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

APPENDIX III

IFA Submission

SUMMARY

Little or no progress has been made in the last decade to eradicate T.B. All the indicators such as:

(i)the % incidence

(ii)the % prevalence.

(iii)The number of confirmed tubercular lesions found in animals coming from officially free herds

(iv)the number of reactors slaughtered

(v)the incidence of T.B. in this country compared with other E.E.C. countries

confirm this view. The lone encouraging point is that the % incidence figure decreased on a monthly basis during the 1985/E round and there were 4,629 restricted herds at the end of the round which is nearly as low as its best in the past.

Major question marks hang over the reliability of the tuberculin test. Any test which fails to detect almost half of reactors during annual testing must be treated with suspicion.

There is an urgent need for more than two full tim staff to be engaged in research, particularly so as there is so much doubt over the future success of the Scheme.

The scheme is the responsibility of the Department and they should be fully accountable for its success or failure. If the task proves impossible for them, responsibility should be given to some other party.

The Government have an important role to in treating the Scheme as a priority and ensuring continuity of funding for it. The stop-go approach to the funding of the Scheme in the past is regrettable.

Finally, both farmers and vets must be given sufficient incentive and encouragement to cooperate in full with the scheme and anyone of them who openly flout the regulations should be severely punished.

Farmers are particularly keen that T.B. be eradicated from the country. They have paid the price more than anyone else for the failure of the Scheme to date. They contributed almost £14 m. directly in disease levies to the scheme in 1985 and suffered another £8 m. in losses due to their cattle going down with T.B.

(iii)Number of confirmed Tubercular Lesions found in animals comingfrom officially free herds.

Table 3 shows the number of confirmed tubercular lesions found in animals coming from officially free herds, slaughtered and subjected to a post mortem inspection and the number of lesions found in animals as a percentage of animal slaughterings in that year. (Approximately 1 million bovine animals are slaughtered each year in export approved enterprises).

The number of animals with lesions coming from officially free herds is perhaps the best indicator of our progress in eradicating T.B. as it should not differ significantly with the amount of testing that took place in any given year.

Table 3 clearly shows that there has been no progress made in the eradication of T.B. since 1979. The situation has, in fact, deteriorated slightly.

Table 3

NO. OF CONFIRMED TUBERCULAR LESIONS FOUND IN ANIMALS COMING FROM OFFICIALLY FREE HERDS

Source:Department of Agriculture.

(ii)Number of Reactors Slaughtered

Table 2 gives the number of reactors slaughtered each year since 1974. The most surprising fact is that there appears to be no relationship between the number of reactors slaughtered and the amount of testing done in a particular year. For example in the 1984 round, 61% of the national herd was tested and there were 33,560 reactors. In the 1980 round, 99% of the national herd was tested and there were just 26,581 reactors.

If the incidence of T.B. was getting lower one would expect less T.B. reactors. Judging by the number of reactors slaughtered the incidence of T.B. has got higher since 1979. In 1979 and 1980, there were 25,382 and 26,581 reactors respectively slaughtered. In 1984 and 1985, there were 33,560 and 31,572 reactors slaughtered i.e. an increase of 25%.

Source:Department of Agriculture.

TABLE 1: Comparison of % Incidence of the 1985/86 and 1980/81 Round By County

Table 5: Analysis of last 6 Bovine T. B. Rounds

* Estimated

Source: Department of Agriculture

Table 4: Monthly Analysis of 1985/86 Bovine T. B. Round

(vi)Comparison with other E.E.C. Countries

Table 6 shows that Ireland has the greatest number of T.B. reactors as a % of the number of cattle in the country of all the E.E.C. countries. The incidence of T.B. in Ireland is almost five times that of Northern Ireland despite our similar farming patterns, climate and environment.

It is quite plain to see from this that we have not been as successful as our European counterparts in eradicating T.B.

Table 6

Comparison of number of T.B. reactors in Ireland with other E.E.C. Countries - 1985

Source:Committee of Public Expenditure Review - 20/5/86.

Section 2

Recommendations

In Section I it has been shown that despite the substantial cost to the Exchequer little or no progress has been made in the last decade to eradicate T.B. The reasons why there has been such slow progress are plentiful and varied depending on which interest group one listens to. Set out in this section are some of the main issues that need to be addressed if we are to successfully and efficiently eradicate T.B. These issues we believe account in the main for the lack of progress made by the scheme of late.

(i) Reliability of Tuberculin Test

The reliability of the tuberculin test is in question. Published data indicate and many experts believe the reliability of the tuberculin test to be in the region of 80-85%. Department of Agriculture officials indicate the reliability of the tubercul test to be in the region of 99%. Clearly, somebody has their sums wrong. On Table 3, we can see that there were 2,609 animals in 1985 found with lesions coming from officially free herds, slaughtered and subjected to a post mortem inspection. Approximately one million bovine animals are slaughtered each year in export approved enterprises. One can calculate, on the basis of the number of animals found with lesions that were slaughtered in 1985 that out of our total cattle population of 7 million one would expect to find 18,263 animals (7 × 2,609) with lesions in the total population. All animals were tested at least once and, on average, one and a half times in 1985 and only lesions were found in reactors: therefore, at least 8,102 infected animals were not located during these operations; if one does the same calculation for previous years, one will see that the picture is pretty well the same.

The Scheme to date has placed undue reliance on one diagnostic test. This is all the more cause for concern when the reliability of that one diagnostic test is in doubt.

(ii) Insufficient Full Time Staff Engaged in Research

While the recent establishment of an Epidemiology Unit in Abbottstown is to be welcomed, there are an insufficient number of staff employed by the Department engaged in research into T.B. full-time. Out of a total laboratory staff of 148 employed by the Department, only two or thereabouts are assigned to research into T.B. full-time.

(iii) Interpretation

Interpretation of the T.B. test procedures varies depending on the destination of the animal i.e. whether the animal is for export or for movement within the country. I.F.A. feel that the interpretation of the results of T.B. testing should not be influenced by the destination of the animal and that the same standards for interpretation should apply to both.

(iv) Continuity of Funding

All relevant interest groups agree that an overall plan is needed and realistic targets set if T.B. is to be eradicated efficiently. Over the years the Scheme has suffered (and as has been reflected in the progress made) from a stop-go approach to its funding.

I.F.A. in common with the other interest groups support fully the completion of the programme outlined in the National Plan and firmly believe that priority should be given to the Scheme and that continuity of funding of the Scheme be ensured for all future years.

(v) Pilot Testing with Department Vets.

The Department should employ a number of veterinary inspectors to carry out T.B. testing on a pilot basis in a sample of herds and compare the results of the testing of the herds by the Department Vets, with those of the veterinary practitioners. This would help act as a control to ensure that all the veterinary practitioners were working to acceptable standards.

In the early 1970’s some 50 temporary veterinary inspectors were recruited by the Department to test for T.B. and it was found that the temporary Department veterinary inspectors found approximately three times more reactor animals and reactor herds presenting lesions, than the veterinary practitioners. In addition, some form of performance related bonus system should be built into the pay package of the veterinary practitioners as an incentive to the speedy eradication of the disease.

(vi) “Multiplier Effects” of Cutbacks in T.B. Scheme

As was shown in Table 1, the net cost of the T.B. eradication programme in 1985 was about £25.3 m. Departmental administration costs which acocunted for 58% of the cost of the scheme in 1985 (£14.7 m.) are largely fixed in nature and will not very significantly with the amount of testing carried out. All the other costs of the Scheme (Veterinary fees and reactor compensation etc.) are variable in nature and will vary directly with the amount of testing carried out.

The point to be made is that a £4 m. outback in the T.B. scheme will not reduce the amount of testing by 16% £4 m. as a percentage of the cost of the scheme £25.3m.) ) but by 38% £4 m. as a percentage of the variable costs of the scheme (£25.3 - £14.7 m. £10.6 m.

It is financial madness to make cut-backs solely in the amount of testing carried out. If cutbacks are to be made they should be made across the board i.e. to Departmental administration costs as well.

(vii) Adequacy of Reactor Compensation

At present, farmers suffer financial loss of up to £500/animal if an animal goes down with T.B. There is a school of thought and one which we in I.F.A. concur with fully, that there would be a greater incentive for farmers to cooperate in the fullest way in eradicating T.B. if levels of reactor compensation were such that the farmer would not suffer serious financial loss if an animal were to go down with T.B.

We note that at the first week’s review of the Bovine T.B. Scheme at which representatives of the Department of Agriculture were present, those representatives were of the opinion that the benefits would far outweigh the costs if compensation for reactors was such that farmers would not suffer material financial loss on T.B. reactors.

(viii) Removal of Section in Act Preventing A.F.T. from Engaging in Veterinary Research.

The Section whereby A.F.T. are prevented by the 1950 Agriculture Act from engaging in veterinary research should be immediately removed. A.F.T. should be actively engaged in veterinary research into T.B. There is a distinct lack of independent research into, amongst other things:

•the reliability of the tuberculin test

•the cause of herd breakdowns

•other tests for identifying T.B.

(ix) Seeking of Expert Guidance

The Department of Agriculture has responsibility for the eradication of T.B. in this country. They should be given adequate resources to devote to the Scheme and they should be made fully acocuntable for the progress made under the Scheme.

If adequate resources are devoted to the progress under the Scheme under the responsibility the Department continues to be as poor as it has been in the recent past, then the idea of bringing in an outside expert (e.g. Veterinary Medicine experts. consultants from foreign countries who have eradicated the disease) to direct and take overall responsibility for the Scheme should be considered.

RECOMMENDATIONS: from Report of National Annual Health Committee 1982.

1.TESTING PROCEDURE

It is recommended that all cattle presented for testing should be tested in strict accordance with the EEC & Dept. of Agriculture instructions whether tested by private practitioner or veterinary inspector.

Comment:

To ensure that the test has been correctly carried out, it will be necessary that each farmer know the correct procedures which the veterinary surgeon should use. Appendix 1 at the back of this document should help farmers in this regard.

2.FREE PRE-MOVEMENT TEST:

It is recommended that the EEC Financed “Free” Pre-Movement Test be introduced immediately

Comment:

The substantial amount of illegal movement of cattle reported to the Committee demands that every effort be made to encourage testing of all cattle prior to sale, as the sales of untested cattle seriously damage the whole eradication scheme. In addition, the high cost of testing small number of cattle tend to encourage some herdowners to sell illegally.

3.PRESENTATION OF ANIMAL:

The conditions of the scheme determines that all cattle in a herd must be presented for testing in a herd test. It is recommended that the District Veterinary Office ensure that this is applied.

Comment:

Any animals which have been withheld from a test will at some future time be presented for a herd test, a pre-movement test, for slaughter at meat factory or butcher or sold for export to third countries.

The surveillance of movement and checking of documents at District Veterinary Offices must be vastly improved in order to close off avenues of cattle movement for people who wish to avoid testing.

4.PERMIT SYSTEM:

It is recommended that the present card system be replaced by a permit type system for all movement.

Comment:

While it is recognised that in theory the card system should provide an excellent health, vaccination and testing record for the animal to which it relates, in practice, it is open to widespread abuse due mainly to the duration of its validity - (12 months). This system was very suitable prior to compulsory pre-movement testing, however, as the testing veterinary surgeon must now certify that the animal has passed a prior test to movement, the card seems to have little value and a change to permit would facilitate much easier control of illegal movement. It is envisaged that the permit will be required for all movement and will be valid for the full 30 days except for animals for immediate slaughter which will require a special slaughter permit. The introduction of the permit system would of course coincide with the introduction of the free pre-movement test.

5.LOCAL AUTHORITY BUTCHERING PREMISES:

It is recommended that the post mortem information which identifies disease through trace-back currently provided by meat factories be extended to the local butchers slaughter houses.

Comment:

At present, approximately 320,000 animals are slaughtered for the domestic and deep freeze trade, in such abattoirs. Due to the high number of such premises and the small weekly slaughterings, veterinary inspection is limited. The Committee feel that, apart from the public health aspect, vital trace-back information is lost in most cases.

6.ISOLATION:

It is recommended that all reactors should be isolated and removed for slaughter as quickly as possible and that pending further testing in 60 days all inconclusive animals should be held in isolation.

Comment:

Farmers are urged to treat seriously the isolation of these animals as they pose a grave risk to clear animals if left loose.

7.DEALERS:

The Committee recommend that all dealers be licenced and should be subjected to frequent testing.

Comment:

A dealer is defined as a person who sells more cattle than he produces. It is necessary that the District Veterinary Offices have records of these people and regular checks should be made on them.

8.COMPENSATION:

It is recommended that the reactor compensation be increased by £70/animal and a restructuring of the hardship fund take place immediately along the following lines:-

1.The present ceiling of £2,500 should be removed.

2.The 20% eligibility level should be reduced from 20% to 15%.

3.Eligible animals should include in-calf heifers and animals killing out at less than 200 Kg (100 Kg at present), and that the 1st & 2nd eligible animals at over 15% should be included for assessment.

4.That the time period for eligibility include from breakdown to clear.

Comment:

Reactor compensation has not increased since 1978. With factory prices for reactors at unrealistic levels, it is vital that reactor payments are brought in line. While recognising the fact that a diseased animal must never be more highly valued than a clear animal, we feel present levels are totally unrealistic and a source of real hardship.

9.RESTRICTED HERDS:

It is recommended that in special circumstances additional financial aid be made available to Restricted Herds with serious physical and financial problems.

Comment:

In many farms the cycle of production is such that quite a number of animals are born into a herd while still restricted. Space must be provided for these animals and if restriction is prolonged severe financial and physical hardship is incurred through increased fodder & stocking rates. If no financial incentive is provided, farmers will be forced to sell young animals which can pose a disease risk to clear herds. By having incentives through special compensation for these hardship cases, we feel the problem will be overcome.

Example:

A fifty acre dairy farmer with thirty five cows, seven in-calf heifers, seven yearlings and seven calves. If such a farmer was restricted, the twenty eight calves which would normally be sold would have to remain on the farm. During their first summer they would require to be fed on ground normally used for hay or silage. In the following winter and spring these calves should be approximately four hundred weight, for which there is no housing and probably no feed. In addition, a further batch will be born the following spring to compound this difficulty.

Costs

Extra silage at 3½ tonnes for winter feed, 3½ × 28 = 98 tonnes @ £15 / tonne = £1,470.

Meal feed for 150 day winter 4 lbs / day. 150 × 4 × 28 = 16,800 lbs of meals.

7.5 tonnes @ £180 / tonne = £1;350

The extremely difficult management factors should also be taken into account. A special fund should be available under a severe hardship similar to above.

10.HANDLING FACILITIES:

It is recommended that every farmer should have proper handling facilities and that the Department of Agriculture should make available an increased grant for this purpose. Veterinary surgeons must refuse to carry out tests unless facilities are adequate.

Comment:

No farmer should allow another farmer use his cattle crush as the of disease spread are apparent. We are not requesting elaborate facilities - a simple structure to pen and restrain animals while being tested is all that is required.

11.DISINFECTION

It is recommended that proper disinfection of premises be carried out after the removal of reactors.

Comment:

Al already pointed out in this document, the T.B. organism is very resistant, so proper disinfection procedure is necessary. The Committee suggests that Farm Relief Groups, Co-Op’s and other interested contractors be encouraged to set up this facility as the washing and disinfection of buildings with high pressure equipment is a very specialised job. A capital grant should be made available to these contractors.

12.SEVERE INTERPRETATION:

We recommend the severe tuberculin interpretation should apply for all internal movement of cattle in the country.

Comment:

The Committee feel that the operation of two interpretations in T.B. testing is unwise and rightly or wrongly the impression is created that some level of disease is tolerable in the national herd. We should never take a lower standard for our home trade than that which is acceptable to our live export trade to EEC countries.

13. FARMERS OF NEIGHBOURING DISEASED HERDS:

It is recommended that in all cases that the District Veterinary Office inform farmers of contiguous diseased herds as soon as possible.

Comment:

The Committee is convinced that this notification is one of the most important aspects of the whole disease eradication programme, as it helps to stop spread of disease.

•it gives the owner of a clear herd some opportunity to protect his herd either by improving fencing or moving cattle to fields not adjoining the diseased farm.

•It also helps to make him more conscious of the proximity of what could be a serious problem for him before it happens and so help him to avoid it.

14.EEC ACCELERATED PROGRAMME:

It is recommended that a satisfactory regime for acceleration be agreed between the EEC and the Dept. of Agriculture immediately.

Comment:

The Animal Health Committee is prepared to discuss changes in the system of nominating veterinary surgeons in order to satisify E.E.C. requirements and provided such changes are not implemented in isolation from the other recommendations in this report.

15.LAND LETTINGS:

It is recommended that farmers renting conacre for grazing notify the D.V.O. whether the letting is through an auctioneer or private deal.

Comment:

In the interest of stopping the spread of disease it is essential, that the district veterinary office (which is in the best position to know the state of Adjoining herds) be consulted before the deal is finalised.

Conclusion

The majority of farmers whose herds have become infected are blameless and have been infected by lateral spread or other deficiencies such as thirty day tested cattle reacting of which could have been avoided if proper notification and help had been given in time.

The real hardship and trauma which an infection places on the farmer is really understood only by that farmer. The financial losses which accrue are only known by him, nobody else loses money. It is hoped that this report will help others to realise his plight and perhaps do a little more to alleviate his difficulty.

The facts and suggestions outlined in this report are not all embracing, however, the Committee believes that they will, if implemented, provide a sound base from which all the parties involved in disease eradication - farmer, veterinary surgeon, Department of Agriculture - can co-operate fully with greater enthusiasm to complete the work. We would ask, in the interest of the farming industry and the country, that a genuine effort be made by all to ensure that Bovine T.B. is completely eradicated from the national herd by 1986. This is a reasonable objective but will only be attainable if disease spread can be curtailed. We regard this as the biggest single role of the Administration, which all farmers and veterinary surgeons must fully support.

Failure to achieve this objective will undoubtedly put at risk our total exports of cattle, meat and dairy products, not only to E.E.C. countries, but also to Third Countries where export refunds are paid by the Community.