Download implementation of new EU-wide controls on Scrapie affected farms

BRITISH VETERINARY ASSOCIATION
Consultation on implementation of new EU-wide controls on Scrapie
affected farms
Submission by the British Veterinary Association (BVA)
INTRODUCTION
1.
Thank you for your invitation to consider the consultation on the implementation of
new EU-wide controls on Scrapie affected farms. While the BVA fully supports any
measures designed to eradicate TSE infections in livestock in the interests of both
animal health and welfare and public health we do have a number of serious
concerns that we wish to highlight.
OVERALL CONCERNS
2.
The BVA would like clarification on exactly when the measures outlined in the
consultation document will be implemented and whether they will continue to apply
to all farms with a confirmed case of scrapie from October 2003.
3.
It is important that these measures will apply equally and without prejudice in all EU
member states and that adequate cross-border surveillance standards for the
detection of diseases is guaranteed.
4.
The BVA is concerned that goats are being treated as if they belong to the same
species as sheep throughout this document and we would like to add that:
5.
(a)
the goat section of the consultation appears to be an “add on” with little
thought given to the implications of the proposals for goats; and
(b)
statements made in relation to goats do not appear to be evidence based
and we should point out that there have been no surveys of goat scrapie
genotypes in the UK.
Furthermore, we would like to raise our more general concern that there has been a
failure to support any extension of the Scrapie Monitoring Scheme to encourage more
goat herds to participate, as well as a failure on the part of Government to fund
routine brain examinations of goats already on the Scheme.
DISEASE CONTROL OPTIONS
6.
While both of the strategies outlined in the consultation document seem to form a
sound basis for the ultimate eradication of scrapie the BVA feels that it is essential
that the farmer and the veterinary surgeon are included in the decision making
process in relation to disease control options.
We would also like to raise the
following issues and questions on the practical implications of the strategies outlined
for the sheep and goat industries:
(a)
without further progress on the National Scrapie Plan, sudden
implementation of either strategy would have an immediate adverse impact
on unregistered UK flocks that are either known or suspected of being
affected with scrapie;
(b)
measures may be perceived by farmers to be draconian thereby discouraging
disease notification and hampering surveillance efforts for scrapie as well as
other diseases;
(c)
the potential for carrying out important research is lost when, following
confirmation of BSE in sheep or goats, the Secretary of State authorises a
complete cull. The Statutory Instrument should give the Secretary of State
the right to seize and move infected stock that may be required for
experimentation and/or further testing on secure sites;
(d)
how has the 3 year sheep/goat free period quoted as being required after
culling and before restocking been arrived at? Is there evidence that this
period is sufficiently long to prevent the likelihood of re-infection of restocked animals - even if they are of more resistant genotype?
(e)
equally, are there circumstances under which that 3 year period could be
shortened? Time spent without stock is likely to have significant financial
implications for farmers, particularly in areas where there are limited
opportunities for diversification e.g. hill and upland farms.
RESTOCKING
7.
Sourcing sufficient numbers of replacement animals carrying resistant genes may be
difficult. For example, affected and genotyped flocks will only be allowed to purchase
ARR/ARR rams; currently this may be impractical in the Blackface breed and some
rare breed flocks where this genotype is known to occur in less than 10% of the
population as well as in certain remote areas where there is restricted access to large
populations of replacements of a suitable genotype. Under these circumstances
commercial flock owners may find themselves competing with pedigree buyers for
replacements, a situation which would be uneconomic in most instances.
8.
Similarly the proposals for restocking of ewes with all ARR/XXX but not ARR/VRQ
genotypes is likely to present practical difficulties, particularly with regard to
crossbred animals which have not been genotyped. It is likely that affected flock
owners will, in effect, have to breed their own replacements, a process which may
take several years.
9.
In order to overcome these difficulties we would like to make the following
recommendations:
(a)
that the removal of susceptible females in genotyped flocks should be
staggered over more than one year;
(b)
removal of stock should be limited to the VRQ gene in the first year and
ARQ/ARQ and other genotypes in the second. Removing the VRQ gene will
remove 95% - 97% of all suspect cases although it must be recognised that
in some flocks this may mean removing more than 50% of the animals;
(c)
in more complex situations where scrapie has been confirmed in sheep with
genotypes such as ARQ/ARQ we accept that whole flock culling with
restocking after a defined period may be the only option;
(d)
the BVA accepts that only ARR/ARR rams should be used in genotyped and
replacement stock but it may be difficult to acquire these. In such cases it
may be appropriate to consider giving financial and logistical assistance to
farmers to help them identify and acquire these animals; and
(e)
compensation must be adequate and we are in favour of a fixed rate for
crossbred flocks similar to that which is outlined in the consultation
document. However, we feel that the ongoing costs associated with the 3
year sheep/goat free period must not be ignored.
Compensation
arrangements must also take into account any financial loss for the farmer
selling his/her farm during the 3 year period.
CONCLUSION
10.
While the BVA fully supports the intention to eradicate TSE infections in livestock we
are concerned that elements of the compulsory proposals as they stand are
draconian and may result in sudden and catastrophic de-stocking as well as problems
with sourcing replacement animals. We strongly recommend that any measures to
control disease are implemented sensitively to promote compliance and that the
farmer and the veterinary surgeon are included in the decision making process.
NOTE
The British Veterinary Association (BVA) is the national representative body for the veterinary
profession in the United Kingdom and represents over 10,000 members. Our chief interest is
to protect and promote the interests of the veterinary profession in this country and we
therefore take a keen interest in all issues affecting the veterinary profession, be they animal
health, animal welfare, public health or employment concerns.