Badger Trust Response To Welsh Government

Welsh Government : A Refreshed TB Eradication Programme

Consultation Response Form : Badger Trust Response

7 January 2017

The Badger Trust is the only UK charity dedicated to the conservation of badgers throughout England, Wales and

Northern Ireland. We seek to protect badgers through science, the law and public support.

We are grateful for being given the opportunity to comment on the Welsh Government’s Refreshed TB

Eradication Policy outlined in the consultation document.

We have provided our comments below as responses to the questions put forward in the consultation document.

The Badger Trust would welcome the opportunity to discuss the Welsh Government’s TB Eradication Programme

in more detail in due course.

For further information or clarification on any of the issues raised in this response, please do not hesitate to

contact us further.

Yours sincerely

Dominic Dyer

Chief Executive


Badger Trust


Tel : 07876 596233 Email or

  1. Do you agree with any of the proposals set out in this document? (Please say what proposals

you agree with and why you agree with them)The Badger Trust recognises the significant and ongoing reductions in new herd incidents in Wales

since the introduction of the TB Eradication Programme in 2008, as summarised in Figure 1 of theconsultation document. The Trust feels this reflects the success of a rational, evidence- and risk-based approach by the Welsh Government, which the Trust both welcomes and applauds.The Refreshed TB Eradication Policy represents an excellent, broad-based approach to bovine TBcontrol. It correctly recognises that the transmission of infection among and between cattlerepresents by far the predominant source of TB infection. It also acknowledges the limitations of thecurrent testing methods in use and identifies additional measures designed to reduce the impact ofthese limitations. It is clear that the current testing methods will always fail to identify a proportionof infected cattle within herds with serious consequences for onward transmission of TB throughcattle movement and the establishment of longer term breakdowns or areas of persistent infection.

Proposals to divide Wales into areas of three different TB incidence categories, each with individualdisease control strategies seems an excellent idea, especially if controlling the movement of cattle within and between these areas is implemented along with testing strategies specific to these areas.

Intelligent use of different testing combinations combined with strict pre- and post-movementtesting and risk-based trading, all seem eminently sensible.

  1. Do you disagree with any of the proposals set out in this document? (Please say what proposals you disagree with and why you disagree with them)

General Aims – The Badger Trust is concerned that whilst the aim of ‘eradicating’ or ‘eliminating bTB

is both positive and bold, it must be borne in mind that the mycobacterium responsible for bovine TB has been with mankind since the earliest days of cattle domestication (c. 9,000 years) and is unlikely to ever be eliminated entirely from such a temperate island with such high and dense populations of both people and cattle.


The Trust raises this point not to be negative or to discourage the Welsh Government’s commendable ambition but because the Trust feels that errors and assumptions made after the national Area Eradication Scheme (AES) implemented in the 1950s and 60s led directly to the re- emergence of the disease through complacency, misunderstandings and overconfidence. In particular the relaxation of the testing regime with intervals stretching up to four years wasespecially unwise, as were assumptions about the efficacy of the skin test and ‘wildlife reservoirs’ of the disease. When this was combined with the kind of intensification of livestock management, increasing herd sizes and increasing volumes and distance of cattle movement, the resulting bTB infection pattern we see today was inevitable.

The Trust feels it is important that the Welsh Government make it clear to all that the fight against TB will be permanent and that whilst aiming for and maintaining OTF status in all regions of Wales is achievable, the effort, methods and practices used to achieve it will have to be maintained on a permanent basis if the kind of catastrophic relapse seen in the UK since the 1980s is to be avoided.

The Trust feels that adopting such a stance is vital to counteract a culture of complacency and misunderstanding amongst both the public and the farming community in particular, about the true nature, scope and causes of TB in cattle. Once this is established then the necessary ‘buy in’ from the public and farming community will make the implementation of the strategy much easier to achieve and reduce any false expectations.

All Sources of TB Infection – The consultation document identifies addressing ‘all the sources of bTB infection’ as a long-term goal, and specifically mentions ‘wildlife including badgers and deer’ among those sources. It goes on to suggest it is ‘difficult to eliminate [bTB] from areas where cattle and wildlife are both infected and can infect each other’.

Broadly, the Badger Trust agrees that it is vital to approach the problem of bTB by including the widest possible range of potential infection sources but cautions against concentrating efforts solely on two mammal species. In reality, the Trust is aware that very little research, attention or effort has been put into identifying or quantifying the infection risk from deer, so that when ‘wildlife vectors’ and ‘solutions’ are mentioned it is usually badgers that are the only intended subject of any proposed interventions.

The Trust feels that it is now a matter of urgency that this apparent ‘paradigm’ is broken. There is nodirect, credible evidence for exactly how and to what extent badgers infect cattle with bTB. To date, ‘probable cause’ has been inferred by statistical analysis of various culling trials rather than by direct observation of clinical evidence. Direct attempts to infect cattle experimentally using infected badgers have proven to take unrealistically long and were conducted under wholly artificial conditions.


Furthermore, research over the last few years (DARD NI, Mullen, Donnelly & Woodroffe et al) has shown that badgers specifically avoid direct contact with cattle in pasture and buildings, and that the only possible infection path between the two species is via their shared environment. Equally, research by Barbier et al, 2016 has confirmed the potential for bTB to be maintained for significant time in the earthworm population, so consideration of the problem in invertebrates must also be noted.

It is therefore clear that historic estimates stating that ‘badgers are responsible’ for c.5% of cattle infections can no longer be relied on. It is also clear that cattle are the origin of extensive contamination of their own environment and that this covers a broad spectrum of potential re-infection vectors that must also include cattle themselves. It cannot any longer be safe to assume or infer any significant contribution to cattle infections from badgers over and above any other environmental source.

The Trust acknowledges and commends the Welsh Government’s commitment to science and evidence based mitigation strategies, and is extremely grateful that any kind of indiscriminate ‘English style badger cull’ has been resisted despite pressure from the farming lobby, veterinarians and political interests. However, until such time as more conclusive evidence is obtained as to what extent badgers are actually responsible for re-infecting cattle within the context of all other potential environmental risks, then the Trust cannot condone any deliberate policy of lethal intervention involving badgers.

  1. Do you have any suggestions about how the controls proposed in this document could beimproved or how they could best work in practice?   . All exemptions to pre-movement testing should be removed. Pre-movement testing should

be maintained for cattle from within the low TB area sourced from herds with a history of bovine TB.

. The SICCT test should be routinely analysed at severe interpretation, and all inconclusive reactors (IRs) should be regarded as positive. . A mandatory risk-based trading approach should be adopted as a matter of urgency, with significant penalties for non-compliance. In particular, cattle movements from a higher-risk area into a lower-risk area should be prohibited. Particular attention should be given to trade from bordering English counties where cattle testing and controls have been far less stringent in recent years, where the disease is effectively endemic, and from where the risk should be considered high. Informed Purchasing arrangements should be mandatory, with a full bovine TB history being made available to any potential purchaser of cattle, in addition to a history of other cattle health issues that might impact the sensitivity of bovine TB

testing (such as liver fluke or Johne’s disease).

. The IFN-. test should be used on a continual basis, particularly within the high TB areas, and

only OTFW herds within the high TB area which test clear on combined SICCT testing at severe interpretation and IFN-. testing should be declared OTF.

. It is notable that while the High TB Area (Border) is described as having the ‘highest number of new breakdowns’, it does not have the highest proportion of herds under restriction. This might suggest that the movement restrictions on infected herds are not being applied for long enough following a breakdown, leading to the premature removal of restrictions from herds that still harbour infection. In view of the limitations of the testing regime, a review of the restriction periods applied to new breakdown herds and the criteria that need to be met before movement restrictions are lifted, would be desirable.


. Separate units containing animals from the same herd should be considered as individual units for the purpose of bovine TB control, and all appropriate testing and movement restriction measures should be applied accordingly. It may also be worth considering splitting up in the same way any exceptionally large herds on single large units.

. Biosecurity measures should focus on preventing the potential spread of infection throughdirect or indirect contact between cattle in adjacent or different herds, and isolating test-positive cattle prior to slaughter. Measures should focus on establishing good farmbiosecurity practices, and should include advice on creating effective boundaries between adjacent herds, reducing the potential spread of infective materials through practices such

as muck spreading, movement of farm staff, visitors and vehicles, and the potential for infection to be spread through farm shows and auctions. . In some European countries slurry must be treated to neutralise bTB before it is spread on land and this should be a requirement throughout the UK. . Approved Finishing Units should only be authorised to receive cattle from within the risk

area in which they are located, and exemptions removed to ensure all finishing units are subject to the same testing requirements and restrictions as other units. . Compensation payments to farmers should be clearly linked to compliance with inter alia risk-based trading practices, testing requirements, rapid and effective reactor isolation, and good biosecurity practices. Severe penalties should be applied in cases of non-compliance.

4 Are there any other controls you think we should consider to help meet the aims set out in this


. A policy of whole-herd depopulation should be used in all cases of long-term persistent infection or recurrent infection within herds. We understand that this has already been implemented in some instances but the policy should be formalised and applied automatically once appropriate criteria have been set and are understood by all stakeholders.

. Following whole herd depopulations, a mandatory minimum period of time before restocking with cattle should be implemented to allow for comprehensive decontamination of buildings, equipment and the general farm environment. During the national AES in the 1950s and 60s this period was set at six months but in light of the fact that bTB mycobacteria can survive in cattle faeces for up to six months and with the potential for persistence in the

worm population identified by Barbier et al then a period of at least a year would seem

more appropriate. . In all aspects of its advice to farmers regarding specific measures that need to be taken regarding the elimination of bTB, there needs to be some way of ensuring compliance otherwise the success of the plan could be jeopardised and/or the date by which success is achieved unacceptably delayed. There therefore needs to be an effective sanctions regime in place similar to that which ensures that tests are not missed.

. The Badger Trust regularly encounters an extraordinary range of opinions and

misunderstandings regarding the basic facts of bTB, how it is spread and even what the

current measures in place are intended to deliver. This situation has exacerbated a

polarisation of views often played out in the media but also within government and

internally among stakeholders. This has led in turn to differing sets of views becoming

entrenched to the point of ‘unshakeable belief’. Whilst not directly a ‘control measure’ the

Welsh Government nevertheless should consider ways in which this knowledge deficit can

be addressed so that all stakeholders are at least operating with the same set of facts. This is

of particular concern to the Trust in relation to what appear to be little more than myths and

superstitions regarding the role of badgers and bTB.

. One significant contributor to the problem of bTB seems rarely considered or ever acted

upon, namely the subject of immunity. The nature of the disease in terms of the lifecycle of

the pathogen and the reaction of the immune system of the host is such that while the host

cannot entirely rid itself of the mycobacterium, it can effectively render it unable or at least

difficult to spread. This is contingent on a healthy immune system response from the host,

which is in turn dependent on the health, welfare and nutrition of the animal in question.

It is widely recognised that poor animal health, poor husbandry and overcrowding are

significant risk factors for bTB yet it seems to be tolerated as ‘a fact of life’ for ‘modern’

farming. Clearly if this is allowed to continue then progress against the disease will be

severely hampered.

Fundamental to this is the important distinction between infected and infectious. Unhealthy

animals kept in poor conditions quickly become infectious and the rate of spread of the

disease accelerates. Healthy animals still retain the disease but whilst they will still test

positive at the same rate as unhealthy animals, the rate of spread will be slower and the rate

of eradication faster.

All practical measures to ensure optimum animal health should be taken including hygiene,

stress levels and diet. Minerals and trace elements such as selenium have been identified as

key to maintaining strong immune system performance and should be part of the feeding

regime for all cattle.

  1. We have asked a number of questions relating to specific proposals. If you have any other

comments on other aspects of the TB Eradication Programme, please set them out below.

Learning From Farms Without bTB – It is natural when confronted with a problem as serious as bTB

to concentrate efforts to understand the situation on areas where the problem is worst. However, in

order to really understand how bTB might be successfully tackled it is also essential to examine

those farms where bTB is not – and maybe never has been – a problem. There is clearly a great deal

to be learned by comparing a broad spectrum of farm level data between farms that never suffer

from bTB and those that suffer considerably. By identifying the differences between the two a ‘best

practice guide’ can be produced and circulated to all farms so that those that only rarely suffer from

bTB can join those that never do, and those that suffer frequently can set about clearing the disease

on a more permanent basis.

Cattle Slaughtered vs. New Herd Breakdowns – The reasons behind the increase in numbers of

cattle slaughtered in Wales due to bTB since mid-2014 need to be more effectively communicated to

farmers and the wider public. The document correctly emphasises that the increases are essentially

the result of improvements to cattle controls and the bTB testing regime (especially the increased

use of the IFN-. blood test). However, it is clear this information is being misrepresented by various

interested parties who claim that the increases show that the Welsh Strategic Framework, is ‘failing’

and are using this to call for wildlife interventions (namely culling badgers). The Welsh Government

should do all it can to robustly defend both its policy and record on bTB reduction to date, and to

explain why its considerable achievements so far will continue into the future.

Badger Interventions – Whilst the Welsh Government has rightly ruled out employing an ‘English

style’ badger cull there has nevertheless been some discussion on whether some form of badger

control might be considered in areas subject to high-level and persistent infection in cattle.

The Badger Trust’s position on this remains that there is little compelling evidence to suggest the use

of badger controls, even within such areas, would stand any chance of successfully reducing bTB in

cattle. Clearly vaccinating badgers reduces the level of infectious bTB in badgers but until there is

clear epidemiological proof of exactly how and to what extent badgers are able to re-infect cattle

then any intervention simply risks diverting attention and valuable resources away from mitigation

strategies that are known to work.

It is clear from recent analysis that levels of badger infection even within the Intensive Action Area

(IAA) in Pembrokeshire are low. The 2014 All Wales Badger Found Dead survey found that of c. 650

badgers tested only 6.6% tested positive for bTB, and even within the IAA none of the c. 30 badgers

found dead to date (2 results ‘pending’ at the time of publication of the Consultation Document)

were identified as being infected.

Clearly this indicates that baseline levels of bTB infection in Welsh badgers are very low. On top of

this it is necessary to make the important distinction between ‘infected’ and ‘infectious’. Not all bTB

positive badgers are necessarily excreting the disease. Healthy badgers will have neutralised the

mycobacterium in the normal way and will pose little if any risk to cattle. The Randomised Badger

Cull Trials (RBCT) from earlier this century identified an average of c. 15% of badgers testing positive

for bTB and 1.6% as ‘super excretors’. The base level for bTB positive badgers in Wales is lower (0-

6.6%) which suggests the number of badgers capable of infecting cattle is likely to be a fraction of

one per cent of the total.

The Welsh Government TB team has indicated elsewhere that it would only use clear evidence of

bTB infection before any intervention involving badgers was made, which of course would be

essential. This, however, raises all sorts of practical difficulties. Firstly, badgers must be trapped to

be assessed and this is not as straightforward as it seems. Even during the RBCT only c. 70% of

badgers were trapped and over time badgers become ‘trap shy’. Given the low number of infectious

badgers in Wales there would be a significant risk that these would not be trapped, thereby negating

the whole point of the operation. This is less of a problem when vaccinating badgers as the objective

is to increase the overall levels of immunity within the group. If the objective is to permanently

remove them then the risk of failure is high.

Notwithstanding that, once the badgers have been trapped the assessment of infection must be

made. It is widely accepted that the DPP trap-side test is insufficiently sensitive to rely on (c. 55%) so

further tests would have to be made in tandem. These would necessitate somehow marking badgers

for future recapture or simply hoping that they would be – which, of course, could not be


Any kind of intervention with badgers is fraught with problems particularly in terms of disturbing

their behaviour (perturbation). Despite years of study this phenomenon is not fully understood as

even low levels of disturbance caused by trapping can cause badgers to change their patterns of

behaviour and occupation of their territory. This makes it impossible to predict the outcome of any

intended intervention.

The reaction of badgers to selective culling is even more problematic. The age, gender and

dominance of individual badgers will affect the outcome of this kind of intervention in different

ways, as would the level of stress in the residual badger population. All of this is extremely hard to

predict and almost impossible to measure.

This in turn raises an apparent paradox concerning whether or not – or at least, to what extent –

badgers are responsible for spreading bTB to cattle. If one accepts that the risk is high then the

results the RBCT suggest that selective (‘reactive’) culling can be responsible for increases in cattle

infections, which would be entirely counterproductive. If one accepts that the risk is negligible then

there is little merit in intervening with badgers at all except perhaps to ensure their levels of

immunity to bTB are maintained at the highest levels possible either through vaccination or by easily

administered nutritional supplements.

Whatever the answer is, the fact that levels of bTB in Welsh badgers are very low means that the

amount of return on the ‘investment’ in badger intervention is likely to be both negligible and

undetectable in any case.

The only real problem posed by badgers is one of distraction. There is clearly a false perception

amongst many in the farming community and related lobbies that badgers are a ‘major source’ of

bTB infections in cattle, and this has led to some serious problems in their attitude to dealing

effectively with the disease. One often hears statements along the lines of, “there’s no point doing

anything else unless we get rid of the problem in wildlife,” for which they specifically mean badgers.

These beliefs are formed partly because of serious misinformation but also through a desire to

deflect attention from the obvious shortcomings of much of the way we farm and trade cattle in the


These perceptions have also penetrated the minds of policy makers and government departments

resulting in long overdue action on improved testing, movement controls, risk-based trading and

bio-security advice. However, many in the farming community still appear unwilling to accept this

and continue to demand ‘something is done about badgers’. This will continue to hamper progress

until all stakeholders accept that bTB is a cattle problem greatly exacerbated by current farming and

trading practices, and that it is only by concentrating all efforts on reducing the disease in cattle that

any progress be will be made in reducing the disease both in herds and in the wider environment.

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