Committee Reports > List of Committees > Dáil > 1986 > Committee on Public Expenditure > Report - Review of Public Expenditure for the Eradication of Bovine Tuberculosis

APPENDIX II

Letters from the Clerk to the Committee

30 August, 1985.

Mr. P.M. Judge,

Clerk of the Committee on Public Expenditure,

Leinster House,

Dublin 2.

Dear Mr. Judge,

I refer to your letter of 24th July 1985 and to previous correspondence concerning the cost of the Bovine TB Eradication Scheme and the lack of progress under that Scheme.

A comprehensive review of all aspects of the Scheme was carried out during 1984. Because of the failure to make any significant advance in TB eradication in recent years, the Government, in the National Plan “Building on Reality 1985/87”, cited the final eradication of bovine TB as an urgent priority, and provided additional funding for the eradication programme for the duration of the Plan. The allocation of these funds, however, was made conditional on the introduction of a number of radical reforms in the Scheme, including

-direct Department of Agriculture nomination (rather than farmer nomination) of veterinary surgeons to carry out all Scheme testing;

-testing fees to be paid direct by the Department to the veterinary surgeon who carries out the test and who will be personally responsible for its proper execution;

-payment of reactor grants to be made conditional on removal of reactors for slaughter within a maximum of ten days;

-tight official supervision of all trading at marts;

-strict enforcement of all procedures and prosecution in all cases of detected breaches of disease regulations;

-establishment of a central Epidemiology Unit in the Department of Agriculture to co-ordinate and assist in the analysis of disease outbreaks, prevention of disease spread, etc.

These changes have been implemented under the 1985 TB eradication programme which is currently in progress and will enable it to be carried out on a more effective basis than heretofore. In addition, the legislation governing bovine TB is being examined and updated at present with a view to eliminating any existing weaknesses.

In chronically infected herds, where the approach of repeat testing and removal of reactor animals has failed to eradicate the the intention is to encourage depopulation of the Government’s decision to include in its funding a stock replacement should promote the depopulation while the Depopulation Fund Scheme itself has been improved.

It is believed that the above-mentioned measures form the a successful eradication strategy. Given the necessary co-operation from the various parties involved, they should real impact on disease incidence levels and begin to furnish a on the massive investment made in the TB Scheme over the years.

Yours sincerely,

(G. Fogarty)

Assistant Principal Officer.

20 September, 1985.

Mr. P. M. Judge,

Clerk to the Committee on Public Expenditure,

Leinster House,

Dublin 2.

Dear Mr. Judge,

I refer to your letter of 13 September concerning the Bovine TB Eradication Scheme.

Progress under the Scheme is measured largely on the basis of detailed returns furnished to Headquarters by the twenty-seven District Veterinary Offices located around the country. These returns, which are forwarded at the end of each month, include such information as the number of herds in each county; the number of herds tested; the number of herds and animals disclosed as reactor; the number of tests, including retests and check tests, carried out to date under the current testing programme, etc. From these returns can be calculated the number of restricted herds and the percentage herd prevalence of the disease on a county and national basis.

In addition, quarterly returns are furnished showing the numbers of reactors slaughtered and the incidence of TB lesions in reactor and non-reactor cattle slaughtered at registered meat factories.

The disease picture which the above-mentioned information provides enables the Department to pinpoint counties or areas where additional measures, such as intensification of testing, may be required to combat the spread of infection.

I hope this information will be helpful to you.

Yours sincerely,

(G. Fogarty).

Assistant Principal Officer.

4 November, 1985

Mr. P. M. Judge,

Clerk to the Committee on Public Expenditure,

Leinster House,

Dublin 2.

Dear Mr. Judge,

I refer to your further letter dated 4 October on the Bovine TB Eradication Scheme.

Any assessment of progress under the Scheme, including the question of setting targets, should have regard to developments in the recent past. In the mid-seventies, following a dispute between private veterinary practitioners and the then Minister - connected with the Minister’s wish to engage lay blood samplers on the Brucellosis Eradication Scheme in the interests of economy and efficiency - testing on the BTE Scheme was suspended for eighteen months as a consequence of which the incidence of bovine TB had increased sharply viz. to 7.5% of herds by the end of 1977. Full round testing had resumed in the Autumn of 1976 and the priority from 1977 onwards was to reduce the high disease incidence in the shortest possible time. Considerable progress towards this end was made over the following years - in 1979, ‘80 and ‘81 disease incidence on annual round of testing was 3.95%, 2.94% and 2.11% respectively.

In June 1982, at the conclusion of the 1981/82 round of testing, the level of infection was found to have increased to 2.76%. In the light of this setback, it was decided that, rather than proceed with the following a special six-month programme of blitz testing should be launched in the worst-affected areas. Following this intensive testing, concentrated on herds at greatest risk, the incidence had increased to 3.16% by the end of 1982. It is to be expected that disease incidence rises in the immediate aftermath of intensive testing in difficult areas. Full round testing resumed in the Spring of 1983 and an incidence of 2.24% was recorded at the end of this round, i.e. March ‘84. The ‘84 programme was, however, curtailed to about two-thirds of herds tested because of the reduced (to £21m financial allocation that year and at the end of 1984, TB was identified as present in 2.77% of herds in the country. It was clear at that stage that, if further substantial progress were to be made in eradicating covine TB, important improvements would have to be made in the operation of the Scheme. These improvements were announced by the Government in the National Plan and accompanied by a decision to commit substantially increased funding (£85.5m) over a three year period in an intensified effort to eradicate the disease. Details of the improved procedures were given in my letter of 30 August.

The question of direct nomination by the Department of the Veterinary Surgeon to carry out testing, rather than by the farmer as hitherto, gave rise to a further dispute with the representative body for private veterinary practitioners. Following the resolution of this dispute in May 1985 the Minister was in a position, for the first time, to envisage a medium-term strategy at least up to the end of 1987 and begin a fresh campaignat eradication of the disease over this period. The first in June and scheduled to continue up to March 1986, of the disciplined programme is progressing well, and herd had been tested up to the end of September.

The assessment of progress must also have regard to the diversity circumstances at local level. The disease eradication programme through twenty-seven District Veterinary Offices throughout the country, The disease picture varies considerably from county to county, depending on factors such as the number and structure of cattle herds, the type of terrain, fragmentation of holdings, existence of commonage, inadequate boundary fencing, etc. An essential part of the current programme involves a careful assessment by the Veterinary Officer in charge of each Office of the disease situation in his county and the preparation of a programme of testing to suit local conditions. These programmes must take account for each area of the pattern and prevalence of disease and the financial and manpower resources available, both from the Department’s veterinary staff and private veterinary practitioners. Each local plan is subject to ongoing review, in consultation with senior Veterinary Officers of the Department, in the light of results achieved as the round progresses. The objective at local level in the course of this round has been the organisation of resources so as to make the maximum impact on reducing disease levels. Specific targets have not been insisted on though of course the Veterinary Officers are aware of the progress that should be made in their areas of responsibility. The question of setting targets for each county and for the country as a whole will be considered when we are in a position to assess thoroughly the results of the first round of the current three-year programme, now being conducted under the newly introduced and more satisfactory conditions. This assessment will take place towards the end of this year and early in 1986.

Yours sincerely,

(G. Fogarty),

Assistant Principal Officer

15 November, 1985

Mr. John Mc Carrick,

Adviser to the Committee on Public Expenditure,

Leinster House,

Dublin 2.

Dear Mr. Mc Carrick,

I refer to your telephone call of 13 November concerning the Bovine TB Eradication Scheme.

When an animal is found to have TB lesions at slaughter, the herd from which it moved is placed under restriction and remains so until it has passed two consecutive tests. Previous herds (if any) to which the animal belonged are traced where possible and these herds are subjected to a check test if they have not been tested since the slaughtered animal moved out of them.

In relation to the Epidemiology Unit, I may have given the impression that its membership included people from outside the Department. The position is that the members of the Unit are attached to this Department within which they also have other areas of responsibility.

Finally, on the question of the restriction of herds, I might mention that a herd may be placed under restriction for reasons other than the disclosure of reactor animals, e.g. a dealer’s herd where the presence of infection may be suspected, or in the case of a herdowner who refuses to allow his herd to be tested.

Enclosed as requested is a copy of the 1981 Report by the EEC Commission on disease eradication.

Yours sincerely,

(T. A. Byrnes)

Higher Executive Officer.

9 May, 1986.

Mr. P.M. Judge,

Clerk to the Committee on Public Expenditure,

Leinster House,

Dublin 2.

Dear Mr. Judge,

I refer to your letter of 4 April requesting further information concerning the operation of the Bovine TB Eradication Scheme.

As regards holdings deemed to have been infected with bovine TB between 1980 and 1985 the following table shows the number of holdings infected at the end of each round of testing, i.e. prevalence, together with the number of herds identified as reactor as a result of the round, i.e. incidence.

Ø reactor herds disclosed as a result of round testing; figures for ‘85 and ‘86 refer to monitor, check and special programme testing.

* A full round of testing was not carried out in 1982/83 but a special programme of “blitz” testing operated in the worst infected areas during the latter half of 1982.

Comprehensive information is not readily available in relation recurrent outbreaks; however, I would draw your attention of the 4,629 herds restricted as at the end of the locked up since 1984, and 58 since 1983.

The amount and distribution of TB in the cattle population is by the mechanisms under which reactor herds are identified. mechanisms are (a) the regular rounds of testing, carried out on an area or block basis, as a means of monitoring the national herd; (b) the retesting of reactor herds until they are clear; (c) the testing of all herds contiguous to reactor herds; (d) the testing of inconclusive herds; (e) special check testing of herds in high-risk areas; (f) check testing after 6 months of reactor herds which have gone clear; (g) the pre-movement test and (h) post-mortem examination showing TB lesions, especially in clear animals. Where infection is disclosed by any of these means the herd is placed under restriction (no movement in or out is allowed, except under permit) and adjoining herdowners are notified by the District Veterinary Office.

As regards the statistics, disease prevalence is considered the most reasonable measure of the TB situation at any time, particularly when considered in conjunction with the number of herd tests carried out in the preceding period. The number of restricted herds as a percentage of the total number of herds indicates the point prevalence of the disease. This figure gives a reasonable indication of the overall disease situation by taking into account both ends of the eradication process, viz.movements out of the restricted herd category (i.e. herds going clear) as well as movements into that category. It is, of course, not the only indicator available and incidence figures also appear in the monthly statistics made available by the Department.

Each District Veterinary Office provides a detailed statistical return at the end of each month. Statistics compiled from herdowners files and records include an update of the number of herds tested, the number of herds and animals disclosed as reactor, the number of herds restricted since the start of the testing programme, the number of tests, including retests and check tests, carried out under the programme, etc. Quarterly returns of TB lesions in ‘clear’ and reactor animals are furnished by the Department’s officers at meat export premises. These returns serve as a basis for the eradication strategy and are made available to the Animal Health Council which advises the Minister on animal health matters.

At 6 April, 1986, at the conclusion of the 1985/86 testing programme, the TB prevalence figure was 2.42% of herds.

There is no comprehensive information available of skin TB nor would the Department surveys. The disease is unique, in that with the possible leprosy, it can only be diagnosed clinically. It is not considered a hazard to individual animals.

The Bovine Tuberculosis (Attestation of the State and General Provisions Order, 1978 defines a reactor as “an animal which, by reason of a test or otherwise, a veterinary inspector believes or suspects is affected with bovine tuberculosis or is capable of infecting other animals with bovine tuberculosis”. In the context of the test a tuberculin reactor is a reactor animal by virtue of its response to the intradermal injection of avian and bovine tuberculins (comparative test) or bovine tuberculin alone (single intradermal test). The comparative test is the test routinely used in Ireland.

EEC Directive 80/219 Annex B details (a) the antigens to be employed and (b) the mode of interpretation. Copy enclosed - paragraphs 28-33 refer.

The responsibility for designating an animal a reactor rests with the Department’s Veterinary Inspector. Any animal that gives a positive reaction to a tuberculin test is automatically removed as a tuberculin reactor. It is usual in infected groups of cattle to designate as reactors all animals positive or inconclusive to the comparative test, using the EEC interpretation. In heavily infected herds an animal with an inconclusive or positive reaction at the bovine injection site may be removed as a reactor. An animal with a negative but borderline reaction at the bovine injection site (i.e. an increase of 2mm in skin-fold thickness) may also be removed as a reactor if suspected of being a hidden focus of infection.

The latest (1980) figure available in respect of areas let to other persons in conacre amounts to 395,200 hectares. This includes feeding barley, village and grazing, including hay and silage; separate data is not available for the number of rented farms and commonages used for grazing cattle.

Yours sincerely,

(P. Hennessy)

Questions for written reply for the Department of Agriculture.

1. Please state the targeted number of herds 1986 Round and whether that will be completed in the calender year.

2. Please submit a copy of the recommendations of the Animal Health Council, referred to in the ICOS submission and give the Department’s response to them.

3. An IFA Animal Health Committee report on T.B. issued in 1982 contains a map (copy attached) identifying districts with greater than 5% incidence. Could the Department kindly furnish a comparable map showing the position after the 1985 Round.

4. Please state the minimum additional cost of a full Round and necessary follow-up testing for 1986 based on the outcome of 1985.

5. Please state if testing is now exclusively assigned to IVU or if there is any truth in the allegation that 130 vets who resigned or were expelled from the IVU because they supported the Department nomination in 1985 have, not since been assigned herds for testing.

6. Please state what targets could be set in terms of cost level or in frequency of testing and number of years to achieve the Northern Ireland level of T.B. prevelance, and what reduced programme of monitoring should then apply, at what cost to the taxpayer?.

7. Please state what additional resources are required to give effect to the recommendations of the veterinary expert group:

- to provide for research to develop supplementary tests.

- to find an adequate epidemiology unit.

- to follow up on reactor identification by identifying/removing the cause of breakdown.

- to provide compensation for removal of cattle sheds where they cannot be adequately disinfected.

8. Please submit any comments you may wish to make on submissions made to the Committee by IVU, IVA, VeterinaryGroup, IFA, ICOS and The Concerned Veterinary Practitioners Association. (copy attached)

9. It has been suggested by our expert witnesses that the interpretation of the test was varied in the past at the direction of the Department of Agriculture perhaps under instruction from the Department of Finance to contain cost, with a view to reducing the number of animals on which compensation would be paid.

Is there any possibility that there could be any vestige of truth in this allegation which the Committee understands is a view widely held by practising vets?

10. The question of veterinary inspection of animals slaughtered for domestic market was raised. Is the Department satisfied that the new Bill now before the Senate will give the same standards of inspection for the domestic and export markets and that both will be equally useful in providing information to assist in disease eradication programmes?

11. The farmers’ levy now about covers the direct costs of the scheme in vet fees and materials excluding reactor compensation and, of course, administration. Is that a realistic balance or are taxpayers likely to be asked to carry more or less of the costs involved in the future?

12. Inadequate control over cattle movement other than through marts has been cited as a major weakness in the scheme. What does the Department propose to do about it?

13. The Department has given a net present value of £750 million approximate to the direct expenditure for the State on T.B. eradication since 1954. This excludes the administration cost, which in 1985 was 35% and was much higher in other years when the level of testing was lower.

Could the Department give an accurate total cost to T.B. in today’s costs?

The IFA suggest that the farmers’ costs and losses are Could the Department offer any more accurate estimate of farmers’ costs?.

14. The White paper on the Public Service refers to the establishment of Executive Units to undertake certain tasks. Has the Department considered the appropriateness of establishing an executive unit for disease eradication. Does the Department wish to make any comments to such a suggestion?.

15. It was suggested that the 30 day premovement test should be dropped in low incidence counties and that the same test interpretation should apply for movement tests in high incidence counties as for exports. What is the Department reaction to this suggestion?.

16. Is there any board governing the professional standards of veterinarians in Ireland or in other European countries to parallel. The Boards governing the legal, medical and dental professions or has there been any proposal to establish such a board. Does the Department wish to comment on this issue in the context of disease eradication?.

17. When will the national herd be fully computerised?. What will this mean in terms of (a) increased control

(b) reduced administration cost.

What is the total cost of this operation?

Will this operation coincide with a review of numbers with a view to eliminating any situation where two herds are effectively operating as one?

18. We are advised that the incidence of T.B. in Northern Ireland is one fifth the rate applying here. Can the Department give details of prevelance incidence over the years or indicate whether T.B. was always less of a problem there?.

10 July, 1986.

Mr. P. Judge,

Clerk to the Committee on Public Expenditure,

Leinster House,

Dublin 2.

Bovine T.B. Eradication Scheme

Dear Mr. Judge,

The enclosed memorandum sets out our position in relation to the questions in the note accompanying your letter of 11 June.

In relation to the invitation to give our views on the submission of other bodies, in accordance with my undertaking at the public hearing on 27 May a separate memorandum is enclosed giving our views on the submission of the Irish Farmers Association. Since it would take a great deal of time to comment adequately on all the points made by the other bodies, may I suggest that the Committee raise with us at the session planned for 22 July any particular points on which it would like to have the Department’s reaction.

As a general comment, most the suggestions put forward by the bodies concerned have been considered by the Department at some stage. Indeed, we find ourselves in broad agreement with much of the analysis and conclusions of the responsible veterinary bodies, especially those of the Irish Veterinary Association. However, the adoption of many of the suggestions would present practical difficulties, especially from the point of view of public finance. Other suggestions seem to us to be secondary to the main requirements of the eradication effort or, as in the case of arguments about the reliability of the test on which we have given our views in some detail, constitute an unnecessary and unhelpful distraction from the fundamentals of the eradication programme.

It will be clear to the Committee that some of the views put forward tend to reflect particular interests. Much of the analysis involved in such cases is not soundly based and we do not go along with the conclusions of the bodies concerned.

In relation to question 11 you will appreciate that policy with regard to the financing of the schemes, including rates of disease levies, is a matter for determination by the Government.

As explained at the hearing, our basic view is that the Scheme as operated during the 1985/86 round of testing, following the changes introduced by the Government in 1985, provides a sound basis for a successful eradication effort. We are open to ways of improving the Scheme and will continue to introduce worthwhile adaptations consistent with effective use of public resources and the relevant EEC Directive.

Yours sincerely,

AN ROINN TALMHAÍOCHTA - FARM DEVELOPMENT SERVICE

GUIDELINE COSTS FOR PLANNING

1. Costs of Farm Structures

* Costs also vary according to the volume of slurry storage provided.

Note: Costs vary according to length of feeding period.

Haybarn costs also vary with baled or loose bay.

Memorandum on questions from Committee on Public Expenditure

1.£5.5m (approx) has so far been allocated to testing by private veterinary practitioners under the 1986 programme. The cost, in fees, of testing are national herd once is £9 m. approx. While the foregoing gives indication of herd coverage the number of herds tested will be influences by the extent to which individual Superintending Veterinary Inspectors consider that the disease situation requires that particular herds be tested more than once and also by the volume of testing carried out directly by the Department’s Veterinary Inspectorate.

2.The recommendations referred to are attached. These recommendations, some of which were discussed in the course of the hearings, have been considered and implemented, where feasible e.g. in relation to the continuation and intensification of all check testing and back-up services in bad areas; improving communication at local level through more frequent meetings between the Dept., veterinary practitioners and herdowners for the purpose of fighting disease; the depopulation of chronically infected herds; the carrying out of post mortem examination on domestic trade slaughterings (Bill to be introduced in next Dail session); reducing the time allowed for disposal of reactors to 10 days; the introduction of a computer system which when fully operational will assist the tracing of reactor animals and the identification of contiguous herds.

The main constraint in relation to the adoption of the other recommendations is finance.

3.A map indicating the position at the end of the 1985/86 round is enclosed requested.

4.The minimum additional cost of a full round in 1986 i.e. over and above the resources already committed to the 1986 programme, would be £5.5m (approx.)

5.Neither membership of the IVU nor the position taken by individual veterinary surgeons in the course of the 1985 “dispute” are factors in the arrangements for the allocation of testing.

to constitute a danger from the disease viewpoint.

8.See covering letter and memo on submission from the IFA.

9.There is no basis for this allegation.

10.Detailed Heads of the Slaughterhouses Bill are currently under examination by the other Departments concerned and the aim is to have it introduced in the next Dail session. The Bill provides for the same standards of veterinary inspection of animals slaughtered at domestic premises as apply at export plants, and it provides also for returns to the Minister e.g. in relation to disease eradication requirements.

11.This is an aspect of public policy for determination by the Government.

12.The movement of cattle into or out of a holding (except under permit when moving direct for slaughter) is subject to the animals having passed a pre-movement test within the previous 30 days if intended for export, or 60 days if for the home market. There is, therefore, no differentiation in the rules as between cattle sold privately on through the marts. We believe that the current laws are adequate.

13.The total cost of the TB scheme to date including administration, in to-days terms, amounts to some £1,000 million. Administrative costs (including the brucellosis scheme) more 33% of total costs in 1985.

There is no reliable estimate available of farmer losses due to disease. These will have varied with a number of factors including the type and quality of the animal concerned, the timing of slaughter, and the market situation.

14.The Department has not fully explored the implications of establishing an Executive Unit to administer the Disease Eradication Scheme. While a properly financed Unit would have advantages the present District Veterinary Office structure

has the advantage of maximum flexibility in operating the Schemes administered through the offices e.g. headage grants, fodder schemes and a wide range of veterinary requirements. Separation of these implications from the point of view of costs.

A decision to establish an Executive Unit would also require careful consideration of the legislative implications since the Diseases if Animals Acts and the Regulations made thereunder provide the basis for the powers and obligations various parties under the Schemes. It can be argued also that the importance of disease eradication and control from the point of view of the general welfare of the farming community, exports of livestock and livestock products and the confidence of trading partners in guarantees provided by Ireland in these matters, requires active involvement in the Schemes by central government, acting through the Department of Agriculture.

It must be said also that as far as eradication is concerned the prospects of success of an Executive Unit are likely to be no greater than those of the Department in a situation where financial constraints would prevent it from putting into operation and sustaining the desired programme.

15.The validity period of the pre-movement test for TB is 30 days in the case of animals for export and 60 days where intended for the home market. The pre-movement test which is in any event mandatory under EEC legislation is an essential mechanism for identifying reactor animals and herds.

With regard to the interpretation of the test, detailed instructions are available to the Department’s veterinary officers on the most appropriate interpretation in individual cases. The normal practice is that the severe (export) interpretation is applied where the disease history of a particular herd or the circumstances of a particular area or county require it.

16.The board governing the ethics and professional standards of veterinarians in Veterinariy Council, 53 Lansdowne Road, Dublin 4.

17.The computer processing system installed at all District Veterinary offices of the Department of Agriculture in early 1986 at a cost of £1.2m is being implemented on a phased basis.

Phase 1 is now operational in the following areas:

(1)Herd and Veterinary Practitioner records

(2)Scheduling and listing of all tests since 21 April, 1986

(3)Recording of test data (with animal details for reactor nerds

(4)Payment of testing fees

(5)Establishment of an animal file including movement information.

Further implementation will concentrate on disease prediction, prevention and containment through epidemiological analysis of factors affecting the disease. The data base will be extended to encompass the national herd thereoy enaoling the introduction of a movement permit to replace the existing identity card systems and the facility of tracing at animal level on a national basis. The national herd is now estimated at 7½ million animals therefore total capture of this level of detail before late 1987 is unlikely. Additionally the epidimiological features of the design of the new system will provide a platform for assisting with control programmes in other diseases of cattle or other farm animals in the future.

Speculation on job savings would be premature at this point. While there is and will be an increasing improvement in data access and retrieval there is a parallel increase in data entry and management. It is important however that this development be viewed in the context of providing a radical new dimension to the Disease Eradication Scheme on the epidemiological front in addition to reorganisation of all scheme data thereby allowing the maximum utilisation of personnel and financial resources with realistic amoitions for final eradication.

18.The incidence of TB in Northern Ireland hards since 1969 is as follows:-

Department of Agriculture,

10 July, 1986.