, and raw milk suppliers, why can't this market have a self-funded test and cull programme?
 
With regards to your fifth paragraph, I suggest you re-read this section. One of the main thrusts of the Torgerson report was to explore the risk of transmission other than through milk. This report confirmed that it is virtually non-existent and human disease would not increase beyond a small handful of cases, even if every cow in the UK had bTB. This is, of course, because most milk is now pasteurized, which surely makes the current eradication programmes superfluous from a human health perspective?
 
With regards to the seventh paragraph. BCG vaccine works in cattle and is likely to be as effective as the existing skin test in controlling bTB. It is just that cattle who have been vaccinated will give a positive reaction to the intradermal skin test – hence cattle vaccination for bTB is currently banned in the EU. In view of the HUGE deficit problems that now exist in the UK, why can’t the UK get a derogation NOW from the EU. I am very concerned that the EU commission acts on the advice of the veterinary profession that makes the animal health legislation in the EU. The latter is the profession that is currently benefitting financially from keeping the archaic and unreliable skin test going. Please advise how the EU and DEFRA works to safeguard against such vested financial interests?
 
With regards to the penultimate paragraph. Can you please explain why the Government uses the term ‘eradicate’ when this is a global concept – nothing can eradicate the disease? Do you really mean eliminate? So we could vaccinate animals to minimalise its impact.
 
According the World Health Organisation, Eradication is the reduction of an infectious disease’s prevalence in the global human or animal host population to zero. It is sometimes confused with elimination, which describes either the reduction of an infectious disease's prevalence in a regional population to zero, or the reduction of the global prevalence to a negligible amount.
 
Bearing in mind that around 85% of cattle and 82% of the human population are in areas where bovine TB is either only partially controlled or not controlled at all and rapidly increasing globalisation, why is the UK spending millions of pounds (now approaching £100 million annually) at a time of financial crisis on a disease where the risks are hypothetical and the impact on human health negligible?
 

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