TB Strategy Team
Department for Environment, Food and Rural Affairs
Area 104
1A Page Street
LONDON AWC 734
SW1P 4PQ

24 June 2004

Dear Sir/Madam

PREPARING FOR A NEW GB STRATEGY ON BOVINE TUBERCULOSIS

Thank you for the opportunity to comment on the proposed strategy for controlling bovine TB. Apologies for the delay necessary for discussions to take place at Council’s meeting on 14 June.

FAWC endorses the efforts being made to control bovine TB but would like to flag up for consideration some of the welfare problems that could potentially arise.

It is FAWC’s view that any new strategy affecting the handling, movement and even culling of cattle should have an animal welfare risk assessment carried out on it in order to recognise any potential welfare problems. For example, cattle subject to TB checks are exposed to more handling than would ordinarily be the case.

Should there be a vaccination campaign in the future then we would only re-iterate our advice given in our Report on the Foot and Mouth Disease outbreak in 2001, i.e. that there would need to be public reassurance that animals that have been vaccinated may appropriately and safely enter the human food chain (if this is the case). Public distrust of vaccinated animals could lead to animal welfare risks.

When reactors are identified on a farm no cattle can leave the premises, other than for slaughter, for a considerable time. This raises the issues of overcrowding, unsuitable housing and overwintering problems, particularly in upland areas. Any strategy should be clear about how the welfare issues associated with restricted movement will be considered. There is also the risk that abattoirs will not be willing to slaughter reactors which may result in longer transport time than might otherwise be necessary.

FAWC sees much merit, and common sense, in the biosecurity measure of isolating cattle brought onto the farm until they have been tested for bovine TB. This minimises risk to other cattle already present. It should be recognised that poor health is in itself a welfare issue and there is potential for suffering during incubation and manifestation of the disease.

Council would briefly raise the ethics of culling, balancing the values of life and purpose and the need for disease control. FAWC is not minded to come down on either side of this equation but asks that Defra note the issue when considering its strategy on bovine TB.

While not strictly falling within FAWC’s remit, comments have been raised on the potential cull of badgers. Concerns that we feel should be addressed by the strategy include:

With kind regards,

Yours faithfully

Judy MacArthur Clark