The Scottish Government

Dear Sir or Madam

I am writing to invite comments on the enclosed consultation document "Preparing for a new GB Strategy on Bovine Tuberculosis".

Whilst the incidence of bovine tuberculosis (TB) in Scottish cattle is presently relatively low compared to certain areas of England and Wales it has increased over recent years. However there is no evidence in Scotland of disease being transmitted to cattle from wildlife.

The majority of new cases have been as a direct result of cattle brought into Scotland from other, high incidence parts of GB and Ireland. For example the recent increase of TB in the South West of Scotland can be attributed to cattle restocking following the outbreak of FMD in 2001. This is a worrying situation and we believe it is important now to consider measures that will, (a) reduce the likelihood of infected cattle being brought into Scotland, and (b) help to identify as quickly as possible any infected cattle that might be introduced.

In the long term we wish to see effective controls in place to protect the Scottish herd from imported disease. That is why we are proposing to introduce a system of both pre and post movement testing of all cattle brought into Scotland from areas of high TB incidence. The cost of this new testing regime would be shared between the industry and central Government. This is one of the measures that we hope can be introduced relatively quickly and one which, we believe, will produce both an early and significant long term improvement in the current disease incidence in Scotland.

In order to give interested parties sufficient time to consider this paper, there is a twelve-week period for responses. If you wish to make comments on the issues covered by the paper, please send them to the following address by 10 ^th May 2004.

Karen Lindsay, Animal Health & Welfare Division,
Scottish Executive Environment and Rural Affairs Department,
Room 350, Pentland House,
47 Robb's Loan,
EDINBURGH
EH14 1TY
If you have any queries contact Karen Lindsay on 0131 244 6178.

We would be grateful if you would clearly indicate in your response which questions or parts of the consultation paper you are responding to as this will aid our analysis of the responses received.

If you wish to access this consultation online, go to http://www.scotland.gov.uk/view/views.asp You can telephone Freephone 0800 77 1234 to find out where your nearest public internet access point is, if you prefer to submit your response by e-mail to:- animal.health@scotland.gsi.gov.uk

A new e-mail alert system for SE consultations (SEconsult) was launched in December 2003. This system will allow stakeholder individuals and organisations to register and receive a weekly e-mail containing details of all new SE consultations (including web links). SEconsult will complement, but in no way replace SE distribution lists, and is designed to allow stakeholders to "keep an eye" on all SE consultation activity and, therefore, be alerted at the earliest opportunity to those of most interest. We encourage you to register as soon as possible.

We will make all responses available to the public in the Scottish Executive Library by 24 ^th May 2004, unless confidentially is requested. A Respondee Information Form is attached for your use. All responses not marked confidential will be checked for any potentially defamatory material before being logged in the library or placed on the website. Also attached for your information is a note on the Scottish Executive Consultation Process.

If you consider that we have omitted any relevant person or organisation from our consultee list, I would be grateful if you could advise me of their details and I will arrange for copies of these papers to be forwarded to them

Parallel consultations are being issued by the Department for Environment, Food and Rural Affairs and the Welsh Assembly Government.

Yours faithfully

Ian W Strachan

Animal Health and Welfare

British Veterinary Association
Centre for Infectious Diseases, University of Edinburgh
COSLA
Crofters Commission
Deer Commission (Scotland)
Dept of Veterinary Clinical Studies, Glasgow Veterinary School
Food Standards Agency
Forestry Commission
Institute of Auctioneers and Appraisers
Livestock Marketing (Scotland) Ltd
Moredun Research Institute
National Beef Association
National Dairy Cattle Association
National Farmers Union (Scotland)
Quality Meat Scotland
Royal (Dick) School of Veterinary Studies
Royal Environmental Health Institute of Scotland
Royal Highland and Agricultural Society of Scotland
Scottish Agricultural College, Edinburgh
Scottish Association of Meat Wholesalers
Scottish Association of Young Farmers Clubs
Scottish Beef Council
Scottish Centre for Infection and Environmental Health, Glasgow
Scottish Crofters Union
Scottish Dairy Association
Scottish Landowners Federation
Scottish Natural Heritage
SSPCA
The Independent Farming Group
The Royal Society of Edinburgh
University of Glasgow Veterinary School
Veterinary Laboratories Agency, Lasswade
Women's Farming Union
Local Authority District Councils.

B. RESPONDEE INFORMATION FORM

Please complete the details below and attach it with your response. This will help ensure we handle your response appropriately:

Name:

Postal Address:

Consultation title:

1. Are you responding as: (please tick one box)

(a) an individual (go to 2a/b)

(b) on behalf of a group or organisation (go to 2c)

2a. INDIVIDUALS:

Do you agree to your response being made available to the public (in SE library and/or on SE website)?

Yes (go to 2b below)

No, not at all

2b. Where confidentiality is not requested, we will make your response available to the public on the following basis ( please tick one of the following boxes)

Yes, make my response, name and address all available

Yes, make my response available, but not my name or address

Yes, make my response and name available, but not my address

2c ON BEHALF OF GROUPS OR ORGANISATIONS:
Your name and address as respondees will be made available to the public (in the SE library and/or on SE website). Are you content for your response to be made available also?

Yes

No

3. We will share your response internally with other SE policy teams who may be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for the Scottish Executive to contact you again in the future for consultation or research purposes?

Yes

No

C. The Scottish Executive Consultation Process

Consultation is an essential and important aspect of Scottish Executive working methods. Given the wide-ranging areas of work of the Scottish Executive, there are many varied types of consultation. However, in general Scottish Executive consultation exercises aim to provide opportunities for all those who wish to express their opinions on a proposed area of work to do so in ways which will inform and enhance that work.

While details of particular circumstances described in a response to a consultation exercise may usefully inform the policy process, consultation exercises cannot address individual concerns and comments, which should be directed to the relevant public body. Consultation exercises may involve seeking views in a number of different ways, such as public meetings, focus groups or questionnaire exercises.

Typically, Scottish Executive consultations involve a written paper inviting answers to

specific questions or more general views about the material presented. Written papers are distributed to organisations and individuals with an interest in the area of consultation, and they are also placed on the Scottish Executive web site enabling a wider audience to access the paper and submit their responses18. Copies of all the responses received to consultation exercises (except those where the individual or organisation requested confidentiality) are placed in the Scottish Executive library at Saughton House, Edinburgh (K Spur, Saughton House, Broomhouse Drive, Edinburgh, EH11 3XD, telephone 0131 244 4552).

The views and suggestions detailed in consultation responses are analysed and used as

part of the decision making process. Depending on the nature of the consultation exercise the responses received may:

If you have any comment about how this consultation exercise has been conducted, please send them to: [If a separate channel has been established to handle feedback and complaints on your consultation, insert the appropriate details below; otherwise, refer to your contact details above]

Name: Karen Lindsay
Address: Animal Health and Welfare Division, SEERAD, Room 350, Pentland House, 47 Robbs Loan, Edinburgh EH14 1TY
E-mail: karen.lindsay@scotland.gsi.gov.uk

EXECUTIVE SUMMARY

Developing a new strategy for tackling Bovine TB represents a major challenge for the Scottish Executive, other GB Agriculture Departments, the farming industry, the veterinary profession and other interested organisations including those representing wildlife interests. Bovine TB is one of the most difficult animal health problems that we currently face in Great Britain, with incidence in GB herds increasing by about 18% per annum and costs to both Government and industry increasing year on year. TB cases in Scotland have increased from 4 incidences in 2000 to a provisional figure of 21 incidences in 2003. The expenditure to the Scottish Executive and the UK Government, including research in Scotland and elsewhere in the UK, is forecast to cost £71 million in 2003/4. Whilst the incidence of TB in Scotland is relatively low at present, it is imperative that, in the short term, the TB Strategy safeguards our position and, in the long term, leads to the prevention of disease incursion with significantly reduced disease in future years.

The incidence of TB among Scottish herds is relatively low compared to England and Wales, particularly the South West of England and South Wales. However, TB has been on the increase in Scotland over the past few years and, although it can usually be traced to infected cattle brought in from high risk areas, it is vital that we have robust precautions in place to try to identify infection before cattle are brought into Scotland, identify imported infected cattle as early as possible and take measures to ensure that any infection is not transmitted to other cattle or to wildlife.

In some other countries with TB, cattle control measures similar to those in place in GB seem to have been effective in managing the disease in the absence of a wildlife reservoir. Fortunately, there is no indication yet that TB is being spread to cattle in Scotland from wildlife. However, there is no room for complacency and we do need to consider how to tackle the threat from the wildlife reservoir in GB, in particular in the badger populations in the South West of England and Wales. Working towards a successful solution will require commitment and pragmatism from all key partners if we are to find a fair, balanced and effective way forward.

In developing a new TB strategy we are guided by the Animal Health and Welfare Strategy (AHWS). This consultation is the first step in implementing the AHWS in relation to TB. It sets out the principles on which a TB Strategy will be based and seeks to open the debate on the way forward. The next step will be the development of a draft strategy, which we aim to publish later in 2004.

In this consultation paper we have identified some important questions for the future TB strategy which we hope you will help us answer. We need to establish a 'vision' of what we might achieve in terms of disease control over the next 10 years, to define roles and responsibilities of key stakeholders and consider how we can work in partnership with them. We must explore the rationale for Government intervention and how costs, benefits and risks should be balanced. We are committed to evidence based policy making. We have therefore set out key areas where scientific evidence is emerging that will help to determine future policy decisions. Whilst there is yet no evidence to suggest that TB is being transmitted to cattle from a wildlife reservoir it is, nevertheless, worth noting that the Department for Environment, Food and Rural Affairs (Defra) have now effectively ruled out small scale reactive culling of badgers in England in light of advice from the Independent Science Group (ISG) that this may actually increase incidence of TB in cattle. However, the wide ranging research programme is expected to yield evidence on the effects of proactive badger culling, pathogenesis in cattle and quantitative transmission between cattle and badgers, vaccine development, and diagnostics.

The short term policy options are considered in the second part of this consultation which sets out proposals for how we might better align our controls with those set out in EU law, including adjusting testing frequencies, and measures for reducing the risk of geographic spread of bovine TB from high to low incidence areas. A key element is the proposal to introduce a requirement in Scotland for pre and post movement testing, for which farmers will pay. This has been advised as best practice by the Scottish Executive for some time, and we propose that this now becomes a legal requirement.

We are also proposing to make a number of minor changes to the TB Order 1984 as amended, consistent with proposals that were consulted on in 2001 but that were not pursued due to the FMD outbreak.

1. Purpose of the document

1.1 The purpose of this consultation is to initiate work on implementing the Animal Health and Welfare Strategy (AHWS) in relation to bovine Tuberculosis (TB) by inviting views of stakeholders on:

• the principles on which a new 10 year strategy should be based so as to achieve a sustainable control policy for bovine TB in GB, and
• detailed proposals for new short term measures to seek to control the geographic spread of bovine TB, particularly to areas, such as Scotland, where the level of incidence of the disease is currently low.

1.2 The TB Strategy should be seen within the context of the Animal Health and Welfare Strategy for Great Britain and the Scottish Implementation Plan - www.scotland.gov.uk/library5/environment/ahws-00.asp. The Animal Health and Welfare Strategy sets out an ambitious set of challenges to animal keepers in raising standards consistently over time and sets out the role of Government in supporting this. Important justifications for Government intervention are protecting public health, promoting international trade and facilitating best industry practice. The Scottish Implementation Plan - which is subject to regular review - outlines how this work is being taken forward. It sets out a significant body of work undertaken by Government but reminds animal keepers that they are the ones who can do the most to raise standards and performance.

1.3 The first part of this document seeks to open debate on what a new strategy needs to address, including the implications of scientific developments for practical policy options. The second part sets out proposals for short-term cattle based measures.

1.4 Our aim is for short-term measures to be in place during 2004. We will consult again on a draft long-term strategy later in 2004 and publish a new long-term strategy in 2005.