Response to DEFRA Consultation

Submission of the British Deer Society to DEFRA in response to DEFRA Consultation document "Preparing for a new GB strategy on bovine tuberculosis" February 2004 and Independent Scientific Review of the Randomised Badger Culling Trial and Associated Epidemiological Research. Godfray HC et al, March 2004.

[Consultation period closes 4th June 2004]

1. Background

The British Deer Society [BDS] is a charity committed to the welfare of deer in the UK. The Society promotes informed wild deer management based upon sound scientific principles with the intention of maintaining the health of the national wild deer herd and encouraging balanced co-existence of wild deer populations with farming, horticultural and other land uses throughout the UK. The Society supports the health and welfare of wild deer, deer in parks, deer farms and private collections by way of education and training in the areas of deer management and public information. The Society is advised upon scientific, welfare and veterinary matters by professional and academic experts in the relevant fields. This submission has been prepared by the BDS Veterinary Advisor.

2. Submission to DEFRA

2.1 The specific responses in this submission are made in response to and in the light of paragraphs 3.2.1, 3.3.22-28, 3.3.30, 4.6.2, 4.6.3 and 5.3.30 of the Consultation Document and in the light of the Godfray report.

2.1.1 The British Deer Society strongly supports the suggestion made in the Executive Summary and in Chapter 2 of the Consultation Document that a new 'vision' of what may be achieved in terms of disease control is necessary. The BDS believes that additional powers will be required to deal with the actual and potential problems of wildlife reservoirs and would support the implementation of such powers. The Society is convinced that Government intervention is essential [2.1.1 Q4. & 4.4] and that such intervention must be based upon empirical scientific evidence and not moderated by unreasonable pressure group opinion.

2.2 The pathogenesis and epidemiology of TB in wild deer

2.2.1 For the following reasons deer are unusual and possibly unique amongst European ungulates, including farmed livestock, in respect of the pattern of TB infection:

• Deer may be infected with both bovine and avian TB and both may cause severe disease in individual animals.
• Respiratory and alimentary routes and sites of infection appear to be equally important.
• Significant numbers, often the majority, of clinical TB lesions in deer fail to stain positive by normal ZN laboratory staining methods.
• In an infected population of deer, although a proportion will show gross lesions, many infected animals only show signs of subtly swollen lymph nodes and many are asymptomatic carriers.
• Pooled lymph node culture from asymptomatic deer in contact with individuals showing gross lesions often reveal very high infection rates in the whole group.
• Fulminating TB infection is often seen in young deer [<2yo], whilst older, carrier animals may have few or no obvious lesions.
• When clinical or post mortem signs are obvious, they may manifest in a in wide range of lesions, from classical mammalian caseous or calcified TB nodules to very large abscesses with liquid pus. Any internal abscess within a deer must be taken as suspicious of TB.
• Recent and ongoing evidence suggests that there may be a few "hotspot" areas in lowland England where significant levels of TB are found in wild deer. These areas are usually associated with high TB infection rates in cattle and high deer densities.

2.3 The environmental and ecological interaction of deer with farmed livestock

2.3.1 Of the six species of deer found wild in the UK, the three larger species, red [Cervus elaphus], sika [Cervus nippon] and fallow [Dama dama] are much more socially organised than the three smaller species, roe [Capreolus capreolus], muntjac [Muntiacus reevesi] or Chinese Water Deer [Hydropotes inermis]. The large deer tend to aggregate into herds, the smaller deer tend to be more solitary.

2.3.2 In contrast to the environmental and agricultural situation in North America and much of Europe, where the large deer occupy forest, woodland or wilderness areas, in the UK herds of red, fallow and sika frequently have a close association with farmed livestock, grazing the same pasture and subsisting on the same crop fodders. There is very close contact between wild deer and cattle in large areas of lowland Britain. This intimate co-existence of large wild ruminants with domestic livestock is very uncommon in other western countries with advanced livestock husbandry.

2.3.3 Although bovine TB has been reported in the smaller deer [roe, muntjac Chinese water deer], the most frequent reports and serious foci of infection have occurred in red, fallow and sika.

2.3.4 Young adult deer, particular young stags and fallow bucks are the individuals most likely to travel considerable distances and also appear particularly vulnerable to TB infection.

2.3.5 The BDS is particularly concerned by evidence of significant levels of TB infection in deer in the Hereford/Gloucester areas and in south east Exmoor. Both are areas where high cattle TB breakdown rates occur.

2.3.6 Deer to deer transmission of TB has been shown to occur by both the respiratory and alimentary routes, the latter occurring through both faecal contamination of pasture and by susceptible deer sharing feedstuffs with infected animals. Although deer to cattle or badger to deer infection has not been demonstrated, neither has it been investigated.

2.3.7 The fragile but expanding UK deer farming industry is would also be put at increased risk if TB were to become established in wild deer and not addressed at an early stage.

2.4 The shortcomings of the current legislation in respect of TB in wild and park deer

2.4.1 The Tuberculosis [Deer] Order 1989 as amended and the Tuberculosis [Deer] Notice of Intended Slaughter and Compensation Order 1989 were framed to respond to the problem of TB in farmed deer. The mandatory controls requiring the marking and retention of records of all deer moved have been relaxed since inception.

2.4.2 The Orders provide for control of infection on premises and for elimination of infection in managed herds in which intradermal skin testing is possible. The Orders fail completely to address the possibility of an outbreak of infection in a wild population of deer.

2.4.3 Under the current Orders it is mandatory for any suspicion of TB in any deer [whether farmed, park, or wild] to be reported to DEFRA, but the powers of control arising from the confirmation of infection apply only to enclosed premises.

2.4.4 Section A restrictions may be placed upon premises on which TB in deer has been confirmed, and will only be lifted when the remaining deer are tested clear by intradermal testing. This clearly has no bearing upon wild deer and is also extremely unsatisfactory in the case of enclosed park deer, which can not be handled.

2.4.5 Under current legislation a TB infected deer park may remain under Section A restrictions indefinitely, with DEFRA having no further powers to limit the spread of infection to wildlife. BDS has experience of a deer park remaining under Section A restrictions for twelve years, until the owners were persuaded to remove all the deer to allow the restrictions to be lifted [over 30% of the deer were clinically affected by TB at post mortem examination].

2.5.6 Under the current Orders DEFRA has no power to investigate the possibility of infection in wild deer, even if TB positive carcasses are reported and investigated. There are no enforceable means by which DEFRA can assess the level of TB infection in a given wild population, once the presence of TB has been confirmed from post mortem submissions. The BDS has evidence that in south east Exmoor the level of TB infection in red deer may be as high as 50% in some limited localities.

2.5.6 Current legislation governing the control of TB takes no account of the presence on infected cattle farms of other large ruminants [deer] or indeed other mammals [such as badgers] which are equally susceptible to TB and which are free to come and go from the restricted areas. [Legislation in respect of other notifiable ruminant diseases is inadequate in this respect also].

2.5.7 The Godfray Report recommends that DEFRA TB policy assumes that badgers are a significant wildlife reservoir of disease [5.5.1]. Whilst the possible involvement of badgers has received much attention and investigation, current policy and legislation appears to restrict objective scientific investigation of the possible role of deer in some TB hot-spots

2.6 The recommendations of the British Deer Society

2.6.1 TB policy and strategy should take into account the possibility that in some limited areas wild deer play a significant role in the epidemiology of the disease.

2.6.2 The BDS does not believe that TB infection in wild deer is currently widespread or common. In fact, the Society believes that deer are likely to become vectors or reservoirs only in exceptional circumstances and when the deer population density is unhealthily high.

2.6.3 None the less, the BDS recommends that in areas where the incidence of cattle TB breakdowns is high or there is evidence of significant TB infection in wild deer, DEFRA should seriously consider taking to itself the following legal powers:

• To require the mandatory submission of pooled lymph nodes from all deer culled within the defined area by legitimate deer managers.
• To order if necessary a forensic cull of wild deer within the defined area to establish the presence and/or level of TB infection in the wild deer.
• To order a cull of deer on infected premises where infected deer are enclosed but can not be tested by intradermal testing [e.g. infected park deer].
• To order the reduction of unhealthily wild high deer populations where evidence strongly indicates that the deer are playing a significant role in the spread or maintenance of TB in cattle or are acting as a infectious wildlife reservoir.
• To prohibit the artificial feeding of wild deer in defined TB hot-spot areas

2.6.4 In all situations in which deer may be culled under such powers it is essential that qualified experienced deer managers are employed. The BDS would not support the enforcement of such powers by means of requirements upon landowners or farmers inexperienced in deer management.

2.6.5 The BDS believes that such powers should be used only in very exceptional circumstances, but the absence of such powers at present is significantly hindering the investigation of the role of deer in TB in a few localities.

2.6.6 As there is clear evidence that artificial feeding of wild deer significantly increases the transmission of TB, the BDS recommends that this practice should be strongly discouraged in all circumstances.

3 The basis of this submission

Facts and opinions within this submission are based upon published refereed literature or upon personal experience and research. Details can be supplied and comments and enquiries should be directed in the first instance to the BDS Veterinary Advisor through the Society's Headquarters address.

British Deer Society May 2004