The UFU has submitted its response to DAERA’s consultation on implementing some of the recommendations from the TB Strategic Partnership group. The consultation covered six main areas – governance, tools and processes, wildlife, preventing disease (herd health management), finance and funding, and research.
Last week we summarised our position on governance and research and this week we cover tools and processes.
The answers to the questions have been shortened to fit UFU Watch. The consultation and answers in full are available at www.ufuni.org
Do you agree that there should be a mandatory requirement for herd-keepers to have their animals undergo gamma interferon testing where DAERA considers it necessary and that all animals which test positive to the gamma interferon test should be removed?
Yes. The UFU considers it essential that infected animals are detected and removed from herds as quickly as possible. We are aware that in certain instances, the gamma interferon test can provide a valuable tool to enhance the sensitivity of TB surveillance. Furthermore, our members believe that if DAERA is willing to invest the additional resources to increase TB test sensitivity, it is reasonable that industry works with DAERA to enable the speedy removal of reactor animals. Therefore our membership is supportive of making it compulsory to give up reactors to the gamma interferon test.
Our membership requests that DAERA share the criteria for which herds/batches within herds can be tested using the Gamma Interferon test online (DAERA website – Bovine Tuberculosis testing) and explain why it is not currently used in some cases so people can better understand why it may be used in some instances and not others.
Do you agree that ‘chronic herds’ should be recognised as a distinct entity for action and that there should be a renewed approach to dealing with chronic herds as outlined based on the likelihood that intervention will have a positive impact?
No. Our committees discussed the potential positives and drawbacks of this proposal at length. Whilst committees recognised that where a herd has been OTW for an extended period of time resources should be directed to understand the reason for this prolonged breakdown and to try to help the farm regain OTF status, committees were opposed to the public labelling of an individual farm as ‘chronic’. Committees were concerned as there was no information within the consultation as to suggest how a chronic herd is to be defined and therefore it is impossible to gauge the impact or number of farmers identified by this label. Furthermore, the committee considered that those farmers that do unfortunately find themselves in a prolonged breakdown situation already know they are in a prolonged breakdown (as do their private vets and local DVO offices). As such, the relevant parties who would be involved in formulating a disease response plan to eradicate TB from the herd already know the situation without the farm being subject to labelling and potential reputational damage.
Do you agree that the Department should introduce measures to prevent restocking of breakdown herds through a phased approach?
Implementation of this policy needs careful consideration and additional policy tools are likely to be required to mitigate the market and financial impact to businesses affected. Given the current level of disease in Northern Ireland, our committees are extremely concerned by the potential impact of this measure and would urge extreme caution in its consideration.
Do you agree that the Department should introduce an interim transition stage where no movements will be permitted following a bTB breakdown until at least one further full herd test has been completed (whether clear or not) and reactors have been removed?
At this stage, our committees have chosen to split our response into a beef sector answer and a dairy sector answer.
Beef sector - No.
Within the beef sector, committees are extremely concerned that any move to prevent beef finishers (many of whom are constantly under TB restriction) or store producers from buying in animals would cause significant market disruption and block the route to market for many store cattle producers and beef rearing producers (many of whom lack sufficient winter housing or forage to cope with loss of the ability to move animals further along the supply chain) without offering any substantial disease control benefit as many of these animals are destined for slaughter in coming weeks/months.
Furthermore, as the business model for both store cattle and finishers relies entirely on the ability to buy in and raise/finish cattle, our committees are very concerned about the potential impact on business cash flow if either part of the supply chain is not able to buy in cattle for at least 60 days.
Based on these concerns, the UFU is opposed to this proposed policy.
Dairy - Yes.
Historically, concerns in relation to this proposal from dairy farmers have been around the cash flow impact if a farmer loses a large number of milking cattle and is unable to buy in replacements (i.e. decrease in milk volume/year-end tax implications). Our committees are aware that in the case of bad breakdowns, current policy from DAERA is to prevent farmers from buying in based on a veterinary risk assessment. As such, these cash flow concerns are already a reality for farmers suffering a large/prolonged breakdown. In consideration of this fact, and given that the policy does offer an increased likelihood of ensuring that TB is fully removed from the herd that suffers a new breakdown event before buying in replacement animals thereby hopefully removing the disease before it becomes more established in the herd, the UFU is able to accept the proposal for dairy herds not to be able to buy in for one herd test regardless of result (with the exception of one stock breeding bull if required for breeding purposes). After this point, our membership wish to see this revert to the current status quo where the decision on whether or not to buy animals in is based on a business discussion and veterinary risk assessment between the farmer and the vet which strikes a balance between likelihood of success of the measures helping to removing TB from the herd and impact on the business’ cash flow situation.
At this stage, our committees would like to highlight that historic opposition to this policy has mainly been due to concerns around route to market and business cash flow impacts. Committees are aware that solutions to these concerns have been identified and are in practice in GB and ROI via the establishment of ‘Approved Finishing Units’, ‘Depopulation Grants’, and ‘Income Supplement’ payments. For example, in ROI dairy herds receive a depopulation grant/income supplement of €55 per animal per month, and suckler herds receive a depopulation grant/income supplement of €38.09 per animal per month where more than 10% of the herd has been removed. Our membership are supportive of the establishment of such policies in Northern Ireland to help overcome the concerns and financial impact that surround the imposition of purchasing restrictions.
Do you agree that, in the medium-term, the Department should prevent restocking of herds that do not test clear at the first retest (subject to epidemiological assessment)?
Response as per previous question. We cannot consider medium term solutions until the immediate barriers in the short term have been overcome.
Do you agree that, in the long-term, the Department should require a negative full herd test before allowing movement onto a farm following any disclosure episode?
Response as per pervious question. We cannot consider long term solutions until the immediate barriers in the short term have been overcome.
Do you agree that moves should be permitted from bTB breakdown herds to approved rearing/finishing herds which are 100% housed and which meet defined, strict biosecurity conditions?
Yes. The UFU is supportive of allowing moves from bTB breakdown herds to approved rearing/finishing units which are 100% housed and meet adequate biosecurity conditions (e.g. non-grazing approved finishing units in GB). The UFU is supportive of this measure as many farmers who find themselves in a prolonged breakdown situation run into stocking density issues, fodder shortages, slurry storage issues, or the added workload of caring for additional animals over a prolonged period of time begins to have a serious impact on the welfare of the farmer and their family due to additional time needed to care for additional livestock. The UFU is however concerned that those farmers that do wish to move towards establishing themselves as an alternative control herd face significant financial barriers associated with developing the necessary on-farm infrastructure to meet the required biosecurity protocols. As such, the UFU would like to see financial assistance provided via the FBIS to help producers to overcome these financial obstacles and make the establishment of an ACH a more realistic financial possibility.
Alternatively, committees are aware of early stage proposals to potentially restructure beef research within CAFRE/AFBI. If through this process, the possibility arose that some livestock housing was likely to be under utilised or surplus to requirements, we would be in favour of converting this building to an ACH in order to provide an outlet for industry and to provide industry with a model and research on costings to establish an ACH and examples of how biosecurity could be improved on farm practically.
Do you agree that legislation should be introduced to authorise PVPs to apply DNA tags to reactors when reading the test?
Yes. Whilst it is the belief of our membership that deliberate interference with the outcome of a TB test is a rare occurrence, the UFU agrees that DNA tagging at reactor disclosure would enhance the continuity of reactor identification and reduce the possibility of fraud within our industry.
Do you agree that, in the event that the pilot scheme demonstrates that there is value in doing so, the Department should undertake reactor quality assurance checks as appropriate?
Yes. As per previous question. Whilst our membership believes that interference with TB test is a rare occurrence within the industry, our membership is supportive of measures that reduce or prevent fraud provided there is evidence to suggest that there is value in doing so. Our membership is concerned by the potential possibility of innocent individuals having their reputation tarnished or incomes reduced due to false allegations and urge that this measure be considered with caution.
Do you agree that the Department should expand the use of molecular techniques in order to support its strategy to eradicate bTB?
Yes. The UFU is frustrated that despite strong scientific evidence of bTB in wildlife, matching strains of bTB in local cattle and wildlife, and that it has been scientifically acknowledged that bTB moves in both directions between cattle and wildlife, that the science to date has not been sufficient to resolve disputes between farmers and environmental NGOs that in order to eradicate TB it must be addressed in both the cattle population and the local wildlife reservoir.
The UFU is therefore supportive of continuing to strengthen this evidence base to justify eradicating TB in both the cattle and wildlife reservoir.