皇家华人and farming industry has seen several significant developments in TB policy, firstly the and the .
More recently, Defra consultations have further built on these proposals. The government鈥檚 bTB eradication strategy must continue to focus on eliminating this bacterium through proven and established policies as we enter the next chapter towards achieving a TB-free England by 2038.
Through the nature of this disease and policy area, the NFU recognises that both the disease and industry patterns change and as such has produced this working strategy that will remain live, regularly updated, and edited, to ensure our strategy focuses on what farming and food producers need to eradicate TB from this country.
Informed trading
This section outlines the need for more information to be provided to industry, fuelling an industry culture change, empowering, and enabling farmers to make far more informed purchasing decisions around the livestock they buy.
Once the industry has access to this information, trading principles may be established, which is when this information will be used to 鈥榤anage risk.鈥� It is important to differentiate the two objectives of having further information made available to industry and for this information to then be used to consequently influence an enforced RBT (risk-based trading) model.
Short-term recommendations
6/12 months
1. Information at the point of sale
Using the functionality of the LIP (Livestock Information Programme), the following information should be made available at the point of sale through official and validated data systems. This does not constitute a formal risk rating, but provides industry with more information then currently available.
The below information should be made available through the system.
- Ear tag
- Breed
- DOB (Date of Birth)
- Sex
- Number of Movements/Previous Holdings
- TB freedom (TB Free status expressed in years)
- Date of last TB test.
Future policy should ensure that this information can be accessed simply by the prospective keeper at or before the animal鈥檚 sale.
Information should be available to support all forms of transaction or movement i.e. farm to farm, agent/dealer, live and electronic auctions. Opportunities should be presented through the introduction of the new Livestock Information Programme and Bovine EID implementation.
2. Availability of information
The provision and availability of information should be mandatory. This requires regulation change to facilitate.
3. Promotion of bio-security measures and responsible trading
Through a government and industry partnership, the NFU would like to see greater uptake of AFU/LFU (approved/licensed finishing units), building on the table below, to create a robust supply chain.
Longer term, further evidence is required to demonstrate to industry how other bio-security measures can reduce a producer鈥檚 risk.
Total number of AFU/LFU units
(*Update pending)
| Unit type | 2017 | 2018 | 2019 | 2020 | 2021 |
| AFU grazing | 97 | 90 | 71 | 58 | 36 |
| AFU non-grazing | 256 | 271 | 275 | 291 | 287 |
| LFU | 42 | 44 | 44 | 47 | 48 |
Government policy for finishing units needs to provide long-term certainty that will encourage producers to invest.
This should be driven by clear operational and licensing conditions which avoid loading unnecessary costs onto the producer. Our asks, illustrated through the GB Calf Strategy bTB subgroup, demonstrate a clear solutions to deliver on this objective.
皇家华人TB Advisory group fully support bio-security measures being promoted through small grants and similar schemes, these measures are beneficial to many policy objectives in addition to TB eradication.
4. Further developing
While the NFU feels ibTB is a useful tool, due to the time lag and often poor quality of information (for example holding information), there is limited confidence in the service.
The industry welcomes steps to increase transparency, however, the NFU needs to understand ibTB鈥檚 involvement in the future presentation of greater information, for example displaying further TB information, such as 3km radial zones.
In time, the NFU hopes ibTB will provide a platform for the information generated through the LIP to be displayed, while utilising data from other new technologies coming to market, such as whole genome sequencing.
Medium-term recommendations
12/24 months
1. Drive a culture change in policy delivery on farm (currently administered by the APHA)
This is the foundation for 鈥榞rass roots鈥� farmer confidence within the bTB eradication strategy. This includes ensuring correct resource is placed within APHA to deliver the level of service required through communications, advisory services and on farm visits (including testing).
The current farmer experience is frequently resulting in negative encounters, affecting farmer confidence. The farming industry continues to call for an improved service for effective policy delivery.
An updated communication plan, ensuring detailed guidance notes and effective materials for farmer communication are available. Initial proposal from the NFU on interferon Gamma testing provides an example of possible improvements.
皇家华人supports the role of a TBAS (TB Advisory Service) and wants to further understand the impact of TBAS in TB eradication, through a cost/benefit analysis.
2. Mandatory information at the point of sale.
To monitor and review industry practice and provide incentives or further changes to regulation to achieve the outcome of displaying information.
3. Detailed analysis
Provide the agricultural industry and stakeholders with far more detailed information and analysis on livestock movement profiles at a local and national level, allowing industry to quantify and further understand the apparent and perceived risks of different movement profiles and patterns.
4. To create a new way of working
Current and future policy should be discussed alongside up-to-date evidence of the functionality and cost basis with industry, creating a true co-delivery approach.
Until far more information is collected, presented effectively, and shared regularly with industry, bTB will remain a government-owned policy and will not engage industry in true partnership.
Long-term recommendations
24 months +
皇家华人would consider further measures to provide information following:
- Accurate and timely data being provided on an individual animal basis at the point of sale, on a mandatory basis.
- Successful policy implementation, through well-resourced delivery teams.
- Industry access to all relevant information to assess and critique future government policy proposals at an early stage.
皇家华人strongly recommends that a comprehensive review of the current RBT model of the High-Risk Area/Edge/Low Risk Area should occur, evaluating the approach and geographical areas used before any further changes to RBT models are implemented.
A comprehensive review of the CHECS (Cattle Health Certification Standards) policy for bTB. The current policy disengages many parts of the farming industry from even considering the scheme.
Some farms will never be able to achieve CHeCS certification due to geographic constraints out of the farm鈥檚 control 鈥� there must always be a viable and equitable alternative to CHeCS in the bTB policy suite.
Surveillance and diagnostics
The testing and surveillance tools used to find bTB within our herds are incredibly complex.
The farming industry must be able to take advantage of new and developing scientific diagnostic innovations in our disease testing regime.
These could involve using known tests under different circumstances or using new tests as part of the diagnostic arsenal. The priority must always be to resolve outbreaks effectively and quickly, minimising risk of outward disease transmission and reducing the financial burden on the farm business.
Short-term recommendations
6/12 months
1. Effective policy delivery
As mentioned in other sections, effective policy delivery (currently administered through APHA) is absolutely pivotal to the success of current and future policy.
Bovine TB testers (whether veterinarians or 鈥榣ay鈥� testers) must provide a stringent official service in the interests of disease eradication; no exceptions should be tolerated.
As such, the NFU supports using systematic data analysis to achieve targeted APHA field audits, focussing resource on those veterinary professionals demonstrating the greatest anomalies or variation.
2. Terminology
The current terminology regarding TB status is difficult to understand and confusing. The terms OTF (officially bovine tuberculosis free status), OTF-S (officially bovine tuberculosis free status suspended) and OTF-W (officially bovine tuberculosis free status withdrawn) causes confusion for some members; this should be simplified. There are some good examples of effective communication and terminology evident within our industry, such as Johne鈥檚 disease scores which could be utilised.
The communication with farmers regarding 鈥楾B Confirmed or non-confirmed鈥� should also be simplified, to remove unnecessary industry confusion.
皇家华人is supportive for the move away from today鈥檚 tuberculin, to ensure even greater consistency, replacing this mixture with defined antigens is one prominent proposal.
3. Continue to develop a broader range of statutorily available tests
This is to ensure disease is found, and dealt with quickly and appropriately utilising local veterinary advice. Any identified reactor must be recognised and compensated for through the cattle compensation order.
Regulation should allow this to be complimented by optional additional private testing.
4. Bespoke disease management plan
For herds under restriction, a bespoke disease management plan developed in conjunction with the cattle keeper and veterinary professionals should be included, facilitating necessary discussions surrounding available tests and how best to remove infection from the herd.
It is crucial that data is shared between government systems, farmers and private veterinary professionals going forwards.
4. Radial testing
皇家华人calls for an adjustment to current policy for radial testing within the LRA and supports complete movement restrictions from notification until testing (removing the 28-day movement window); herds should be restricted until testing demonstrates a clear outcome 鈥� greater communication of pre-movement testing responsibilities in this period should be included in government guidance.
This policy must be combined with a more logical approach to radial testing, ensuring that holdings are in a cycle of six monthly testing, as opposed to a sporadic approach of letters and testing sequences. Measures to promote earned recognition as well as a move to annual testing for those continually exposed to radials, should be explored.
5. Reactor removals
Having inconclusive reactor cattle on farm significantly increases the risk of having a further breakdown at a later date. 皇家华人supports more IRs being compulsory slaughtered to eradicate disease from herds, in areas or populations where vets believe it would improve the chances of containing the disease.
A period of up to 10 days can be used for reactor removals once an animal is declared a reactor on farm (practically this period can be a lot longer with some farms experiencing delays of several weeks); this should be shortened to a maximum of one week, reducing the burden on the keeper and the risk of this animal further spreading disease.
6. Compensation
Utilising the tool of compensation to further promote best practice or penalise perceived 鈥榬isky鈥� behaviour has been discussed.
皇家华人remains supportive of compensation as a clear payment to compensate for the loss of the animal from the herd. While measures to promote best practice should be encouraged, any financial penalty or incentive should not impact the statutory payment to compensate for an animal, as this risks a range of unintended consequences, such as incentivising poor compliance.
7. Risk assessments
Up to date risk assessments are critical to the success of the bTB eradication strategy and to ensure the confidence of key stakeholders such as the farming community. 皇家华人calls for Defra to provide an up-to-date risk assessment for key species, in particular Camelids, wild deer, and sheep.
8. Statutory requirements on Camelid keepers
For Defra to review (given evolving trends) the statutory requirements on Camelid keepers, with an express concern that they may be becoming a maintenance host in areas of otherwise reducing infection.
Medium-term recommendations
12/24 months
1. Tests
A variety of new and adapted tests present opportunities to incorporate within future policy. 皇家华人requires further evidence as to the quality of these tests, within English conditions, before the NFU would support further use.
It is important to note that policy delivery is critical, the NFU would require clear signs of current successful policy implementation, such as ensuring pre/post movement testing compliance rates are within a small margin of 100%, before any of these introductions are considered.
2. Holistic approach
A holistic approach to the bTB eradication policy is needed, introducing a suite of measures to deliver effective disease management and prevention. An annual cost/benefit analysis review of post-movement testing within the Edge area should be considered to ensure proportionality as a control method.
This policy should complement measures that are put in place to enable control of the disease in all vectors. The highlighted that a high percentage of new TB incidents, across all risk areas, had no evidence of cattle movements suggesting a high local reservoir of disease (Edge Area 52%).
Introducing further cattle controls before addressing this source of infection is a severe failing of government policy, for the farming industry, the bTB eradication strategy and the taxpayer.
3. Faster re-definition of geographical areas
It is critical to adjust quickly to the geographical spread of the disease. A flexible approach, which does not require formal consultation, would enable more adaptive disease management, and allow a stronger focus on the Edge area - a major concern for farmers attempting to eradicate bTB.
This would require comprehensive communication between the government and industry to ensure the implications are well understood by all parties, such as through local TBEGs (Tuberculosis Eradication Groups).
4. Slaughterhouse surveillance
Raising awareness within slaughterhouse inspection teams and utilising statistical analysis to further target audits within slaughterhouses would ensure the best possible compliance with slaughterhouse surveillance across the country, ensuring as much disease as possible is found, monitored, and removed.
Long-term recommendations
24 months +
During breakdowns, herds are heavily regulated to ensure the breakdown is effectively managed. Providing slight regulatory freedoms to enable farmers to take on more testing, utilising voluntary private tests to enable herd management decisions, would further the potential removal of bTB from the herd.
皇家华人supports the recommendation of an 鈥榚arned recognition鈥� licensing approach, providing this approach is practical, logical, and developed in partnership with key industry stakeholders, such as the NFU.
Embracing technology, through wireless callipers, would again be seen as positive and reduce human inconsistency, however this would have to be understood / balanced against the costs involved.
Wildlife control
The aim of this page is to set out the NFUs strategy towards eradicating bTB, a bacterium.
It is accepted that , making badger control a key part of the bTB eradication strategy within England.
The highlights badger control as 鈥榓n important option to help in controlling disease鈥�, within the Defra response to Godfray, the success of this policy is confirmed, quoting the .
A recent concluded that, on average, a 56% reduction in herd incidence is achieved in the fourth year of culling. The removal of individuals from an infected population (culling) is a common and vital strategy used to eradicate diseases across the globe.
Badger vaccination cannot be used as a direct alternative to culling and evidence is needed to provide the NFU and wider farming industry confidence that badger vaccination has any effect in reducing bTB in cattle, before proving its ability for delivery at the necessary scale, cost-effectively.
The references an ambition to begin phasing out culling, gradually replacing this with government supported badger vaccination and surveillance.
皇家华人supports using all effective tools in bTB eradication, but all policymakers and stakeholders must acknowledge that vaccination and culling do not achieve the same outcomes.
As such, the NFU is clear that badger culling must remain the principal means of controlling the spread of bTB infection from badgers, in areas of high or rising infection. Any transition or adaptions from the recognised wildlife culling procedures should be consulted on with industry before proposals to end current measures are enacted.
Short-term recommendations
6/12 months
1. Year-round information
Government publications on bTB should be issued throughout the year and not withheld to create so called 鈥榖TB moments鈥�. This should be combined with a longer-term strategy, discussed within the governance section.
2. Maintain the existing bTB eradication approach across England
This should incorporate existing Intensive and Supplementary Badgers Controls until an independent review of the bTB strategy is completed. The additional evidence base that will be gained from the new areas moving into SBC (supplementary badger control) further demonstrate its effectiveness.
3. Targeted badger control
Ensure targeted badger control is accessible within the long-term eradication strategy.
4. Transparency on badger vaccination
Further transparency from the government regarding where badger vaccination has been licenced should be published.
Any licensed vaccination areas should meet strict licensing criteria, equal to culling licence conditions. Providing clear evidence as to effort, results, and cost. This will also build evidence to inform future policy as to the role of vaccination within the bTB eradication strategy. Such evidence may include details of:
- Level of land access 鈥� to ensure the policy provides a meaningful contribution.
- That a sufficient proportion of badgers have been vaccinated.
- Evidence of cattle farmer participation.
- A clear and comprehensive cost/benefit analysis.
5. Review KPIs
Using evidence from existing culls, consider whether the KPIs used to judge effectiveness are relevant and appropriate.
6. Timely evidence
Timely evidence surrounding the interaction between farmed livestock and badgers is critical to understanding the implementation of disease hotspots.
The current methodology of collecting roadkill badgers is slow, heavily reliant on stakeholder interaction and often provides poor quality evidence. 皇家华人calls for a stronger survey system, commissioned and funded by the APHA or alternative government department, to establish a clear indicator of disease pressures within the wildlife population, as quickly as possible, minimising the risk of disease transfer and allowing an appropriate solution to be delivered.
The statement in the Defra response to Godfray 鈥榗ulling would remain an option where epidemiological assessment indicates that it is needed,鈥� further exaggerates the need for a clear system, to provide timely, independent, and accountable information to both industry and government.
皇家华人continues to call for further information to detail how epidemiological led culling will be utilised in the future and reinforces the call for detailed information from Defra, to provide confidence to the farming industry before any current wildlife control policies or systems are adapted or removed.
Medium-term recommendations
12/24 months
1. Licence new cull areas
Natural England must continue to licence new cull areas where there is a need to deal with bTB, utilising all relevant evidence that indicates there is disease within the badger population.
Utilising wildlife control within the Edge area must be prioritised to prevent further disease spread.
2. Build upon 鈥榟otspot鈥� methodology
Further review or trial the targeted removal of badgers around an epidemiologically defined area, building upon the successful 鈥榟otspot鈥� methodology.
3. Research into TB prevalence within the badger population
皇家华人supports further research into TB prevalence within the badger population, to assist the development of a targeted strategy for disease control in each risk area.
4. Badger vaccination
The Defra response to Godfray addresses various badger vaccination schemes. Before any such pilots are considered, the NFU requires clear evidence of:
- The relationship between vaccinating badgers and the level of TB incidence within cattle 鈥� whatever vaccination models are used (complementary, cordon sanitaire, etc.)
- A clear and deliverable model for administering badger vaccination within large scale projects.
- Transparency as to how these projects would be funded and what organisations would lead these vaccination projects.
- Official cost/benefit analysis on the role of badger vaccination within theb TB eradication strategy 鈥� a requirement identified within figure 3.1 of the Defra response to Godfray.
皇家华人notes the activity in East Sussex, hosting a largescale trial badger vaccination area.
皇家华人is supportive of utilising this area to clarify several of the above concerns as to whether badger vaccination could be an effective tool to eradicate bTB. However, the NFU does not support any transition away from badger culling (an evidenced and proven part of the eradication strategy within the HRA and Edge area), until this trial has been proven to offer a deliverable, cost-effective policy option that reduces bTB incidence in cattle.
5. Research
More information needs to be made available to the NFU and industry about how the disease self-sustains in the badger population, including further research into the impact of badger densities.
6. Cost-sharing measures
Further consideration of cost-sharing measures between government and industry, which will encourage farmer sign up to wildlife control in areas with lower cattle densities but high levels of disease, such as within parts of the Edge area.
7. Test, Vaccinate or Remove results
Further information following the results from TVR (Test, Vaccinate or Remove) used in Northern Ireland as well as similar programs in the Republic of Ireland post-culling. This will aid understanding of whether these approaches could be used within England and whether badger density is a key factor in this decision-making process.
7. Landowner engagement
Defra should increase its engagement with significant landowners and NGOs, to allow the eradication strategy to be rolled out across land under their control.
Further promotion of the evidence and science base will enable farmer tenants to choose the most appropriate control measures for their own business and the local area, as well as offer support to these organisations to join farmer led groups.
8. Analysis of wider wildlife population
Further analysis into bTB within the wider wildlife population to build an understanding of the significance within localised areas, for instance in deer or other non-bovines.
This must be underpinned by a reliable government funded collection service for the carcases of wild animals found, to ensure reporting, enabling up to date information alongside the removal of a potential infection source from the local environment.
Long-term recommendations
24 months +
Support the work of the NFU by continuing to build evidence to understand the impact of a reduced badger population on the wider ecological area, including building upon the early evidence of increases in hedgehogs and bumble bee populations.
Governance structures
The governance systems used to manage and ultimately control bTB are absolutely crucial to the 2038 eradication policy.
皇家华人has and will always, remain committed to an evidence-based policy that delivers on the eradication of this disease.
Decisions regarding the Derbyshire cull area caused huge uncertainty, with this decision eroding the confidence in the government鈥檚 bTB strategy within farming communities across the country.
If a government/industry partnership is to successfully eradicate this disease, key decisions, following the science and evidence, need to be taken in a timely fashion with agreement from both parties.
Short-term recommendations
6/12 months
1. Stronger network
皇家华人supports encouraging a stronger local and county network of farmer meetings, alongside government officials to build relationships and improve knowledge transfer at a 鈥榞rass roots鈥� level.
Clear terms of reference and objectives must be set down to ensure that such meetings have purpose and can demonstrate benefit to the farming community.
Add additional resources to help fund such meetings. Avoid disrupting current groups by installing new processes.
2. TB advisory service
皇家华人supports the concept of a TB advisory service and wants to further explore the impacts of initiatives such as TBAS in bTB eradication, through data and particularly cost/benefit analysis.
Engage and build a more consistent service from PVS (Private Veterinary Surgeons) to assist this process, utilising initiatives such as having a bTB ambassador in each practice could be a positive way of achieving this outcome.
3. Consultation fatigue
皇家华人recognises the key point made in the Godfray review, focussing upon 鈥榗onsultation fatigue鈥� 鈥� the NFU feels a far better method of engaging with industry could be achieved. 皇家华人is supportive of a wider strategy and commends the Godfray review process, to seek views of key principles and broad strategy, while utilising consultations to confirm details.
Consultations should continue to be used to finalise detailed policy, however these should be planned and clearly marked within a broader five-year plan from the government. This should have cross party commitments to ensure the continued eradication of the disease, regardless of the political party.
It is important to stress the need for a standardised consultation process, taking due account of national bodies and their constitutional accountability and strategic view upon policies.
4. Farm assurance
皇家华人notes that through various proposals within the Godfray review, farm assurance is discussed as a mechanism to change farmer practices. 皇家华人sees no place for assurance schemes within a future bTB governance model.
Red Tractor, for example, is a voluntary Food Standard that promotes food quality, traceability, and provenance.
Medium-term recommendations
12/24 months
1. Simplify operational processes
There are severe challenges in removing high-level policy decision making from Ministers. However, devolving much of the disease control operations to a new body that would be more efficient and synchronised compared to the current APHA, Defra Policy, Natural England, and Local Authority system, would provide multiple advantages.
皇家华人would support measures to simplify operational processes and provide a better service back to farmers, while delivering a more cost-effective policy to the taxpayer.
2. Farmer/veterinary relationship
皇家华人supports measures to further develop the farmer/veterinary relationship. Exploring options to provide more post breakdown advice, traditionally administered by APHA vets, would require more resource (in some form), to assist an often-stretched APHA team.
3. A bTB implementation forum
皇家华人believes that more can be done to drive the necessary mechanisms to enable the culture change to be TB free by 2038. Supporting measures to further develop an industry/government partnership approach.
Building industry confidence in Defra鈥檚 policy is critical.
It is the NFU鈥檚 view that only those invested in tackling the disease should have a seat at the table; the group must remain focussed on eradicating a devastating disease from this country, while maintaining a viable and sustainable farming sector.
4. Transparent compliance regime
While we have called for a flexible approach within a farm management structure, we must ensure the compliance regime is transparent, understood by all and is carried out with consistency, addressing any poor compliance.
This approach needs to be taken across the policy area 鈥� covering the variety of legislation impacting upon bTB eradication.聽
5. Promotion of positive procedures
Future systems should encourage as well as penalise producers, outside of the compensation order.
For example, a flat rate payment for AFU/LFUs could be provided, due to the reduced government costs of surveillance testing and continuation of industry trading profiles.
4. Penalising non-compliance
Different channels should also be considered for penalising non-compliance, past the current cross-compliance procedure. This could include preventing any trade in livestock until non-compliances have been rectified.
皇家华人is supportive of utilising licensing to differentiate producers through earned recognition, a concept that could have numerous beneficial outcomes. As the Godfray review highlights, this could then allow greater flexibility in utilising alternative tests, for example, allowing the farmer and local veterinary lead far more flexibility and ownership of on-farm disease eradication.
Long-term recommendations
24 months +
皇家华人calls for a continuation of a rigorous enforcement regime post Pillar One payments, to ensure compliance continues within the medium to long term.
Biosecurity in all its forms is a key driver of enhanced animal health and welfare, productivity improvements and a factor in meeting our net zero ambition, whilst also being a key contributor within any disease eradication strategy.
Future policy should recognise positive biosecurity measures and proactively reward those undertaking them.
It is imperative this reward goes to those already undertaking measures, as well as those looking to improve businesses.
It is critical to note that while reviewing other countries鈥� governance systems for eradicating bTB, there have been some very successful changes to governance structures.
鈥�Whether full industry ownership of the disease in cattle is possible when government determines the policy on control in wildlife is not clear.鈥�
Godfray review, 2018
Such an example is New Zealand, where more responsibility and cost is placed upon industry.
However, that transition of authority and cost will always be incredibly challenging while protections are still upheld within the wildlife population, with little evidence to suggest any success.
The Godfray review directly references this severe barrier to change: 鈥榃hether full industry ownership of the disease in cattle is possible when government determines the policy on control in wildlife is not clear.鈥�
Cattle vaccination
CattleBCG vaccination is emphasised by Defra and ministers as a crucial element in their five-year bTB eradication plan for 2025, garnering optimism from the veterinary and farming sectors.
皇家华人believes this impending milestone is unrealistic with uncertainty persisting following Defra鈥檚 announcement of a third phase of the UK field trials in March 2024 to provide further data and options on the DIVA (Detect Infected among Vaccinated Animals) test.
Both veterinary and livestock industries seek consistent collaboration with the government to manage farmer expectations and ensure a successful future policy. 皇家华人stresses the need for a comprehensive understanding of the supporting evidence and effectiveness of future policy options to progress strategic goals.
Disclosure at the earliest opportunity allows the necessary time to deliver effective and realistic communication to our members.
Short-term recommendations
6/12 months
1. Trial results
Results from phase two of the UK field trials should be made widely available at the earliest opportunity, including evidence submitted for marketing authorisations.
Clarity is required on Phase Three goals, participation criteria, testing strategies, key performance markers including a revised realistic timeline for completion and authorisations to transition into deployment phases.
2. Transparency on selection criteria
Enhanced transparency from the government on any selection criteria, operational planning, economic assessment, future funding transition, significant milestones, and established timelines.
A clear explanation of fully/partially/individually funded vaccination is crucial to prevent farmer disengagement, and these details must be disclosed in any consultation process.
3. Budget
Both APHA鈥檚 budget and Defra鈥檚 long-term funding of the bTB eradication strategy must be sufficient to deliver all that is required and have resilience built to cope with inflationary pressure on expenditure.
Government subsidy for APHA-delivered cattle vaccination during the 鈥榩roof of concept phase鈥� is imperative until knowledge gaps are addressed and resolved through live evaluation and monitoring.
4. Careful consideration of consultation outcomes
Defra should prioritise careful consideration of consultation outcomes, avoiding premature positive narratives and allowing adequate time for a well-considered approach.
Balancing engagement and acceptance are challenging in time-sensitive grassroots communications with numerous unanswered questions, and immediate support from producers cannot be guaranteed; it requires thoughtful deliberation over an extended period.
5. Unintended trade consequences
Industry and supply chain have repeatedly highlighted the need for robust assurances that unintended trade consequences, both nationally and internationally, have been thoroughly analysed and addressed.
Outcomes from Defra鈥檚 engagement with WOAH (World Organisation for Animal Health) and trading partners on their acceptance of both CattleBCG and the DIVA test must be communicated to stakeholders, supply chain and industry promptly.
There is a high risk that any perceived negative impact on processing or selling products will undermine future policy. The importance of this engagement cannot be overstated.
Medium-term recommendations
12/24 months
1. Acceptable threshold for vaccine efficacy
For farmers to consider taking up vaccination for their herd they must trust in the evidence, effectiveness, and efficacy of the vaccine and be reassured uptake will not result in negative impacts to their business.
Establishing an acceptable threshold for vaccine efficacy is essential.聽
2. Clear producer purpose and benefit
APHA to define a clear purpose and benefit to the producer for vaccination in the proposed initial deployment area.
Disseminate concise, digestible information to the industry through trusted partners capable of offering appropriate, risk-based guidance to farmers. Additional information and guidance are needed on the administration of BCG alongside other vaccines.
3. Review of 90-day meat withdrawal
Potential challenges, like those related to the fifth quarter, may persist beyond the initial phase, affecting carcass values.
Concerns about a two-tier system could discourage farmers from opting in for vaccination. A review of the precautionary mandated 90-day meat withdrawal outlined in marketing authorisations for UK field trials is necessary.
Statutory compensation should be explored if farmers face financial penalties due to the inability of a vaccinated animal to enter the food chain if it remains in place during the initial deployment phase.
4. Voluntary uptake
Until the benefits of cattle vaccination in different epidemiological environments are truly understood and supported by robust science and evidence within the bTB eradication strategy uptake should be voluntary.
5. Testing challenges
The potential coexistence of vaccinated and unvaccinated cattle may create testing challenges. A comprehensive understanding of the diagnostic capabilities of the DIVA test is essential, especially in conjunction with any adjustments to testing protocols for herds transitioning to partial or full vaccination.
6. Funding model
A robust and clearly defined funding model needs to be developed for all phases of deployment. The time limit for funding must be established before commencement so the industry understands when/if they will start paying.
Long-term recommendations
24 months +
Before considering initial deployment, the government must establish and secure resources for the vaccine delivery method, ensuring protection against the risk of reallocation during outbreaks of other notifiable diseases, as observed with recent AI/BTV3 incidents.
If/when delivery encompasses farm vets, it must be recognised that there is already a shortage in the industry and the current Veterinary Surgeons Act prevents Vet Techs from delivery. 皇家华人supports proposed changes on the role of Vet Techs and continues to ask the government to expedite legislative change which may support the use of an exemption order.
Funding should encompass both the vaccine and its delivery. In the veterinary partnership, financial viability is crucial for engagement, as demonstrated by vets opting out due to the non-viability of delivering TB testing. Ensuring the financial feasibility of vaccine delivery is essential for veterinary partners' active participation.
Farmers in the LRA bordering the Edge area may be interested in vaccination to protect their herds from bTB, they may be willing to pay for it themselves as an insurance policy. This may only be possible after the 鈥榩roof of concept鈥� stage.
聽Cattle vaccination must be depoliticised, a change in government must not interfere with vaccine roll out and there must be a clear exit strategy.
Research and development
皇家华人supports a continued, consistent approach to the research and development budget.
This should be based upon tangible cost benefit analysis, to ensure the eradication measures that offer the greatest improvements in bTB eradication are prioritised and brought to the market as soon as possible.
Suggestions through the Godfray report, such as a tuberculin improvement, are just one such example. Within the longer term, offering resource for cattle vaccination is imperative.
With the DIVA test becoming available to industry, bringing cattle vaccine to market could have numerous advantages for the eradication strategy. However, industry needs to understand a realistic time scale to bring this to market, including the time to implement the necessary research requirements and the time and costs associated with gaining approvals from trading partners and organisations.
Summary
This page provides a vision for bTB eradication with key calls from the NFU.
皇家华人strongly suggests that the policy recommendations be considered a foundation for a longer term approach, with government working alongside industry to build an improved and trusted relationship, where all involved have the key focus of eradicating this disease from the countryside.
皇家华人reinforces our ultimate aim to eradicate this disease by 2038, whilst maintaining and enhancing a vibrant and sustainable livestock industry, free from bTB.