Title Number : IW79155

This title is dealt with by Land Registry, Weymouth Office.

The following extract contains information taken from the register of the above title
number. A full copy of the register accompanies this document and you should read that
in order to be sure that these brief details are complete.
Neither this extract nor the full copy is an 'Official Copy' of the register. An
official copy of the register is admissible in evidence in a court to the same extent
as the original. A person is entitled to be indemnified by the registrar if he or she
suffers loss by reason of a mistake in an official copy.
This extract shows information current on 22 JUN 2014 at 20:46:13 and so does not take
account of any application made after that time even if pending in the Land Registry
when this extract was issued.
REGISTER EXTRACT
Title Number : IW79155
Address of Property : Land lying to the south of Main Road, Wellow, Yarmouth
Price Stated : 40,000
Registered Owner(s) : WILLIAM SACKVILLE GWYNNE LAWRENCE and MICHELLE FLORENCE
REINE LAWRENCE of Wellow House, Main Road, Wellow,
Yarmouth PO41 0SZ.
Lender(s) : None
1 of 3
This is a copy of the register of the title number set out immediately below, showing
the entries in the register on 22 JUN 2014 at 20:46:13. This copy does not take account
of any application made after that time even if still pending in the Land Registry when
this copy was issued.
This copy is not an 'Official Copy' of the register. An official copy of the register
is admissible in evidence in a court to the same extent as the original. A person is
entitled to be indemnified by the registrar if he or she suffers loss by reason of a
mistake in an official copy. If you want to obtain an official copy, the Land Registry
web site explains how to do this.
A: Property Register
This register describes the land and estate comprised in
the title.
ISLE OF WIGHT
1 (31.05.2013) The Freehold land shown edged with red on the plan of the
above title filed at the Registry and being Land lying to the south of
Main Road, Wellow, Yarmouth.
2 (07.01.2014) The Transfer dated 12 December 2013 referred to in the
Charges Register contains a provision as therein mentioned.
B: Proprietorship Register
This register specifies the class of title and
identifies the owner. It contains any entries that
affect the right of disposal.
Title absolute
1 (07.01.2014) PROPRIETOR: WILLIAM SACKVILLE GWYNNE LAWRENCE and MICHELLE
FLORENCE REINE LAWRENCE of Wellow House, Main Road, Wellow, Yarmouth
PO41 0SZ.
2 (07.01.2014) The price stated to have been paid on 12 December 2013 was
40,000.
3 (31.05.2013) RESTRICTION: No disposition by the proprietor of the
registered estate (other than a charge) or by the proprietor of any
registered charge prior to the expiration of 80 years from 3rd May 2013
is to be registered without a certificate of a conveyancer that the
disposition is not made in breach of the provisions of the Schedule to
a Transfer dated 3rd May 2013 and made between Ian Lister Kelly and
Patricia Mary McCowen (1) and Neil Robert Payne and Michelle Payne(2)
C: Charges Register
This register contains any charges and other matters
that affect the land.
1 (31.05.2013) The land is subject to the rights granted by a Deed of
Grant dated 9 May 2002 made between (1) Ian Lister Kelly and Patricia
Mary McGowen and (2) Southern Water Services Limited.
The said Deed also contains restrictive covenants by the grantor.
NOTE: Copy filed under IW78009.
2 (31.05.2013) A Transfer of the land in this title and other land dated
3 May 2013 made between (1) Ian Lister Kelly and Patricia Mary McCowen
and (2) Neil Robert Payne and Michelle Payne contains restrictive
covenants.
NOTE:-Copy filed under IW78248.
3 (07.01.2014) A Transfer of the land in this title dated 12 December
2013 made between (1) Neil Robert Payne and Michelle Payne and (2)
Title number IW79155
2 of 3
C: Charges Register continued
William Sackville Gwynne Lawrence and Michelle Florence Reine Lawrence
contains restrictive covenants.
NOTE: Copy filed.
4 (07.01.2014) The land is subject to the rights reserved by the Transfer
dated 12 December 2013 referred to above.
End of register
Title number IW79155
3 of 3
Preventing or controlling ill health from
animal contact at visitor attractions
Industry Code of Practice
Version 1 published June 2012
CONTENTS
Page
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Part 1: PRINCIPLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Chapter 1: What is risk? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Chapter 2: Guiding principles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Part 2: PRACTICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Chapter 3: Planning and organising . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Chapter 4: Risk assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Part 3: SUPPORTING INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
Chapter 5: The role of information in risk control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
Chapter 6: Advice to teachers and others who organise visits for children . . . . . . . . . . . . . . . . . . . . . 45
Chapter 7: Incident reporting and investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Chapter 8: Dealing with a major incident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Chapter 9: The law and visitor safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
Appendix 1: Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
Appendix 2: Sources of advice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
1
Every year millions of people visit premises where members of the public, particularly children, are
encouraged to view or touch animals.
The purpose of this Code of Practice is to help ensure visitor health and safety by providing
sensible, practical and proportionate guidance on preventing or controlling ill health at
visitor attractions.
This Code of Practice has been produced by the industry and is aimed at the owners, operators and
managers of such visitor premises.
It provides guidance, including pictures and real-life case studies, of practical measures that you can apply at
your premises to help you comply with the law and keep visitors safe. The examples are from businesses,
ranging from conventional farms that open to the public for one day a year to attractions that may cater for
hundreds of thousands of visitors each year.
The code is modelled on Managing Visitor Safety in the Countryside, principles and practice published by
the Visitor Safety in the Countryside Group (www.vscg.co.uk).
Context
INTRODUCTION
The Health and Safety Executive was consulted
in the production of this publication. It endorses
the sensible, proportionate, reasonable and
balanced advice to owners on managing visitor
health and safety set out in the industry Code of
Practice.
Health and Safety Executive
The Chartered Institute of Environmental
Health supports the adoption and promotion of
this Industry Code of Practice and believes that
compliance with these standards will be the means
to minimise risks to health from visitor contact with
animals.
The Chartered Institute of Environmental Health
The Code of Practice is based on guidance from the Health and Safety Executive (HSE) Agriculture
Information Sheet No 23(rev2) Preventing or controlling ill health from animal contact at visitor attractions
(AIS23), which has been withdrawn. AIS23 was revised following the outbreak of Escherichia coli O157 at a
visitor attraction in Surrey in 2009. The Health Protection Agency (HPA) set up an Independent Investigation
Committee chaired by Professor Grifn the report of which, Review of the major outbreak of E. coli O157
in Surrey, 2009 was published in June 2010 and can be found at:
http://www.grifninvestigation.org.uk/
The proposal to develop the Code of Practice to replace existing HSE guidance was discussed with
Professor Grifn and the Advisory Committee on Dangerous Pathogens.
The Code of Practice has been produced by the Access to Farms partnership which includes
representatives of a number of organisations whose members encourage visitors, especially children, to visit
their farm attraction, farm or other attraction to view, touch or pet animals.
2
Access to Farms members
3
Visits to these attractions have increased signicantly over recent years and every year millions of people go
to these attractions.
These visits play a valuable part in the education and development of children and young adults, and
provide an enjoyable experience for many people. It is uncommon for members of the public to become
ill as a result of such visits. However, there have been a relatively small number of cases of serious ill health
involving members of the public resulting from exposure to micro-organisms such as E. coli O157 and
Cryptosporidium carried by animals.
As with most activities, visits to farms and farm attractions can never be considered free from risk. However,
we believe it is possible to reduce the levels of risk and still provide a valuable and enjoyable recreational
and educational experience.
Premises covered by the Code of Practice
These include:
Farm attractions such as open farms and farm parks.
Animal contact enclaves within other attractions, including those at zoos.
City farms or other educational establishments.
Working farms with livestock that occasionally open to the public, e.g. for school visits or to participate
in Open Farm Sunday or similar events.
Rare breed and rescue centres.
Agricultural shows or country fairs where livestock are present.
Travelling menageries or mobile petting enterprises.
Other similar visitor attractions at which the public have contact with animals.
Whilst the general principles covered in this document are equally applicable to zoos, specic guidance
on managing zoonotic disease (disease passed from animals to humans) in zoos is contained in Managing
zoonotic risk in zoos and wildlife parks. This can be found at:
http://www.biaza.org.uk/uploads/Animal%20Management/zoonoticrisk.pdf
This Code of Practice does not apply to the following destinations except where they may have an animal
contact enclave:
Moors and mountains
Historic properties
Forests
Way marked trails
Waterways
Open countryside
Visitor centres
Nature reserves
Footpaths
Country parks
Archaeological remains
For these settings, guidance in the Managing Visitor Safety in the Countryside: Principles and Practice
booklet is applicable.
4
There are several reasons for managing visitor safety:
Moral: First and foremost we want our visitors to return home happy and satised with their experiences.
We have a moral obligation to consider their health and safety and protect them from unnecessary or
unreasonable risk.
Legal: We have legal duties to ensure the safety of those we do not employ but who are affected by our
workour visitors. These duties are explained in more detail in Chapter 9.
Financial: We need to demonstrate that all reasonable and practicable steps have been taken to reduce
the risks, thereby reducing unnecessary costs arising from implementing inappropriate or disproportionate
health and safety measures.
Reputation and authority: We cannot create an environment that is free from all risk. However, we must
demonstrate to the public, regulators and government that we have done all that is reasonably practicable
and within our powers to control or minimise the risks down to acceptable levels. If there is a zoonotic
outbreak, we are then in a much better position to defend our position and retain public trust.
Business: Attracting and satisfying visitors is fundamental to many of our businesses. Creating a healthy and
safe environment is essential to attract visitors and therefore makes good business sense.
Education: There is an educational benet from demonstrating how good practice results in healthy and safe
visitor experiences, with potential transferable learning value to our visitors.
This Code of Practice covers the building blocks of visitor risk management and aims to improve standards
across the industry whilst promoting consistent enforcement by the regulators.
The principles contained within the Code of Practice provide a framework to guide management decisions
and ensure that the experiences of visitors are memorable for the right reasons.
Subsequent chapters deal with specic areas of risk management. The headings will be familiar to readers
with a background in occupational safety or knowledge of the HSEs Guide to Successful Health and Safety
Management (HSG 65).
The Code of Practice describes the measures that need to be taken to protect visitors. It does not
address the health and safety of staff, including employees, volunteers and helpers. Nor is it aimed at
premises that offer work experience where children come to carry out work activities. It is also not
intended to address premises where agricultural or horticultural activities are undertaken by members of
the public, such as allotments on city farms and similar premises. We still have a duty to comply with our
legal obligations to protect these people and risk assessments for the activities they undertake will need
to be carried out.
5
CHAPTER 1: WHAT IS RISK?
Consideration of risk is important at several levels:
Potential risk to society
Reduction of educational and development opportunities. Many children and young adults derive great
educational and developmental benet from visiting our sites, learning through experience.
Potential risk to the individual:
Personal illness or death
Long term effects of illness
Loss of employment, income, or educational opportunities
Impoverished experience
Increased costs
Passing disease onto relations and friends.
It is important to understand how people view and accept risks. People are likely to be less tolerant of
risk when:
They are exposed to the risk whether they want to be or not (involuntary exposure).
They have no control over the outcome.
There is uncertainty about what could happen and its likelihood of happening.
They have no personal experience of the risks involved (fear of the unknown).
It is difcult to imagine the level of exposure to risk.
There is potential for a major catastrophe (even though the risk of it happening may be low, should it
come about the consequences would be severe).
The benets of taking the risks are not clear.
They are exposed to the risks but others get the benets.
The potential illness would result from human failure.
It involves vulnerable groups including children.
Some of these factors account for peoples common misconceptions when asked to rank the relative safety
of road, rail and air travel. There is often a mismatch between an individuals perception of risk and that
deduced from risk assessment.
Part 1: PRINCIPLES
6
Potential risk to your organisation:
Damage to reputation.
Loss of income if visitors dont come because they perceive that the risk of harm is too great.
Civil claims arising from visitor illness, leading to nancial loss.
Prosecution and penalties for breaches of criminal law.
Impact on the morale and esteem of employees.
Adverse outcomes like these arise from either a failure to recognise and deal with a hazard or through
making the wrong response. Our aim is to have the best of both worldsto introduce risk control
measures that are sufcient to safeguard visitors, but do not lessen the attraction.
What are the animal-related ill health risks at visitor attractions?
All animals naturally carry a range of micro-organisms, some of which cause no illness in the animal but can
be transmitted to humans. Diseases passed from animals to humans are known as zoonoses. Some zoonotic
diseases may cause ill health; in some cases the diseases may be severe or life threatening. Equally, some are
more amenable than others to treatment, and some may leave lasting ill health.
A range of zoonotic diseases can be acquired from animal contact at visitor attractions including:
Verocytotoxigenic Escherichia coli or VTEC of which E. coli O157 is one
Cryptosporidium parvum
Chlamydophilia abortus (formally called Chlamydia psittaci)
Toxoplasmosis
Salmonella spp.
How do people become infected?
People can become infected with micro-organisms through consuming contaminated food or drink, through
direct contact with contaminated animals, by contact with an environment contaminated with animal faeces
or by being bitten. Very low numbers of micro-organisms can cause human infection.
How safe is a visit to an attraction?
Given an estimated 10 million people visit such attractions each year, we consider the risk of infection
to be low.
A review by the Health Protection Agency, published in 2010, found that there were 55 outbreaks of
gastrointestinal disease linked to petting farms between 1992 to 2009 in England and Wales. An HPA press
release said: Although the overall risk of infection is low in light of the millions of farm visits each year, these
outbreaksover a 17-year periodled to 1,328 people becoming infected, of whom 113 were hospitalised.
Illness ranged from mild through to severe diarrhoea and occasionally more serious conditions. The majority
of these outbreaks were caused by E. coli O157 (55 per cent) or Cryptosporidium (42 per cent).
http://www.hpa.org.uk/NewsCentre/
NationalPressReleases/2010PressReleases/101215Handwashingkeytoreduceriskfromfarmvisits/
7
We acknowledge that zoonotic disease can be very serious for those affected, particularly young children
and the elderly. However, the risk needs to be seen in the context of an historically very low incidence of
infection at visitor attractions where the public are encouraged to view or touch animals. Although the
number of reported cases of zoonotic diseases varies from year to year, there is no evidence to suggest a
substantive increase in the prevalence or incidence of infection in Britain.
8
CHAPTER 2: GUIDING PRINCIPLES
This chapter sets out the principles that we use to guide us when deciding what actions to take to reduce
the risk of zoonotic diseases to visitors. Subsequent chapters expand on these principles.
AWARENESS
Ensure that your visitors know the risks they face.
Visitors should be aware of the risks they face and have the chance to decide whether or not to accept them.
Inform and educate your visitor about the nature and extent of hazards, the risk control
measures in place, and the precautions that they themselves should take.
Risk can be controlled through information and education as well as physical measures. People on organised
visits, e.g. school trips, can be made aware of hazards in advance through their organisers. Information can be
included on the attractions website and on site maps/plans given to visitors on arrival. Signs and notices at
entrances and around the site are also an important means of communicating information.
RESPONSIBILITY
It is reasonable to expect visitors to exercise some degree of personal responsibility.
It is reasonable to expect visitors to follow simple instructions made known to them by staff or on
leaets and signs - such as washing hands before eating, drinking or smoking and washing hands after
leaving contact areas.
Visitors should be expected not to touch or approach animals they may be allergic to, or where signs
specically prohibit contact.
It is reasonable to expect parents, guardians and leaders to supervise people in their care.
Parental/carer responsibility should include, for example, supervising children when washing their hands and
preventing young children sucking their ngers immediately after handling animals or their environment.
RISK CONTROL
Assess risks
Every attraction should carry out a site risk assessment.
A risk assessment would typically involve: identifying how the public could be exposed to micro-organisms;
the likelihood of it happening; the possible consequences, and what measures need to be taken to reduce
the risks to an acceptable level. The risk assessment would indicate the need to carry out further assessment
after a specied interval, or when there is a change in the activities provided. It should be reviewed regularly
to verify risk mitigation strategies are in place and are working.
9
Risk control measures should be consistent.
Consistency is important within a particular site and between organisations. Note that consistency is not the
same as uniformity.
Monitor the behaviour and experiences of visitors to review visitor safety plans.
Learn from experience of incidents and near misses. Add questions about accidents to visitor surveys. Have
systems in place for accident reporting and investigation, and for letting others know what lessons you have
learned. Monitor changes in the number and type of visitor to ensure risk controls remain valid.
10
CHAPTER 3: PLANNING AND ORGANISING
This chapter introduces a framework for planning your approach to visitor safety, ensuring that it integrates
with other management activities. We build on the general principles set down in recognised management
systems.
1
Whilst some of this chapter may be familiar to those in occupational health and safety, it is
intended to help the wider range of people involved in visitor safety management.
Elements of an organisations Visitor Safety Plan
Whatever the size of organisation and resources available, establish a policy for visitor safety and have a
strategy for its implementation. Set clear objectives and have a good management plan to achieve them.
Learning from experience is important. You should review the outcomes and, if necessary, make changes to
improve things.
Visitor safety management is no different to other management processes that demand a systematic
approach, as shown in the diagram below.
Part 2: PRACTICE
Plan Do Check Act
Review
Policy and
Planning
Implementation
and Operation
Performance
Monitoring
Learn and
Improve
Refer to
Guiding Principles
11
1. Plan
Policy and strategy development
Developing a policy for visitor safety management and promoting a strategy for its achievement will ensure
effective use of your organisations resources as well as ensuring visitor safety.
An effective policy will:
Demonstrate the commitment of senior management to visitor safety.
Integrate visitor safety management with other relevant organisational policies and management activities
throughout the organisation.
An effective strategy will:
Clearly set out how your organisation is structured to deal with visitor safety issues.
Show where you are now, where you want to be, and set out the steps to get there.
Identify the resources, in money and staff time, necessary to achieve the objectives.
Planning and organising
Develop plans for visitor safety management at appropriate levels, depending on the size and structure of
the organisation.
The types of organisation involved with visitor attractions are varied, ranging from small farms that open
to the public one day a year to large enterprises attracting 250,000+ visitors each year. It is reasonable
to expect a large attraction to have a detailed safety plan. For a small farm open one day a year a risk
assessment would sufce.
2. Do
Implementation and operation
How will you communicate relevant information to visitors?
See Chapter 5 for further information on communication.
Dene clear roles.
State who is responsible for carrying out each task, producing overall visitor safety plans, undertaking individual
risk assessments and acting on their ndings. Be clear who will audit the process and review progress.
List the hazards that your visitors might encounter and assess the risk that they might be harmed.
Risk assessment is central to visitor safety management and is covered in more detail in Chapter 4.
Take care when using generic risk assessments or guidance. They may need adapting to take account of local
circumstances. It is essential to use the knowledge of staff and users who are familiar with the site.
12
3. Check
Performance monitoring
Plan a programme of inspection and keep clear records of your risk assessments and actions.
It helps to follow a written programme of priorities, keeping a record of what has been done and where
and listing work planned for the future. You will then be able to demonstrate progress and ensure that the
investigation and resolution of any outstanding issues is put into your work programme.
Learn from incidents and near misses.
Incident and accident data is a valuable indicator of risk and provides a measure of performance. Do
not ignore near misses, encourage staff to report them and treat them as an opportunity to learn from
something that did not quite happen, this time.
4. Act
Learn and improve
Learn from the information that you have gathered and act to make improvements. Incorporate
mechanisms into routine work that allow feedback to be used to improve services and safety for visitors, or
to explain why no changes are being made.
5. Review
Review against guiding principles
Review is a key part of a management process. Check at each stage that decisions are consistent with the
guiding principles. You should measure progress against plans, identify problems and instigate any corrective
actions that may be necessary.
1. References and further information
Recognised Management Systems:
BS 8800Guide to occupational health and safety management systems
OHSAS 18001Health and safety
HSG65Successful health and safety management (HSE)
13
CHAPTER 4: RISK ASSESSMENT
This chapter sets out the steps necessary for successful risk assessment. This includes the information
required, a suggested methodology and lists what should be recorded. We also look at the relative merits of
different ways of controlling risks and the need to consider controls that reduce risk.
Assessing risks to visitors
There is no universally accepted format for carrying out risk assessments. The HSE recommends a ve-step
approach for risk assessment in the work place. We have used this model as a basis for assessing risks facing
visitors to our premises.
1. Identify the hazards.
2. Consider who might be harmed and how.
3. Evaluate the risks and decide whether the existing risk control
measures are adequate or whether more should be done.
4. Record your ndings and implement them.
5. Review your assessment and update if necessary.
Hazard is anything with the potential to cause harm.
Risk is the likelihood, high or low, that somebody will be harmed by the hazard, the severity of the
harm and the number of people who might be hurt.
Risk control measures are precautions to make an incident less likely to occur and/or the
results less severe.
Further information on risk management can be found on the HSE website at:
http://www.hse.gov.uk/risk/index.htm
Step 1 Identify the hazards
All animals naturally carry a range of micro-organisms, some of which can be transmitted
to humans, in whom they may cause ill health, which in some cases may be severe or life
threatening.
VTEC (including E. coli O157)
One organism that may be present is the verocytotoxin-producing bacterium E. coli O157. E. coli O157 can
cause serious illness, especially in young children and the elderly in whom symptoms may include bloody
diarrhoea and kidney failure. The illness may occasionally be fatal.
14
You should assume that your animals carry E. coli O157 even though they have no signs of this.
Cattle, sheep and goats are the main recognised carriers of E. coli O157. The organism may occasionally
be found in other animals, especially amongst the mixed species often present at visitor attractions. These
include pigs, chickens, horses, donkeys, deer, llamas and alpacas. Farm dogs and wild rabbits can pick up the
infection from an infected environment. Infection can also occur in birds such as wild geese. The organism is
primarily transmitted through contact with animal faeces (dung). It may also be transmitted by contact with
saliva derived from animal grooming activities.
Cryptosporidium parvum
Cr yptosporidium par vum is a microscopic parasite predominantly carried by calves, lambs, deer and goats
that can cause severe diarrhoea in young children and the elderly. It is capable of surviving for a long time
in the environment.
Chlamydophilia abortus
Visitors may also be exposed to Chlamydia abortus (formally called Chlamydia psittaci), the agent of enzootic
abortion and ovine chlamydiosis in humans. This bacterium is carried by sheep and possibly goats. In humans,
it may cause abortion or u-like illnesses.
Other zoonoses that may be present at visitor attractions include:
Salmonella spp.
Orf
Q fever
Ringworm
Campylobacter spp.
Leptospirosis
Toxoplasmosis
Step 2 Consider who might be harmed and how
People can become infected with micro-organisms by consuming contaminated food or drink, through
direct contact with infected animals, by contact with an environment contaminated with animal products
such as faeces, or by contact with saliva.
Very low numbers of micro-organisms can cause human infection.
Anyone can be infected, but children and the elderly are the most vulnerable. Young children are particularly
at risk because they are most likely to put contaminated ngers or items in their mouths (including thumb
sucking, nail biting and dummies/toys). Women who are, or may be pregnant, and people with weakened
immune systems, are also at risk. Only small numbers of the organism are required to cause illness, so just
because something (an animal or an object) is not visibly contaminated with faeces, this does not necessarily
mean it is free from risk.
15
Infection can occur when people come into contact with animal faeces or saliva by:
Touching or kissing animals in petting areas or during bottle-feeding.
Feeding, stroking or touching animals through gates or pens.
Touching gates, or animal pen divisions, or other structures contaminated with faeces.
Picking up contaminated feed from the oor.
Removing contaminated footwear or clothing.
Eating, drinking and smoking with contaminated hands.
Using contaminated play equipment.
Touching personal items taken on to the premises that have become contaminated e.g. dropped toys or
dummies and pushchair wheels.
Being bitten.
Step 3 Evaluate the risks and decide whether the existing precautions are adequate or
whether more should be done
The Code of Practice contains a number of case studies outlining how different types of visitor attraction have
identied risks and come up with solutions to them. In some cases, the solutions have not only ensured control but
lead to an increase in visitor numbers.
The level of overall risk depends on a combination of factors: the likelihood of harm arising; the severity of
the harm, and the number of people who might be affected.
Sign advising women about possible health risks
16
When undertaking your assessment you should be aware that:
All animals (including birds) carry micro-organisms such as E. coli O157 that could represent a hazard to
human health. Animals carrying infection can still appear healthy.
Ruminants (e.g. cattle, sheep and goats) carry E. coli O157.
E. coli O157 is also found in a range of other animals and birds.
Although tests are available to detect the presence of E. coli O157 and other micro-organisms, a negative
test result does not guarantee the animal is free of infection.
E. coli O157 may be introduced to your premises at any time by new stock, wild birds and animals, or
by visitors.
Young stock, stock under stress, pregnant stock or stock that are unfamiliar with people are more likely
to excrete micro-organisms such as E. coli O157.
Other animals on the premises, including pets, may acquire the bacterium through contact with
faeces etc.
Control measures
Control measures are actions that need to be taken to prevent or reduce exposure to a substance
hazardous to health, in this case micro-organisms. Such measures include the layout of the premises
(including giving regard to topography); the cleaning of the premises; provision and use of washing facilities;
supervision; information, and signage. A combination of control measures will be necessary to protect the
health of visitors. To be effective, these measures should be practical, workable and sustainable. They should
be reviewed on a regular basis.
Controlling the risk
In order to minimise and control the risk you should concentrate on the following:
Establishing premises layout and routes, including areas to which visitors should not have access.
Dening, segregating and clearly identifying animal contact areas.
Dening, segregating and clearly identifying non-animal contact areas.
Dening, segregating and clearly identifying eating and play areas.
Providing adequate and suitable washing facilities.
Providing visitor information and signage.
Providing training and supervision of staff.
Establishing livestock management procedures including management of bedding, sick/pregnant/stressed
animals and veterinary input.
Controlling manure/run-off and compost heaps.
These are discussed in more detail in the following sections.
The diagram below shows the risk pathway for micro-organisms such as E. coli O157 and demonstrates
how the pathway can be broken by control measures.
The risk pathway for micro-organisms
Clean site
& avoidance of
faecal contact
Effective
handwashing/hygeine
Denotes point
where pathway
can be broken
Micro-organism
e.g. E. coli O157
in faeces/saliva
Contamination
of environment
Contamination
of hands
Ingestion of
micro-organism
Infection in
some individuals
Infected
animal
Contact prevented e.g.
by double fencing
X
X X
X
17
18
Premises layout and routes
You should:
Decide which areas you want visitors to have access to.
Make sure routes around the premises prevent visitors
from entering non-access areas, e.g. places where work is
going on or where manure is stored.
Consider how you will prevent entry to non-access areas.
For example, providing suitable fencing and warning signs;
Direct visitors to washing facilities as they leave any
animal contact area, before they access eating and play
areas and before leaving the premises.
Avoid directing visitors across tracks or routes regularly
used by stock and farm vehicles. If this is not possible,
make sure visitors do not have to walk through any build
up of faeces, liquid efuent, or soiled bedding material. For
example, regularly clear or clean routes used by livestock
or when cleaning out pens etc, and provide duckboards
or similar so that visitors avoid contaminating their
footwear.
Keep the premises as clean as practicable and ensure
areas to which visitors have access are free from any
build-up of faeces.
Clear sign on locked gate
Well signed entrance to animal feeding area
Take the following precautions if you
intend to use elds that have been
used for grazing or keeping stock for
recreational activities e.g. picnicking,
camping or play area. :
Keep farm animals off the elds for
at least three weeks prior to use.
Remove any visible droppings,
ideally at the beginning of the
period.
Mow the grass, keep it short and
remove the clippings before the
elds are used for recreation.
Keep farm animals off elds during
use.
Always wash hands before eating,
drinking and smoking.
Ensure adequate supervision of
children, particularly those aged
under ve.
19
Animal contact
You should:
Decide on suitable contact areas where visitors
will be able to pet or feed animals.
Decide which animals are suitable for contact
areas. Sick or injured animals should be excluded
from contact with the public.
Not allow the public to enter pens where
animals are housed (this is because faeces or
contaminated bedding will be underfoot and
visitors may themselves carry infections on their
footwear that could put your animals at risk).
Do not allow visitors to enter pens where
animals are housed
Visitors can be allowed to enter pens or enclosures specically designed for the handling of animals,
such as pens which lambs are brought into for feeding. These should be closely supervised and be near
to washing facilities. Staff should remind visitors to wash their hands after animal contact e.g. feeding the
lambs. The staff should also remove faecal contamination from the pen as soon as possible.
Ensure adequate and suitable washing facilities are
available and are used by visitors when leaving
contact areas.
Ensure fencing and other barriers are regularly
inspected and properly maintained.
Ensure that animal contact areas where visitors
stand or walk are as free as possible from any
faeces, and put in place measures to prevent
contamination from liquid manure or surface run-
off where necessary.
Regularly clean and disinfect pen divisions and
gates in animal contact areas where visitors are
able to touch them. A variety of cleaning methods
are available. Not all disinfectants are suitable so
take advice from your vet.
Dont allow faeces to remain on and contaminate
walkways or other areas used by the visitors.
Dont allow contaminated bedding or run-off
material to contaminate walkways or other areas
used by visitors. Solid boarding at the base of pens
can be used to prevent spillage onto walkways.
Retain all bedding and faecal material
within the pens
Ensure that eating (including sweets,
gum and ice cream), drinking, putting
contaminated items in mouths (including
dummies, pens and pencils) are
discouraged and smoking is prohibited
in animal contact areas. Signs should
be displayed instructing visitors of this
requirement.
Ensure an adequate number of trained
staff for contact areas.
Where eating and play areas are adjacent
to areas containing animals, ensure
that measures are provided to prevent
members of the public touching the
animals, e.g. by providing double fencing.
This should be positioned at a distance
that will prevent visitors reaching through to touch the animals and to prevent animals reaching over or
through the fence to contact people.
Do not allow run-off to contaminate walkways
Example of double fencing, stock and electric
fences used together
Single fencing can
be acceptable on
farm trails
Example of double fencing, high and low stock fences
20
In some non-contact areas, it will not be reasonably practicable to provide double fencing along enclosures
where animals are kept. Examples include livestock farms that open occasionally, such as on Open Farm
Sunday, or along a farm walk/trail through elds. In such cases, the areas should be clearly signed to inform
visitors they are entering a non-contact area and touching, petting and feeding of animals is not allowed.
Eating and play areas should be located within non-contact areas. Any decision to rely on single fencing and
signage rather than double fencing must be justied in your risk assessment.
Food is allowed to slide down the pipes into the
pen for the pigs
Food is placed in the trailer and by turning a handle the
tractor and trailer back out and the food is tipped from
the trailer for the cattle
Problem 1
Animal paddocks were not double fenced and play areas
and picnic benches were nearby.
Solution
I did not want double fence with stock fencing and rails
because this made the animals seem too far away. So, we
used high tensile wire with three strands and electried
it far enough away from the main fence so no one could
touch it or the animals. We also put standpipes in all the
gateways so we can pressure wash the paddock sweeper
to avoid contamination of walkways.
Cost: Labour 1,500 Materials 2,195
Outcome
The result is exactly what we wanted. The whole area is
now a clean area for picnics and play. And we dont get
any goats heads stuck in the fencing!
Problem 2
Stopping contamination of walkways.
Solution
The solution was easy. We put sleepers
along the bottom of the gates and in
some places we have put sheep hurdles
in front of the gates as well to create an
area where no one walks.
Cost: Sleepers 2.4mts 18.99 Sheep
hurdles 21.00 each.
Outcome
We now have animal areas with no
faecal material in the walkways. This has
reduced the risk of contamination of
footwear.
Case study: Mead Open Farm, Billington, Bedfordshire
This is a commercial attraction with approximately 160,000 visitors each year.
21
Children can still enjoy feeding animals in non-contact areas
22
Eating areas
You should:
Site eating or picnic facilities away from areas where animals can be contacted, or where wind blown
contaminated material (e.g. straw from muck heaps) might be present, and preferably at the end of any
farm trail, walk or tour, or outside the main areas of the premises.
Ensure that visitors have to pass through or by washing facilities before entering eating areas.
Ensure visitors are advised, e.g. by adequate signage, to wash their hands before eating.
Exclude animals including captive birds from eating areas. They could contaminate eating areas with
faeces. Consider wing clipping, double gates into eating areas and adequate fencing to exclude them.
Where eating areas are adjacent to animal contact areas, prevent animal contact, e.g. by providing double
fencing. This should be positioned at a distance that will prevent visitors reaching through to touch the
animals and to prevent animals reaching over or through the fence to contact people.
Provide adequate waste bins and clear discarded food from eating areas to discourage wild birds and
rodents from feeding and contaminating the area.
Locate ice cream and sweet kiosks in the non-contact areas of the premises, such as the eating areas or
at the exit where visitors have passed washing facilities. Remind visitors using the kiosks, by notices or
verbally, to wash their hands before touching or eating purchased food or sweets.
This is not acceptable. Where eating areas are
situated next to animal contact areas, animal
contact must be prevented.
Double fencing to prevent contact with animals
23
Play areas
You should:
Site play areas away from areas where animals can be contacted, and preferably at the end of any farm
trail, walk or tour, or outside the main areas of the premises.
Ensure that visitors are advised, e.g. by adequate signage, to wash their hands before and after using play
areas.
Exclude animals including captive birds from play areas. They could contaminate play areas and
equipment with faeces. Consider wing clipping, double gates into play areas and adequate fencing to
exclude them.
Where play areas are adjacent
to animal contact areas, prevent
animal contact, e.g. by providing
double fencing. This should be
positioned at a distance that will
prevent visitors reaching through
to touch the animals and to
prevent animals reaching over
or through the fence to contact
people.
Ensure that play areas and
equipment are designed so
they can be cleaned on a
regular basis to remove any
contamination.

Washing facilities on side of food kiosk Sign reminding visitors to wash hands
before eating or drinking
Double fence between play and animal area
24
Washing facilities
While the primary control measures should focus on
reducing and eliminating faecal contamination, the most
effective method of removing dirt and contamination
remains hand washing with soap and running hot and cold,
or warm water followed by hand drying. Soap bars can
easily be dropped onto the oor. Liquid soap is a better
solution.
Washing facilities should be provided at or near the exits
from any area/premises where visitors are encouraged to
have animal contact.
Cleansing wipes or anti bacterial gels are not an
acceptable substitute for proper hand washing.
At temporary events, such as agricultural shows, where
suitable permanent washing facilities are provided (e.g. a
purpose built toilet and washing block), it is acceptable
practice for animal exhibitors or others to provide information and signs to indicate that visitors should
use these facilities after contact with the animals. If such general visitor washing facilities do not exist or are
not situated close by, it will be necessary to provide suitable temporary washing facilities. Washing facilities
should be positioned close to areas where animal contact is allowed.
Further guidance on the provision of washing facilities at agricultural shows is being developed with the industry.
The provision of adequate numbers of washing facilities and their location is crucial to preventing ill health.
Facilities can be individual taps and basins, and/or long sinks with a number of running water outlets. They
need to be provided and easily accessible at or near:
Areas where visitor contact with animals is allowed, such as petting barns. If there is a one-way system
for visitors through the contact area they should be provided immediately adjacent to the exit. If there is
a two-way ow of visitors they should be provided immediately adjacent to entrances and exits. A one-
way system may help to ensure that washing facilities are properly used;
Entrances to eating areas.
Exits from the premises.
Signage or other means of public
communication should state this
25
Washing facilities
An acceptable way to estimate the capacity of washing facilities is to:
Estimate the maximum number of visitors expected or permitted at one time.
Consider how many visitors will be in animal contact areas at any timeyou may already limit numbers
in these areas to allow visitors time to enjoy the experience with the animals.
Assess the rate at which visitors will leave contact areas, e.g. in large groups such as school parties or a
few at a time.
Estimate the time taken to wash hands effectively, remembering that a thorough hand wash may take up
to two minutes.
If you estimate that, for instance, 30 people will leave a contact area every 15 minutes, and each person will
take two minutes to wash their hands, you should provide enough washing facilities for four people to use at
one time (30 x 2 divided by 15 = 4). Make similar calculations for other locations around the premises, such
as the main exits or entrances to eating areas.

You can supplement permanent facilities with temporary ones at busy times, e.g. just before the summer
holidays, in remote areas of the premises, or for short duration events such as country shows or fairs.
Portable units can be hired which have heating, lighting and running water.
Portable hand wash stations
All washing facilities should be/have:
Accessible by all visitors, i.e. at the right heights for both children and adults or with raised standing areas
provided for children. Check these do not create tripping or falling hazards.
Running hot and cold, or warm water (e.g. mixer taps). It is easier to create soap lather with warm water,
and it may encourage visitors, especially children, to wash more thoroughly particularly in cold weather.
Warm water supplies should be tted with a means of restricting the temperature to no more than
43C to avoid scalding.
Liquid soap as soap bars can be dropped on the oor. Bactericidal soaps are not necessary.
Paper towels in and near animal contact areas, as they provide an additional opportunity to remove
contamination. Elsewhere, hot-air hand-dryers are suitable but may lead to queues that discourage
visitors from washing their hands. Reusable hand towels are not suitable.
Properly maintained and cleaned regularly as required, at least daily.
Replenished with paper towels and soap as necessary.
Open or pedal operated waste bins that are emptied as necessary.
Arranged so that visitor throughput and/or water overows etc. do not make the immediate vicinity
muddy and put people off using the washing facilities.
Case study: Dairy farm hosting four school visits a year (50 children)
Problem
HSE issued an improvement notice relating to hand washing and the use of gels.
Solution
Two additional hand wash basins with warm water, liquid soap dispensers, paper towel dispensers and bins
were installed. The position adjacent to the calf feeding area was agreed with the inspector. Signage was put
up advising people to wash hands. The location was noted in the teacher information pack.
Outcome
More schools are asking to visit since the farm advertised improved washing facilities
26
27
Case study: Ouseburn City Farm, Newcastle
(in excess of 20,000 visitors each year)
Problem1
Environmental Health would not allow the attraction to open its main pedestrian gates because no hand
washing facilities were nearby.
Solution
Money was raised through Newcastle City Council Access Fund to install an external hand washing trough.
This is accessible to children, adults and wheelchair users. Installation included a hand washing trough with
three sets of hot and cold water taps, water feed, hand towel dispenser and tiling.
Cost: approximately 1500
Outcome
The main pedestrian gates can now be opened, allowing the public to enter the farm without having to go
through the visitor centre. The farm entrance is more welcoming and there has been an increase in visitors
who all see the external hand washing facilities and use them.
Problem 2
The signage for hand washing was unclear.
Solution
The hand washing toolkit of the Federation of City Farms and Community Gardens was used to produce
some A4 laminated signs.
Outcome
There is now clear signage throughout the site, advising visitors to wash hands after touching the animals
and showing the location of hand washing. Visitors (including children) are regularly overheard telling each
other to wash their hands.
Only in exceptional circumstances, such as premises that open on an occasional basis in the summer, it may
be acceptable to provide cold running water only, soap and disposable towels. This must be justied in your
risk assessment.
28
Case study: Molescroft Farms Ltd
This is a large arable farm with environmental stewardship. When there are group visits, neighbouring farms
bring cattle and sheep.
During school visits, 30 children attend. Open Farm Sunday can attract up to 250 people. In addition, 300
primary school children visit the Friday before Open Farm Sunday.
Problem
The new toilets and sinks (with hot water) are ne for most visits. However, on the Friday before Open
Farm Sunday the hand washing facilities are not adequate to cope with 300 children.
Solution
They made troughs out of clean unused
sheet foot troughs and tted these under
a line of taps. Cold water was supplied
from two different taps to ensure
sufcient water pressure. Liquid hand wash
was provided under each tap.
Outcome
Children like it. It is only used during
summer so cold water is adequate. During
the rest of the year the normal facilities
are adequate for the reduced number
of visitors. Although it is temporary, the
hooks have been left in position so it can
easily be put back whenever there are
large numbers of visitors (probably every
summer now).
Do not provide buckets or troughs of standing water that are shared or reused by several people. They
do not allow effective hand washing and reusing water can spread micro-organisms among those using it.
Adding a disinfectant to the water does not make the practice acceptable.
29
It is important to encourage your staff, parents, teachers and others who have responsibility
for visitors to make sure that children and other visitors wash their hands properly.
This is not acceptable. Dirty water will be contaminated
Parents should ensure children wash their hands properly
30
Case study: South of England Agricultural Society
Countryside Day for Schools
(2,500 pupils)
Problem
Ensuring pupils do not eat or drink in the livestock area and wash their hands before visiting the food hall
and prior to lunch. Making sure teachers have all the information and take responsibility.
Solution
At the pre-event brieng for teachers, the importance of hand washing was emphasised and a copy of HSE
guidance was given to all teachers.
A map of the site highlighted the location of hand washing facilities.
The existing hand washing facilities were checked for adequacy. As a result, lower hand towel dispensers
were tted to ensure children could reach them.
Extra control measures put in place. A one-way system was introduced in the livestock building so that
children exited past the toilets. This was pointed out at the brieng and highlighted by signage at the event.
Signs were put up to remind visitors about no eating and drinking in the livestock area, wash hands before
touching food etc.
Directional signs to toilets were put up on the day.
The refreshment area for animal exhibitors was moved to outside the livestock building.
Outcome
Apart from the lower hand towel dispensers, the actual facilities were not improved. However, organisation
was improved and measures put in place to make the event as safe as possible.
Example of a hand wash station on mobile petting attraction.
31
Cleaning footwear, pushchairs, wheel chairs etc
The layout of the premises should be planned to minimise the likelihood of contamination of footwear,
pushchairs, wheel chairs etc. Where this unavoidably occurs, you will need to consider providing
suitable facilities to allow visitors to clean contaminated footwear and wheels on pushchairs and
wheelchairs. The facilities should be arranged to reduce the risk of personal contamination from
manure, liquid run off etc. during the cleaning process and be located so that people can easily wash
their hands after this has been done.
Visitor information and
signage
Information should be provided
to visitors covering the:
Risks to health.
Precautions taken to
minimise risks.
Personal responsibility of
visitors to minimise risks,
including complying with
hygiene precautions and
carrying out hand washing.
Site plan, map, route
directions or other
information as necessary.
The information should be included on the:
Attractions website.
Site maps/plans or other handouts given to visitors on arrival.
Leaets DVDs, website links or pre-visit packs for schools and other organised groups should be provided to help
teachers and others to plan their visit and educate children on safety, prevention of illness and hand washing.
Remember the following:
Information should include notices at all entrances to the premises to remind visitors of the need for
good personal hygiene and to inform them that they should only eat or drink in the designated areas.
Consider handouts for visitors and stickers etc. about hand washing.
Signs should be erected in appropriate places reminding visitors to wash their hands when leaving animal
contact areas, before eating, before entering and after leaving play areas, and when leaving the premises.
Washing facilities should have signs showing how to wash hands properly.
This leaet from the Health
Protection Agency, Department of
Health and Defra provides advice
for the public on avoiding infection
from animals when visiting farms. It
may photocopied and distributed
free of charge. It is available from:
http://www.hpa.org.
uk/webc/HPAwebFile/
HPAweb_C/1270122184581
32
Remember that young children may
have dummies or toys that they put
in their mouths. You should remind
accompanying adults not to put
dummies that have fallen to the
ground back into their childrens
mouths.
Pictograms, audio devices, continuous
loop videos or other media may be
useful.
Information should be clearly legible
and may be required in languages
other than English.
Sign at entrance to animal feeding area
Sign at farm attraction entrance Signage at the entrance to a visitor attraction
Case study: Odds Farm Park, Wooburn Common,
High Wycombe
This is a commercial visitor attraction with approximately 170,000 visitors per annum.
Problem 1
Visitors were not taking notice of hand washing or rules for the animal area.
Solution
To stop children rushing into the animal contact area, a simple picket fence and wooden gate with a high
latch was installed to prevent small children from entering without adults.
Secondly, to get visitors to take the animal area rules on board, we made a very basic PowerPoint slideshow
using our own photos. This runs silently and continuously on a 50-second loop.
Costs:
Picket fence and gate 200 + labour
Old PC and screen 11 + time
Outcome
The new gathering area slows the children
down and ensures that they have an adult with
them when they enter the animal contact area.
The moving pictures get everyones attention in
this same gathering area and they take on board
far more of the rules before they enter.
HSE, Environmental Health and the customers
are all pleased with the efforts.
Chapter 5 contains more detail about the role of information.
Case study: Royal Cornwall Showground, Wadebridge, Cornwall
This agricultural show attracts 127,000 people over three days.
Problem
Public access to livestock areas (cattle, sheep, pigs & goats).
Solution
Numerous permanent and mobile toilet blocks were available on site. Signage advising the use of nearby
hand washing facilities within these toilet facilities was erected in livestock areas for those touching livestock.
Outcome
These facilities have been available for a great number of years and therefore no specic improvement can be
regarded as having taken place. However, signage increases public perception of the advisability of good hygiene.
33
34
Training and supervision
You should:
Ensure staff are trained and instructed about the human health risks associated with animals and the
necessary control measures. Dont forget that training should also be provided for temporary or
seasonal staff.
Ensure staff are trained and instructed on what visitors should or should not do.
Provide guidance to staff on how to explain the hygiene message to visitors including the importance of
thorough hand washing, particularly for children.
Arrange adequate and appropriate levels of supervision in contact areas. The number of supervisors will
depend on the size of the animal contact area and the number of visitors permitted or expected in that
area at one time.
Ensure that children are supervised while they wash their hands. Although this is the responsibility of
parents or teachers, in some cases staff may need to help in supervision.
Remind supervisors in animal contact areas (who may also be there to protect the animals) to ensure
that visitors do not eat, drink or put items in their mouths while in these areas and until they have
washed their hands on leaving the contact area.
Ensure supervisors discourage visitors (especially children) from putting their ngers in their mouths, or
kissing the animals.
Stress to your own staff the importance of setting a good example and following good personal hygiene,
e.g. thoroughly washing their own hands when necessary, and not eating or drinking in animal contact
areas.
Staff should discourage kissing of animals
35
Livestock management procedures
You should:
Consider producing an animal or farm health plan in consultation with your vet to help reduce the risks
from zoonoses.
Assess whether animals are healthy before moving them to animal contact areas, but remember that
animals carrying VTEC do not necessarily show signs of illness.
Ensure that animals that have just given birth, or been born, are not put in contact areas.
Immediately remove any animals showing signs of ill health, such as diarrhoea or stress, from animal
contact areas until they have recovered and seek veterinary attention and advice promptly.
Keep animals and their housing clean.
Consider whether replacement stock can come from within the premises rather than being brought in
(this would reduce the likelihood of new infections being inadvertently brought on to the premises).
Where possible, source replacement livestock (especially young animals for bottle-feeding) from a
reputable supplier with known health status where the stock-keeper will have ensured that they have
received an adequate supply of colostrum after being born.
Try to minimise movement and mixing of animals from different groups. This is particularly important to
minimise the shedding of VTEC by ruminants such as cattle, sheep and goats.
Regularly check all animals on display for evidence of illness, consulting your vet as appropriate.
Regularly empty and clean water troughs and provide the animals with clean drinking water.
Manure and compost heaps
You should:
Position manure or compost
heaps well away from areas that
visitors can access, or fence them
off.
Prevent or contain any liquid
run-off where this might
contaminate visitor areas or
routes.
Prevent dried contaminated
material (e.g. bedding) being
blown onto clean non-contact
areas.
Not allow visitors to collect
and bag their own compost or
manure.
Keep visitors away from manure and compost heaps
Case study: Heeley City Farm, Shefeld
This city farm hosts children and adults with learning disabilities on daytime placements and has
approximately 100,000 visitors per annum.
Problem 1: Faeces on paths
Solution All paths are swept down and disinfected before being opened to the public. A gate was put on
the stable entrance with a sorry we are closed for cleaning sign. A poster of a clean and unclean path was
displayed to give staff/volunteers a pictorial reference of acceptable practice.
(Visitors can be unreasonable about not being allowed in to the stables or having to wait.)
Costs - Gate made from recycled wood, printing and laminating sheet.
Outcome This has improved the facility because all staff work to the same standard. It is good for adults
with learning disabilities and children with English as second language.
Problem 2: Animal bedding spilling out
Solution Solid fronts(1/2 height so children can still look through) have been put on to the front of gates
and pens in the stables to stop bedding spilling on to clean paths and to stop little children reaching through
the bars and touching dirty bedding. It also discourages laddering, where people stand on rails to look at
animals with dirty shoes then little children touch the rails and get muck on their hands.
Outcome Solid fronts have reduced the spillage from pens.
Problem 3: Hand washing facilities needed improving
Solution Extra sinks are to be installed outside with hot running water. They will be in the form of taps over
a trough to catch the water. Bigger groups of children will be able to wash their hands and staff will nd it
easier to stand and supervise correct hand washing. Groups of people in wheel chairs, i.e. nursing home
residents, can easily wash hands whilst still sat in chairs with staff helping.
Costs - Expensive. The work is part of new 100,000 toilet facilities.
Outcome This will make us more attractive to visiting groups and individuals. We can expand sensory/
reminiscence tours for dementia patients.
Problem 4: Attending festivals
Solution We no longer attend events that cannot provide running hot water for hand washing. If we
do attend events, animals have to be double fenced and no contact with public is allowed. The cost of a
portable hot water washing unit is out of our price range.
Outcome We lose some bookings. People are cross and disappointed not to touch the animals.
Problem 5: Recording
Outcome New recording sheets, daily recording, weekly and monthly deep cleaning schedule.
Costs - Extra staff time for new cleaning system.
36
37
Problem 6: Training
Outcome Extra E. coli training for staff by a health and safety ofcer.
Costs - Staff time for the trainer and staff taking time out of normal duties.
Problem 7: Play area
Solution New cartoon signs to prevent eating in the playground. They explain that muck from footwear on
play equipment can be transferred to childrens hands and so eating is not allowed.
Costs - Staff time to design poster and printing.
Case study: New Forest & Hampshire County Show, New Park, Brockenhurst, Hampshire
This agriculture show attracts 95,000 visitors.
Problem1: Risk of infection through contact with animals.
Solution A full risk assessment on infection control is completed prior to the event. Visitors are kept to
a specic route, minimising the direct contact with animals. All animals are kept in pens. Visitors are not
allowed in the car parks and only see the animals once in their pens. Visitors are removed from the area
when the animals are moved from their pen to the judging rings.
Outcome Identies risks. It ensures that the visitors stay away from animals outside of their pens. This
reduces contact with the public whilst allowing good viewing. It reduces the risk of visitors touching animals
whilst outside of their pens.
Problem 2: Risk of infection from dirty bedding.
Solution Each pen is cleaned and disinfected daily. Fresh straw is then put into the empty pen. The dirty
straw is removed from the site. Stockman and stewards are responsible for the removal of faeces produced
in the transport of animals. This is especially important when occurring in the walkways.
Outcome It has reduced the risk of infection.
Problem 3: Insufcient knowledge about the need to wash hands
Solution Signage in the livestock marquees informs the public to wash hands after touching animals.
Stewards are trained to inform the public that there is a need to wash hands after direct contact with
animals. Exhibitors are written to prior to the event informing them of the importance of infection control
at the show. Directional signage moves the public from the livestock to the nearest hand wash facilities.
These facilities are located close to the marquees to ensure that no one gets lost. Information sheets in
schedules and the show programme emphasise the need to use hand wash facilities after touching animals.
Outcome Increased knowledge of the need to wash hands after touching an animal.
Ensures that the public know where the nearest facilities are.
Problem 4: Visitors eat food without washing hands.
Solution All food units on site identify the need to wash hands before consuming food. These units are
always located next to the hand wash facilities.
Outcome Increased knowledge of the need to wash hands after touching an animal. The risk of infection is
reduced.
Problem 5: Facilities are not maintained.
Solution Hand wash facilities are monitored throughout the event with one person for every nine sinks.
Outcome This reduces the risk of facilities becoming unusable.
38
39
Step 4 Record your ndings and implement them
You must be able to demonstrate that you have a system in place to spot hazards, but you are not required
to record every possible type. Concentrate on the signicant hazards that could result in serious harm, or
affect several people.
You should keep a record of your assessment where any signicant risk is identied, whether or not any
further precautions are proposed. This will be useful for later review and for sharing the ndings with your
site staff.
When writing down your results, keep it simple. A risk assessment is not expected to be perfect, but it must
be suitable and sufcient. You need to be able to show that:
A proper check was made.
You considered who might be affected.
You dealt with all the obvious signicant hazards, taking into account the number of people who could
be affected.
The precautions are reasonable, and the remaining risk is low.
You involved your staff or their representatives in the process.
If, like many businesses, you nd that there are quite a lot of improvements that you could make, big and
small, dont try to do everything at once. Make a plan of action to deal with the most important things
rst. Health and safety inspectors acknowledge the efforts of businesses that are clearly trying to make
improvements.
A good plan of action often includes a mixture of different things such as:
A few cheap or easy improvements that can be done quickly, perhaps as a temporary solution until
more reliable controls are in place.
Long-term solutions to those risks most likely to cause accidents or ill health.
Long-term solutions to those risks with the worst potential consequences.
Arrangements for training employees on the main risks that remain and how they are to be controlled.
Regular checks to make sure that the control measures stay in place.
Allocating clear responsibilities who will lead on what action and by when.
Remember, prioritise and tackle the most important things rst. As you complete each action, tick it off
your plan.
40
Step 5 Reviewing risk assessments
You should regularly review risk assessments as a matter of course.
In addition, they should be reviewed immediately after any signicant incident or near miss and following
signicant changes to visitor activities or working practices on site. Such changes may necessitate additional
and/or alternative risk control measures.
The revised ndings should be recorded and retained for future reference.
In summary:
Identify the hazards on your site.
Know who is using your site and what they are doing there.
Think about what accidents could happen (or have happened) and how they might be caused
Decide if current risk control measures are adequate or more needs to be done.
When introducing new risk controls choose the most effective ones that are practicable bearing in mind
their impact on benets.
Record your ndings and review your risk assessments on a regular basis.
41
CHAPTER 5: THE ROLE OF INFORMATION IN RISK CONTROL
This chapter considers the role of information and education in risk control. We emphasise the need
to give visitors the knowledge to consider their behaviour so they can take responsibility for their own
health and safety.
The management of safety should be an integral part of your overall system to meet all the needs of your
visitors. There are opportunities at different stages of the process.
Well-designed safety information should:
Alert visitors to the nature and severity of hazards and risks and provide information about restrictions.
Give visitors the information to understand risks to which they are likely to be exposed, and the
precautions they should adopt.
Give information about the nature and extent of risk control measures provided by the site operator.
Make clear to visitors what is expected of them, on the understanding that they share responsibility for
their own safety.
Our aim should not be to disclaim responsibility. Signs and leaets that state visitors enter at their own risk
have little validity in civil law. However, providing safety information that ensures visitors are made aware of
hazards should help to prevent accidents and ill health. It may also help to demonstrate that you have acted
reasonably in the event of a claim against you if an accident does occur.
Good information can help visitors to develop the skills and condence to take appropriate responsibility
for their own safety.
Different ways of providing information
Leaets, posters, tickets and booklets
Signs (including pictorial), notices and information boards
Audio and/or video messages
Use of signs with themed characters/colour coding along the route
Verbally
Websites
Recorded telephone information lines
Part 3: SUPPORTING
INFORMATION
42
You should identify any partners to your visitor attraction and work with them to achieve a common
information strategy.
Diversity and social inclusion
Think about the needs of different types of visitor. Ensure that any information you publish is accessible for
all. Consider different formats, sizes, typefaces, colours and languages.
Communications strategy checklist
Who is the audience you want the information to reach?
Consider specic audiences, e.g. people new to the site or particular age/ability groups
Dont forget even regular visitors need reminders.
How is the information going to reach the audience?
Consider information given prior to the visit on a website and at the location through maps, leaets
and signs.
Have you met the needs of people with varying levels of skill and ability?
Can your signs be understood by all visitors or their parent/carer/guardian?
Have you reached your intended audience?
This is hard to assess without research or survey work, but you may get some idea from hits on a
webpage.
Has the information been effective?
Monitor the behaviour of your visitors to see if you have achieved your objectives
SIGNAGE
Advisory, warning and prohibition signs
You may need advisory, warning or prohibition signs to tell visitors about things that have an impact on
their visit. However, do not put up signs unless your risk assessment indicates that they are the most
appropriate measure for risk control. You may be able to use a better option such as creating a route that
avoids the hazard.
43
When you decide to use signs you must give thought to their content, design, location and maintenance, if
they are to be effective.
Advantages:
Concise means of conveying information.
Simple pictorial information widely understood.
Relatively cheap to produce and install.
Can be used to warn visitors of hazards that are not readily obvious.
Limitations:
Prone to damage and deterioration so require ongoing maintenance or investment in more
expensive versions.
Can be ignored by intended audience especially if there are too many.
Limited effectiveness for children.
Limited value for foreign language speakers.
Limited value for the visually impaired.
Visually intrusive in places of beauty or historical signicance.
Some additional points should be noted:
Poorly designed or badly positioned signs are not effective.
Signs can be used together with other physical measures, such as fencing. They can explain why
access is restricted.
There is no need to provide warning signs where the hazard is obvious.
Overuse of signs or leaving old signs in place after the hazard has gone undermines their effectiveness.
The use of signs to disclaim responsibility or liability is not usually appropriate.
Safety advice can often be incorporated into the content of general information panels.
Signs must be regularly inspected and maintained.
Sign design
Be consistent in your use of signs. Otherwise the visitor is likely to be misled. Safety signs fall into
ve categories:
Prohibitory
Mandatory
Warning
Safe condition
Fire-ghting
44
When you are certain that a sign is needed, decide which category is appropriate. There are standard
designs and colours for each category. These are prescribed by the Health and Safety (Safety Signs and
Signals) Regulations 1996. Although these regulations apply to the safety of employees in work situations,
there is great merit in applying them, as far as is practicable, to visitor safety signs.
You can use an information board to give a fuller explanation and incorporate other information about, for
example, emergency procedures, management strategy, nature conservation, or environmental protection.
Examples of hand washing signage are available at:
http://www.farmgarden.org.uk/publications/856-clean-hands-zone-toolkit
Sign location
Give careful consideration to the position of signs. General warning notices need to be seen on arrival by
as many visitors as possible. They are usually located at the main points of access to a property. Signs in car
parks are best placed at the point where visitors exit on foot to the place of interest.
Warn visitors about hazards in time for them to take in and act on the information before being exposed to
the risk. This can be particularly important for controlling children.
Sometimes small repeat signs are necessary for hazards that recur along a route.
Monitoring and review
Observe how people react to signs and notices to ensure that they are in the correct location, understood
and acted upon.
Check them regularly for damage and deterioration.
Remove signs as soon as they become out of date.
The role of education
If your organisation has an education strategy, include visitor safety within the wider educational objectives,
particularly when preparing guidance for site visits. Educational opportunities include:
Direct work with schools and communities.
Indirect work, for example, via website information.
Work with school and community groups that organise activities in the countryside. Use the opportunity
for local staff to explain the guiding principles and emphasise how visitors have some responsibility for their
own safety.
45
CHAPTER 6 ADVICE TO TEACHERS AND OTHERS WHO
ORGANISE VISITS FOR CHILDREN
This advice is for teachers and others who organise visits by children on the precautions necessary to
reduce the risk of ill health arising from contact with animals.
All animals naturally carry a range of micro-organisms, some of which can be transmitted to humans, where
they may cause ill health. Some of these, such as Escherichia coli O157 (E. coli O157) or Cryptosporidium
parvum (a microscopic parasite), present a serious health hazard and have the potential to cause serious
illness and health problems which may be particularly severe in young children.
As with many other educational or recreational activities, visits can never be considered free from all risk.
However, while the hazards are real, the risk of infection in children can be readily controlled by simple everyday
measures. The following practical steps will help make your visit even more safe, healthy and enjoyable.
Before your visit, you should:
Read and understand the advice in the industry Code of Practice, and discuss arrangements for the visit
with the management at the site.
Conrm that the control measures provided at the site match the recommendations in the industry
Code of Practice.
Seek advice from your local authority or organisation on what the appropriate ratio of pupils to
teachers/leaders/assistants/parents should be.
Discuss and agree with the supervisors, parents or staff of the school, crche leaders of youth
organisations etc. their roles and responsibilities during the visit. In particular, they must understand the
need to make sure that the children wash, or are helped to wash, their hands thoroughly after contacting
animals and before eating. Key points to cover with the children should include:
explaining the rules for the visit, stressing that they must not eat, drink or chew anything (including
sweets) outside the areas in which you permit them to do so;
explaining why they must wash their hands thoroughly after contact with the animals, and before
eating or drinking anything;
demonstrating how to wash their hands properly;
discussing the requirements for appropriate clothing, including suitable footwear. You should liaise with
the attraction to ascertain what this is;
checking that cuts, grazes etc on childrens hands are covered with a waterproof dressing.
46
During and after the visit, make sure that the children:
Are reminded of the rules/precautions to take upon arrival at the site.
Do not kiss animals.
Always wash their hands thoroughly before and after eating, after any contact with animals and again
before leaving the site.
Eat only food that they have brought with them or food for human consumption that they have bought
on the premises, in designated areas.
Never eat food that has fallen to the ground.
Never taste animal foods.
Do not suck ngers or put hands, pens, pencils or crayons etc. in mouths.
Where practical and possible, clean or change their footwear before leaving.
Wash their hands after changing their footwear.
Check that the children stay in their allocated groups during the visit, and that they:
Do not use or pick up tools (e.g. spades and forks) or touch other work equipment unless permitted to
do so by site staff.
Do not climb on to walls, fences, gates or animal pens etc.
Listen carefully and follow the instructions and information given by the site staff.
Approach and handle animals quietly and gently.
Do not chase, frighten or torment the animals.
Do not wander off into unsupervised or prohibited areas e.g. manure heaps.
Remember the children are your responsibility during the visit:
You should supervise them during the visit, especially during hand washing to make sure that each child
washes thoroughly. Site staff may be able to help with this supervision.
Allow plenty of time for hand washing before eating or leaving the site so that the children do not have to rush.
If a member of your group shows signs of illness (e.g. sickness or diarrhoea) after a visit, advise them or their
parent/guardian to visit the doctor and explain that they have had recent contact with animals. Please also
contact the attraction you visited and inform them of the illness.
Additional advice
Further advice on E. coli O157 including a video on hand washing is available at:
http://www.hse.gov.uk/campaigns/farmsafe/ecoli.htm
Other advice is available from a number of other government websites including:
http://www.hse.gov.uk/
www.hpa.org.uk/
www.hps.scot.nhs.uk/
www.dh.gov.uk/en/index.htm
http://www.defra.gov.uk/
http://vla.defra.gov.uk/
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CHAPTER 7: INCIDENT REPORTING AND INVESTIGATION
Incident reporting is an important element in managing visitor safety. We want our visitors to enjoy their
experience and return home unharmed. It is essential to learn from incidents and near misses that do occur.
Why investigate incidents?
To help manage the incident.
To prevent future similar incidents.
To check whether your risk control measures are sufcient and effective.
It may be a statutory requirement. Some cases of ill health to the public must be reported, usually to the
environmental health department of your local authority, or to the Health and Safety Executive.
To provide information in case there is a claim for compensation, or a need to defend a legal action.
To identify trends in the pattern of incidents or accidents.
To measure whether your safety record is improving or worsening.
Common obstacles to investigations
Difculty in collecting information.
Fear of blame. To counteract this it helps to create a management culture in which staff and visitors are
encouraged to report accidents and near misses.
Over-complicated reporting systems. Introduce simple and clear systems that minimise paperwork.
Staff being unaware of the value of the information they supply. It is essential to give feedback and show
how things have changed as a result of incident investigations.
Visitors may not know how or where to report incidents.
Incident reporting procedures
It is important to have a clear process for reporting and investigating incidents. This should include
consideration of the need to inform insurers or involve legal advisors if claims are likely to result. You should
also consider whether the incident could give rise to media enquiries and how these would be handled.
You are legally bound under the Reporting of Injuries Diseases and Dangerous Occurrences Regulations
1995 (RIDDOR) to report certain accidents, dangerous occurrences and types of ill health to the enforcing
authority
You must also ensure that the person who investigates an incident has the necessary skills, knowledge and
experience.
Many organisations have specic forms to report incidents and record investigations. Often the two are
combined. They typically gather the following information:
48
Basic facts
Where the incident happened
What happened
Date and time
Who was involved
Physical site characteristics
Facilities or equipment involved
Activities of those involved
The weather at time of incident (you may also wish to consider details of clothing
and footwear worn at the time)
The nature of actual or potential exposure to possible infection
Damage to property or environment (actual or potential)
What control measures, if any, were in place.
Gathering evidence
Evidence is critical to establish the facts and determine the causes of incidents and it should be gathered
before any changes are made to the site (other than those necessary to prevent any recurrence), and whilst
the events are fresh in peoples minds. Information to be gathered should include:
Photographs or video recordings of the incident/site.
Witness statements written or recorded.
Any equipment or infrastructure damaged or otherwise, implicated in the incident.
Be careful when asking for statements at the time of the event from witnesses who may be distressed. It
might be more sensitive to ask for an address and telephone number in order to make contact later.
Incident history
The investigator needs to establish whether:
A similar incident has happened before.
Recommendations had previously been made to prevent a recurrence.
If so, were the recommendations carried out?
Causes
If there is not an obvious direct cause to the incident, it is necessary to look beyond the immediate cause of
an incident to see if there are important underlying reasons. Often there are several inter-related causes.
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Recommendations
Recommendations are actions to lessen the possibility of a similar incident occurring in the future or
to mitigate its effect to an acceptable level. Where recommendations are made they should be given a
timescale for implementation and responsibility should be allocated for carrying it out.
Review
There should be a review to see if the recommended actions have been taken and to assess whether they
were adequate and appropriate. Responsibility for carrying out the review should be allocated to a person
with an appropriate level of authority.
50
CHAPTER 8: DEALING WITH A MAJOR INCIDENT
A number of zoonotic diseases are notiable under veterinary and/or human health legislation. However, not
all zoonotic diseases in animals or humans are notiable.
The primary purpose of the notication system is to identify possible outbreaks and epidemics and initiate
appropriate action as soon as possible. Accuracy of diagnosis is secondary, and generally clinical suspicion is all
that is required. If the diagnosis later proves incorrect, the notication can be changed or cancelled.
In April 2010, new Health Protection Regulations for England came into force. These include The Health
Protection (Notication) Regulations 2010, which made changes to the requirement for notications of
infectious disease.
An Incident or Outbreak Control Team (OCT) will be formed for signicant outbreaks of zoonotic disease.
Standard principles for managing incidents/outbreaks apply.
Depending on the individual situation and disease, membership of the OCT may include representatives
from the:
HPAs local Health Protection Unit, for example, the Consultant in Communicable Disease Control.
Local authority (Environmental Health Ofcer).
Primary Care Trust.
Local acute trust (Microbiologist or Virologist, Infection Control Nurse).
Other agencies as necessary may also be included, for example, the Health & Safety Executive or the
Food Standards Agency.
Veterinary involvement may be provided by the Animal Health Veterinary Laboratory Agency.
Further information regarding the investigation of zoonotic disease can be found in Guidelines for the
Investigation of Zoonotic Disease (England and Wales) issued in April 2009 at:
www.hpa.org.uk/Topics/InfectiousDiseases/InfectionsAZ/Zoonoses/Guidelines/
51
CHAPTER 9: THE LAW AND VISITOR SAFETY
This chapter looks at the legislation and court judgements that affect visitor safety and outlines your
responsibilities under the law. References in this chapter are to legislation for England and Wales. There are
differences in the legislation in Scotland.
Someone injured through your negligence can bring an action for damages against you in a civil court of law.
If you are found negligent, you may be ordered to pay compensation for loss of earnings, medical expenses,
pain, suffering and the like.
Claims for damages after accidents are perceived to be on the increase, with solicitors and accident
claim practitioners touting for new business by offering no win no fee terms. Concern about the growth
of the compensation culture led to the introduction of the Compensation Act in 2006. This brought in
changes to the law on liability and breach of statutory duty aimed at tackling perceptions that can lead to
a disproportionate fear of litigation and risk-averse behaviour. Despite this, Lord Young states in his 2010
report Common Sense, Common Safety, the problem of the compensation culture prevalent in society
today is one of perception rather than reality. The number of claims for damages due to an accident or
disease has increased slowly but nevertheless signicantly over recent years. Furthermore, there is clear
evidence that the public believes that the number of claims and the amount paid out in damages have also
risen signicantly.
Not only organisations but also individuals can face prosecution in a criminal court for not complying with
legal duties imposed by government legislation. You can be ned, or even face imprisonment if found guilty in
a criminal court.
Criminal law
Health and Safety Legislation
Health and Safety at Work etc. Act 1974
A criminal offence will arise from a failure to comply with legal duties imposed by the Health and Safety
at Work etc. Act 1974 (HSWA) and regulations made under it.
This legislation places a duty on employers to ensure, as far as is reasonably practicable, that in the course of
conducting their undertaking, members of the public are not put at risk.
The phrase conducting their undertaking also includes cleaning, maintenance and repair of the plant,
machinery and buildings necessary for carrying on the business. The employer cannot delegate responsibility
for this duty. Therefore, in effect, you need to consider the consequences of the actions of contractors as
well as your employees.
You need to consider the cost and effectiveness of any precautions that you can take to minimise risk of
harm. If a precaution is cheap, easy to take and is very effective, then it is reasonable to implement it even
if the risk of harm is small. If the risk of harm is great, then more expensive precautions may be reasonable.
These decisions need to be balanced against the benets arising from the site or the activity, as we have
considered in earlier chapters.
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Enforcement of health and safety legislation
Responsibility for the enforcement of health and safety legislation rests with the Health and Safety Executive
(HSE) and local authorities. Their inspectors have powers to investigate incidents and complaints or carry
out routine inspections. When there has been a breach of health and safety law the enforcing authority can
serve improvement or prohibition notices or prosecute.
The local authority will be the enforcing authority for most visitor attractions.
Where an offence is committed with the consent, connivance or neglect of any director, manager, secretary
or other similar ofcer, that person may be guilty of an offence along with the organisation. If the breach
in the law results in death, the police are involved and they may refer the case to the Crown Prosecution
Service.
The Corporate Manslaughter and Corporate Homicide Act 2007 created a criminal offence
of corporate manslaughter in England, Wales and Northern Ireland and corporate culpable homicide in
Scotland. This Act applies to all companies, most government bodies, partnerships, trade unions, employers
associations and incorporated charities. Crown immunity has been largely abolished. The Act does not apply
to unincorporated bodies such as some charities, friendly societies etc. or individuals.
Corporate manslaughter and corporate homicide investigations are led by the police. They can be lengthy
and intrusive. The existing provisions of the HSWA still apply.
Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH)
E. coli O157 and other micro-organisms that may cause ill health are subject to the Control of Substances
Hazardous to Health (COSHH) Regulations 2002 (as amended). These Regulations require an employer or
self-employed person to:
Assess the risks to employees, self-employed people and the public from exposure to hazardous
substances, including micro-organisms.
Prevent, or, where this is not reasonably practicable, adequately control exposure to the hazardous
substances.
Introduce and maintain control measures.
Inform, instruct and train employees about the risks and precautions to be taken.
Inform visitors about the risks and precautions to be taken.
Regularly review the assessment and the effectiveness of control measures.
Guidance on COSHH can be obtained from the HSE website http://www.hse.gov.uk/coshh/index.htm
53
Management of Health and Safety at Work Regulations 1999 as amended
The Management of Health and Safety at Work Regulations 1999 require you to carry out risk assessments to
identify hazards and take any necessary steps to reduce the risk of an incident. Regulation 3(1)(b) states that:
Every employer shall make a suitable and sufcient assessment of the risks to the health and
safety of persons not in his employment arising out of or in connection with the conduct by him
of his undertaking.
In effect this means that your risk assessments should consider the risks to visitors you invite onto your
property, or other people who might be affected by your undertaking or your activities.
Regulation 5 states: Every employer shall make and give effect to such arrangements as are appropriate,
having regard to the nature of his activities and the size of his undertaking, for the effective planning,
organisation, control, monitoring and review of his preventive and protective measures. Where the employer
employs ve or more employees, the arrangements should be recorded. (We discuss how you can meet
these requirements in Chapter 4.)
Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1999 (RIDDOR)
You are legally bound under RIDDOR to report certain accidents, dangerous occurrences and types of
ill health to the enforcing authority. They may well send an inspector to investigate. The authority will also
investigate complaints made by members of the public. It is essential that you are able to demonstrate that
you have effective procedures in place to identify and manage risk
Independent Regulatory Challenge Panel
An Independent Regulatory Challenge Panel has been established to handle complaints about advice given
by either the HSE or local authority inspectors and will seek the expert advice of assessors in reaching a
conclusion.
Any case where someone believes the enforcing authority is incorrect or has gone beyond what is required
to control the risk adequately is eligible for consideration by the panel. The panel will not consider issues
where other independent appeals processes exist, such as enforcement notices or prosecutions.
Further information is available at:
http://www.hse.gov.uk/contact/challenge-panel.htm
Public Health legislation
Application of the Health Protection Regulations 2010 (England & Wales)
These health protection powers are for use where voluntary cooperation to avert a health risk cannot
be secured and where other methods of control are ineffective, unsuitable or disproportionate to the risk
involved. The Department of Health has published Guidance that was written by the Health Protection Agency
and the Chartered Institute of Environmental Health, which describes how these powers should be used.
Powers that impose restrictions or requirements are conditional on strict criteria being met. The local
authority makes an application to a JP who must be satised that the relevant criteria are met. The criteria
cover evidence of infection or contamination, assessment of the potential for signicant harm to human
health, risk of spread to others and necessity for action to be taken in order to reduce or remove that risk.
The legislation also contains various safeguards for people who might be subject to the legal measures.
54
The measures are contained in the Public Health (Control of Disease) Act 1984 (as amended) together
with the Health Protection (Local Authority Powers) Regulations 2010 and the Health Protection (Part 2A
Orders) Regulations 2010.
For further information see:
Health Protection Legislation (England) Guidance 2010
Information about Public Health legislation in Scotland is available at:
http://www.legislation.gov.uk/asp/2008/5/contents
Civil law
The foundation of most personal injury actions is in proving negligence under common law. An action for
damages is brought in the civil courts.
To win an action and be awarded compensation the injured person must be able to demonstrate that they
were owed a duty of care, and there was a breach of that duty leading to the injury.
A civil case can also be brought for breach of statutory duty that results in injury or ill health.
Common law duties essentially derive from decisions made by judges over the years. Under common law
you owe someone a duty of care if there is:
sufcient proximity between you and the person injured, and it was
reasonable to foresee that harm may result from your actions, and
it is fair, just and reasonable to impose a duty of care on you.
Proximity can be geographical, contractual, or through a care situation (for example between teacher and
child). If you breach that duty of care, and foreseeable physical or psychological damage results, then you
are liable to negligence. An employer may be held liable for the negligence of his employees (this is called
vicarious liability).
The visitor must take reasonable care for his own safety. If he doesnt and comes to harm, then his
contributory negligence would lessen any claim against you.
Note that children cannot be expected to appreciate dangers in the same way as adults. It is highly unlikely
that contributory negligence could be attributed to the actions of a very young child. Adults, however, will be
expected to exercise responsibility for children in their care.
In civil law, the duty of care has been further dened by legislation. Under the Occupiers Liability Acts of
1957 (OLA57) and 1984 (OLA84), the occupier of premises owes a duty of care to lawful visitors (OLA57)
and trespassers (OLA84), by reason of the state of the premises and things done or omitted to be done on
them. In Scotland, a similar duty of care is owed under the Occupiers Liability (Scotland) Act 1960.
The occupier is the person or body that has sufcient control over the premises to be in a position to take
the steps necessary to protect people who otherwise may be at risk.
If there is more than one occupier, each owes a duty of care that is in relation to the degree of control each
has over the premises.
An occupier has the duty of care and cannot delegate this duty to someone else. So, in effect, you may be
responsible for the actions of contractors working on your behalf.
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Visitors
Under Section 2(2) of the OLA57, the occupier has:
A duty to take such care as in all the circumstances of the case is reasonable to see that
the visitor will be reasonably safe in using the premises for the purposes for which he is
invited or permitted by the occupier to be there.
You must consider the particular needs of people you invite onto your property.
You must be able to demonstrate that your precautions are reasonable in the circumstances.
You must be prepared for children to be less careful than adults. Furthermore, a warning sign, however clear
in itself, cannot warn if the child is unable to read. However, in some circumstances, particularly in the case of
a young child, the parent may hold the primary duty of care.
Warning a visitor of dangers might be sufcient to absolve you from liability, but only if it was sufcient to
enable the visitor to be reasonably safe.
Under OLA57, you can choose to restrict or exclude your liability by imposing entry conditions. However,
the Unfair Contract Terms Act 1977 says that:
A person cannot by reference to any contract term or to a notice exclude or restrict his
liability for death or personal injury resulting from negligence.
In the case of other loss or damage, liability can only be excluded or restricted if the terms are reasonable.
56
CHECKLIST
Use the checklist to ensure that you are addressing issues that will help to keep your customers safe from
exposure to microbiological contaminants and zoonoses. This document may help you record your COSHH
assessment. It can be printed on A3 paper.
PREMISES LAYOUT AND ROUTES Current standard Action required By whom Date
Are the public access areas segregated
from the main farm work areas?
Areas of the farm to which members
of the public have access need to be
dened and segregated in order to
implement the control measures.
Are the visitor routes around and
through the attraction clearly dened?
Are the visitor routes kept reasonably
clean and free from build-up of animal
faeces?
Sensible hygiene practices indicate
that trafc routes should be clean to
minimise risks of contamination of
hands and footwear and reduce transfer
of faecal matter to non-animal areas.
ANIMAL CONTACT
Are adequate washing facilities provided
adjacent to areas of animal contact?
The primary control measure is good
hygiene.
Are non-contact animals segregated
from the public?
Access to animals that have been
designated as non-contact should
be managed in accordance with the
guidance.
APPENDIX 1
57
PREMISES LAYOUT AND ROUTES Current standard Action required By whom Date
Are the public prevented from entering
animal pens (except in staff supervised
specic contact areas)?
You need to prevent the public
entering animal living pens, as faeces or
contaminated bedding will be underfoot.
Are visitors prohibited from eating,
drinking and smoking in the animal
contact areas?
Permitting these activities in areas
with recent faecal contamination is
unacceptable.
Is contaminated bedding or run-off
prevented from contaminating walkways
or other visitor areas?
Faeces should not be allowed to
remain on and contaminate walkways
or other areas used by visitors. Also
contaminated bedding or run-off
material should not be allowed to
contaminate walkways or other areas
used by visitors.
EATING AREAS
Are visitors in eating areas prevented
from contact with animals in adjacent
areas? (Remember temporary eating
areas such as ice cream vans and sweet
kiosks.)
Eating in areas where contact is possible
should not be permitted and in all cases
thorough hand washing is a primary
control measure.
Are visitors advised to wash their hands
before eating or drinking?
Hand washing after contact with animals
or animal faeces is a primary control.
58
PREMISES LAYOUT AND ROUTES Current standard Action required By whom Date
PLAY AREAS
Are children prevented from reaching
and touching animals in areas adjacent
to play areas?
Where play areas are adjacent to
animal areas, animal contact should be
prevented, e.g. by double fencing.
Are visitors advised to wash their hands
before and after using play areas?
Visitors should be advised to wash their
hands before and after using play areas.
WASHING FACILITIES
Have sufcient numbers of washing
facilities been provided?
Thorough hand washing is a primary
control measure.
Are washing facilities provided
immediately adjacent to petting areas,
eating areas, or areas where contact
with animals or their faeces likely,
including exits?
Thorough hand washing is a primary
control measure.
Is clean running hot and cold or warm
water provided?
Thorough hand washing is a primary
control measure.
If only cold water facilities are provided,
has a justication by risk assessment
been completed?
In exceptional circumstances, such as
premises that open on an occasional
basis in the summer, providing cold
running water soap and paper towels
only may be acceptable. This must be
justied in a risk assessment.
59
PREMISES LAYOUT AND ROUTES Current standard Action required By whom Date
Is liquid soap provided?
Thorough hand washing is a primary
control measure.
Depending on type and method in
which they are used, bars of soap
may not be effective and may present
additional microbiological risks
Are personal means of drying hands
thoroughly provided?
Drying by paper towel or hot-air
dryer forms part of the thorough hand
washing as a primary control measure.
Are cleansing wipes or anti bacterial gels
prohibited as a substitute for proper
hand washing?
Thorough hand washing is a primary
control measure. Anti bacterial wipes
and gels are not an effective means of
preventing exposure to E. coli O157 or
cryptosporidium.
.
Is the water used in hand washing
allowed to drain away quickly?
Re-using used hand washing water must
not be possible.
Are the segregated/clean picnic and
eating areas co-located with suitable
washing facilities?
Permitting eating in areas where
there is the potential for recent faecal
contamination is unacceptable and in all
cases thorough hand washing prior to
eating is a primary control measure.
60
PREMISES LAYOUT AND ROUTES Current standard Action required By whom Date
VISITOR INFORMATION & SIGNAGE
Is information available for visitors about
the risks to health, the precautions taken
to minimise risk and on the need for
good hygiene?
Information should be available on the
attractions website, on site maps and
other handouts given to visitors on
arrival. Leaets or pre-visit packs should
be provided to schools and other
organised groups to aid planning.
Are washing stations clearly signposted
on the route around premises?
Are there signs to instruct on hand
washing techniques?
TRAINING AND SUPERVISION
Are employees/staff sure about what
visitors can and cannot do?
The concern is that staff may not
appreciate the risk and thus not prevent
members of the public from e.g. eating
in animal handling areas.
Are employees/staff sure of how to
explain the hygiene message to visitors?
Are employees/staff sure how to
manage difcult and uncooperative
visitors?
Are there arrangements in place to
determine and apply adequate and
appropriate levels of supervision?
61
PREMISES LAYOUT AND ROUTES Current standard Action required By whom Date
LIVESTOCK MANAGEMENT
PROCEDURES
Are there procedures for managing the
health of the livestock?
New animals introduced to the farm,
newly born and newly birthed animals
and sick animals, may present a broad
range of zoonotic illnesses. They are no
more likely to have E. coli O157 than
any other animals, but their state may
mean that they are more likely to shed
this organism into the environment.
The current guidance provides advice
on good livestock management practice
and of cleanliness of livestock quarters
(see below).
Are animals reasonably clean and
their pens without a build-up of faecal
material?
Cross contamination risks increase
where animals are dirty.
MANURE & COMPOST HEAPS
Are manure and compost heaps
and their liquid run-off managed and
segregated? Is the spread of faecal
matter prevented?
Sensible hygiene practices indicate
that trafc routes should be clear and
methods of segregation, typically fences
or channels, set to minimise risks of
contamination of hands and footwear
and reduce transfer of faecal matter to
non-animal areas.
62
SOURCES OF ADVICE
There are a number of organisations that offer advice and guidance, some of which is freely available and
some which is only available to members.
The National Farm Attraction Network http://www.farmattractions.net
The Federation of City Farms and Community Gardens http://www.farmgarden.org.uk
Farming and Countryside Education http://www.face-online.org.uk/
Farms for Schools http://www.farmsforschools.org.uk/
The National Farmers Union http://www.nfuonline.com/
The National Farmers Union Cymru http://www.nfu-cymru.org.uk/
The National Farmers Union Scotland http://www.nfus.org.uk/
The Association of Show and Agriculture Organisations http://www.asao.co.uk/
Linking Environment and Farming http://www.leafuk.org/leaf/home.eb
The Royal Highland Education Trust http://www.rhet.org.uk
APPENDIX 2
63

www.gov.uk/defra
Consultation on tuberculosis (TB) animal
disease controls for deer and camelids.

April 2014



Crown copyright 2014
You may re-use this information (not including logos) free of charge in any format or
medium, under the terms of the Open Government Licence. To view this licence, visit
www.nationalarchives.gov.uk/doc/open-government-licence/ or write to the Information
Policy Team, The National Archives, Kew, London TW9 4DU, or e-mail:
psi@nationalarchives.gsi.gov.uk
This document/publication is also available online at:
http://www.gov.uk/defra
Any enquiries regarding this document/publication should be sent by e-mail to
bTBengage@defra.gsi.gov.uk, or by post to:
Deer/Camelid Consultation
TB Programme
Department for Environment, Food and Rural Affairs
Area 5D, Nobel House
17 Smith Square
London SW1P 3JR



Contents
Chapter 1: Introduction ........................................................................................................ 4
Purpose of the consultation .............................................................................................. 4
Who will the proposals affect? .......................................................................................... 4
Why changes are needed? .............................................................................................. 4
Defras Policy Intention ..................................................................................................... 5
How these proposals will be taken forward ...................................................................... 5
Consultation ..................................................................................................................... 5
Disclosure ........................................................................................................................ 6
Confidentiality and Freedom of Information ...................................................................... 6
Responding to the consultation document ....................................................................... 6
Chapter 2: Background to the Policy and Legislation and Proposed Changes .................... 8
General Background to TB Policy in non-bovine domestic species ................................. 8
Question 1: Do you have evidence to support a different approach to TB in non-bovine
farmed species? (please specify) ................................................................................. 8
Deer: Background to the Legislation ................................................................................ 8
Question 2: Does the current deer legislation provide a satisfactory framework of
essential controls on TB in deer? If not, why not and what is missing? ..................... 9
Question 3: Does the current legislation create unnecessary burdens on deer
farmers? What is your evidence; and what would you do about it? ......................... 10
Camelids: Background to the policy ............................................................................... 10
Proposed legislative changes: The changes we propose to make: ................................ 10
Question 4: Are the safeguards proposed (para 2.10(b)) the right ones and are there
others that should be put in place to protect the public? ............................................. 11
Question 5: How can we best ensure that all camelid owners are aware of these
proposed new powers? ............................................................................................... 11
Legislative changes that we do not propose to make at this time but will keep under
review ............................................................................................................................. 12


Question 6: Are there any other comments you wish to make about these proposals?
(Please provide evidence in support of further changes you are proposing) .............. 12
Administrative changes to the current arrangements for TB testing of camelids ............ 12
Question 7: Do these administrative changes in TB testing of SAC go: too far, far
enough, not far enough? Explain why......................................................................... 13
Annex A: List of consultees ................................................................................................ 14
Annex B: Response Form .................................................................................................. 15
Annex C: Consultation criteria ........................................................................................... 18
Annex D: Economic analysis for a statutory compensation scheme for South American
Camelids (SAC) ................................................................................................................. 19
Question 8 Do you know of any further sources on camelid numbers, herd sizes and
businesses in England? .............................................................................................. 20
Question 9 Do you have any information on how long it takes farmers to gather and
present camelids for testing? ...................................................................................... 21
Question 10 Do you know any further sources on the sale values of camelids,
particularly llamas, in England? .................................................................................. 21
Question 11 Do you know any sources of information on the economic returns of
different camelid enterprises in England? ................................................................... 21
Question 12 Do you know of any evidence on the economic impact of TB in camelid
herds in England? ....................................................................................................... 21


1
Summary of Proposals
A consultation issued by the Department of
Environment, Food and Rural Affairs
Scope of the consultation
Topic of this
consultation
This consultation sets out proposals:
(i) to consolidate the two current Tuberculosis (TB) Deer
Orders into a single new Order without further alteration in
England. This consolidation would streamline the regulatory
framework in England and in particular reduce the burden on
deer keepers and their veterinary advisers. For information on
relevant Orders please see:
www.legislation.gov.uk/uksi/1989/878/article/9/made
www.legislation.gov.uk/uksi/1989/1316/contents/made
www.legislation.gov.uk/uksi/1993/2010/contents/made
(ii) for a statutory compensatory payment for positive tested
camelids (in particular llamas and alpacas) to keepers for
animals that the Secretary of State decides to remove as TB
reactors or suspect animals together with proposals for the
marking of camelids that react to the TB test; and prohibition
of vaccination and therapeutic treatment for TB in camelids.
We also propose to introduce statutory powers similar to
those already applied in the case of deer to test and slaughter
camelids suspected of being affected by TB.
(iii) for revised administrative arrangements for testing
camelids in TB breakdown situations.
See
Chapter
2
Scope of this
consultation
The main purpose of the consultation is to set out proposals
and seek your views on the consolidation of the various Deer
Orders, and the inclusion of provisions relating to statutory
compensation of camelid keepers for the removal of TB
infected animals in England. The consultation also includes
proposals for changes to the administrative arrangements
concerning the testing of camelids in TB breakdown
situations. The outcome of the consultation will assist the
Department in drafting the replacement Order; and the
drawing up of administrative guidance for handling TB
breakdown situations.

Subject to the outcome of the consultation, it is proposed that
an Order is laid before Parliament in summer 2014. The three
existing GB-wide Deer Orders will remain in force in Scotland.
The administrative changes are proposed to be introduced
concurrently with the replacement Order coming into effect.
See
Chapter
2
Geographical
scope
The changes only apply to England.

2
Economic
Analysis
The proposed changes have been supported by economic
analysis. Further information is sought from consultees.
See
Annex
D

Basic information
To This consultation will be of particular interest to deer and
camelid keepers and vets in England and those bovine and
non-bovine animal keepers that farm nearby to such kept
animals.

Body/Bodies
responsible for
the consultation
This consultation is being carried out by the Department for
Environment, Food and Rural Affairs.

Duration Consultation starts: 9th April 2014
Consultation closes: 6th May 2014

Enquiries During the consultation, if you have any enquiries, or wish to
receive hard copies of the consultation documents, please
contact:

Camelid/Deer Consultation
TB Programme
Department for Environment, Food and Rural Affairs
Area 5D, Nobel House
Smith Square
London SW1P 3JR

Email: bTBengage@defra.gsi.gov.uk

How to respond Any comments on the proposals and the economic analysis
(Annex D) in this consultation document can be
communicated to Defra by responding to an on-line survey on
the Citizen Space website. The survey is accessed via the
following address: https://consult.defra.gov.uk/bovine-
tb/consultation-on-tb-controls-for-deer-and-camelids. The
deadline for comments is 6th May 2014.

Alternatively, comments can be e-mailed. To do this, you can
either copy the response form (Annex B) into a separate
attachment, or copy the questions into an e-mail message,
and send - with your answers - to:-
bTBengage@defra.gsi.gov.uk

You may wish to print off the response form and send your
comments by post to:

Camelid/Deer Consultation
TB Programme
Department for Environment, Food and Rural Affairs
Area 5D, Nobel House
Smith Square
London SW1P 3JR


3
After the
consultation
When this consultation ends, we will send respondents a
summary of the responses received and our proposed way
forward and publish the results on the GOV.UK website.
If you do not want your response - including your name,
contact details and any other personal information to be
publicly available, please tick the box in the on-line survey or
(if youre replying by e-mail or by post) on the response form
or otherwise say so clearly in writing when you send your
response to the consultation. Please note, if your computer
automatically includes a confidentiality disclaimer that will not
count as a confidentiality request. Please explain why you
need to keep details confidential. We will take your reasons
into account if someone asks for this information under
freedom of information legislation. But, because of the law,
we cannot promise that we will always be able to keep those
details confidential.

The summary of responses will be put on GOV.UK at
https://www.gov.uk/government/publications?publication_filter
_option=consultations
This summary will include a list of names of organisations that
responded but not individual contact details.


Compliance
with the
Consultation
Principles
This consultation is being conducted in accordance with the
terms of the Governments Consultation Principles see:-
https://www.gov.uk/government/uploads/system/uploads/attac
hment_data/file/60937/Consultation-Principles.pdf
See
Annex C


4
Chapter 1: Introduction
Purpose of the consultation
1.1 This consultation sets out the Governments proposals for consolidating the
provisions of the GB-wide Tuberculosis (Deer) Orders in England. These Orders have
already been revoked in Wales by Tuberculosis (Wales) Order S.I. 2011/692. Scottish
Governments intention for these Orders is to revoke and replace these Orders in due
course. They comprise:
The Tuberculosis (Deer) Order 1989 SI 1989 No 878;
The Tuberculosis (Deer) Notice of Intended Slaughter and Compensation Order
1989 SI 1989 No 1316; and
The Tuberculosis (Deer) (Amendment) Order 1993 SI 1993 No 2010
1.2 This consolidation also provides an opportunity to look across the piece in England
at tuberculosis (TB) regulation of non-bovine animals generally (particularly goats, pigs
and sheep). We have concluded that the current approach to the disease in non-bovines is
proportionate, but we will continue to keep the situation under close review. Nevertheless,
this consolidation of the three Deer Orders in England does create an opportunity to
introduce a statutory TB compensation scheme for camelids (in particular alpacas and
llamas) and other statutory measures similar to those that already apply to deer. This
proposal for a statutory compensation scheme replaces the present non-statutory TB
payment where keepers agree to hand over reactors for slaughter in return for
Government TB testing their animals.
1.3 This consultation on a statutory compensation scheme for camelids is also an
opportunity to consult widely on proposals for improved testing of these animals in TB
breakdown situations.
Who will the proposals affect?
1.4 Those owning or keeping deer or camelids on land in England that may be affected
or suspected of being affected by TB caused by Mycobacterium bovis (M. bovis), the
bacterium that causes TB in cattle and other animals.
Why changes are needed?
1.5 English deer farmers and their vets have to consult three separate Orders to
understand what they need to do when TB affects a deer herd. This proposal consolidates
these Orders into one document without making any substantive change to the present
arrangements.
1.6 The non-statutory slaughter arrangements with payment made to camelid keepers
to remove animals suspected to be infected with TB was introduced in 2008 as a

5
temporary measure. There is an ongoing need to remove animals suspected of having TB
in order to prevent the spread of this disease that can devastate small businesses. This
consolidation of the deer Orders provides an opportunity to establish statutory
compensation and to introduce other measures where camelids are tested positive or
suspected of TB.
1.7 Research has shown that the tuberculin skin test used on camelids is only
moderately successful in detecting animals infected with the bovine TB bacterium M.bovis,
but that sensitivity of detection of the bacterium can be dramatically increased (to
approximately 80 percent by using a combination of two antibody (blood) tests in parallel
interpretation It is proposed to introduce administrative changes in the testing regime of
TB-infected camelid herds and other at-risk herds to reflect this new situation.
Defras Policy Intention
1.8 The policy objectives for these changes are to-
o reduce administrative burdens for deer farmers vets and relevant external
stakeholders by consolidating old Animal Health Act 1981 Orders;
o increase certainty about the basis on which compensatory payments are made to
camelid keepers for the removal of their TB-affected animals; while providing better
safeguards for the public; and
o administratively deploy better, mandatory, tests and improve the clarity over roles
and responsibilities.
How these proposals will be taken forward
1.9 We propose to revoke the Deer Orders in England in line with the Departmental
commitment to the Governments Red Tape Challenge; and to use the opportunity to
utilise this non-bovine TB Order to introduce: statutory testing of camelids; a power to
slaughter animals testing positive; a compensation scheme; and other measures regarding
marking, and the prohibition of vaccination and therapeutic treatments for camelids.
Alongside the legislative changes the main administrative change on camelid testing
(mandatory antibody testing along with the existing skin test) will be delivered by the
Animal Health and Veterinary Laboratories Agency (AHVLA) following a suspicion of
exposure of animals to the M.bovis bacterium.
Consultation
1.10 The list of consultees, including the devolved administrations, to which this
document has been sent, is at Annex A.
1.11 Comments are invited from all interested parties, and not just from those to whom
the document has been sent.

6
1.12 This consultation document follows the format recommended by Better Regulation
Executive for such proposals. The criteria applicable to all UK public consultations under
the Consultation Principles are set out in Annex C.
Disclosure
1.13 Normal practice will be for details of representations received in response to this
consultation document to be disclosed, and for respondents to be identified.
1.14 You should note that:
If you request that your representation is not disclosed, the Minister will not be able to
disclose the contents of your representation without your express consent and, if the
representation concerns a third party, their consent too. Alternatively, the Minister may
disclose the content of your representation but only in such a way as to anonymise it.
In all cases where your representation concerns information on a third party, the Minister is
not obliged to pass it on if he considers that disclosure could adversely affect the interests
of that third party and he is unable to obtain the consent of the third party.
1.15 Please identify any information which you or any other person involved do not wish
to be disclosed. You should note that many facsimile and e-mail messages carry, as a
matter of course, a statement that the contents are for the eyes only of the intended
recipient. In the context of this consultation such appended statements will not be
construed as being requests for non-inclusion in the post consultation review unless
accompanied by an additional specific request for confidentiality, such as an indication in
the tick-box provided for that purpose in the on-line survey or in the response form at
Annex B, or if you choose to send an e-mail make it clear in your message.
Confidentiality and Freedom of Information
1.16 It is possible that requests for information contained in consultation responses may
be made in accordance with access to information regimes (these are primarily the
Freedom of Information Act 2000, the Data Protection Act 1998 and the Environmental
Information Regulations 2004). If you do not want your response to be disclosed in
response to such requests for information, you should identify the information you wish to
be withheld and explain why confidentiality is necessary. Your request will only be
acceded to if it is appropriate in all the circumstances. An automatic confidentiality
disclaimer generated by your IT system will not of itself be regarded as binding on the
Department.
Responding to the consultation document
1.17 As mentioned under Basic Information on page 2, any comments on the proposals
and the economic analysis (Annex D) in this consultation document should be submitted to

7
Defra by 6th May 2014. This can be done in a variety of ways:
o By responding to an on-line survey on the Citizen Space website. The survey is
accessed via the following address: https://consult.defra.gov.uk/bovine-
tb/consultation-on-tb-controls-for-deer-and-camelids.
o Alternatively, comments can be e-mailed. To do this, you can either complete the
response form (Annex B) and copy into a separate attachment or copy the
questions into an e-mail message and send - with your answers - to:
bTBengage@defra.gsi.gov.uk
o We should also be grateful for any comments on the economic analysis which
accompanies the consultation document.
o You may wish to print off the response form and send your comments, or any
requests for further copies of this document, to:

Camelid/Deer Consultation
TB Programme
Department for Environment, Food and Rural Affairs
Area 5D, Nobel House
17 Smith Square
London SW1P 3JR Tel: 020 7238 6735

8
Chapter 2: Background to the Policy and
Legislation and Proposed Changes
General Background to TB Policy in non-bovine
domestic species
2.1 The TB Strategy published on 3
rd
April 2014
1
explains that many species of non-
bovine farmed South American Camelids (SAC), captive deer, goats, pigs and sheep,
companion animals (e.g. cats, dogs and ferrets), zoo and wild mammals are susceptible to
M. bovis infection. Only a relatively small number of such animals are identified as infected
each year through scanning surveillance and the evidence suggests that, with the
exception of the badger, these species are generally spillover hosts and appear to pose
a very small risk of spreading M. bovis to cattle and badgers.
2.2 Defra keeps the evidence under ongoing review but the current policy approach to
surveillance and TB testing of non-bovines is a proportionate one. Now that the TB
Strategy has been published we will revisit the matter of TB in non-bovine species
generally but, as a first step, the Government is proposing to consolidate the existing Deer
Orders in England. We are also proposing to introduce statutory testing and slaughter of
camelids testing positive; a statutory compensation scheme; a power to mark animals that
are to be removed and a statutory prohibition on vaccination and therapeutic treatments
that may adversely affect TB testing. We also plan to update administrative TB testing
arrangements.
Question 1: Do you have evidence to support a different approach to TB
in non-bovine farmed species? (please specify)
Deer: Background to the Legislation
2.3 The Tuberculosis (Deer) Order 1989 contains provisions relating to tuberculosis in
deer and, in particular, provides for
a. the compulsory notification of tuberculosis in deer and in carcasses of deer (articles
5 and 6);
b. the investigation by a veterinary inspector into the existence of tuberculosis in deer
and the examination by him of deer and their carcasses for this purpose (article
6(1), (2) and (3));

1
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/300447/pb14088-bovine-tb-
strategy-140328.pdf

9
c. the imposition (by notice in Form A served by a veterinary inspector) of certain
requirements in respect of deer which are affected or suspected of being affected
with tuberculosis, including the isolation of such deer from all other deer and from
cattle (article 6(4), (5) and (6));
d. the testing of deer (if required by notice) and the reporting of the results of such
tests (article 7);
e. the prohibition of the vaccination and treatment of deer for tuberculosis (article 8);
f. precautions which may be required (by notice) to be taken against the spread of
tuberculosis in deer, including the isolation of deer and the cleansing and
disinfection of premises (articles 9 and 10);
g. the marking and identification of deer (article 13);
h. the prohibition of the exposure for sale in a market of a deer by its owner unless it is
marked or identified in accordance with the provisions of the Order and the mark or
identification is clearly legible (article 14); and
i. offences (article 17).
We intend to make minor changes to the notice provisions (f) above to tailor them more
closely to comparable provisions in Article 18 of the Tuberculosis Order (England) 2007
2

which mainly deals with TB in bovine animals.
2.4 The Tuberculosis (Deer) Notice of Intended Slaughter and Compensation
Order 1989 prescribes the amount of compensation payable for deer slaughtered by the
appropriate Minister due to tuberculosis infection under section 32 of the Animal Health
Act 1981. The compensation payable is 600 or 50 per cent of its market value (calculated
in accordance with the provisions of the Order), whichever is the less (article 4).
Compensation payable for the slaughter of deer which are required to serve as controls
during the quarantine of imported deer is limited to their carcass value, less reasonable
expenses (article 5). The Order also requires the appropriate Minister, where he intends to
cause a deer to be slaughtered under section 32, to serve a notice of intended slaughter
on the owner or person in charge of the deer requiring him to detain and isolate the deer
pending such slaughter (article 3 and Schedule).
2.5 The Tuberculosis (Deer) (Amendment) Order 1993 amends the Tuberculosis (Deer)
Order 1989 to remove the general requirement for marking or identifying farmed deer.
Marking is required for deer carcasses (other than wild deer) and live deer which are to be
moved on or off premises, and deer which are to be tested for tuberculosis.
Question 2: Does the current deer legislation provide a satisfactory
framework of essential controls on TB in deer? If not, why not and
what is missing?

2
http://www.legislation.gov.uk/uksi/2007/740/made


10
Question 3: Does the current legislation create unnecessary burdens on
deer farmers? What is your evidence; and what would you do about
it?
Camelids: Background to the policy
2.6 Camelid keepers have since 2008 received a non-statutory payment when agreeing
to the testing and slaughter of a TB confirmed or suspect animal. The non-statutory
payment was always seen as a temporary measure to meet an immediate need; and that
a statutory payment scheme should be introduced in due course. This consolidation of the
Deer Orders provides just such an opportunity.
2.7 The proposed statutory compensation scheme is being introduced alongside
administrative changes to AHVLAs TB testing regime, the details of which are set out
below. To safeguard the public interest, as in the case of deer, we propose to introduce
statutory controls to mark animals that are to be removed for slaughter as TB reactors and
to prohibit vaccination and the use of therapeutic or prophylactic TB treatment as these
may affect TB testing results. With the introduction of the statutory compensation scheme
we propose that the new Order should contain explicit provisions in one piece of legislation
to make it clear what keepers can expect in terms of testing of their animals and the
removal of TB reactors.
2.8 Because of the low sensitivity of the tuberculin skin test in camelids an antibody
(blood) test has been used to supplement the skin test on a research basis since 2006. As
a piece of research it was reasonable to seek the voluntary agreement of keepers to its
deployment. In 2011 antibody tests for TB in camelids were validated by AHVLA, since
when discussions with the industry have taken place regarding their wider deployment.
Separately the industry has sought to develop proposals for a voluntary health surveillance
scheme on which discussions are continuing but Defra reserves its position to look again
at options for statutory surveillance if the voluntary industry scheme cannot deliver the
desired results. With all the necessary research complete the Government proposes for
now to continue to pay for skin and blood testing in herds in which TB has been identified
or is suspected, and compensate keepers for the removal of their affected animals for
slaughter.
Proposed legislative changes: The changes we propose
to make:
(i) Deer
2.9 Taken together, we believe the current Deer Orders made under the Animal Health
Act 1981 set out a sensible and proportionate structure for controlling TB in the farmed
and park deer sector. There has been no major pressure for change since their
introduction in 1989. For that reason we are proposing in England to consolidate all of the
current provisions into a single Order which will make it easier for the deer keeper, their
vet and other stakeholders to establish their duties and legislative requirements.

11

(ii) Camelids
2.10 We propose to:
(a). Introduce statutory payment of compensation to camelid keepers for the
slaughter of affected animals under section 32(3) of the Animal health Act 1981 at
the same fixed rate as currently paid under the non-statutory arrangement (750
per animal).
(b). Also introduce safeguards:
i. that provide for the marking of animals that are to be removed for slaughter
and prohibition of vaccination, and
ii. prohibit the use of therapeutic or prophylactic TB treatments of camelids
since these may affect TB testing results and increase the risk of developing
M. bovis strains that are resistant to drugs used to treat TB in humans.
Question 4: Are the safeguards proposed (para 2. 10(b)) the right ones
and are there others that should be put in place to protect the public?

(c). Introduce statutory powers of testing and removal of TB reactors alongside the
statutory compensation. We propose in addition that where a keeper:
- fails to co-operate with the AHVLA testing requirements then they will under the
proposed new Order be responsible to reimburse the Government for any testing costs
and expenses reasonably incurred by the Secretary of State for the purpose of making
good the keepers default (similar to the position under article 8(4) of the bovine TB
Order S.I. 2007/740).
- refuses to allow their animals to be tested the keeper will be committing an offence
under the Animal Health Act 1981 and the herd will be placed under movement
restriction until such time as the disease risk is determined to have ended.
The proposed Order is made under the Animal Health Act 1981 and therefore inspector
powers of entry, testing, seizure and slaughter are all contained in the parent Act and
therefore are not replicated in the Order. As with other 1981 Act Orders this proposed
Order will be enforced by local authorities. Obstruction of inspectors in the exercise of
their duties and non-compliance with any requirements of the Order will be prosecuted
under the 1981 Act.
Question 5: How can we best ensure that all camelid owners are aware
of these proposed new powers?

12
Legislative changes that we do not propose to make at
this time but will keep under review
(i) Deer
2.11 From our conversations with stakeholders we are aware that some in the deer
farming industry would like changes made: to the level of TB compensation; to
arrangements for the TB testing of deer to allow for blood testing; and to remove the
requirement for deer farmers to pay for TB tests.
2.12 The Animal Health and Welfare Board for England (AHWBE) has been reviewing
compensation generally and we propose to revisit compensation for deer when that review
has completed its work.
2.13 The tuberculin skin test is currently the only internationally recognised standard for
TB testing of deer. We have encouraged the deer industry to consider carrying out their
own research to validate blood tests as supplementary ante-mortem diagnostic tools for
TB in captive deer, and if that happens successfully we will look again at whether to
provide for such additional validated tests.
2.14 The costs of TB testing of deer are currently borne by deer farmers and we propose
to look again at the whole issue of who pays for testing as part of a wider consultation on
TB in non-bovine animals.
(ii) Camelids
2.15 From our conversations with stakeholders we are aware that some in the industry
would like changes made to the level of TB compensation.
2.16 AHWBE has been reviewing compensation generally and we propose to revisit this
when that review has completed its work.
Question 6: Are there any other comments you wish to make about
these proposals? (Please provide evidence in support of further
changes you are proposing)
Administrative changes to the current arrangements for
TB testing of camelids
2.17 Based on all the available evidence the Government does not propose to change
the current arrangements and introduce a statutory surveillance scheme for TB in camelids
like the one we have for cattle. But the Government is proposing to deploy better tests to
identify disease and to do this within a statutory framework similar to that which has
successfully been used for deer for more than 20 years. To date AHVLA staff have in
many cases been prepared to invest extra time and effort to persuade keepers to have
their animals TB tested only to find some keepers change their minds about testing or the
removal of reactors when the results are known. We intend that with the introduction of

13
statutory compensation the present voluntary form of agreement should be replaced by a
notice requiring camelid keepers to test animals, and those that test positive to TB will be
subject to a notice of intended statutory slaughter.
2.18 We propose the new testing regime for known infected herds will comprise a
tuberculin skin test with injection of bovine tuberculin only (i.e. a more severe interpretation
than that currently used) followed by two antibody blood tests in parallel interpretation (i.e.
with animals positive to either or both tests being considered infected and removed). The
Government will continue to pay for this skin and blood testing and compensate keepers
for the removal of their affected animals with the same level of payment for animals that
are culled until the outcome of the AHWBE review of compensation is known. By making
these more sensitive tools available the Department will expect keepers to cooperate with
veterinary inspectors carrying out the timely testing of their animals.
2.19 At present TB screening of any animal that may have been moved out of a TB-
infected herd before the infection was diagnosed on the premises of origin is by
comparative skin testing only. With the availability of validated antibody TB tests, the
Government proposes that any spread-tracings instigated by AHVLA from herds with
confirmed M. bovis TB will be subject to the same TB testing regime as the infected herd
of origin. In other words, animals identified as TB spread-tracings will have to pass a
single (bovine tuberculin only) intradermal test followed by two antibody blood tests in
parallel interpretation, at the Governments expense.
2.20 There are other cases where M. bovis infection is only suspected in a camelid
herd, but not confirmed by laboratory culture, or where a herd are identified by AHVLA as
being at risk of TB because of their proximity or epidemiological links (known as back-
tracing) to infected, cattle, deer, goats or other camelids. In those situations, the
Department proposes to use the current comparative skin test followed by the dual
antibody test with serial interpretation (i.e. removing only SAC that are positive on both
antibody tests) at the Departments expense.
2.21 As llamas and alpacas are traded internationally and any TB breakdowns abroad
caused by undetected TB-infected animals exported from the UK could have serious
implications for the reputation of UK plc, particularly in Europe. The Department is
proposing that the guidance for exporters is amended so that they should undertake (and
pay for) private pre-export TB testing using the existing skin and an antibody TB test of
their choice in the 30 days prior to date of export. If exporters fail to act in accordance with
the revised guidance the Department will consider other actions, including regulation, to
protect the UKs export market.
2.22 The changes proposed here will be complemented by revised guidance on the TB
testing of camelids, to ensure that keepers of these animals have the best available
information to inform the important decisions that they may be called upon to make.
Question 7: Do these administrative changes in TB testing of camelids
go: too far, far enough, not far enough? Explain why

14

Annex A: List of consultees

British Alpaca Society
British Deer Farms and Parks Association
British Llama Society
British Veterinary Association
British Veterinary Camelid Society
Camelid TB Support & Research Group
Country Land and Business Association
National Farmers Union
Scottish Government
Veterinary Deer Society
Welsh Government

15

Annex B: Defra Consultation on tuberculosis
(TB) animal disease controls for deer and
camelids - Response Form

Questions

Question 1: Do you have evidence to support a different approach to TB
in non-bovine farmed species? Yes/No* (*delete as appropriate)

(If yes, please specify)




Question 2: Does the current deer legislation provide a satisfactory
framework of essential controls on TB in deer? Yes/No*
If not, why not and what is missing?




Question 3: Does the current legislation create unnecessary burdens on
deer farmers? Yes/No*
If yes, what is your evidence; and what would you do about it?







16

Question 4: Are the safeguards proposed (para 2.10(b)) the right ones
and are there others that should be put in place to protect the public?
Yes/No*





Question 5: How can we best ensure that all camelid owners are aware
of these proposed new powers?




Question 6: Are there any other comments you wish to make about
these proposals? Yes/No* (Please provide evidence in support of
further changes you are proposing)




Question 7: Do these administrative changes in TB testing of SAC go:
too far/far enough/not far enough?* Explain why.




Question 8: Do you know of any further sources on camelid numbers,
herd sizes and businesses in England? Yes/No* (If yes, please specify)







17

Question 9: Do you have any information on how long it takes farmers
to gather and present camelids for testing? Yes/No* (If yes, please
specify)





Question 10: Do you know any further sources on the sale values of
camelids, particularly llamas, in England? Yes/No* (If yes, please
specify)




Question 11: Do you know any sources of information on the economic
returns of different camelid enterprises in England? Yes/No* (If yes,
please specify)




Question 12: Do you know of any evidence on the economic impact of
TB in camelid herds in England?




If you do not want your response - including your name, contact details
and any other personal information to be publicly available, please
tick the box or otherwise say so clearly in writing when you send your
response.






18

Annex C: Consultation criteria
The criteria in the "Consultation Principles" (http://www.cabinetoffice.gov.uk/resource-
library/consultation-principles-guidance) apply to all UK national public consultations on
the basis of a document in electronic or printed form.
Though they have no legal force, and cannot prevail over statutory or other mandatory or
external requirements (e.g. under European Community law) they should otherwise
generally be regarded as binding on UK Departments and their agencies unless Ministers
conclude that exceptional circumstances require a departure.
The key Consultation Principles are:
departments will follow a range of timescales rather than defaulting to a 12-week
period, particularly where extensive engagement has occurred before;
departments will need to give more thought to how they engage with and consult
with those who are affected;
consultation should be digital by default, but other forms should be used where
these are needed to reach the groups affected by a policy; and
the principles of the Compact between government and the voluntary and
community sector will continue to be respected.
Defra believes that in relation to this particular consultation that we have followed the
criteria. If you have any comments in relation to Defras approach to consultation then they
may be contacted at: consultation.coordinator@defra.gsi.gov.uk.
Please do not send specific responses to this consultation to the consultation co-ordinator.
We will be happy to receive those at: BTBengage@defra.gsi.gov.uk.

19

Annex D: Economic analysis for a statutory
compensation scheme for South American
Camelids (SAC)
Rationale for intervention and intended effects
Bovine TB (TB, caused by Mycobacterium bovis) is a serious infectious, often fatal,
bacterial disease of cattle and other mammals, including South American camelids:
alpacas and llamas. In England, around 9 camelid herds per year are identified by Animal
Health & Veterinary Laboratories Agency (AHVLA) with confirmed new TB infections
caused by M. bovis. The government intervenes generally because actions taken by one
animal keeper in relation to TB on his or her premises may allow onward spread that
causes losses and costs to others (including keepers of other susceptible species). Such
interventions are in proportion to the risks involved.
Current government intervention with herds of camelids that have TB is partly based on
voluntary agreement with keepers. The law does not specify the flat 750 public-funded
non-statutory payment that is currently offered for each animal identified as affected and
culled. Section 32(3) of the Animal Health Act 1981 requires compensation to be set down
in an Order and the lack of a statutory compensation scheme leaves the government
unable to invoke other statutory control measures (powers of entry, testing and removal of
animals) in a limited number of cases. Defra lawyers have advised that a statutory
compensation scheme must be placed in law.
The primary aim is to improve disease management by ensuring all camelid keepers with
animals affected by TB undergo a new enhanced testing regime (comprising compulsory
skin and double blood testing); and for those who currently refuse to have their herd tested
to comply. TB blood testing of infected camelid herds has been voluntary. Camelid
keepers could get their animals de-restricted on the back of negative skin test results
alone, thus increasing the risk of leaving infected animals undetected in the herd
compared with the far more sensitive combined skin and blood TB testing regime.
Policy options
Defra has considered the risks of retaining the current (business as usual) arrangements
as well as those associated with withdrawing all government support for TB in camelids.
On balance Defras preferred option is to establish a statutory compensation scheme with
compensation at the current non-statutory payment level of 750 per animal culled.

The introduction of a statutory scheme will enable AHVLA to invoke other statutory powers
to enter premises and test when there is a suspicion of TB, and remove animals where
necessary.


20

Benefits from the preferred option

a) Improved control of TB.
b) Reducing the potential spread of TB as infected animals could further spread the
disease in the herd, or even off the premises, particularly in the final stages of the
disease.
c) A possible welfare gain of quickly culling infected animals rather than leaving them
to die of TB.

Risks and Uncertainties

Future levels of TB in camelids are uncertain, as is the future number of camelids
slaughtered due to additional testing along with their potential value given the wide range
of infection prevalence within affected herds. There is a risk of non-cooperation when
mandatory blood testing is rolled out, as some in industry are known to be sceptical of
blood testing.

Economic analysis

South American Camelids in England

We have limited evidence of the impact of TB and the controls on the camelid industry. As
a result, a number of assumptions have been made to estimate the economic impact of
introducing a statutory compensation scheme for camelid keepers.

Based on advice from the British Llama Association (BLA) and British Alpaca Society
(BAS) we estimate there are between 28,000 and 34,000 camelids in England, a third of
which are kept by 250-300 commercial businesses. This suggests an average business
herd size of 37. These businesses are mainly breeders plus fleece producers, meat
producers, and trekking establishments.

Question 8: Do you know of any further sources on camelid numbers,
herd sizes and businesses in England?

Defra statistics

show that around 65 camelid businesses were affected by TB in England in
2012 and there have been on average 9 new breakdowns confirmed by culture in England
per year. Per breakdown, around 8 animals are slaughtered with 74 slaughtered in total
per year on average. This has led to 55,500 paid in compensation per year.

Impacts on businesses of TB controls

TB controls in camelids include: testing for disease; movement restrictions on premises
that are found to have disease or refuse testing; and, the removal and slaughter of TB
affected animals. These controls, whilst they are designed to control and prevent further
disease, will impose costs on keepers.

The majority of the costs of testing are currently paid by AHVLA including vet fees,
transport of samples and culture. However, we recognise that keepers face costs in

21

gathering and presenting animals for testing. This has been estimated at an average of 2
hours per test, monetised using standard farm labour wage rates from Nix 2013.

Question 9: Do you have any information on how long it takes farmers
to gather and present camelids for testing?

Early identification and culling of camelids that are infected with TB may impose costs on
keepers where they could have gained further enjoyment and economic value from them.
This will depend upon the length of time a camelid could live undetected with TB and the
economic value of the animal over that time. Whilst the current non-statutory payment
takes some account of the replacement value of camelids, the true economic loss is
measured by their economic potential.

We have limited information on the economic returns for different camelid enterprises. We
have used the sales values of cria (young camelids) from www.alpacaseller.co.uk and
production costs from Nix to estimate the potential economic value for breeding stock.

Question 10: Do you know any further sources on the sale values of
camelids, particularly llamas, in England?

Question 11: Do you know any sources of information on the economic
returns of different camelid enterprises in England?

Any costs need to be viewed against the benefits of earlier disease detection, prevention
of onward spread within the herd or into neighbouring farms/wildlife and the possible
welfare gain of culling infected animals sooner.

Question 12: Do you know of any evidence on the economic impact of
TB in camelid herds in England?


Sources of evidence

Defra stats: https://www.gov.uk/government/statistical-data-sets/other-tb-statistics
Nix (2014) John Nix Farm Management Pocketbook, 44
th
Edition, Agro Business
Consultants.
Sensitivity of combined skin and blood testing: Veterinary advice, based on
AHVLAs report of TB blood test evaluation study in alpacas (Rhodes et al. 2012)

22

and peer-reviewed published research: http://cvi.asm.org/content/19/10/1677 and
http://cvi.asm.org/content/18/12/2143
Dean et al. (2009) Use of serological techniques for diagnosis of Mycobacterium
bovis infection in a llama herd http://www.ncbi.nlm.nih.gov/pubmed/19749210
Alpaca sale value: www.alpacaseller.co.uk


60
Chapter 4:
The Regulatory Framework
for Open Farms
61
Chapter 4:
The Regulatory Framework
for Open Farms
Chapter 4: The Regulatory Framework for Open Farms
4.1 Regulatory Control of Open Farms
4.2 Current UK Legislation
4.3 Main Regulatory Bodies
4.4 Inspection Procedures
4.5 Standards for Farms including Open Farms
4.6 References
Key Points
The legal and institutional framework for protection of human health and the prevention of
disease outbreaks in Great Britain is complex. The prevention of an outbreak involves different
laws and combinations of regulatory authorities from those involved in the control of an
outbreak of disease
Separate regimes have been set up by Parliament for animal health including zoonoses, public
health, food safety and occupational health and safety. Each regime is the responsibility of
a different Government Department, with separate agencies and different mechanisms for
delivery of the intended outcomes
Four separate streams of legislation apply to health hazards that may be present at Open
Farms, covering:
Public health
Food safety
Animal health
Health and safety at work
Prevention of risks to human health arising at Open Farms is governed principally by food
safety, and by health and safety law which covers risks to visitors and depends primarily on
compliance by farm operators with statutory duties
There is a wide range of regulatory and enforcement options for the control of risks to health
and safety. Options include prohibition, licensing, regulations, approved codes of practice and
non-statutory guidance
Responsibility for enforcing the law at farms is shared between the Health and Safety Executive
(HSE) and the local authorities (LAs), depending on the kind of activity at each farm. Inspectors
have powers to serve improvement or prohibition notices and to prosecute
International comparisons show that there is no European Directive for Open Farms but we
found some regulations and guidance in individual European countries, plus North American
and Australian States. The Netherlands is currently strongly considering replacing its current
guidance system with an enforceable statute in view of the risk of zoonotic infection.
62
4.1 Regulatory Control of Open Farms
Different kinds of farm-related activity are regulated in different ways and by different authorities, as set
out in detail in a paper by Weightmans Solicitors commissioned by the Health Protection Agency (HPA)
(i). Prevention of outbreaks of disease at Open Farms involves laws and a combination of regulatory
authorities that differ from those involved in investigation and control of an outbreak.
Prevention depends on compliance by farm operators with duties laid down in food safety, and in
health and safety laws. Food safety law is enforced by LAs whereas responsibility for enforcing health
and safety law is shared between LAs and the national health and safety regulator, the HSE, depending
on the kind of activity at each farm. The HSE inspects the vast majority of agricultural premises but
enforcement of health and safety law at Open Farms is the responsibility of LAs, for the reasons
described below.
The HSE and LAs maintain a joint liaison committee (HELA) (1), set up in 1975 to provide effective
liaison between enforcing authorities. HELA seeks to ensure that health and safety legislation is enforced
consistently among LAs and between LAs and the HSE. It provides a national forum for discussion and
exchange of information, and issues guidance on enforcement of legislation to the HSEs inspectors and
LAs, whose Environmental Health Offcers (EHOs) carry out health and safety inspections as well as
performing other functions such as food hygiene inspections at Open Farms.
The allocation of enforcement responsibilities under the Health and Safety (Enforcing Authority)
Regulations 1998 in respect of farm-related activities is fragmented, as can be seen below in an extract
from an administrative circular (2) interpreting the 1998 regulations. Issued to LAs by HELA, it contains
an A-Z guide explaining the allocation of responsibility for enforcement at various kinds of premises
including agricultural, entertainment and leisure activities (see extracts in Table 4.1).
Chapter 4: The Regulatory Framework for Open Farms
63
Table 4.1: Responsibility for health and safety enforcement at premises for agricultural, entertainment
and leisure activities
Type of
activity
Agency
responsible
Scope of responsibility
Agricultural
activities
HSE Reg.2(1)(a) defnes this as including horticulture, fruit growing, seed
growing, dairy farming, livestock breeding and keeping, including the
management of livestock up to the point of slaughter or export from
Great Britain, forestry, the use of land as grazing land, market gardens
and nursery grounds and the preparation of land for agricultural use.
(Sch 2 para 7). But these activities are not defned as agricultural
activities when carried out at a garden centre or other shop. (Reg.
2(1)(b)). LA enforced. For this purpose livestock breeding and
keeping does not include activities the main purpose of which is
entertainment. (Reg 2(1)). Thus Open Farms visited by the general
public would be LA enforced.
Agricultural
shows
HSE Any activity at an agricultural show which involves the handling of
livestock or the working of agricultural equipment. (Sch 2 para 7).
Horses do not fall within defnition of livestock unless used for any
agricultural activity, eg, ploughing. LA where no agricultural activity,
unless part of a farm and not a separate legal entity.
Animals, birds
or other
creatures
LA In connection with the care, treatment, accommodation or exhibition
except as below.
HSE Where the main activity is horse breeding or horse training at a stable,
or is an agricultural activity or veterinary surgery (Sch 1 para 11).
Handling of livestock (Sch 2 para 7), fsh, maggot and game breeding
except in a zoo (Sch 2 para 10). Research.
Education HSE
Entertainment
(public)
LA HSE has responsibilities where the LA is the duty holder and for specifc
Sch 2 activities in premises, eg, fairgrounds, broadcasting, recording,
flming, and any activity at an agricultural show which involves the
handling of livestock or the working of agricultural equipment.
Leisure/cultural
activities
LA Sch 1 para 9 allocates a wide range of premises to LAs, for example
sports facilities, cinemas, circuses, racecourses, riding schools, etc. Cultural
activities will include non-educational pursuits such as dance schools,
other than those attached to schools.
HSE Where the main purpose of the premises is educational or vocational
training similar to that provided in the mainstream educational system,
such premises will remain with HSE including their evening use for leisure
purposes.

Pony trekking LA/
HSE
The enforcing authority will depend on the main activity.
May be subject to the Adventure Activities Licensing Regulations 1996.
Zoos LA (Sch 1 para 11).
Source: HELA administrative circular LAC 23/15
64
Open Farms are not specifcally defned by the 1998 Regulations but as their main purpose has been
identifed by HELA as entertainment they are the responsibility of LAs (Table 4.1). These arrangements
mean that the national health and safety regulator is responsible for, say, 100,000 agricultural holdings
throughout Great Britain (3), including farms that open only occasionally to the public, whereas a few
hundred Open Farms are inspected by LAs. In practice, most LAs will each have only one or two Open
Farms to inspect.
Regulation 5 of the Regulations allows enforcement responsibility for any particular premises or activity
to be transferred from the HSE to the LA, or vice versa.
4.2 Current UK Legislation
The legal and institutional frameworks for protection of human health and the prevention of outbreaks
are complex. Over time, separate regimes have been set up by Parliament for animal health (including
zoonoses), public health, food safety and occupational health and safety. Each regime is the responsibility
of a different Government Department, with separate agencies and different mechanisms for delivery of
the intended outcomes.
England and the devolved administrations in Scotland, Wales and Northern Ireland have each
established their own regulatory institutions and pursue their own policies for public health, animal
health and food safety, whereas health and safety at work has not been devolved but remains reserved
to the Westminster Parliament. These complicating factors have relevance to the issues we have been
asked to address.
4.2.1 Prevention Health and Safety Law
There is no European or international regulatory standard for Open Farms. Thus health and safety law
applies for the prevention of risks to human health from activities at Open Farms in Great Britain.
Health and safety law was reformed in the early 1970s after Parliament decided that Britains
performance in preventing work-related injuries and ill health was unsatisfactory. The Health and Safety
at Work etc Act 1974 (HSWA), based on the common law duty of care, has replaced the previous
prescriptive and outdated requirements that had accumulated over the years in the Factories Acts.
HSWA applies across the whole of Great Britain. It is goal-setting in the sense that it requires an
outcome to be achieved rather than being prescriptive in setting out rigidly what has to be done.
Sections 2 to 7 of the Act contain the so-called general duties of employers and others for ensuring
the protection of human health and safety. These general duties always apply, whether or not additional
measures are specifed. Essentially, they require employers to ensure the health and safety of employees
so far as is reasonably practicable (SFAIRP). The term so far as is reasonably practicable has been the
subject of interpretation by the Courts. In the decided case of Edwards v National Coal Board (4), Lord
Asquith said:
Reasonably practicable is a narrower term than physically possible and seems to me to imply a
computation must be made by the owner in which the quantum of risk is placed on one scale and the
sacrifce involved in the measures necessary for averting the risk (whether in money, time or trouble) is
placed in the other, and that, if it be shown that there is a gross disproportion between them the risk being
insignifcant in relation to the sacrifce the defendants discharge the onus on them.
Chapter 4: The Regulatory Framework for Open Farms
65
Section 3 of the Act is particularly relevant to businesses such as Open Farms or fairgrounds which
invite members of the public into their premises, as it requires every employer to conduct his
undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his
employment who may be affected thereby are not thereby exposed to risks to their health or safety.
Risks to the health of visitors from activities such as arise in the running of an Open Farm are thus
clearly covered by Section 3.
In addition to these general duties, the Act allows a range of other regulatory options. These may be
described as a hierarchy of regulatory controls that may be applied to risks ranging from high to low as
illustrated by Figure 4.1.
Figure 4.1: The hierarchy of regulatory controls that may be applied to risks
Risk Tolerability Regulatory options
Extremely high Intolerable Bans, proscriptions
High Licensing, permits
Notifcation, registration
Special regulations
Medium
Approved Codes of Practice
(ACoPs)
Low Guidance
Very low Insignifcant Ignore
A very dangerous substance or activity may be banned. However bans are unusual as much can often
be done technically or through safe systems of work to eliminate or considerably reduce the hazard
and so remove or reduce the risk. For high risks which are not banned the law expects the maximum
effort in terms of time, trouble and expense in order to reduce them to a level as low as reasonably
practicable. A licence to operate may be required to which conditions may be attached (eg, for the safe
operation of nuclear power stations, for stripping of asbestos from buildings or for businesses running
adventure activities). Alternatively a safety case might have to be submitted for acceptance by the
regulator before operations may begin (as in the case of offshore oil and gas installations).
66
Special regulations may be made under the Act to deal with a particular hazard (eg, lead, asbestos,
electricity) and may apply either to all or certain industries. Many apply to Open Farms and some with
particular relevance to this Investigation are:
The Management of Health and Safety at Work Regulations 1999 (5) which make more explicit the
general duties contained in HSWA, require among other fundamental provisions that employers
appoint a competent person and carry out a risk assessment and (if more than fve persons are
employed) record signifcant fndings
The Health and Safety (Enforcing Authority) Regulations 1998 (6) which allocate responsibility for
enforcement of health and safety legislation (HSE) at different kinds of premises and activities between
HSE and LAs. These are set out in Schedules to the regulations
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) (7) extends to
microbiological risks. The regulations impose duties on employers and require among other things that
they do not carry out work which is liable to expose any employees to any hazardous substance unless
they have made a suitable and suffcient assessment of the risk and of the steps that need to be taken
to meet the (other) requirements of the regulations. The duties on employers extend to other persons
(including members of the public) who may be affected by their work activities.
4.2.2 Great Britains National Strategies for Health and Safety
In 2000 the HSE agreed a strategy (8) with the Government for Revitalising health and safety at work,
in which targets were set to reduce the incidence of injury and ill health and the number of days lost
from work; to be achieved by 2010. A key element of this strategy was to reduce the incidence of ill
health at work. Following a review, HSE announced in September 2004 that delivery of these targets
would in future be addressed by two strategic programmes Fit for work, ft for life, ft for tomorrow (9)
and Major Hazards. Subsequently, HSE and the local authorities entered into a Partnership Agreement
through which they committed to working more closely together in future. In June 2009 and following
a public consultation exercise, HSE launched a new strategy, The Health and Safety of Great Britain:
Be part of the solution (10) and a joint Statement of Commitment, agreed by HSE and the Local
Authorities Co-ordinators of Regulatory Services (LACORS) to further embed and consolidate
partnership working, see: www.hse.gov.uk/lau/statement.htm.
Chapter 4: The Regulatory Framework for Open Farms
67
4.3 Main Regulatory Bodies
It is not only the legal framework that is complex. A multifaceted administrative network exists,
comprising several separate departments, agencies and authorities with responsibilities or interests
touching on Open Farms to a greater or lesser extent. Principal among these in England and Wales are
the following:
For public health:
Department of Health (DH)
HPA reports to DH
LAs
Department for Environment, Food and Rural Affairs (Defra) and
Veterinary Laboratories Agency (VLA), an agency of Defra
For animal health:
Defra
Animal Health (AH), an agency of Defra
VLA
LAs
For food safety:
Food Standards Agency (FSA)
LAs
Defra
For health and safety at work
Department of Work and Pensions (DWP)
HSE
LAs.
LACORS is part of the Local Government Association Group. It is not a regulatory body or authority
but regards itself as part of the regulatory structure, being a council funded organisation that has a long
established role in supporting various council regulatory services including health and safety, food safety
and animal health.
Northern Ireland has its own arrangements for the above functions. Scotland and Wales have made
their own arrangements under devolved powers with the exception of health and safety at work
(the HSEs remit covers Great Britain but not Northern Ireland). We heard evidence from devolved
administrations about their approaches to prevention and control of outbreaks of E. coli O157 and took
this into account in our analyses in Parts C and D.
68
Figure 4.2 The regulatory framework as it relates to Open Farms
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Chapter 4: The Regulatory Framework for Open Farms
Figure 4.2 illustrates the main departmental bodies and layers of administration involved in regulating
public health, food safety, animal health and human health and safety at Open Farms. Some of the
principal stakeholder groups are also shown, for example those representing industry, professions,
public, and local authority interests. Major delivery agencies such as the Health Protection Agency,
Food Standards Agency, Animal Health and the Health and Safety Executive and their enforcement
arms are included but for the sake of simplicity other elements of the system are not, such as advisory
committees discussed elsewhere in the report.
69
4.4 Inspection Procedures
Since the 19
th
Century independent regulatory inspection of how businesses are complying with their
legal duties and meeting their responsibilities has been a fundamental part of the UKs health and safety
system. Regimes for public health, food safety and animal health and welfare have developed in parallel
but separately. Each has its own procedures and standards for inspection.
Some years ago the HSE developed a method to enable its inspectors to prioritise health and safety
inspections of businesses according to the degree of risk and managements competence to control it.
Known as the Inspection Rating System, it was described in a circular LAC 67/1 (Revised 3) issued to
LAs in July 2003.
Enforcement decisions under health and safety legislation are made by reference to the HSEs
Enforcement Policy Statement (11) which is consistent with the principles set out in the Crown
Prosecution Services code for Crown Prosecutors, ie, principles of consistency, transparency, targeting
and proportionality. Further information on the code can be found at:
www.cps.gov.uk/publications/code_for_crown_prosecutors/index.html
In support of the statement, HSE has developed an Enforcement Management Model (EMM)
which helps inspectors decide on what would be appropriate enforcement action in the particular
circumstances. The EMM is not intended to fetter inspectors discretion when making enforcement
decisions or direct enforcement in any particular case. Rather, it seeks to promote consistency and
proportionality in enforcement by confrming the parameters that need to be considered and the
risk-based criteria against which decisions are made. In 2004 the HSE and LACORS on behalf of
LAs entered into a formal partnership agreement (12) and a joint report in 2009 (13) includes
consideration of the progress made in joint planning and joint working that followed an independent
evaluation conducted by PA Consulting in May 2008 (14).
The HSE developed and shared with LAs an Enforcement Management Model (EMM) in 2003 to help
inspectors make decisions about taking actions that will be in line with the policy and proportionate to
risks. Depending on what they fnd, inspectors may decide to exercise their enforcement powers under
HSWA (15). Actions may range from prosecution to giving oral advice during an inspection, and include
serving an improvement notice if in the inspectors opinion a person is contravening a legal requirement.
The notice may require the contravention to be remedied and will usually include a schedule setting
out what needs to be done. There is an appeal procedure.
A prohibition notice may be served where the inspector is of the opinion that activities being carried
on (or likely to be carried on) involve or will involve a risk of serious personal injury. The notice may
stop the activity immediately or at the end of a specifed period. Again, there is an appeal procedure.
Prosecutions are few in number compared with notices served. They may follow egregious breaches of
law, particularly if death or injury has been caused.
Under their Partnership arrangements, further efforts have been made by the HSE and LAs to work
together and to record enforcement procedures in instructions shared by their inspectors. The HSE
and LAs have a duty under Section 18 of HSWA to make adequate arrangements for enforcement.
In 2008 they developed a Section 18 Standard (16) setting these out, including common measures to
ensure their inspectors are competent to undertake regulatory activities. An Annex to the circular LAC
70
67/1 (Rev 3) contained guidance to the HSEs staff and LAs about actions that may be appropriate in
different circumstances. That circular was under review at the time of the Godstone outbreak and was
replaced in October 2009 by new Priority Planning Guidance. The guidance is described as providing
the necessary detail to help LAs comply with the S18 Standard on Priorities and Planning and Targeting
Interventions and is consistent with priority planning guidance used by HSEs own inspectors.
4.5 Standards for Farms including Open Farms
4.5.1 Approved Codes of Practice
Practical advice on compliance may be given by a regulator in the form of an approved code of practice
(ACoP). For example, an ACoP may explain the meaning of a suffcient and suitable risk assessment in
the COSHH regulations (17). An ACoP may be produced for microbiological hazards as is the case for
control of legionella (18). ACoPs have a special legal status under HSWA. If employers are prosecuted
for a breach of health and safety law and it is proved that they have not followed relevant provisions of
an applicable ACoP, a court may fnd them at fault unless they can show compliance in some other way.
There is no ACoP specifcally for E. coli O157. We noted that since 2007, some Codes of Practice have been
approved to do with gas installation, construction, asbestos and work equipment (see www.hse.gov.uk).
4.5.2 Accreditation Schemes
Self-regulation and voluntary accreditation are recognised as playing a part for setting standards.
Accreditation schemes, whereby a business or individual can seek a badge from an independent expert
organisation with competence to carry out inspections and audits, offer assurance to the public that
the business is meeting any relevant standards. The Access to Farms Farm Inspected scheme is an
accreditation scheme for farms where educational activities are undertaken.
4.5.3 HSE Guidance on Open Farms
Agriculture remains one of the most hazardous industrial sectors, with a fatal injury incidence rate in
2008/09 (19) of 5.7 per 100,000 workers (compared with 2.4 per 100,000 workers in construction and
a national average of 0.6 per 100,000 workers).
Approximately 530,000 people work in agriculture (source: Defra Census 2008) which includes a
range of sectors including arable, dairy, livestock and mixed farming, the growing of fruit and vegetables,
arboriculture, forestry, production horticulture, agricultural and animal husbandry services.
HSEs strategy for addressing the poor health and safety performance of the industry has changed over
time. For many years, the interventions chosen were based on inspection. Latterly, greater resource has
been directed to promoting and raising awareness among much greater number of farmers through
a variety of communications methods, including direct marketing, Safety and Health Awareness Days
(SHADs) and working with key industry infuencers and stakeholders. This approach has resulted from a
regulatory decision that an inspection based approach was neither effective nor cost effective in tackling
an industry characterised by micro-businesses, self employment and family enterprises. This analysis has
continued to underpin HSEs strategic approach to the industry.
Chapter 4: The Regulatory Framework for Open Farms
71
The current strategy (Agriculture Revisited) agreed by the HSE Board in May 2008 is set out in Board
paper 08/24 which can be accessed from the HSE website.
The Investigation noted the Prevention of Accidents to Children in Agriculture Regulations 1998
(PACAR) and the associated ACoP (20) introduced in April 1999. The regulations apply to farmers or
persons responsible for agricultural activities and prohibit children from driving or riding on certain
classes of vehicle or agricultural plant and machinery. They do not address the health risks to children
from agricultural activities and were not brought to our attention by any witnesses. There is also advice
and guidance for farmers (21) that includes how to reduce the risk of accidents to children and young
people whether residents or visitors and refers to risks from animals including (briefy) E. coli O157
infection.
To assist Open Farms with risk assessments the HSE published free information sheets setting out
advice to farmers on practical steps to ensure the health and safety of visitors, including one aimed
specifcally at Open Farms and the risk of E. coli O157 infection (Agricultural Information Sheet AIS23
[discussed in Chapter 8]). LA Inspectors are expected by HELA to make reference to this when
inspecting Open Farms. The leafet contains a supplement designed to help teachers and others who
organise visits to farms (AIS23 Supplement) (see Appendix 5).
Another information sheet Common Zoonoses in Agriculture (AIS2) gives general guidance for
farmers on the range of diseases carried by animals that can also affect humans and the precautionary
measures that should be put in place on working farms and also if the farm is open to the public (see
Appendix 6).
The advice contained in published guidance such as AIS23 is non-statutory, and is usually accompanied
by this legal disclaimer:
This leafet contains notes on good practice which are not compulsory but which you may fnd helpful in
considering what you need to do.
Employers are thus free to take other action, but the HSE takes the view that if they do follow guidance
they will normally be doing enough to comply with the law.
In 2003 the HSE produced a four-minute video (22) containing advice about the risk at farms from
E. coli O157. This can still be viewed on the HSE website.
The HSE issued guidance (23) to inspectors in 2003 on applying the principles of the EMM to risks to
health and the standards expected in AIS23 (Rev) on Open Farms (see Appendix 7). In 2005 HELA
also launched a secure intranet website called HELex where HSE and LAs enforcement offcers can
communicate with one another by uploading, downloading and exchanging relevant information and
data. This site is not publicly accessible.
After the Godstone outbreak, and following a request by the HPA to the HSE and LAs that all Open
Farms should be visited, HELA issued another circular (24) to LAs on 21 October 2009 entitled
E. coli O157 outbreak August/September 2009. This contained revised advice from the HSE about
inspections of Open Farms, reaffrming LAC 61/1 general guidance on application to health risks with
an annex explaining how to apply the EMM to various scenarios they might fnd. The circular contained
a statement: HSEs Biological Agents Unit (BAU) is satisfed that the guidance in AIS23 (Rev) is proportionate
and ft-for-purpose providing sensible, practical advice, consistent with that provided in other countries, eg, USA.
It is aimed at farmers and through the supplement at teachers or others in charge of visits as a work activity,
not at members of the public generally.
72
4.5.4 International Standards for Open Farms
Chapter 1 identifes that agricultural and environmental exposures are a well recognised cause of
E. coli O157 outbreaks across the world. During the Investigation we searched on the internet and also
sought information from expert authorities for more detail on international standards and legislation
relevant to Open Farms.
In the USA, a number of outbreaks of E. coli O157 have been associated with animal contact, but
there is no Federal US law that specifcally addresses the issue of preventing disease associated with
animals in public settings. The Animal Welfare Act (9CFR Ch.1, Section 2.131) administered by the US
Department of Agriculture (USDA) requires petting zoos to hold a licence and is aimed principally
at assuring humane treatment of animals, not the protection of human health. However the licensing
requirements demand supervision at all times by a trained and competent person if the animals are
being handled. Suitable barriers must be in place to protect both the animals and the public from
harm. In 2009, Centers for Disease Control and Prevention (CDC) issued a Compendium of Means
to Prevent Disease Associated with Animals in Public Settings (25). This was because of the inadequate
understanding of disease transmission among visitors, especially children to Open Farm-type premises
and also because of instances in which numerous persons became ill. The report, which includes petting
farms (ie, Open Farms) provides recommendations for public health offcials, veterinarians, animal venue
staff members, exhibitors, visitors, physicians and others concerned with minimising risks associated with
animals in public settings.
Pennsylvania enacted legislation that specifcally regulates petting zoos (26) and North Carolina enacted
legislation in July 2005 that requires petting zoos to obtain permits and undergo inspections (27); the
bill is called Aedins Law in honour of two-year-old Aedin Gray whose exposure led to life-threatening
haemolytic uraemic syndrome (HUS) and its purpose is to control public contact with animals, inform
the public of risks related to animal contact, provide transition areas, regulate animal care and license
petting zoos. Massachusetts and Washington State have available brief recommendations (28,29). The
South Australian Governments Department of Human Services has also issued guidelines for control
of infections at petting zoos and in Canada the Ontario Farm Animal Council has issued a single page
guideline (30).
In Europe, while we are aware of the EUs strategy for improving health and safety at work generally,
there is no European Directive that sets out standards or controls over the E. coli O157 risk for
Open Farms. However, we understand that in Sweden there is legislation that requires Open Farms
to be registered and the owners are required to develop a hygiene plan with veterinary input. We
understand that in Denmark, the Danish Ministry of Food, Agriculture and Fisheries (Animal Health
Division) is responsible for certifcation of zoological gardens and farms open to visitors and that there
is requirement that: children under fve years of age are only in exceptional circumstances allowed
into animal areas; the person who is responsible for the farm is also responsible for people who have
been in contact with animals or their faecal products to ensure they wash their hands afterwards; that
visitors are not allowed access to unpasteurised milk or products and all animals must be registered in
the equivalent of a County Parish Holding (CPH). Generic advice is similar to AIS23 but it and other
information additionally suggest:
1. Only wearing clothes and footwear (eg, Wellington boots) which are washable, when on farms
2. Wash all clothes and footwear immediately after any visit to a farm or leave it on the farm
3. Wash all equipment etc, used on the farm
4. Dont kiss the animals, but please pet them and then wash your hands
Chapter 4: The Regulatory Framework for Open Farms
73
5. No dummies are allowed on farms
6. No toys are allowed to be brought onto farms
7. No ordinary shoes allowed
8. An anteroom to change clothes is recommended as a lock for people entering and leaving to
encourage/remind people to change clothes and wash hands
9. Wash all clothes at 60 degrees
10. Information on how to wash hands.
Visitors are also recommended to check the health status of any farm before visiting it and this
information is openly available on the internet in Denmark.
We have received, via VLA, information from the Dutch Food and Consumer Product Safety Authority.
The Dutch recognised human infections with E. coli O157 as the result of Open Farm visits in 2000.
To date, the measures adopted in the Netherlands have been to concentrate on improving the hygiene
on farms (a safe farm environment) and teaching the visitors. The Dutch organisation representing
Open Farms has also worked on a quality/certifcation system to provide information and to motivate
the Open Farm owners to invest in providing a hygienic farm environment. The certifcation is currently
voluntary, but it may become compulsory and if so, public farms not having the basic certifcate (there
are different levels) will be closed to the public. Farms with a certifcate will be inspected on a regular
basis. Furthermore, we have been told that the Offce for Risk Assessment in the Netherlands is
currently proposing a stronger regulatory framework regarding Shiga-toxin (VTEC)-producing and other
relevant zoonotic pathogens such that enforcement will be possible. This proposal is in the context of
the ascending recognition of the importance of zoonotic infection to the human population, especially
for visitors to Open Farms (personal communication, Dr RAA van Oosterom).
4.6 References
1. HELA, the Health and Safety Executive/Local Authority Enforcement Liaison Committee
www.hse.gov.uk
2. HELA administrative circular LAC 23/15 www.hse.gov.uk
3. Defra, December Survey of Agriculture, 1 December 2009 www.defra.gov.uk
4. Edwards v National Coal Board (1949) All ER 743 (CA)
5. Statutory Instrument 1999/3242 www.opsi.gov.uk
6. Statutory Instrument 1998/494 www.opsi.gov.uk
7. Statutory Instrument 2002/2677 (amended 2003) www.opsi.gov.uk
8. Revitalising Health and Safety, 2000 www.hse.gov.uk/revitalising/strategy.pdf
9. Strategy for workplace health and safety in Great Britain to 2010 and beyond, 2004
www.hse.gov.uk/consult/condocs/strategycd.pdf
10. The Health and Safety of Great Britain: Be part of the solution June 2009 www.hse.gov.uk
11. HSE Enforcement Policy Statement updated September 2009 www.hse.gov.uk
74
12. HSE/LACORS Partnership 2004 www.hse.gov.uk
13. HSE/LACORS Partnership Report 2008/2009 www.hse.gov.uk/lau/pdfs/lacors08ar.pdf
14. HSE and Local Authorities in Partnership: an evaluation RR680, HSE
15. See HSWA Sections 2025
16. HSE: www.hse.gov.uk/section18/index.htm
17. COSHH: Approved Code of Practice L5 www.hse.gov.uk
18. Approved Code of Practice Legionnaires disease the control of legionella bacteria in water
systems L8 www.hse.gov.uk
19. Health and Safety Statistics 2008/09 www.hse.gov.uk
20. Approved Code of Practice Preventing accidents to children in agriculture L116 www.hse.gov.uk
21. HSE Farmwise. The essential guide to health and safety in agriculture.
www.hse.gov.uk/pubns/indg427.pdf
22. www.hse.gov.uk/press/e03092.htm
23. OC 130/5, LAC 61/1www.hse.gov.uk
24. LAC 41/5 www.hse.gov.uk
25. Centers for Disease Control and Prevention. Compendium of measures to prevent disease
associated with animals in public settings. MMWR Morb Mortal Wkly Rep 2009, 58(No.RR-5):
1-21 www.cdc.gov/mmwr/PDF/rr/rr5805.pdf
26. Pennsylvania Animal Exhibition Sanitation Act 211 of 2002
http://law.onecle.com/pennsylvania/agriculture/00.025.001.000.html
27. North Carolina Session Law 2005-191, Senate Bill 268.
www.ncleg.net/sessions/2005/bills/senate/html/S268v4.html
28. Recommendations for Petting Zoos, Petting Farms, Animal Fairs, and Other Events and Exhibits
where Contact between Animals and People is Permitted
www.mass.gov/Eeohhs2/docs/dph/cdc/rabies/reduce_zoos_risk.pdf
29. Recommendations to Reduce the Risk of Disease Transmission from Animals to Humans at
Petting Zoos, Fairs and Other Animal Exhibits
http://kitsap.wsu.edu/4h/fair/recommendationspettingzoo.pdf
30. Petting Zoo Guidelines, see www.ofac.org
Independent Investigation Documents available at www.griffninvestigation.org.uk
i The Statutory framework and the roles and responsibilities of relevant public bodies concerned with
protecting public health in relation to visits to Open Farms and when investigating an outbreak of
E. coli O157 a paper by Weightmans Solicitors.
Chapter 4: The Regulatory Framework for Open Farms
75
ACDP/96/P6/Annex 1
HSE information sheet


Preventing or controlling ill health from animal
contact at visitor attractions with supplement
for teachers and others who organise visits for
children


Introduction

1 This information sheet provides advice for those responsible for premises where
members of the public, including children, are encouraged to view, touch or pet animals. Visits to
these sites are primarily for recreational or educational purposes.

Premises covered by this guidance include:
farm attractions e.g. open farms/farm parks;
petting enclaves within other attractions (including those at zoos etc);
city farms or other educational establishments;
working farms with livestock that occasionally open to the public e.g. for school visits
or to participate in Open Farm Sunday or similar events;
rare breed and rescue centres;
agricultural shows or country fairs where livestock are present;
travelling menageries or mobile petting enterprises;
other similar visitor attractions at which the public have contact with animals.

Whilst the general principles covered in this document are equally applicable to zoos, specific
guidance on managing zoonotic disease (disease passed from animals to humans) in zoos is
contained in Managing zoonotic risk in zoos and wildlife parks hyperlink to be added idc
This guidance is issued by The Health and Safety Executive. Following the guidance is
not compulsory and you are free to take other action. But if you do follow the guidance
you will normally be doing enough to comply with the law. Health and Safety
Inspectors seek to secure compliance with the law and may refer to this guidance as
illustrating good practice.
ACDP/96/P6/Annex 1
2. The information contained within this guidance is aimed at owners and managers of visitor
attractions who have legal duties under health and safety law (duty holders). It describes the
measures duty holders should take to protect visitors. Duty holders will also need to ensure that
they comply with their legal obligations to protect the health and safety of their staff, including
their employees, volunteers, helpers etc.

3. Teachers and others who organise visits should read the separate supplementary sheet which
forms part of this advice, to help them make sure that children do not become ill as a result of
visits. It may be useful to assist with the process of risk assessment which should be carried out
before the visit takes place.

4. Visits to premises covered by this guidance play a valuable part in the education and
development of children and young adults, and provide an enjoyable experience for many people.
It is unusual for members of the public to be made ill as a result of such visits. However, there
have been a relatively small number of serious cases of ill health reported as a consequence of
visits to premises.





Background

5 All animals naturally carry a range of micro-organisms, some of which can be
transmitted to humans, where they may cause ill health, which in some cases may be
severe or life threatening. Much of this guidance refers specifically to the verocytotoxin
producing bacterium E. coli O157 because it poses a serious hazard to the health of people
visiting such premises. E. coli O157 can potentially cause serious illness, especially in young
children in whom symptoms may include bloody diarrhoea and kidney failure.

6 Cattle and sheep are the main recognised carriers of E. coli O157. The organism may
occasionally be found in other animals, especially amongst the mixed species often present at
visitor attractions. These include goats, pigs, chickens, horses, deer, llamas and alpacas. Farm
dogs and wild rabbits can pick up the infection from an infected environment. Infection can also
occur in birds such as wild geese. The organism is primarily transmitted through contact with their
faeces (dung)

7 Another harmful micro-organism is Cryptosporidium parvum. This is a parasite carried by
calves, lambs, deer and goats and can cause severe diarrhoea in young children and the elderly.
It is capable of surviving for a long time in the environment.

8 People can become infected with E. coli O157 or Cryptosporidium parvum through
consuming contaminated food or drink, through direct contact with contaminated animals, or by
contact with an environment contaminated with animal faeces.

As with many other activities, visits to such premises can never be considered free from all
risk. However, implementing the control measures in this guidance will help ensure that the
risk of infection from Escherichia coli O157 (E coli O157), from contact with animals is low.
Hazard and risk
Throughout this guidance the term hazard is used to describe anything with the potential to
cause harm and risk used to describe the chance or probability of harm occurring coupled
with its severity.
It should be assumed that animals at visitor attractions carry harmful micro-organisms such as
Eschericha coli O157 (commonly known as E. coli O157 or VTEC) and Cryptosporidium
parvum. Therefore, as with many other activities, visits to such premises can never be
considered free from all risk. However implementing the control measures in this guidance will
help ensure that the risk of infection from contact with animals is low.
ACDP/96/P6/Annex 1

9 Very low numbers of micro-organisms can cause human infection and so it is important
that those responsible for the premises control the risks to visitors.

10 A number of essential control measures can help reduce the risk of people
especially children, becoming infected through contact with faeces and faecal material.
These include: good general cleanliness around the premises; including prevention of animal
soiling on paths and walkways; containing animal bedding material within pens; the careful
transporting and storage of manure; good animal husbandry; separating animal contact and non-
contact areas; provision of adequate hand-washing facilities; information for staff and visitors; and
proper supervision of animal contact and hand-washing.

11 Controlling the risks from E. coli O157 and Cryptosporidium parvum will also
control the risks from most other organisms, which are transmissible to humans by the
hand to mouth route. Precautions against other types of zoonoses are covered by HSE
Agriculture Information Sheet 2 (rev2) Common zoonoses in agriculture.

The law
12 The Health and Safety at Work etc Act 1974, and associated health and safety
regulations, place duties on a wide range of people (duty holders). If you open your premises to
the public, including for charity events, you will have duties under health and safety law.


Assessing the risk

13 When undertaking your COSHH assessment you should:
assume that all animals (including birds) carry micro-organisms such as E. coli O157 that
could represent a hazard to human health. Animals carrying infection can still appear
healthy;
remember that ruminants (e.g. cattle, sheep, and goats) carry E. coli O157;
take into account E. coli O157 is also found in a range of other animals including pigs,
horses, donkeys, deer, alpacas, llamas, cats, dogs, wild rabbits, chickens and other
birds;
recognise that although tests are available to detect the presence of E. coli O157 and
other micro-organisms a negative test result does not guarantee the animal is free of
infection as infected animals do not shed the micro-organism all the Animals which have
previously tested negative may begin to excrete the organism at a later date;
acknowledge E. coli O157 may be introduced to your premises at any time by new stock,
wild birds and animals, or by visitors;
COSHH
E. coli O157 and other micro organisms that may cause ill health are subject to The Control of
Substances Hazardous to Health (COSHH) Regulations 2002 (as amended). These
Regulations require an employer or self-employed person to:
assess the risks to employees, self-employed people and the public from exposure to
hazardous substances, including micro-organisms;
prevent, or, where this is not reasonably practicable, adequately control exposure to
the hazardous substances;
introduce and maintain control measures;
inform, instruct and train employees about the risks and precautions to be taken;
inform visitors about the risks and precautions to be taken;
regularly review the assessment and the effectiveness of control measures.

Guidance on COSHH can be obtained from the HSE website
http://www.hse.gov.uk/coshh/index.htm
ACDP/96/P6/Annex 1
bear in mind when selecting animals for petting areas that young stock, stock under
stress, or stock unfamiliar with people etc are more likely to excrete E. coli O157;
accept that other animals on the premises, including pets, may acquire the bacterium
through contact with faeces etc.


Exposure to E coli O157

14 You should assume that your animals carry E. coli O157 even though they have no
symptoms. The organism can be spread to humans by hand to mouth contact, e.g. hands
contaminated with E. coli O157 from faecal sources coming into contact with the mouth.
Children, especially those under 5 years old, are particularly at risk as they are most likely to put
contaminated fingers or items in their mouths (including thumb sucking, nail biting and
dummies/toys). Only small numbers of the bacterium are required to cause illness, so just
because something (an animal or an object) is not visibly contaminated with faeces, this does not
necessarily mean it is free from risk.


15 People may become infected when they come into contact with animal faeces or saliva
by:
touching or kissing animals in petting areas or during bottle feeding;
feeding, stroking or touching animals through gates or pens;
touching gates, or animal pen divisions, or other structures contaminated with faeces;
picking up contaminated feed from the floor:
removing contaminated footwear or clothing;
eating, drinking and smoking with contaminated hands;
using contaminated play equipment;
touching personal items taken on to the premises that have become contaminated e.g.
dropped toys or dummies and pushchair wheels.


Controlling the risk

16 In order to minimise and control the risk you should concentrate on the following:
establishing premises layout and routes, including areas to which visitors should not have
access;
defining, segregating and clearly identifying animal contact areas;
defining, segregating and clearly identifying non-animal contact areas;
defining, segregating and clearly identifying eating and play areas;
providing adequate and suitable washing facilities;
providing visitor information;
providing information and signs for visitors;
providing training and supervision of staff
establishing livestock management procedures; including management of bedding and
sick/pregnant/stressed animals;
controlling manure/run-off and compost heaps.
Control measures
Control measures are actions that need to be taken to prevent or reduce exposure to a
substance hazardous to health in this case micro organisms. Such measures include: the
layout of the premises; the cleaning of the premises; provision and use of washing facilities;
supervision; information; signage; etc. In practice, a combination of control measures will be
necessary to protect the health of visitors. To be effective these measures should be practical,
workable and sustainable. They should be reviewed on a regular basis.
ACDP/96/P6/Annex 1

These are discussed in more detail in the following sections.

17 Premises layout and routes

You should:
decide which areas you want visitors to have access to;
make sure that routes around the premises prevent visitors from entering non-access
areas, e.g. parts of the premises where work is going on, or where manure is stored etc.;
consider how you will prevent entry to non-access areas. For example, providing suitable
fencing and warning signs;
direct visitors to washing facilities as they leave any animal contact area, before they
access eating and play areas and before leaving the premises;
avoid directing visitors across tracks or routes used regularly by stock and farm vehicles.
If this is not possible then make sure visitors do not have to walk through any build up of
faeces, liquid effluent, or soiled bedding material. For example, regularly clear or clean
routes used by livestock or when cleaning out pens etc, and provide duckboards or
similar so that visitors avoid contaminating their footwear;
keep the premises as clean as practicable and ensure areas to which visitors have
access are free from any build-up of faeces.

18 Animal contact

You should:
decide on suitable contact areas where visitors will be able to pet and feed animals:
decide which animals are suitable for contact areas;
not allow the public to enter animal pens (as faeces or contaminated bedding will
underfoot and visitors may themselves carry infections on their footwear that could put
your animals at risk;
ensure adequate and suitable washing facilities are available and are used by visitors
when leaving contact areas;
ensure fencing and other barriers are regularly inspected and properly maintained;
ensure that animal contact areas where visitors stand or walk are as free as possible
from any faeces, and put in place measures to prevent contamination from liquid manure
or surface run-off where necessary;
regularly clean and disinfect pen divisions and gates as required in animal contact areas
where visitors are able to touch them;
not allow faeces to remain on and contaminate walkways or other areas used by the
visitors;
not allow contaminated bedding or run-off material to contaminate walkways or other
areas used by visitors;
ensure that eating (including sweets and ice cream), drinking, putting contaminated items
in mouths (including dummies) and smoking are prohibited in animal contact areas (signs
should be displayed instructing visitors of this requirement);
ensure an adequate number of trained staff for contact areas;
ensure where eating and play areas are adjacent to areas containing animals, measures
are provided to prevent members of the public touching the animals, e.g. by providing
double fencing. This should be positioned at a distance that will prevent visitors reaching
through to touch the animals and to prevent animals reaching over or through the fence
to contact people.

In some non-contact areas, it will not be reasonably practicable to provide double fencing
along enclosures where animals are kept. Examples would be: livestock farms that open
occasionally e.g. Open Farm Sunday; and along a farm walk/trail through fields. In such
cases the areas should be clearly signed to inform visitors they are entering a non-contact
ACDP/96/P6/Annex 1
area and touching, petting and feeding of animals is not allowed. Eating and play areas
should not be located within non-contact areas. Any decision to rely on single fencing and
signage rather than double fencing must be justified in your risk assessment.

19 Eating areas

You should:
site eating or picnic facilities away from areas where animals can be contacted, and
preferably at the end of any farm trail, walk or tour, or outside the main areas of the
premises;
make sure that visitors have to pass through or by washing facilities before going to
eating areas;
ensure visitors are advised, e.g. by adequate signage to wash their hands before eating;
exclude your animals including captive birds from eating areas. They could contaminate
eating areas with faeces. Consider wing clipping, double gates into eating areas and
adequate fencing to exclude them;
ensure where eating areas are adjacent to animal contact areas, animal contact must be
prevented e.g. by providing double fencing. This should be positioned at a distance that
will prevent visitors reaching through to touch the animals and to prevent animals
reaching over or through the fence to contact people;
provide adequate waste bins and clear discarded food from eating areas to discourage
wild birds and rodents from feeding and contaminating the area;
position ice-cream and/or sweet kiosks etc in the non-contact areas of the premises, such
as the eating areas or at the exit where visitors have passed washing facilities, and
remind visitors using the kiosks, by notices or verbally, to wash their hands before
touching or eating purchased food or sweets.

20 Play areas

You should:
where possible site play areas away from areas where animals can be contacted, and
preferably at the end of any farm trail, walk or tour, or outside the main areas of the
premises;
ensure visitors should be advised e.g. by adequate signage to wash their hands before
and after using play areas;
exclude your animals including captive birds from play areas. They could contaminate
play areas and equipment with faeces. Consider wing clipping, double gates into play
areas and adequate fencing to exclude them;
ensure where play areas are adjacent to animal contact areas, animal contact is
prevented e.g. by providing double fencing. This should be positioned at a distance that
will prevent visitors reaching through to touch the animals and to prevent animals
reaching over or through the fence to contact people;
ensure play areas are cleaned on a regular basis to remove any contamination

Washing facilities

21 While the primary control measures should focus on reducing and eliminating faecal
contamination, the most effective method of removing dirt and contamination remains
handwashing with soap and hot and cold or warm running water.

22 Washing facilities i.e. soap and running water should be provided at or near the exits
from any area/premises where visitors are encouraged to have animal contact. Cleansing wipes
or anti bacterial gels are not an acceptable substitute for proper hand washing.

ACDP/96/P6/Annex 1
23 At temporary events, such as agricultural shows where there are suitable permanent
washing facilities provided e.g. a purpose built toilet and washing block, it is acceptable practice
for animal exhibitors or others to provide information and signs to indicate that visitors should use
these facilities after contact with the animals. If such general visitor washing facilities do not exist
or are not situated close by, then it will be necessary to provide suitable temporary washing
facilities. Ideally washing facilities should be positioned close to areas where animal contact is
permitted.

Further guidance on the provision of washing facilities at agricultural shows is being discussed
with the industry.

24 The provision of adequate numbers of facilities and their location is crucial to preventing
ill health. Facilities can be individual taps and basins, and/or long sinks with a number of running
water outlets. They need to be provided and easily accessible at or near:
areas for intentional contact (petting barns etc). If there is a one-way system for visitors
through the contact area they should be provided immediately adjacent to the exit; if
there is a two-way flow of visitors they should be provided immediately adjacent to
entrances and exits. A one-way system may help to ensure that washing facilities are
properly used;
entrances to eating areas;
the exit from the premises.



25 All washing facilities should:
be accessible by all visitors, i.e. at the right heights for both children and adults or with
raised standing areas provided for children. Check these do not create tripping or falling
hazards;
have running hot and cold or warm water (e.g. mixer taps). It is easier to create soap
lather with warm water, and it may encourage visitors, especially children, to wash more
thoroughly particularly in cold weather. Warm water supplies should be fitted with a
means of restricting the temperature to no more than 43C to avoid scalding;
have liquid soap. Bactericidal soaps are not necessary;
have paper towels. Hot-air hand-dryers are suitable but may lead to queues which
discourage visitors from washing their hands. Reusable hand towels are not suitable;
Washing facilities
An acceptable way of estimating the capacity of the washing facilities is to:
estimate the maximum number of visitors expected or permitted at one time;
consider how many visitors will be in animal contact areas at any time - you may
already limit numbers of visitors in these areas to allow them time to enjoy the
experience with the animals;
assess the rate at which visitors will leave contact areas, e.g. in large groups such as
school parties or a few at a time;
estimate the time taken to wash hands effectively, remembering that a thorough hand
wash may take up to two minutes.

If you estimate that, for instance, 30 people will leave a contact area every 15 minutes, and
each person will take two minutes to wash their hands, you should provide enough washing
facilities for four people to use at one time (30 x 2 divided by 15 = 4). Make similar calculations
for other locations around the premises, e.g. at main exits or entrances to eating areas.

You can supplement permanent facilities with temporary ones at busy times e.g. just before
the summer holidays, in remote areas of the premises, or for short duration events e.g.
country shows or fairs. Portable units can be hired which have heating, lighting and running
water.
ACDP/96/P6/Annex 1
be properly maintained and cleaned regularly as required, at least daily;
be replenished with paper towels and soap as necessary;
include open or pedal operated waste bins which are emptied as necessary;
be arranged so that visitor throughput and/or water overflows etc do not make the
immediate vicinity muddy and so put people off using the washing facilities.


26 In exceptional circumstances, such as premises that open on an occasional basis
in the summer providing cold running water only, soap and disposable towels may be
acceptable. This must be justified in your risk assessment.

27 Do not provide buckets or troughs of standing water which are shared or reused by
several people - they do not allow effective hand washing, and reusing water can spread micro-
organisms among those using it. Adding a disinfectant to the water does not make the practice
acceptable.

28 It is important to encourage your staff, parents, teachers and others who have
responsibility for visitors to make sure that children and other visitors wash their hands
properly.

29 Cleaning footwear, pushchairs, wheel chairs etc

You should ensure your planned layout will prevent contamination of footwear, pushchairs, wheel
chairs etc, Where this unavoidably occurs you will need to consider providing suitable facilities to
allow visitors to clean contaminated footwear and wheels on pushchairs and wheelchairs. The
facilities should be arranged to reduce the risk of personal contamination from manure, liquid run
off etc during the cleaning process.

30 Visitor information

Information should be provided to visitors covering:

risks to health;
precautions taken to minimise risks;
personal responsibilities of visitors to minimise risks including hygiene precautions;
site plan, map, route directions or other information as necessary.

The information should be included:

on the attractions website; and
on site maps/plans or other handouts given to visitors on arrival.

Leaflets or pre-visit packs for schools and other organised groups should be provided to help
teachers and others plan the visit.

31 Information and signs

Information should include notices at all entrances to the premises to remind visitors of
the need for good personal hygiene, and to inform them that they should only eat or drink
in the designated areas.
Consider handouts for visitors and stickers etc about hand washing.
Signs should be erected in appropriate places reminding visitors to wash their hands
when leaving animal contact areas, before eating, and when leaving the premises.
Washing facilities should have signs showing how to wash hands properly.
ACDP/96/P6/Annex 1
Remember that young children may have dummies or toys that they put in their mouths.
You should remind accompanying adults not to put dummies that have fallen to the
ground back into their childrens mouths.
Pictograms, audio devices, continuous loop videos or other media may be useful.
Information should be clearly legible and may be required in languages other than
English.


32 Training and supervision

You should:
ensure staff are trained and instructed about the human health risks associated with
animals and the necessary control measures. Dont forget that training should also be
provided for temporary or seasonal staff taken on during busy periods;
ensure staff are trained and instructed on what visitors should or should not do;
provide guidance to staff on how to explain the hygiene message to visitors including the
importance of thorough hand washing, particularly for children;
arrange adequate and appropriate levels of supervision in contact areas. The number of
supervisors will depend on the size of the animal contact area and the number of visitors
permitted or expected in that area at one time;
make sure that children are supervised while they wash their hands. Although this is the
responsibility of parents or teachers, in some cases staff may need to help in supervising;
remind supervisors in animal contact areas (who may also be there to protect the
animals) to ensure that visitors do not eat, drink or put items in their mouths while in
these areas;
ensure supervisors discourage visitors (especially children) from putting their fingers in
their mouths, or kissing the animals;
stress to your own staff the importance of following good personal hygiene, e.g.
thoroughly washing their own hands when necessary, and not eating or drinking in animal
contact areas.

33 Livestock management procedures

You should:
consider producing an animal or farm health plan in consultation with your vet to help
reduce the risks from zoonoses;
assess whether animals are healthy before moving them to animal contact areas, but
remember that animals carrying E coli O157 do not suffer ill-health effects;
ensure that animals that have just given birth, or been born, are not put in contact areas;
immediately remove any animals showing signs of ill health, such as diarrhoea, or stress
from animal contact areas until they have recovered;
keep animals and their housing clean;
consider whether replacement stock can come from within the premises rather than being
brought in (this would avoid new infections being inadvertently brought on to the farm);
where possible, source replacement livestock (especially young animals for bottle
feeding) from a reputable supplier with known health status where the stock-keeper will
have ensured that they have received an adequate supply of colostrum after being born;
try to minimise movement and mixing of animals from different groups (this is particularly
important to minimise the shedding of E. coli O157 by ruminants such as cattle and
sheep);
check all animals on display regularly for evidence of illness, consulting your vet as
appropriate;
regularly empty and clean water troughs and provide the animals with clean drinking
water.

ACDP/96/P6/Annex 1
34 Manure and compost heaps

You should:
position manure or compost heaps well away from areas that visitors can access, or
fence them off;
prevent or contain any liquid run-off where this might contaminate visitor areas not allow
visitors to bag their own compost or manure.


Additional advice

Further advice on E. coli O157 including a video on handwashing is available at:
http://www.hse.gov.uk/campaigns/farmsafe/ecoli.htm


Sources of advice

The National Farm Attraction Network (http://www.farmattractions.net), the Federation of City
Farms and Community Gardens (http://www.farmgarden.org.uk) Farming and Countryside
Education (http:www.face-online.org.uk), and Farms for Schools
(http:www.farmsforschools.org.uk) all provide advice and other services. Consider using the
assurance or inspection schemes run by some of these organisations.

Where the premises are part of a commercial farm this will normally be HSE
(http:www.hse.gov.uk); in other cases it will be the local authority for your area
http://www.direct.gov.uk/en/Dl1/Directories/Localcouncils/index.htm


Other advice is available from a number of other government websites including:

http://www.hpa.org.uk/
http://www.hps.scot.nhs.uk/
http://www.dh.gov.uk/en/index.htm
http://ww2.defra.gov.uk/

Advice can also be provided by veterinary surgeons (see telephone books for contacts)

Further information
HSE priced and free publications are available by mail order from HSE Books, PO Box 1999,
Sudbury, Suffolk CO10 2WA Tel: 01787 881165 Fax: 01787 313995 Website:
www.hsebooks.co.uk (HSE priced publications are also available from bookshops.)

This publication may be freely reproduced, except for advertising, endorsement or commercial
purposes. First published 3/11. Please acknowledge the source as HSE.
AIS23(rev3) C100



ACDP/96/P6/Annex 1



Avoiding ill health from animal contact at
visitor attractions Advice to teachers and
others who organise visits for children


This supplement advises teachers and others who organise visits by children on the precautions
necessary to reduce the risk of ill health arising from contact with animals.

All animals naturally carry a range of micro-organisms, some of which can be transmitted to
humans, where they may cause ill health. Some of these, such as the bacterium Escherichia coli
O157 (E coli O157) or Cryptosporidium parvum, present a serious health hazard and have the
potential to cause severe illness and health problems which may be particularly acute in young
children.

As with many other educational or recreational activities, visits can never be considered free from
all risk. However, while the hazards are real, the risk of infection in children can be readily
controlled by simple everyday measures. The following practical steps will help make your visit
even more safe, healthy and enjoyable.

Before your visit, you should:

read and understand the advice in the main AIS23 information sheet, and discuss
arrangements for the visit with the management at the site;
confirm that the control measures provided at the site match the recommendations in
AIS23;
seek advice from your local authority or organisation on what the appropriate ratio of
pupils to teachers/leaders/assistants/parents etc. should be;
discuss and agree with the supervisors, parents or staff of the school, creche, leaders of
youth organisations etc, their roles and responsibilities during the visit. In particular, they
must understand the need to make sure that the children wash, or are helped to wash,
their hands thoroughly after contacting animals. Key points to cover with the children
should include:
o explaining the rules for the visit, stressing that they must not eat, drink or chew
anything (including sweets) outside the areas in which you permit them to do so;
o explaining why they must wash their hands thoroughly after contact with the
animals, and before eating or drinking anything;
o demonstrating how to wash their hands properly;
ACDP/96/P6/Annex 1
o discussing the requirements for appropriate clothing, including suitable footwear.
You should liaise with the attraction to ascertain what this is;
o checking that cuts, grazes etc on childrens hands are covered with a waterproof
dressing.

During and after the visit, make sure that the children:
are reminded of the rules/precautions to take upon arrival at the site;
do not kiss animals;
always wash their hands thoroughly before and after eating, after any contact with
animals and again before leaving the site;
eat only food that they have brought with them, or food for human consumption they have
bought on the premises, in designated areas, and never eat food which has fallen to the
ground, or taste animal foods;
do not suck fingers or put hands, pens, pencils or crayons etc in mouths;
where practical and possible, clean or change their footwear before leaving;
wash their hands after changing their footwear.
.
Check that the children stay in their allocated groups during the visit, and that they:
do not use or pick up tools (e.g. spades and forks) or touch other work equipment unless
permitted to do so by site staff;
do not climb on to walls, fences, gates or animal pens etc;
listen carefully and follow the instructions and information given by the site staff;
approach and handle animals quietly and gently;
do not chase, frighten or torment the animals;
do not wander off into unsupervised or prohibited areas e.g. manure heaps.

Remember:
the children are your responsibility during the visit;
you should supervise them during the visit, especially during hand washing to make sure
that each child washes thoroughly. Site staff may be able to help with this supervision;
allow plenty of time before eating or leaving so that the children do not have to rush.

If a member of your group shows signs of illness (e.g. sickness or diarrhoea) after a visit, advise
them or their parent/guardian to visit the doctor and explain that they have had recent contact
with animals.

Additional advice

Further advice on E. coli O157 including a video on handwashing is available at:
http://www.hse.gov.uk/campaigns/farmsafe/ecoli.htm


Further information
Extra copies of this information sheet and supplement are available free from HSE Books, PO
Box 1999, Sudbury, Suffolk CO10 2WA. Tel: 01787 881165 Fax: 01787 313995 or can be
downloaded fromhttp://www.hsebooks.co.uk

Printed and published by the Health and Safety Executive Reprinted 3/11 AIS23(rev3)supp C100





www.defra.gov.uk
The Strategy for achieving Officially Bovine
Tuberculosis Free status for England
April 2014


Crown copyright 2014
You may re-use this information (not including logos) free of charge in any format or
medium, under the terms of the Open Government Licence. To view this licence, visit
www.nationalarchives.gov.uk/doc/open-government-licence/ or write to the Information
Policy Team, The National Archives, Kew, London TW9 4DU, or e-mail:
psi@nationalarchives.gsi.gov.uk
This document/publication is also available on-line at:
www.gov.uk/defra

PB 14088


Contents
Secretary of States foreword: Achieving a bovine tuberculosis free England ..................... 6
I. The Strategy for achieving Officially Bovine Tuberculosis Free status for England ........ 10
Objective ........................................................................................................................ 10
Rationale for intervention ............................................................................................... 10
The problem of bTB........................................................................................................ 11
Defining the solution ....................................................................................................... 11
Implementing the solution .............................................................................................. 13
Low Risk Area (LRA) .................................................................................................. 15
Edge Area ................................................................................................................... 16
High Risk Area (HRA) ................................................................................................. 16
Research .................................................................................................................... 16
Governance ................................................................................................................ 17
II. Background .................................................................................................................... 21
Bovine tuberculosis ........................................................................................................ 21
History of bovine tuberculosis in England ....................................................................... 21
Evidence ........................................................................................................................ 28
Strategy aim ................................................................................................................... 29
Rationale for intervention ............................................................................................... 31
Strategy approach .......................................................................................................... 33
Targets and timeline ....................................................................................................... 34
Targets ....................................................................................................................... 34
Timeline ...................................................................................................................... 35
Key elements ................................................................................................................. 37
Developing our risk-based approach .............................................................................. 37
Introduction ................................................................................................................. 37


Existing bTB control measures applied in England ..................................................... 41
Developing cross-cutting bTB control measures in all risk areas ................................ 48
Developing area risk-based strategies ........................................................................ 53
Low Risk Area (LRA) strategy .................................................................................... 53
Edge Area strategy ..................................................................................................... 55
High Risk Area (HRA) strategy ................................................................................... 56
Next steps to develop our risk-based approach .......................................................... 58
Developing new tools ..................................................................................................... 58
Introduction ................................................................................................................. 58
Defras Evidence and Investment Strategy ................................................................. 58
The bTB research programme .................................................................................... 59
Governance, delivery and funding .................................................................................. 66
Governance ................................................................................................................ 67
Delivery ....................................................................................................................... 68
Funding ....................................................................................................................... 68
Monitoring and evaluation of the Strategy ...................................................................... 70
Glossary ......................................................................................................................... 72
Annexes ......................................................................................................................... 77
Annex A Badger controls and population ................................................................. 77
Annex B Enhancements of cattle measures since 2011 .......................................... 80
Annex C Sources of evidence ................................................................................. 82
Natural science ........................................................................................................... 82
Socio-economic science ............................................................................................. 82
Surveillance reports .................................................................................................... 82
Statistical reports ........................................................................................................ 82
Annex D Bovine tuberculosis in Europe ................................................................... 83


Annex E Defras bovine tuberculosis research programme ..................................... 84
Background ................................................................................................................ 84
Research spend by scientific area .............................................................................. 84

6
Secretary of States foreword: Achieving a
bovine tuberculosis free England
Bovine tuberculosis (bTB) is the most pressing animal health problem in the UK. The crisis
facing our cattle farmers, their families and their communities cannot be overstated. It is a
devastating zoonosis that threatens our cattle industry and presents risks to other
livestock, wildlife species such as badgers, domestic pets and humans.
This was once a disease isolated to small pockets of the country; in 1979 only 0.01
percent of British cattle tested as infected. It has now spread extensively northwards and
eastwards from infected pockets in the south west of England and Wales. The number of
new herd breakdowns has doubled every nine years and in the last decade we have
slaughtered 314,000 otherwise healthy cattle across Great Britain in our attempt to control
this disease. In 2013 over 6.2 million bTB tests were performed in England leading to the
slaughter of over 26,000 cattle. One quarter of herds in the South West and West
Midlands were placed under movement restrictions at some point; bTB causes misery for
affected farmers. In the last decade it has cost the taxpayer 500 million. In 2014 it will
cost the taxpayer nearly 100 million with costs to farmers estimated to run to tens of
millions of pounds.
If we do not get on top of the disease we will see a continued increase in the number of
herds affected, further geographical spread and a taxpayer bill over the next decade
exceeding 1 billion. It is therefore vital that farmers, vets, non-government organisations
and politicians work together to free England of bTB. We want to build a thriving cattle
sector which maintains our countryside, trades internationally and delivers economic
growth.
The current surveillance and control scheme is based on the traditional approach applied
across Europe: routine skin testing of cattle, removal and slaughter of test reactors
combined with post-mortem surveillance at slaughter and movement controls placed on
infected herds. In the absence of a major wildlife reservoir, this approach has been
successful in allowing many EU countries and regions, for example Scotland, to achieve
Officially bTB Free (OTF) Status. It has also been successful at preventing the
establishment of disease in many counties in the north and east of England, areas we
believe do not yet have a significant reservoir of infection in wildlife. The same approach
has reduced the spread of the disease in the areas where bTB is established but on its
own it is not enough.
Where there is a reservoir of disease in wildlife, tackling this disease will require long-term
solutions and considerable national resolve. Half measures are simply not enough. I intend
to pursue policies which will reverse this trend well before the end of this decade, achieve
OTF status for parts of England on the same timescale and thereafter progressively rid the
whole of the country of bTB. So we need a control and eradication strategy with these

7
clear aims at its heart. It must be dynamic, tailored to the sources of disease and the
potential for eliminating it. It must adapt as new tools become available.
In achieving these aims, we must learn the lessons from those countries that have
succeeded in tackling bTB where there has been a reservoir of the disease in wildlife. I
have visited Australia, New Zealand, the Republic of Ireland and the USA. I have talked to
the Ministers, farmers and officials involved and I intend to apply the lessons of their
success here in England:
Australia achieved official freedom from bTB in 1997 after a sustained campaign
over nearly three decades.
Michigan has reduced the prevalence of TB in white-tailed deer by 60 per cent
since the mid-1990s and reduced the average annual number of livestock herds
affected with bTB to single figures since 2005.
New Zealand achieved a reduction in the number of infected herds from 1,700 in
the mid-1990s to 66 in 2011/12.
The Republic of Ireland reduced the proportion of herds affected from 9.6 percent in
1995 to 7.4 percent in 2010. In the same period it increased from 0.8 percent to 9
percent in England and from 5.5 to 7.9 percent in Northern Ireland. The number of
bTB reactors in the Republic of Ireland fell by over 65 percent between 1999 and
2013, from 44,903 to 15,612, the lowest level since the eradication programme
started in the 1950s.
The vital lesson I have taken from these countries is the importance of stringent cattle
control measures in combination with tackling the primary wildlife reservoir, be it the water
buffalo in Australia, the white-tailed deer in Michigan, the brush-tailed possum in New
Zealand or, closer to home the badger in the Republic of Ireland. An additional factor
which has contributed to their success is the fact that their programmes are either led by
industry or delivered by industry and government working in partnership, with both parties
contributing to the cost.
No two countries are the same, so we will need to be smart in how we adapt and apply the
key elements of others eradication strategies to our countryside. However, the common
thread is undoubtedly the sustained and adaptive application of a control programme that
addresses significant reservoirs of infection in cattle and wildlife as well as pockets of
infection in other species such as camelids, deer and goats, through a partnership
approach.
I am delighted to publish the Governments bTB Strategy for England following a public
consultation and extensive dialogue in 2013. For the first time it:
brings together all the tools we need to address the disease including those
currently available and those under development such as cattle vaccine,
explicitly rejects the one size fits all approach, recognising the need to apply
different tools in different herds depending on local circumstances and disease risk,

8
sets targets by which we can measure progress towards achieving OTF status for
England.
The Strategy is comprehensive using all available tools to:
contain bTB in the high risk area and progressively reduce its spread, thereby
increasing the number of bTB-free herds,
maintain the commercial viability of herds in the high risk area,
maintain consumer confidence and exports without undermining the detection and
control of bTB,
reduce the risk of spread of the bTB to currently free areas,
rapidly find and eliminate bTB wherever it occurs,
reduce and eliminate the spread of TB from badgers,
identify and apply management practices that minimise transmission risk within
herds,
deploy market measures, regulation, incentives and deterrents to reduce the risk of
disease spread due to movements.
The Strategy will simply not work without addressing the reservoir of TB infection in
badgers. The option of using injectable badger vaccine has been available since 2010.
However, we estimate that a third of badgers in endemic areas are infected with TB; we
know that the vaccine does not cure them and that they remain free to spread TB. Despite
the fact that injectable badger vaccination does not entail all the licensing criteria
landowners must meet to carry out culling, there has been no widespread deployment
either by farmers or NGOs. Based on first veterinary principles and supported by
modelling, one would expect culling to be more effective than a badger vaccination
programme; that is why I have decided to continue the policy of badger culling in endemic
areas learning lessons from the pilots in 2013.
As well as using available tools, I am determined to develop new ones to support the
Strategy. Over this Parliament, we are investing 24.6 million in the development of
effective TB vaccines for both cattle and badgers. Our scientists are leading the world in
the development of a deployable cattle vaccine. I secured a clear programme from
Commissioner Tonio Borg (DG-SANCO) on the work necessary to bring a cattle vaccine to
the market. We are making progress in designing the large scale field trials necessary to
take this forward. Subject to an assessment of costs and benefits, I am committed to
meeting the earliest deadline for its implementation, but the need for the field trials and
changes in the law mean that a usable cattle vaccine is still many years away. In the
future, an oral badger vaccine might address some of the deployment issues with
injectable vaccine deployment and serve as a targeted control measure. Although some
progress has been made, we have not yet identified a candidate vaccine to take forward
for authorisation. We will also continue to invest in the development of improved diagnostic
tests for both cattle and badgers such as DNA-based technologies. My goal is to move to
a position whereby we have the tools to enable us to deploy a targeted approach,
identifying and removing only TB-infected badgers either at individual or sett level. In the
meantime we will not sit on our hands and let the problem get worse.

9
A key point drawn from other countries is the need for a partnership approach to
governance, delivery, and funding of eradication programmes with farmers making the key
implementation decisions and significantly contributing to the costs. The New Zealand
government has commissioned an independent, farmer-led body, jointly funded by industry
and government with responsibility for oversight and implementation of the eradication
strategy. It has been a great success. I am absolutely clear that if we are to tackle this
disease successfully, we need a different way of working together in England, which
acknowledges the respective responsibilities for government and industry both in terms of
what we do and how we pay for it. I intend to continue discussions with the industry as to
how we might achieve this new way of working.
I accept that the right approach is not always the popular approach. The House of
Commons gave its view in J une 2013, when it endorsed by a majority of 61 votes a motion
reflecting our strategic approach. This includes drawing on international experience which
demonstrates the importance of bearing down on bTB in cattle and wildlife. It also stresses
the need to employ every available tool to deal effectively with the disease, researching
and investing in the development and deployment of new technologies.
I am extremely grateful for the work of the Animal Health and Welfare Board for England,
the Bovine TB Eradication Advisory Group for England and to all those who responded to
our public consultation or took part in stakeholder and public dialogue events. The
Strategy, which they have all played a part in developing, recognises that achieving OTF
status for England will be a long haul. I am however confident that it is not beyond industry
and government to achieve it for England within the timescales we envisage. My aim is for
England to be free of bTB by 2038 with healthy livestock living alongside healthy badgers.
Our livestock industry, our badgers and our countryside deserve no less.

The Rt Hon Owen Paterson MP
Secretary of State for Environment, Food and Rural Affairs

10
I. The Strategy for achieving Officially Bovine
Tuberculosis Free status for England
Objective
The objective of the Government is to achieve Officially Bovine Tuberculosis Free (OTF)
status for England by 2038. It also has an interim objective of achieving OTF status for
large parts of the north and east of England as soon as possible but most likely by 2025.
This will be achieved by three key actions:
a) establishing three bovine tuberculosis (bTB) management regions or zones (a High
Risk Area, a Low Risk Area and a buffer zone (Edge Area) in between);
b) applying a range of measures to control the disease within these zones that is
practical and proportionate to the disease risk while maintaining an economically
sustainable livestock industry;
c) ensuring that there is shared governance of the delivery process between the main
beneficiaries including the food and farming industry and the taxpayer.
This activity will be led increasingly by the farming industry and other stakeholders, and
their responsibilities will include the effective application of disease control measures in
cattle, securing best practice in livestock farming including on-farm methods for preventing
the spread of disease, and addressing the reservoir of bTB in wildlife
1
whilst maintaining
biodiversity. We explicitly recognise the need to adapt our approach as the epidemic
evolves and new evidence and technology becomes available and to embrace partnership
working with a range of stakeholders, as well as working effectively in the European Union
(EU).
Rationale for intervention
Bovine tuberculosis (bTB) is an increasing social and economic problem in England.
There is a strong social and economic case for controlling the disease in order to support a
thriving and sustainable livestock sector and the United Kingdom (UK)s statutory bTB
eradication programme is designed to comply with international standards for trade. The
fact that the bTB situation in the UK (excluding Scotland) is the worst by far in the EU and

1
While Mycobacterium bovis has been found in wildlife other than badgers, evidence from surveillance and
modelling indicates that the badger remains the principal and possibly the only wildlife maintenance host in
England. However, we will continue to review the potential role of other wildlife species in the epidemiology
of bTB.

11
probably the worst in the developed world, poses an increasing risk to intra-EU and
international trade. Additionally, bTB can pose a risk to human health.
The problem of bTB
Over the past three decades, the incidence of bTB in England has continued to increase
and the disease has spread from parts of the South West. Although most of the north and
east of England has had a very low incidence of bTB herd incidents (breakdowns) there
has been a much higher disease incidence in the West and South West. Parts of Wales
have had a similar problem but Scotland achieved OTF status in 2009.
The epidemiology of bTB is complex and, despite considerable investment in the evidence
base over the last 20 years, much remains highly uncertain. While the evidence that is
available needs to be used and weighted appropriately according to its relevance and
reliability, there is a need to pursue an adaptive approach to policy development,
particularly as the evidence base grows and new interventions are tried and tested.
We will deploy a package of interventions, flexibly informed by scientific and veterinary
advice, to address all likely routes of disease transmission. Due to the biology of bTB and
its complex epidemiology, most effects of interventions will only be seen several years
after their introduction and, even then, it will be difficult to assign cause and effect to any
particular intervention. As a result, each of these interventions is open to challenge by
those with different perceptions of where the real problem lies. Consequently, success is
measured through the combined impacts of a national system of intervention, rather than
looking at individual control measures in isolation.
Defining the solution
There is no single intervention that will on its own achieve control of the bTB epidemic.
Disease control needs to be constructed around controlling all routes of transmission of
the disease. These are principally cattle-cattle, but will also include cattle-badger, badger-
badger and badger-cattle as well as spillover into other susceptible species. The different
contribution made by these routes will vary with circumstances.
This approach means using all the available interventions in proportion to their likely
contributions to the aim of achieving reduced disease incidence in cattle, and as part of the
national framework. Therefore we need to:
bear down on the highest impact risks using the latest and most relevant evidence;
ensure that future interventions are designed to minimise these risks and that they
are applied proportionately to the circumstances; and

12
ensure that those who are responsible for managing the behaviours that change the
risks are aware of their responsibilities and are incentivised to deliver effective
disease control.
Improved application of epidemiological techniques has the capacity to refine our
understanding of the risk factors determining the probability of infection with bTB and to
design interventions in ways that are increasingly effective. This is a key priority and we
are committed to developing this by strengthening our application of epidemiology at local,
regional and national scales. Additional data collection and epidemiological analysis
conducted alongside implementation of integrated controls will lead to improvement in
modelling and risk assessments and in turn to improvement in the design of cost-effective
interventions to reduce disease.
This approach to risk assessment, enabling interventions to be tailored to specific
circumstances, has the greatest probability of success if it is shared with the farming
community and implemented in a partnership between farmers, veterinarians and
regulators. We intend to adapt compulsory surveillance and control measures, and the
way in which compensation funding is used, both to improve the implementation of control
measures and incentivise risk reduction actions at the scale of individual farms.
It is widely accepted that no single intervention has the capacity to control the disease.
Each intervention has strengths and weaknesses, which will vary depending upon local
circumstances. Therefore an integrated approach to controlling bTB will require the use of
a range of disease surveillance and control interventions, including statutory and non-
statutory controls.
Current statutory controls include continued surveillance for disease within cattle herds
and at slaughter, pre-movement testing, removal of bTB test reactors and other cattle
suspected of being infected with bTB from the national herd, and additional measures in
bTB breakdown herds such as movement restrictions, disinfection, and more sensitive
tests to increase the chances of removing infection from affected herds and to reduce the
probability of spread between herds.
Non-statutory controls include a range of measures that are expected to reduce the
likelihood of introducing infection into cattle herds. These include: the risk-based trading
scheme introduced in 2013 in response to the recommendations of an industry-led Risk-
Based Trading Group to enable farmers to better understand and act on the risk of
introducing disease when buying cattle; post-movement testing; biosecurity measures on
farms against both cattle-cattle and badger-cattle transmission; reduction in badger
populations; and BCG vaccination of badgers against bTB by injection. BCG is not a very
effective vaccine.
Notable potential interventions that are either not currently available or not deployable on
an operational scale are cattle TB vaccination, oral TB vaccination of badgers, the
identification and removal of TB-infected badgers and alternative approaches to badger
population control ideally focussed on removing from the population only those badgers
infected with TB. A combination of scientific and technical challenges means that each of

13
these approaches requires further work before they can be implemented but we will look to
deploy them to best effect as they become available. Ongoing research and pilots are
examining ways in which some of these interventions can be turned into operational tools.
Implementing the solution
The approach to controlling bTB ultimately aims to tackle the disease nationally. However,
achieving this will require us to apply different sets of interventions according to
circumstances because the problem is different in different parts of the country. In practice,
interventions take place mainly at the scale of individual farms but it is important to see a
coherent link between the application of these interventions and the wider national
objective of achieving OTF status by 2038.
Regional variation will be addressed by different generic control policies in three
management regions or zones. These zones are defined as the High Risk (HRA) the
Edge, and the Low Risk (LRA) Areas (Figure 1).

14
Figure 1 Geographical location of the three risk areas in 2013


















Local variation in disease characteristics can be addressed, for example, by more frequent
surveillance testing of local herds in response to emerging problems and where the
epidemiological evidence shows that bTB herd breakdowns detected by testing or by
slaughterhouse surveillance are in some way geographically and temporally associated.
This kind of intervention is already a standard approach within the LRA and Edge Area. As
our epidemiological knowledge improves, it may signal new ways of controlling the disease
at these local levels and we will introduce new measures to achieve this whenever feasible
and cost-effective.
The strategic disease control principles used in implementation are set out in Table 1. This
builds upon the interventions that we know from past experience are effective. Applying
Low Risk Area:
- Crude herd
prevalence ~0.1%
- Has remained
stable since 2006
Edge Area:
- Crude herd
prevalence ~1%
- Is steadily
increasing
High Risk Area:
- Crude herd
prevalence ~9%
- Increased from
~1.5% in 1995

15
these in proportion to the risk will improve their effectiveness. It also uses the information
we have from surveillance, epidemiology and local knowledge to greatest effect. It will lead
to a step change in the effectiveness of our approach to control bTB because it will focus
the resources in those places and situations where the problem is most profound.
Table 1 Strategic disease control principles

Define areas of the country on the basis of risk (Figure 1).
Focus disease control measures on those risks, to contain the disease in the
HRA and progressively reduce its size.
Establish a risk rating system for herds and incentivise actions by farmers to
reduce their risk.
Reduce the risk of spread of the disease to currently free geographic areas
and to unaffected cattle herds in affected areas.
Rapidly find and eliminate disease in cattle when it occurs in areas previously
free of disease.
Reduce the spread of TB between cattle both within and between herds.
Minimise the exposure of cattle to infected badgers (a key risk factor for its
introduction to cattle) and other possible wildlife vectors.
Deal promptly with any other epidemiologically significant reservoirs of TB
infection that are discovered.
Move towards an increasingly farmer-led control and eradication process, with
farmers significantly contributing to the costs of implementing the practical
decisions they are taking to eradicate the disease.
Improving bio-security is a priority. This focuses attention on the processes involved in
disease transmission. Early interventions to improve bio-security include developing the
voluntary risk-based trading scheme introduced in 2013, deploying measures at the farm
level to reduce cattle-cattle and wildlife-cattle transmission, providing the necessary
incentives to farmers to achieve risk-reduction, improving advice for farmers, improving
compliance and enforcement, and tackling TB in non-bovine species such as South
American camelids.
The intention is to progress region-by-region towards OTF status. Consequently a key
development to achieve this is the introduction of a risk-based approach to disease control
applied to three management regions or zones. The differing approaches being adopted in
these zones are set out in Table 2. Zoning will allow the system of disease management
to be proportionate to the impact upon the industry and be flexible to the different
circumstances of evolving disease risk in each zone.
Low Risk Area (LRA)
The LRA covers large parts of the north and east of England (Figure 1). It has a low
incidence of bTB and no recognised significant reservoir of the disease in wildlife.
Consequently, the objective in the LRA is to continue to protect it from the ingress of
disease through the movement of cattle and the possible resulting infection of wildlife
vectors. This will continue to involve testing of cattle before being introduced from other

16
areas, as well as improving risk-based surveillance and incentivising risk-based
approaches such as risk-based trading and the testing of cattle after being introduced as
happens in Scotland. Isolated outbreaks will be controlled using the most sensitive tests to
remove infected cattle and by testing neighbouring herds for disease. This approach is
designed to achieve early OTF status for this geographical area.
Edge Area
The Edge Area is the buffer zone between the HRA and the LRA (Figure 1) which
contains local disease fronts advancing from the HRA towards the LRA. The incidence of
bTB in the Edge Area is much lower than that in the HRA, but higher than that in the LRA.
Additional evidence is needed to determine the respective role of cattle and wildlife in the
spread of the disease in the Edge Area. The Edge Area will be managed to contain and
reverse the spread of bTB from the HRA to the LRA, with the aim of obtaining OTF status
for this geographical area as soon as possible. This will incorporate strict cattle measures
similar to those applied to the LRA with the additional focus on surveillance to identify the
role of wildlife vectors. Management of these wildlife vectors will include vaccination and
possibly culling where the evidence supports its deployment.
High Risk Area (HRA)
This zone covers the South West, West Midlands and East Sussex (Figure 1) and it is
where a relatively high proportion of herds are infected by bTB. It is also where there is a
high proportion of repeat cases among herds, and there is a recognised reservoir of
infection in badgers. Even against this background, some herds and areas remain bTB-
free, and we want to do all we can to maintain this position. This will include applying the
methodology currently used in the LRA and Edge Area where it is cost-effective to do so.
The objective is to halt and then reverse the increasing prevalence of bTB and ultimately
to achieve OTF status for this geographical area. Because of the greater challenge in this
area, and recognising the need for proportionality of the impact of disease control on the
capacity of the industry to operate, we need to develop a more complex set of
interventions that address the specific local needs. This includes incentivising risk-based
approaches, such as risk-based trading and farm management measures, to reduce the
likelihood of both cattle-cattle and badger-cattle infection. Management of the latter will
include vaccination and culling.
Research
Research into the development of new interventions to control the disease is an essential
part of the Governments strategy. This includes continuation of our search for affordable
and effective vaccines for both cattle and badgers, more effective diagnostic tests and the
development of the capacity to provide near-real-time epidemiological intelligence to
inform how disease can be controlled in specific circumstances. It also includes new
research into more effective ways of controlling the routes of transmission of disease
between wildlife and cattle. An essential component of future research capacity will
continue to be the collection of information about the nature of bTB risk, including

17
effectiveness of different sets of interventions and the ways in which these provide benefits
for farm businesses. This will contribute to an approach involving adaptive learning; as we
implement new ideas we will learn from them and make them incrementally better.
Governance
Experience in other countries has shown that governance is key to addressing
successfully the control and elimination of bTB. For example, in New Zealand delegating
responsibility for the control of bTB to an independent organisation with strong
representation from the farming industry has been an important feature of their strategy.
The Government will work with stakeholders to develop an enhanced partnership
approach to the delivery of OTF status.
Within the context of such an approach the role of government will be to review delivery
and provide the necessary support to ensure that delivery is efficient and effective and that
operational decisions are taken at the most appropriate level. This recognises that tackling
bTB carries significant costs to farmers and other taxpayers and that these costs are not
sustainable, but also that additional investment will be required over the short term to bring
the disease under control and reduce the costs in the long term.
We will develop proposals for a sustainable funding model for this governance structure in
partnership with stakeholders. The experiences of both New Zealand and the Republic of
Ireland provide evidence of the success of innovative delivery and co-financed bTB
disease control.
Table 2 Summary of current measures and additional future measures or options
Risk area Type of measure Current measures Additional future
measures or options
2

All Risk Areas Surveillance -Slaughterhouse
surveillance
-TB surveillance in non-
bovines
-Enhance the sensitivity of
slaughterhouse
surveillance
-Enhance the sensitivity of
TB surveillance in non-
bovines
Breakdown
management
-Movement restrictions
-Isolation and rapid
removal of suspected
infected animals/contacts
-Increased testing in
-Phase out the practice of
lifting restrictions on
different parts of bTB
holdings at different times
-Introduce more sensitive
testing of cattle traced

2
Subject to change in the light of new evidence and experience

18
Risk area Type of measure Current measures Additional future
measures or options
2

infected and surrounding
herds
-Epidemiological
investigations/reports
from breakdown herds
-Introduce stricter
measures for bTB
breakdown herds on a risk
basis
-Extend the time between
short-interval herd tests to
reduce the risk of test de-
sensitisation and increase
detection of residual
infection
-Improve epidemiological
investigation/ reporting
-Introduce stricter
measures for TB
breakdowns non-bovine
-Enhance the
management of persistent
and recurrent breakdowns
Other disease
prevention
-Voluntary risk-based
trading
-Advice and guidance
-Sanctions
-Public health protection
measures
-Improve advice and
guidance
-Improve local information
on bTB
-Review pre-movement
testing exemptions
-Review compensation to
encourage risk-reduction
-Improve biosecurity on
and off farm
-Encourage voluntary local
eradication boards
-Work with industry to
support risk-based trading
-Consider interferon-
gamma assay for private
pre- and post- movement
testing
-Pilot bTB enforcement

19
Risk area Type of measure Current measures Additional future
measures or options
2

team
- Support the introduction
of bTB risk accreditation
standards
Low Risk Area Surveillance Four-yearly herd testing
(except higher risk herds
on annual testing)

-Improve risk-based
testing by reviewing
current approach to
identifying higher risk
herds and based on
recommendations from
research
Breakdown
management
- Interferon-gamma assay
of higher risk breakdown
herds
-Surveillance skin testing
of herds within 3km radius

Other disease
prevention
-Biosecure (non-grazing)
Approved Finishing Units
-Regional epidemiology
reporting
-Introduce compulsory
post-movement testing into
LRA
-Encourage improved
biosecurity in other
finishing units receiving
cattle into the LRA
Edge of High Risk Area Surveillance -Annual herd testing
Breakdown
management
- Interferon-gamma assay
of higher risk breakdown
herds
-Skin testing of contiguous
herds
-Surveillance skin testing
of herds within 3km radius
(some counties)

Reduce risk of TB
from badgers
-Biosecurity
-Injectable badger
vaccination
-Increase surveillance for
TB in badgers
-Deploy oral badger
vaccination (R&D)

20
Risk area Type of measure Current measures Additional future
measures or options
2

Other disease
prevention
-Compulsory pre-
movement testing
-Biosecure Approved
Finishing Units
-Regional epidemiology
reporting
-Deploy cattle vaccination
(R&D)
High Risk Area Surveillance -Annual herd testing
Breakdown
management
-Skin testing of contiguous
herds
-Additional use of
interferon-gamma assay in
some herds e.g. where the
risk of TB infection from
badgers is under control
-Improve field
epidemiological
investigation of
breakdowns (including use
of genetic sequencing)
Reduce risk of TB
from badgers
-Biosecurity
-Injectable badger
vaccination
-Badger culling pilots
-Badger culling
-Deploy oral badger
vaccination (R&D)
Other disease
prevention
-Compulsory pre-
movement testing
-Biosecure Approved
Finishing Units
-Deploy cattle vaccination
(R&D)
-Regional and cluster
based epidemiological
reporting
Notes:
1. Measures in all areas are deployed in addition to measures in specific risk areas.
2. R&D indicates areas in which the Government is funding multi-million pound research projects to
develop operational tools.

21
II. Background
Bovine tuberculosis
Bovine tuberculosis (bTB) is a chronic infectious disease of cattle caused by the bacterium
Mycobacterium bovis (M. bovis). While cattle are particularly susceptible to infection, M.
bovis can also infect a range of other mammalian species. bTB is primarily a respiratory
disease. Infection most often happens when moisture droplets containing M. bovis are
inhaled but there are other routes of infection e.g. eating or drinking contaminated
material.
The risk posed by M. bovis to human health in the UK is considered very low. The
European Food Safety Authority (EFSA) and the European Centre for Disease Prevention
and Control (ECDC)
3
have advised that the main transmission routes of M. bovis to
humans are through drinking raw milk or eating raw milk products from bTB-infected cows.
Historically, before the introduction of milk pasteurisation and tuberculin testing of cattle
herds, M. bovis infection in humans was much more common. M. bovis can also be
transmitted through direct contact with infected animals; if bTB is left unchecked, we could
potentially see more cases of M. bovis infection in humans associated with spillover of
infection into non-bovine species that have close contact with humans. EFSA
4
has also
advised that there is no evidence suggesting that M. bovis is a meat-borne hazard for
humans in the EU.
The vast majority of cases of TB in humans in the United Kingdom (UK) are caused by
human-to-human transmission of M. tuberculosis.
History of bovine tuberculosis in England
Efforts to eradicate bTB from Great Britain (GB) were initially driven by public health
concerns and the desire to increase the productivity and welfare of the national cattle herd.
The voluntary herd schemes up to the 1950s were replaced by compulsory schemes. The
whole of GB became 'attested' on 1st October 1960 i.e. each cattle herd was certified as
being subject to regular tuberculin skin testing with immediate slaughter of any reactors.

3
EFSA (European Food Safety Authority) and ECDC (European Centre for Disease Prevention and Control),
2014. The European Union Summary Report on Trends and Sources of Zoonoses, Zoonotic Agents and
Food-borne Outbreaks in 2012. EFSA J ournal 2014;12(2):3547, 312 pp. doi:10.2903/j.efsa.2014.3547
http://www.efsa.europa.eu/en/efsajournal/pub/3547.htm
4
EFSA BIOHAZ Panel (EFSA Panel on Biological Hazards), 2013. Scientific Opinion on the public health
hazards to be covered by inspection of meat (bovine animals). EFSA J ournal 2013;11(6):3266, 261 pp.
doi:10.2903/j.efsa.2013.3266 http://www.efsa.europa.eu/en/efsajournal/pub/3266.htm


22
For the next two decades there was a steady decline in the incidence of reactor cattle,
clinical cases and infected herds detected and every year new counties would be
designated bTB-free areas in which the herd testing frequency could be gradually relaxed
to reflect the improved situation. In 1979 the lowest bTB prevalence was recorded in GB,
with 0.49 percent of all herds tested having a reactor, which equated to 0.018 percent of all
cattle tested.
While the frequent testing of cattle herds and the removal of reactors to limit cattle-to-cattle
spread of M. bovis remained the cornerstone of bTB control, a high prevalence of bTB
persisted in parts of south west England despite enhanced herd control measures. In the
early 1970s the badger was first identified as a possible wildlife reservoir of infection for
cattle in this area. A series of different strategies were developed throughout the 1970s,
1980s and 1990s to tackle this wildlife source of bTB alongside further cattle-based
measures in the area. Gassing (1975-1982) and clean ring (1982-1986) strategies were
used prior to an interim badger culling strategy in place between 1986 and 1997,
whereby badgers were removed only from farms where a bTB incident had been
confirmed by M. bovis culture and where, following investigation, it was thought that
badgers were the most likely source. Annex A provides further information.
The progressive reduction in bTB incidence stalled in the mid-1980s and subsequently the
incidence progressively increased with new breakdowns extending eastwards and
northwards (Figure 2). Prior to this, bTB herd incidence in south west England had
remained about three times higher than in the rest of GB despite the retention of an annual
(and occasionally more frequent) tuberculin skin testing regime for herds in this area.
The Krebs report published in 1997 concluded that the sum of evidence strongly supports
the view that, in Britain, badgers are a significant source of infection in cattle. The main
recommendation was to set up a controlled field experiment (the Randomised Badger
Culling Trial (RBCT)) overseen by the Independent Scientific Group on cattle TB (ISG) to
quantify the impact of culling badgers on bTB incidence in cattle. Immediately after the
publication of the Krebs report, the Government suspended all badger removal operations
outside the RBCT pending its outcome. Statutory compensation for bTB reactor cattle was
increased from 75 percent to 100 percent of the individual market value of a normal animal
from 1998.






23
Figure 2 Number of skin and interferon-gamma test reactors and slaughterhouse cases
found between 1986 and 2010 in cattle holdings experiencing bovine TB breakdowns with
officially TB-free status withdrawn per km
2
per year

In 2001 the national bTB testing programme was severely disrupted due to a major
outbreak of Foot and Mouth Disease, which led to anomalous bTB statistics from 2001 to
early 2003. This led to a marked fall in the number of bTB breakdowns and reactors
detected in 2001, followed by a sharp increase in 2002 as tuberculin skin testing of herds
resumed (Figure 3). Another consequence of the outbreak was the geographical spread of
bTB to new areas of England through the restocking of depopulated herds.


24
Figure 3 The evolution of the bTB epidemic in Great Britain

The Final Report of the ISG published in 2007 included the findings of the RBCT (1998-
2005). Using data from the start of the RBCT, it has been estimated that badgers
contributed to some 50 percent of cattle herd bTB breakdowns in high incidence areas,
either directly (badger-to-cattle spread of M.bovis) or indirectly (badger-to-cattle, followed
by cattle-to-cattle spread of M.bovis). This is why any successful bTB control and
eradication strategy must use all available tools to address effectively all the different
routes of spread of M. bovis (Figure 4).
Figure 4 Different routes of spread of M. bovis between cattle and badgers


25
From 2006 a range of additional cattle surveillance testing and movement controls were
introduced in England, including compulsory pre-movement tuberculin testing of cattle
moving out of herds in high risk areas and the use of the interferon-gamma test to
supplement the skin test in certain circumstances e.g. in culture and/or lesion positive
breakdowns in non-endemic areas. In 2006 a new statutory compensation system for bTB
reactor cattle was introduced, using monthly tables of values that reflect the average sales
price of different categories of cattle.
By 2008 England reached a historical peak of 6.4 percent of herds experiencing new
culture and/or lesion positive (formerly known as Officially bTB Free status withdrawn or
OTFW) bTB breakdowns. There was no clear trend in the number of cattle movements in
GB between 2002 and 2009
5
. Between 2009 and 2012, the herd incidence remained
below 6.4 percent but the geographical spread of the endemic area continued.
In 2010 an injectable TB vaccine for badgers was authorised and this has been deployed
in local projects funded by government and by non-government organisations. Multi-million
pound government-funded research to develop a deployable cattle bTB vaccine and an
oral TB vaccine for badgers is ongoing.
In 2011 the Government published a comprehensive Bovine Tuberculosis Eradication
Programme for England
6
.
In 2012 most bTB breakdowns in England were in the South West and West Midlands
(Figure 5). By contrast the north and east of England had a very low and sporadic
incidence of breakdowns. Less than 1.5 percent of bTB breakdowns in previously
unaffected herds occurred in the areas of the country at low risk of the infection (Low Risk
Area). Of these, at least half could be traced directly to the movement of infected cattle
from the area at high risk of the infection (High Risk Area) into herds in the Low Risk Area.
The other half represented cases where the likelihood of spread with cattle movements
was high but this could not be established as the index animal had moved on or been
slaughtered without being detected as bTB-infected. These isolated cases in the low risk
area created individual breakdowns with occasional but limited subsequent secondary
spread.

5
Vernon, M.C. (2011) Demographics of cattle movements in the UK. BMC Veterinary Research 2011, 7:31
6
Defra (2011) Bovine Tuberculosis Eradication Programme for England, J uly 2011 (PB 13601)

26
Figure 5 Map showing the uneven geographic distribution of bTB in England. New bTB
herd breakdowns, or clusters of breakdowns, with Officially bTB Free status withdrawn that
were identified in England during 2012 are shown as yellow dots. Counties shown in red
correspond to the current annual testing area of England that has been in force from 1
January 2013. (Source: AHVLA)


27
Additional packages of cattle measures came into effect between 2012 and 2014 (Annex
B). These included changes to cattle bTB compensation, the removal of some pre-
movement bTB testing exemptions, the removal of higher risk links between holdings on
the Cattle Tracing System (CTS) and a ban on new or enlarged Sole Occupancy
Authorities (SOAs) from 2012. This was followed in 2013 by a tightening of cattle
movement controls and a move from parish to county-based bTB testing intervals, further
expanding the area in which cattle herds are tested annually.
In October 2013 the Government began deploying a package of measures as part of a
new strategy for the Edge Area a defined area on the eastern and northern border of the
High Risk Area (see later). This package included advice to farmers, improved information
management, stricter bTB breakdown management and prevention measures, and
extension of access to government financial support for vaccination projects in the Edge
Area. Additionally research projects were set up to estimate likely locations of badger
populations in the Edge Area and to assess how useful post mortem examinations of
badgers killed in road traffic accidents would be in estimating TB levels in local badgers.
In November 2013 the Government launched a voluntary risk-based trading scheme to
encourage farmers to share details of the bTB disease history of cattle they sell and
buyers to act on this information. Since J anuary 2014 farmers with overdue bTB
surveillance or check tests have faced a reduction of their Common Agricultural Policy
Scheme payments. In February 2014 AHVLA announced an enhanced approach to
managing long-term bTB breakdown herds in partnership with the farmers private
veterinary surgeons. In March 2014 Defra announced new powers to cull cattle unable to
be tested for bTB and the removal of further pre-movement bTB testing exemptions.
In 2012 Natural England issued badger control licences in the HRA in Somerset and
Gloucestershire. Each licence has a four-year term authorising control operations to be
conducted each year with no control operations permitted during specified close seasons.
Two pilot culls were completed in 2013 and an Independent Expert Panel assessed the
humaneness, effectiveness (in terms of badger removal) and safety of controlled shooting
of free-ranging badgers to inform decisions on a wider roll out of the policy.
Analysis of the bTB epidemic to 2012 showed that since the beginning of 2003, the relative
rate of increase of new culture and/or lesion positive (formerly known as OTF status withdrawn
or OTFW) bTB breakdowns in England fell by more than half compared with 1986-2000
(Figure 6). This was despite a year-on-year increase in the annual number of herd and animal
tests carried out. However, the rolling average proportion of live cattle herds under restriction
as a result of culture and/or lesion confirmed positive bTB breakdowns rose from just under
one percent in 2000 to just over five percent in 2012. Further information is available in
AHVLAs bTB surveillance reports
7
.


7
Bovine TB surveillance reports are available at http://www.defra.gov.uk/ahvla-en/publication/pub-
survreport-tb/

28
Figure 6 Quarterly numbers of total and OTFW new bovine TB breakdowns detected in
England between January 1986 and December 2012

Evidence
The Government will develop approaches to deliver the Strategy based on the best
available evidence, scientific advice and veterinary advice. The term evidence
encompasses material from multi-disciplinary science research, statistics, economics,
social or operational research and geographical information.
Annex C includes links to components of the bTB evidence base, which is constantly
evolving. This includes independent Natural Science and Socio-Economic Evidence
Statements, and bTB surveillance reports and statistical reports compiled by Government.
In some areas, the Government recognises that further research is required to strengthen
the evidence base. Further information on Defras Evidence and Investment Strategy and
the Bovine Tuberculosis Evidence Plan to strengthen the evidence base is provided in the
section on Developing New Tools.
As well as developing new tools for controlling bTB, the Government will also address the
continuing need to improve the understanding of the epidemiology of bTB. This includes
strengthening field epidemiology to improve incorporation of local information into the
national picture of the epidemic. It also includes the development and use of mathematical

29
models to inform the development, application, assessment, monitoring and evaluation of
bTB control tools and policy options.
Strategy aim
The aim of the Strategy is to eradicate bTB, achieving Officially bTB Free (OTF)
Status
8
for England incrementall y, whilst maintaining an economically sustainable
livestock industry
9
.
The Strategy sets out how the aim will be achieved through greater partnership working,
increasingly non-government-led implementation and a fair sharing of the associated
costs. It draws upon the demonstratively successful approaches taken elsewhere in the
world, for example in:
Australia, where the national eradication programme spanning almost three decades
achieved official freedom from bTB in 1997 through a comprehensive package of
measures to tackle the disease in domestic cattle and wildlife. This included rigorous
culling of feral water buffalo, which were introduced into Australia in the nineteenth
century;
Scotland, which successfully applied a package of conventional cattle measures in the
absence of a significant reservoir of TB in wildlife, to achieve OTF status in 2009;
Michigan in the United States of America, where the bTB eradication project includes
cattle and wildlife controls. Since the mid-1990s, Michigan State has made significant
progress in lowering the apparent prevalence of M. bovis in free ranging white-tailed
deer in the endemic area by over 60 percent through reduction of deer densities by
hunting and restrictions on public feeding and baiting of deer. This strategy has been
implemented with the cooperation of local hunters. Livestock herd breakdowns
averaged 3-4 per year from 2005 to 2011;
New Zealand, where a farmer-led management agency has delivered an effective
national bTB eradication plan comprising cattle and wildlife controls co-financed by
government and industry. The primary wildlife reservoir of M. bovis is in brush-tailed
possums, introduced into New Zealand in the nineteenth century. Wildlife control

8
For a Member State or region to achieve OTF status as defined in Council Directive 64/432/EEC, at least
99.9 percent of the herds within it must have been or remained OTF for at least six consecutive years. OTF
status allows for residual levels of the infection to remain, whereby less than 0.1 percent of herds experience
the infection annually in a region defined as OTF, whilst eradication would represent elimination of the
infection
9
The Strategys aim complements Defras strategic objectives of supporting and developing British farming
and encouraging sustainable food production, enhancing the environment and biodiversity, and managing
the risk of animal disease. These support Governments overarching objective of achieving economic
growth.

30
measures include aerially- or ground-deployed poison bait and trapping. The number of
M. bovis infected cattle and deer herds has reduced from over 1700 in the mid-1990s
to less than 100 (0.13 percent of herds) in 2012/13;
The Republic of Ireland, where there has been a comprehensive bTB eradication
programme including cattle controls and since 2000
10
an increasingly coordinated
reactive cull of badgers in response to epidemiologically linked bTB breakdowns in
cattle. The current badger culling strategy involving up to 30 percent of agricultural land
has been in place since 2004
11
. The Irish programme has seen the proportion of bTB
herd breakdowns fall from 9.6 percent (i.e. percentage of annual active herds with at
least one TB reactor or slaughterhouse case) in 1995 to 7.4 percent in 2010, compared
to increases from 0.8 percent to 9.0 percent in England and from 5.5 percent to 7.9
percent in Northern Ireland over the same period.
12
Cattle bTB testing and
compensation in the Republic of Ireland are co-funded by government and industry;
France, which achieved OTF status in 2000 and is working to eradicate bTB through a
comprehensive eradication programme which includes cattle controls and culling of
infected wildlife species (badgers, wild boar and deer). One of the most heavily infected
dpartements used local trappers to catch and kill some 10,000 badgers over a large
area between 2010 and 2013. Cattle bTB testing is co-funded by government and
industry.
Achieving the aim will be dependent upon:
Effective application of disease control measures in cattle;
Best practice in livestock farming achieved through advice and appropriate, evidence-
based use of rewards and penalties;
Addressing the reservoir of M. bovis in wildlife whilst maintaining biodiversity to enable
a healthy cattle population to live alongside a healthy wildlife population; and
Ensuring a fair balance of costs falling to the general taxpayer, the food and farming
industry and other stakeholders.
The Strategy focuses on keeping the Low Risk Area free of bTB, halting and then
reversing the spread of bTB in the Edge Area, and radically reducing the prevalence of
bTB in the High Risk Area, progressively achieving OTF status for England.

10
Good, M. et al (2011) Impact of the full herd depopulation policy on the recurrence of bovine tuberculosis
in Irish herds, 2003 to 2005. Veterinary Record (2011) doi: 10.1136/vr.d4571
11
Sheridan, M. (2011) Progress in tuberculosis eradication in Ireland. Veterinary Microbiology 151 (2011)
160-169
12
Standardised annual herd prevalence as defined in Abernethy, D.A. et al (2013) Bovine tuberculosis
trends in the UK and the Republic of Ireland, 1995-2010. Veterinary Record (2013) doi: 10.1136/vr.100969

31
Rationale for intervention
The Government wants to see a thriving and sustainable livestock sector in England, one
that, along with the rest of the agricultural sector, helps to support the resilience of the
entire food chain.
In 2012, 481 thousand people worked on UK farms. The value of UK production was 3.8
billion for dairy products and 2.8 billion for beef. The value of UK exports was 1.2 billion
for dairy products and 389 million for beef
13
.
In 2013, the total number of cattle and calves in England was just under 5.4 million. The
female breeding herd, which steadily decreased from just over 2.0 million in 2005 to 1.8
million in 2013, accounted for just over a third of this total; the dairy herd accounted for 61
percent of the breeding herd and remained at 1.1 million animals between 2010 and 2013;
the beef herd decreased from 742 thousand in 2012 to 720 thousand in 2013
14
.
bTB is one of the most pressing challenges facing the industry today; it has social and
economic impacts. In 2012 the estimated average cost of a bTB breakdown in the High
Risk Area was 14,000 to farmers and 20,000 to taxpayers; in 2011/12 the average cost
of a routine bTB test was 350 to farmers and 770 to taxpayers. Based on current
expenditure, the forecast cost to taxpayers alone without additional intervention will
exceed 1 billion over the next decade; this level of expenditure is unsustainable. If bTB is
left unchecked we risk impacting the productivity and capability of the industry threatening
our ability to trade and grow our exports into new and emerging markets. We also risk
undermining confidence in our food and more cases of human infection.
bTB can spread from animal to animal and from farm to farm. Whilst there are a number of
measures that individuals can and should take to help reduce the risk of bTB, achievement
of OTF status and then eradication of bTB in England requires collective action. Individuals
are unlikely to consider the potential costs and benefits to others when deciding how and
when to invest to limit the spread of the disease. For this reason their decisions are
unlikely to be optimal from the perspective of the industry or society. Certain activities can
actually worsen the spread of infection, so a coordinated and strategic approach is
essential if we are to prevent the spread, bear down on, and ultimately eradicate the
infection.
The Governments responsibility is to set out how the disease can be tackled holistically. In
doing so it needs to ensure that the UK meets its legal obligations and reduce the financial
strain on public finances and industry through increased partnership working, industry-led

13
Source: Agriculture in the United Kingdom 2012, UK Rural Affairs Departments
https://www.gov.uk/government/publications/agriculture-in-the-united-kingdom-2012
14
Source: Farming Statistics, Final Crop Areas and Cattle, Sheep and Pig Populations at 1 J une 2013 -
England, Defra https://www.gov.uk/government/publications/farming-statistics-final-crop-areas-yields-
livestock-populations-and-agricultural-workforce-at-1-june-2013-uk

32
delivery and a fair sharing of the costs involved. In so doing it will help put the sector and
public financing of disease control on a more sustainable footing.
The UK programme for accelerating the eradication of bTB
15
is designed on the basis of
Council Directives 64/432/EEC, 77/391/EEC and 78/52/EEC with a view to enabling the
UK to benefit from an EU financial contribution for the programme and mitigating the risk of
infraction proceedings, financial penalties and trade sanctions.
Achieving OTF status for England will provide tangible benefits for the cattle industry, rural
communities and Government. These include significant savings in combating the disease
both to Government and to industry, increasing the ability to trade within the EU and
internationally
16
and alleviating the social impacts.
While Scotland achieved OTF status in 2009, the prevalence of bTB infection in England
contributes to an unacceptably high prevalence of bTB in the UK herd as a whole (Figure
7). Many other EU Member States are already OTF. A map showing the OTF status of EU
Member States can be found at Annex D.

15
Working document on eradication of bovine tuberculosis in the EU accepted by the Bovine tuberculosis
subgroup of the Task Force on monitoring animal disease eradication (SANCO/10067/2013)
http://ec.europa.eu/food/animal/diseases/eradication/tb_workingdoc2006_en.pdf
16
The World Organisation for Animal Healths (OIE) Terrestrial Animal Health Code lays down animal health
standards for international trade. These include requirements for qualifying for official freedom from bTB.
http://www.oie.int/

33
Figure 7: National herd prevalence
17
for bovine TB in EU member states
18


The Government does not envisage disadvantages arising from the achievement of OTF
status for England in a staged manner. Nevertheless, it proposes working with the
Agricultural and Horticultural Development Board to assess any regional market impacts
which might arise as a consequence of pursuing a staged approach (i.e. by counties or
groups of counties) to achieving OTF regional status for England.
Strategy approach
The Strategy reflects the Governments commitment to tackle bTB in a comprehensive and
balanced way, with achievement of OTF status for England. The approach will be:
Comprehensive and adaptive: tackling M. bovis infection in cattle, other farmed
animals and wildlife, addressing all transmission routes to tackle bTB in cattle, making
best use of all available evidence and tools whilst funding research to address evidence
gaps and develop new tools;

17
Prevalence proportions have been calculated as the percentage of cattle herds infected with or positive for
M. bovis during 2010. The red symbol size is proportional to the prevalence of M. bovis in cattle herds
18
Source: Ru,G. et al (2013) Bovine TB Control: valuable insights from countries on steps toward
eradication. Veterinary Record 2013 172: 310-311 doi: 10.1136/vr.f1347 citing EFSA & ECDC (2012) The
European Union Summary Report on Trends and Sources of Zoonoses, Zoonotic Agents and Food-borne
Outbreaks in 2010. EFSA J ournal 10, 2597

34
Risk-based: with controls targeted according to risk of infection and based on scientific
and veterinary advice; and
Staged: to provide the means to stop the spread of infection, bring it under control, and
bear down on it to achieve and maintain OTF.
To achieve a balanced approach, the Strategy embraces:
Partnership working: Many individuals and groups have a direct involvement in
controlling the disease and will benefit from England achieving OTF status. The
Government, the farming and food industries, the veterinary profession, local
authorities, wildlife interest groups and other stakeholders will need to collaborate
effectively to deliver the Strategys aim. Government will maintain open dialogue on bTB
policy development guided by the Strategy. It will work closely with devolved
administrations, particularly in the context of the evolution of the UKs bTB eradication
programme.
Fair balance of costs and supported responsibility: Government will work with those
at the forefront of the disease to support farm businesses in taking more responsibility
for disease control, for example by appropriate use of rewards and penalties to
encourage best practice. Government will explore innovative governance arrangements
and delivery models.
Working effectivel y i n the EU: Government, as the competent authority, will ensure
that England complies with EU bTB legislation, while pushing for a more flexible, risk-
based EU legal framework under a new Animal Health Regulation
19
. Government will
work closely with the European Commission in the context of the evolution of the UKs
bTB eradication programme and in presenting evidence for OTF status for regions of
England. Government will also work through the EU to ensure that the World
Organisation for Animal Health (OIE) animal health standards for international trade are
aligned as far as possible with rules for intra-EU trade.
Targets and timeline
Targets
The initial Strategy targets are set out in Table 3, below. The targets will be used to
monitor and evaluate the Strategy (see Monitoring and Evaluation of the Strategy) and
further targets may be developed.

19
On 6 May 2013, the European Commission adopted a package of measures to strengthen the
enforcement of health and safety standards for the whole agri-food chain. The main elements include Animal
Health and Official Controls. The package is subject to consideration by the European Parliament and the
Council with possible entry into force in 2016, followed by a proposed three-year transition period.
http://europa.eu/rapid/press-release_IP-13-400_en.htm

35
Table 3 Initial targets
Basic measures of
performance
Targets Delivery scale Indicators of success
Annual proportion of
Officially bTB-Free (OTF)
herds

Progressive attainment of
OTF status for individual
counties (or groups of
counties) within the current
low risk area
20

Between 2018 and 2025 1. The achievement of OTF
status for individual
counties in England
2. The reduction in the
geographical coverage
of the High Risk and
Edge Areas in England
3. In longer term, the
achievement of OTF
status for England

Achievement of OTF status
for all counties in the current
low risk area
By 2025
Maintain herd prevalence
below 2% overall in the edge
area
21

By 2019
Reduce herd prevalence
below 1% overall in the edge
area
By 2025
Achieve OTF status for the
lowest prevalence counties in
the edge area
By 2025
The Government will set
targets for individual counties
within the high risk area

Achieve OTF status for
England
By 2038
Timeline
Figure 8 illustrates the tentative timeline for potential deployment of measures to achieve
the targets in the preceding section.

20
Cumbria, Durham, Lancashire, Northumberland, Yorkshire, Humberside, Lincolnshire, Cambridgeshire,
Norfolk, Suffolk, Essex, Hertfordshire, Bedfordshire, Greater London, Surrey, Kent, West Sussex and Isle of
Wight
21
As defined in 2013

36
Figure 8 Tentative timeline of activity


2015 2020 2025 2030 2035 2038
Ongoing monitoring and evaluation will be carried out (see Monitoring and Evaluation of
the Strategy).
2013: Deploy pilot badger cull
From 2013: Deploy Edge Area strategy
From 2013: Deploy Risk-Based Trading Scheme
From 2013: Ongoing research and development


From 2014: Further development of area risk-based strategies and cross-cutting measures

Earliest 2019: (Subject to research breakthrough and authorisation)
Possible deployment of authorised oral badger TB vaccination
Earliest 2015: (Subject to research breakthrough) Start regulatory work to authorise oral
badger TB vaccination
Earliest 2017: (Subject to successful field trials) Start EU negotiations and
regulatory work to permit use of cattle TB vaccination with validated DIVA test
Earliest 2023: (Subject to successful field trials, legal
change and authorisation) Possible deployment of
authorised cattle TB vaccination with intra-EU trade
2038: Achieve
OTF status for
whole of England
2025: Achieve OTF
status for current
low risk area
Earliest 2018: Start EU negotiations to secure OTF status for parts of England
Earliest 2015: (Subject to research, Animal Test Certificate, trial design and cost: benefit
assessment) Cattle TB vaccination/DIVA test field trials
Earliest 2019: (Subject to successful field trials, legal change and
authorisation) Possible deployment of authorised cattle TB vaccination
without intra-EU trade

37
Key elements
Developing our risk-based approach
Introduction
This section sets out the Strategys risk-based approach. Since J anuary 2013,
geographical areas of England have been assigned one of three bTB risk-based
classifications: Low Risk, High Risk or Edge. The Low Risk Area (LRA) is demarcated by
the four yearly cattle herd testing counties in the North and East of England. The annual
cattle herd testing zone includes the High Risk Area (HRA) and the Edge Area. The inner
boundary of the Edge Area has been determined based on research and surveillance
data, and local knowledge. Figure 9 shows the trend in bTB and the relative risk in each of
the three risk areas. Figure 1 illustrates the coverage of each risk area in England in 2013
with crude herd prevalence (bTB incidents as a proportion of live herds) in each area. The
herd prevalence varies across each area, particularly in the HRA and the Edge Area and
specific county prevalence figures are shown in Figure 10. Table 4 provides details of the
land coverage and the number of herds in each risk area in 2012.
Figure 9 - Variation in the number of culture and/or lesion positive new bovine TB
breakdowns per 100 herd years at risk between 2003 and 2012, in the High Risk Area, Edge
Area, Low Risk Area and whole of England (based on identical geographical areas
throughout)

38
Figure 10 Proportion of live herds with Officially bTB Free status withdrawn by county
between January and December 2012: number of OTFW new bTB breakdowns per 100 live
herds



39
Table 4 Land coverage and number of herds (and percentage of total) in each risk area in
2012
High Risk Area Edge Area Low Risk Area
Land area (km
2
) 38,570 (29%) 21,574 (16%) 72,621 (55%)
Number of cattle herds
in 2012
~24,800 (46%) ~7,800 (15%) ~21,000 (39%)
The aim of the Strategy is incrementally to extend the LRA to the whole of England and
eventually to achieve OTF status. The boundaries of all three zones will be subject to
regular review and will change over time as we move towards achieving this aim.
The Strategy includes sub-strategies for each risk area. Cross-cutting tools such as
biosecurity, advice, compliance and enforcement underpin the approaches. The
Government also needs to ensure that proportionate measures are in place to address the
risk posed by TB in non-bovine species. The underlying approach is common for all risk
areas, i.e. prevent bTB breakdowns, detect bTB breakdowns early, and deal with bTB
breakdowns rigorously. Whilst some control measures apply across all risk areas, others
are tailored as part of individual packages to suit the disease profile of each area. For
example, in the HRA particular emphasis is placed on addressing the reservoir of M. bovis
in badgers alongside conventional cattle-based measures. Table 5 summarises the
objectives for each of the area risk-based strategies.

40
Table 5 - Summary of objectives of area risk-based strategies
For ALL areas of England

Ai m to eradicate bTB, achieving Officially bTB Free (OTF) status for England incrementally, whilst
maintaining an economically sustainable livestock industry

For the LOW RISK AREA

For the EDGE AREA

For the HIGH RISK AREA

General characteristi cs
Low level of bTB
Breakdowns linked to
cattle movements
relatively short duration;
low recurrence
No significant reservoir
of TB in wildlife
North and East of England
General characteristi cs
Levels of bTB variable;
higher than Low Risk
Area but lower than
High Risk Area
Infection spreading
north and east
Role of cattle and
badgers uncertain
Buffer zone east and north of
High Risk Area
General characteristi cs
High level of bTB
Breakdowns relatively
long duration; high
recurrence
Significant reservoir of
TB in wildlife (badgers)

South West and West of
England and East Sussex
Objectives
To expand current area
Short to Medium Term
Maintain or further
reduce very low level of
bTB
Achieve OTF status for
area
Objectives
To move current area west and
south
Short to Medium Term
Stop geographical
spread of bTB
Begin to reduce level of
bTB
Longer Term
Reduce level of bTB
and secure OTF status
for area
Objectives
To contract current area
Short Term
Stabilise level of bTB
Medium Term
Begin to reduce level of
bTB
Longer Term
Reduce level of bTB
and secure OTF status
for area
The level of bTB risk and incidence within each risk area is not uniform and stable. For
example, forty percent of herds in the HRA in the ten years to 2012 did not have a bTB
breakdown in this period; in the LRA, some individual herds may pose greater risks of
infection than others because of their size, bTB history, cattle husbandry and trading
practices. To reflect this, the Government wants to move towards a better definition of bTB
risk on an individual herd basis rather than defining risk simply by geography. AHVLA has
completed work that can generate a bTB risk rating for every herd in the country, which
could be used to support risk-based trading decisions and potentially to enable the
application of the principle of earned recognition whereby best practice is rewarded with
fewer burdens. Alternatively, there is scope for industry to develop an accreditation
scheme to support risk-based trading decisions.

41
The remainder of this section explains:
Existing bTB control measures applied in England
Developing bTB control measures applicable in all risk areas
Developing the LRA strategy
Developing the Edge Area strategy
Developing the HRA strategy
Existing bTB control measures applied in England
The existing bTB control measures in England are directed primarily to controlling M. bovis
infection in cattle
22
. Some measures address the disease in other animals, such as
badgers, deer and South American camelids (SAC) in order to reduce the risk of TB
transmission to cattle. The measures include a mixture of:
measures that fulfil the minimum legislative requirements established by the EU in
order a) to entitle herds and regions of a country to be OTF and to be able to trade with
other Member States and b) to entitle the UK to EU co-financing of certain bTB control
measures (testing, laboratory analysis, compensation);
measures that are statutory (in domestic legislation) and apply to all keepers,
irrespective of a particular situation;
measures that are statutory (in domestic legislation) but are only applied on a
discretionary basis, depending on a particular situation; and
voluntary measures such as private deployment of badger vaccines.
They can be categorised under the following headings: surveillance; breakdown
management, dealing with the risk of TB from badgers; and other disease prevention
(Figure 11). The measures, both statutory and non-statutory, are applied in a tailored
manner across the different disease risk zones reflecting the value of each measure in a
particular disease situation.

22
Cattle includes farmed buffalo and bison

42
Figure 11 Summary of existing bTB control measures applied in England

The existing measures which may be applied in England are:
(1) Surveillance for bTB infection
In cattle, surveillance for bTB is based on using the comparative tuberculin skin test
(the single intradermal comparative cervical test (SICCT)) and slaughterhouse
Measures applied across England
-Combination of statutory and voluntary
- Applied according to bTB risk in different areas
Surveillance
Find infection early
Key measures
include:
For cattle:
- Statutory testing
-Slaughterhouse
surveillance
For other domestic
animals:
- Scanning
surveillance
- Slaughterhouse
inspection
- Targeted testing of
at risk animals
For wildlife:
- Scanning
surveillance and
occasional targeted
surveillance in low
risk areas


Breakdown
Management
Reduce risk of
spread of infection;
Eliminate infection
quickly
Key measures
include:
- Movement
restrictions
- Isolation and rapid
removal of suspected
infected animals
- Occasional partial
or complete herd
depopulation
- Increased testing in
infected herds and
surrounding herds
- Tracing source and
spread of infection
- Epidemiological
investigations
- Notification of
public and
environmental health
authorities

Dealing with risk of
TB from Badgers
Reduce risk of
badger-to-cattle and
cattle-to-badger
infection
Key measures
include:
- Scope for privately
funded licensed
culling projects in
areas with high and
persistent levels of
bTB in cattle
- Scope for privately
funded local projects
involving licensed
use of injectable
badger vaccine
- Voluntary on farm
biosecurity measures
to limit cattle and
badger contact
Other Disease
Prevention
Reduce risk of
infection spread

Key measures
include:
- Advice and
guidance on best
practice including
statutory obligations
- Sanctions
- Statutory pre-
movement testing
- Biosecure
Approved Finishing
Units
-Voluntary risk-based
trading
- Public health
protected through
milk pasteurisation,
TB reactor milk ban,
and slaughterhouse
inspection

43
surveillance. In areas that have endemic bTB or are otherwise considered to be at high
risk of bTB spread, there is annual whole herd tuberculin skin testing of cattle. In the
low risk area (LRA) of the country, four-yearly testing of breeding stock (routine herd
testing) is carried out by default. This herd-based surveillance is statutory, EU law sets
out minimum frequency levels for surveillance testing, depending on disease
prevalence (lower prevalence =less frequent testing). It is not possible to reduce the
surveillance testing frequency below the four-yearly pattern until a country or a region
has gained OTF status. In the LRA, individual herds may be subject to annual whole
herd testing (a discretionary statutory measure) for public (e.g. producer-retailers of
raw milk, or open farms) or animal health (e.g. herds regularly purchasing cattle from
higher risk areas) reasons. Zero-tolerance is applied to the timing of statutory
tuberculin skin testing in cattle: overdue tests trigger movement restrictions and, since
2014, a reduction in Common Agricultural Policy Scheme payments for overdue bTB
surveillance or check tests.
All commercially slaughtered cattle are surveyed throughout the country for signs of
bTB at slaughter (a statutory measure) and this is of critical importance in detecting
herd infection, especially in the LRA, where more than 50 percent of all bTB incidents
are disclosed at slaughterhouse.
Statutory scanning surveillance via compulsory notification and investigation of suspect
clinical cases applies to cattle but such cases are very rare now as active surveillance
tends to remove infected animals before clinical signs appear;
Surveillance in other livestock and in captive deer is carried out by statutory
slaughterhouse and non-statutory scanning surveillance and with occasional targeted
surveillance of at risk herds/flocks (e.g. contiguous or co-located animals);
Surveillance in South American camelids (SAC) and pets is carried out by non-
statutory scanning surveillance. Reporting of confirmation of bTB in private laboratories
is a statutory requirement; and
Surveillance of wildlife is not statutory and is only carried out as part of research or
specific projects/initiatives (e.g. localised deer surveys in 2006, Road Traffic Accident
surveys of badgers in the past; current research by AHVLA/Fera in Gloucestershire;
investigations of unknown breakdown origins in the LRA). However, if there is a strong
suspicion of wildlife spread in an area of low cattle incidence, enhanced wildlife
surveillance is initiated.
(2) Breakdown management
Bovine TB breakdowns in cattle herds are managed with the aim of preventing further
spread of disease and clearing the infection from the herd as quickly as possible. The
following controls are applied uniformly across the country: (i) preventing movements
from the herd (statutory; EU) other than movements to slaughter or to other herds in
some specific circumstances subject to AHVLA licence; (ii) restrictions on movements
into the herd subject to AHVLA veterinary risk assessment and licence (statutory; EU)

44
(iii) short interval testing with the SICCT (at not less than 60-day intervals) until one or
two clear tests dependent on the risk status of the herd (statutory; EU) and (iv) tracing
and testing both the potential source and spread of the infection (statutory; under
domestic legislation). Statutory use of interferon-gamma assay as an additional
breakdown test has been applied to all breakdowns where OTF status has been
withdrawn in the LRA and to some breakdowns in the Edge Area. Since 2014, use of
gamma-interferon testing has been extended throughout the Edge Area where it is
compulsory for TB culture and/or lesion positive breakdowns and discretionary for
lower risk breakdowns based on AHVLA veterinary risk assessment;
Cattle suspected of being infected with bTB, on the basis of the results of the tuberculin
test or the gamma-interferon test must be removed from the herd and slaughtered
within 30 days (EU). Farmers have the option of arranging the removal and sale of the
animal to the slaughterhouse themselves. However, most farmers opt for AHVLA to
arrange the removal and sale of the animal to the slaughterhouse with statutory
compensation payable to the farmer. Statutory compensation is determined primarily
using monthly table values, which reflect 100 percent of the average sale prices of
bovine animals in 51 different categories. The categories are based on the animal's
age, gender, type (dairy or beef) and status (pedigree or non-pedigree). The default
position is to use table valuation although individual valuations may be used in defined
circumstances (e.g. buffalo or bison). Statutory compensation is reduced on a sliding
scale if bTB reactors are detected in overdue tests. The Government retains the
revenue generated from selling the animal to the slaughterhouse (the salvage value)
which takes account of transport, handling and disposal costs.
Following the removal of animals suspected of being infected with bTB, the farmer is
responsible for any statutory cleansing and disinfection of the premises that is required
by AHVLA.
Statutory depopulation of a cattle herd can be applied in cases where repeated testing
does not, or is suspected not, to clear a herd of infection, although it is rarely applied in
practice on a whole herd basis; partial depopulation is more commonly used.
Contiguous risk in breakdown situations is addressed: in the HRA and parts of the
Edge Area, by testing of contiguous herds on a discretionary basis; in the LRA and the
remainder of the Edge Area, by surveillance testing of all herds within a 3 km radius of
the index farm. All testing relating to local risk from a breakdown is enforced under
domestic legislation;
Laboratory confirmation of M. bovis infection in all other livestock species, such as
captive deer, pigs, goats, sheep and SAC normally triggers statutory movement
restrictions and repeat TB testing (or, in the case of animals reared for their meat,
depopulation) of the remaining animals on the infected premises in order to lift the
restrictions. AHVLA also instigates spread and source tracings, as well as testing of
any cattle herds that may be co-located with (or contiguous to) the infected premises.
In the LRA, any incidents of TB in non-bovine species caused by M. bovis infection

45
result in enhanced bTB surveillance (targeted testing) of cattle herds situated within a 3
km radius of the index premises; and
In pets and wildlife, confirmed cases of M. bovis are reported to AHVLA (statutory) and
private deer stalkers are trained and encouraged to submit suspect samples from deer.
The confirmed cases are epidemiologically assessed in terms of potential links to local
disease situation in livestock, deer or camelids and the need for additional surveillance.
(3) Dealing with the risk of TB from badgers
Badgers are not an endangered species in the UK (see Annex A) but they are
protected by UK legislation. The Protection of Badgers Act 1992 and the Wildlife and
Countryside Act 1981 protect badgers and their setts, but make provision for licences
to be granted to kill or trap badgers or to interfere with their setts for the purpose of
preventing the spread of disease, provided the methods of capture and dispatch are
humane. Unlicensed taking, possession, selling, or killing of badgers, or interference
with their setts, is illegal. Badgers are also a protected species under the Convention of
European Wildlife and Natural Habitats (1979) (known as the Bern Convention). The
Convention requires contracting parties, including the UK, to take appropriate
legislative and administrative measures to ensure the protection of badgers. Article 9 of
the Convention allows parties to make exceptions to this for various purposes, but only
provided that the exception will not be detrimental to the survival of the population
concerned.
Licensed methods of culling badgers may be cage trapping and shooting and
controlled shooting of free ranging badgers. Determining the size of badger populations
is challenging and the efficiency of cage trapping and of controlled shooting is variable.
Culling can be deployed subject to land access and a licence from Natural England.
Evidence shows that carefully managed badger culling to achieve a substantial
reduction of the badger population over a sufficiently large geographic area leads to an
overall net reduction in cattle herd bTB breakdowns over a defined period relative to a
similar un-culled area. Small-scale or short term culling may exacerbate the disease
situation through perturbation (see Glossary). The Government considers that licensed
badger culling, delivered effectively, is an important bTB control measure in areas with
high and persistent levels of bTB in cattle epidemiologically linked to endemic TB
infection in badgers. On the basis of historical evidence an estimated one third of the
badger population in endemic areas is infected with M. bovis.
The Government believes that any licensed badger culling projects should be
coordinated, delivered and funded privately. Culling projects should be deployed
strategically to help deliver the aim of staged achievement of OTF status for England.
Two licensed four-year badger culls started in Somerset and Gloucestershire in 2013.
The Government will consult Natural England on revised criteria for licensing culling.
Subject to available resources, the Government will also consider transitional financial
support for private sector-led deployment of the policy.

46
An injectable TB vaccine for badgers (BadgerBCG) has been available on veterinary
prescription since 2010. Injectable vaccine can be deployed subject to land access, a
licence from Natural England, and the vaccine being administered by a veterinary
surgeon or by a trained and competent lay person
23
. Trapping and injecting badgers is
not believed to cause perturbation. BCG is not a very effective vaccine. Evidence
shows that while BCG vaccination of adult badgers can reduce the risk of infection in
unvaccinated cubs in a social group, the vaccine is not totally effective; a spectrum of
protective immunity is seen in uninfected vaccinated badgers with no known benefit in
animals infected with M. bovis (estimated at around one third of the badger population
in endemic areas). Annual cage trapping programmes are required to target newly
emerged badger cubs and maximise immunity in a social group; the annual turnover of
the British badger population is estimated to be 30 percent. Determining the size of
badger populations is challenging and the efficiency of cage-trapping is variable. A
Food and Environment Research Agency (Fera) model
24
suggests that it could take
over forty years to eradicate TB in badgers using vaccination. The effects of injectable
badger vaccine deployment on bTB in cattle are not known. While it is reasonable to
expect it to reduce the incidence of bTB in cattle in endemic areas, there has been no
trial to assess the magnitude and timing of these effects. However, modelling
25

suggests that culling can reduce bTB levels in cattle more quickly than vaccination
alone. In its response to the Environment, Food and Rural Affairs (EFRA) Committees
report on bTB vaccination in 2013, the Government
26
said that badger vaccination
must form part of any strategy to eradicate bovine TB, though badger vaccines cannot
cure diseased badgers. These diseased animals will continue to infect cattle herds.
The Government believes that any licensed badger vaccination projects should be
coordinated, delivered and funded privately. Vaccination projects should be deployed
strategically to help deliver the aim of staged achievement of OTF status for England.
Injectable badger vaccine has been used in a government-funded, five-year Badger
Vaccine Deployment Project (BVDP) in Gloucestershire, established to learn practical
lessons about vaccinating badgers and to train lay badger vaccinators. The
Government has also provided financial support for private vaccination projects through
the Badger Vaccination Fund, a competitive grant scheme which has provided match-
funded grants of up to fifty percent of the first year costs, although uptake to date has

23
Veterinary Surgery (Vaccination of Badgers Against Tuberculosis) Order 2010 (SI 2010 No.510)
24
Final Report of Project SE3294: Further numerical analyses of the badger vaccine study (BVS)
http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&Completed=0&ProjectI
D=16715
25
Smith GC, McDonald RA, Wilkinson D (2012) Comparing Badger (Meles meles) Management Strategies
for Reducing Tuberculosis Incidence in Cattle. PLoS ONE 7(6): e39250. doi:10.1371/journal.pone.0039250
26
Government Response to Environment, Food and Rural Affairs Committee Report on vaccination against
bovine tuberculosis (October 2013)
http://www.publications.parliament.uk/pa/cm201314/cmselect/cmenvfru/705/70504.htm

47
been limited
27
. In 2013, priority access to the Badger Vaccination Fund was extended
to vaccination projects in the Edge Area. In its response to the EFRA Committee, the
Government acknowledged the enthusiasm among voluntary organisations for
deploying badger vaccine but noted that while it was starting to see voluntary groups
working in partnership with farmers to vaccinate badgers, the prospect of vaccination
being carried out over a significant proportion of the endemic area in England remained
remote adding that social research, carried out as part of the BVDP, suggests that
there is little interest from landowners and farmers partly because of the costs involved
and partly because of the limited confidence many have in the ability of badger
vaccination to reduce the incidence of TB in cattle. Nevertheless, the Government said
it would continue to offer to work with other organisations to ensure that their collective
efforts yield maximum benefit. Subject to available resources, the Government will
consider transitional financial support for private sector-led strategic projects, for
example those focussed on maximising the immunity of badgers in locations at
greatest risk of advancing infection. The role of badger vaccination in endemic areas
could develop further as the number of TB-infected badgers is reduced through culling.
(4) Other disease prevention measures
AHVLA provides biosecurity advice to keepers supplementing other sources of
information (e.g. from farming organisations and private vets). Defra funds various
initiatives to provide such advice to keepers and substantial research effort into
biosecurity measures, particularly to address spread from badgers to cattle. Whilst
some biosecurity measures are statutory, many on-farm biosecurity measures are
voluntary;
All surveillance and breakdown testing (including tracing and contiguous testing) must
be carried out within a given time window. Overdue tests trigger movement restrictions
and, since 2014, a reduction in Common Agricultural Policy Scheme payments for
overdue bTB surveillance or check tests;
All cattle over 42-days of age, moving from annually tested herds to live on another
holding must have a valid pre-movement bTB test (statutory) at the farmers expense.
In order to support farmers, there are exemptions to this requirement for movements to
slaughter (including indirect routes approved by AHVLA) veterinary treatment, artificial
insemination centres, shows, common land and between holdings in the same Sole
Occupancy Authority (SOA) located wholly within the annual testing area. These
exemptions are subject to review. As well as potentially detecting bTB breakdowns, the
main benefit of pre-movement bTB testing lies in preventing geographic spread and
many new herd breakdowns. In the seven years since the Government introduced pre-
movement bTB testing in 2006, some 2500 pre-movement bTB test reactors were

27
In 2013, 58 percent of badger vaccination (834 vaccinations out of a total of 1429) in England was carried
out and paid for directly by government. Across England and Wales, this figure rises to 78 per cent (2186
vaccinations out of total of 2781)

48
removed in England, i.e. potentially preventing up to 2500 new breakdowns and all
herds where pre-movement testing disclosed reactors were put under movement
restrictions, potentially preventing even further disease spread.
Keepers are encouraged voluntarily to isolate and post-movement test any new stock
they bring into their herd;
Cattle from restricted herds may be moved under AHVLA licence directly to slaughter.
In order to support farmers, cattle from restricted herds may be moved indirectly to
slaughter under licence via biosecure Approved Collection Centres or Approved
Finishing Units (AFUs). Non-grazing AFUs are permitted in all areas, and stock must
be kept in badger-proof buildings. In the HRA, where there is already a reservoir of M.
bovis in badgers, grazing AFUs are permitted on double-fenced land. Since 2013, the
Government has applied a risk-based, proportionate approach to bTB testing in AFUs
with no routine or breakdown testing (other than in exceptional circumstances) in non-
grazing AFUs;
Cattle keepers are no longer allowed to establish links between holdings in different
risk areas so all movements of cattle between such holdings must be reported to the
Cattle Tracing System (CTS). This enables AHVLA to monitor compliance with pre-
movement testing;
Since 2012, new Sole Occupancy Authorities (SOAs) have not been permitted and new
holdings can no longer be added to existing SOAs.
Developing cross-cutting bTB control measures in all risk areas
Cross-cutting measures which may be applicable to all risk areas are explained below.
(1) Biosecurity
Risk-based trading
The way in which livestock are traded can have a direct impact on the risk of spreading
disease as well as implications for surveillance. Incomplete information in decision making
is a well-established form of market failure that can sometimes require Government
intervention, and this is no less true for controlling bTB in cattle. Introducing cattle from
higher risk herds (e.g. herds which have recently experienced a bTB breakdown)
increases the disease risks for the importing herd. Achieving OTF status for the LRA and
expanding it into the current HRA is a key aim of the Strategy; actions which jeopardise
this need to be discouraged with the costs of consequences of risky decisions falling on
those who take them. Making more bTB history information available to buyers would
enable them to make informed decisions on the disease risk of purchased stock and would
enable farmers to take appropriate action to reduce the risk of spreading bTB.

49
The industry-led Risk-Based Trading Group
28
recommended the development and
introduction of a comprehensive, accessible database as the ideal solution to support a
successful risk-based trading scheme. This would be used by farmers, veterinary
surgeons and auctioneers to inform purchasing decisions and post-purchase behaviour.
As the development of such a database (or interface) is not a quick or simple task, the
group recommended a phased introduction of risk-based trading measures whilst the
requirements and costs of the database can be scoped. In the shorter term, the group
recommended the introduction of other measures such as making an animals bTB history
available at the point of sale; the production of buyer and seller best-practice guidance;
and the development of an accreditation scheme for assigning a risk status to cattle herds.
Since the publication of the Groups report in May 2013, the Government has been
working with the industry to act on all of its recommendations.
The Group strongly favoured the voluntary approach to the introduction of risk-based
trading, and emphasised that the Government and industry working in partnership was the
way forward. However, it cautioned that if this was not successful, a mandatory approach
must be considered to ensure the adoption of risk-based trading and to facilitate informed
decision making by farmers when they trade cattle to help minimise the risk of spreading
the disease by riskier trading practices. There are other tools (e.g. compensation levels)
that can be used to encourage farmers to take advantage of risk-based trading.
On-farm and off-farm biosecurity
Biosecurity measures aim to prevent cattle-to-cattle, cattle-to-badger and badger-to-cattle
spread of bTB
29
. For example, the risk of cattle-to-cattle spread of bTB may be tackled
through timely herd bTB testing, pre- and post-movement testing, isolation of new animals
prior to their introduction into a herd and separating cattle from neighbouring cattle herds.
Other biosecurity measures are aimed at doing everything practical to keep badgers and
cattle apart. There may be an opportunity for farmers to apply for Rural Development
Programme for England funding towards biosecurity tools such as cattle handling facilities
and badger-proof feed troughs. Many biosecurity measures are voluntary, but there is
scope to build on the approach introduced in 2012 which reduced statutory compensation
for bTB reactors disclosed in significantly overdue herd tests. The Government intends to
undertake an evidence-based review of biosecurity measures both on farm and off farm,
and will consider measures that would encourage improved uptake.
Using compensation to encourage risk-reduction

28
Defra (2013) Bovine TB Risk-Based Trading: Empowering Farmers to Manage TB Trading Risks (PB
13911) https://www.gov.uk/government/publications/bovine-tb-risk-based-trading-empowering-farmers-to-
manage-tb-trading-risks
29
Further information on general biosecurity measures is available on the AHVLA website at
http://www.defra.gov.uk/ahvla-en/disease-control/bovine-tb/protecting-herd/. Further information on badger
exclusion measures is provided in Badgers and bovine tuberculosis: on-farm biosecurity and badger
exclusion measures (TIN106) available on the Natural England website at
http://publications.naturalengland.org.uk/publication/970479

50
It is important to consider the extent to which compensation levels influence farmers
approach to managing their bTB risks. For example, in some countries with successful
control strategies such as New Zealand and Spain, cattle compensation is paid at 65
percent and 75 percent of market value respectively. The Government plans to review bTB
compensation with the objective of encouraging risk-reduction, for example by ensuring
that animal (e.g. cattle, South American camelids, farmed deer) keepers observing defined
best practice on biosecurity benefit over those who do not.
(2) Improving advice and guidance to farmers
The Government is committed to exploring ways to provide evidence-based, effective
advice and guidance to farmers, in partnership with the food and farming industry, levy
bodies and the veterinary profession.
Previous examples of biosecurity advice and guidance include films funded jointly by
Defra, the National Farming Union, the Welsh Government and the National Animal
Disease Information System, AHVLA leaflets, and biosecurity workshops for farmers in the
HRA. Previous examples of compliance advice include bTB Information Notes
summarising details of changes to bTB rules, and guidance produced by AHVLA. The
Government will continue to work in partnership with stakeholder representatives to ensure
that such advice is fit for purpose and is disseminated effectively.
The Government has provided funding for and worked with the Farming Community
Network to ensure that its volunteers are kept up to date with bTB policy developments so
that they can provide effective support and business advice to those farmers most in need.
There may be an opportunity for industry to apply for Rural Development Programme for
England funding towards training and information exchange activities.
In November 2013, the Government sought views on proposals compatible with data
protection and other legislation, to provide farmers with sufficient information on the bTB
status of neighbouring herds to enable them to manage any risks to their own herds.
(3) Improving compliance and enforcement
It is crucial that the currently high levels of farmer compliance with bTB controls are
maintained. The small minority of farmers that contravene or ignore disease control rules
jeopardise their own business and undermine the efforts of others. The Government
recognises that non-compliance is not always deliberate, but can be due to the complexity
of the rules and/or poor guidance. Therefore a high priority is to help farmers to comply by
obtaining a clearer understanding of what guidance material they need. The Government
has commissioned a review to consider the multiple sources of available guidance on bTB
rules, find out what works well and not so well, and act on recommendations made. It also
plans to work with industry partners to publicise the importance of compliance.
The Government will work with the farming industry and delivery partners (including local
authorities) to monitor compliance levels and find practical, proportionate and effective
ways to improve them. A project board comprising industry and government

51
representatives is in place to oversee and direct bTB-related compliance and enforcement
activity. In J anuary 2014 the Government built on the existing approach whereby owners
of bTB affected herds that fail to test on time receive reduced compensation for bTB
reactors, by tightening the Common Agricultural Policy Scheme rules for overdue bTB
surveillance or check tests; maximising existing levers to encourage timely testing is more
effective than penalising those that have already increased the risk of spreading bTB
through late testing.
Resources will be focused on areas where non-compliance could be most damaging.
Where significant, damaging and deliberate breaches of bTB controls are identified the
Government will encourage and support robust enforcement action by local authorities.
(4) Tackling TB in non-bovine species
Many species of non-bovine farmed (e.g. South American camelids (SAC), captive deer,
goats, pigs and sheep) companion (e.g. cats, dogs and ferrets) zoo and wild mammals are
susceptible to M. bovis infection. Only a relatively small number of animals are identified
as infected each year through scanning surveillance. Evidence suggests that non-bovine
species other than the badger are generally spillover hosts and appear to pose a very
small risk of spreading M. bovis to cattle and badgers.
All confirmed cases in SAC are investigated by AHVLA to assess epidemiological links
and disease links to cattle or other SAC premises. The evidence from this work suggests
that they often act as sentinel species to local cattle or badger infection; there are no
known cases where a cattle bTB breakdown has been caused directly by transmission
from SACs.
Wild mammals other than badgers can act as maintenance hosts for M. bovis and vectors
of the infection for cattle, as illustrated by the experiences of New Zealand (brush-tailed
possum) Australia (Asiatic water buffalo) Michigan (white-tailed deer) South Africa (Cape
buffalo) the Central and Southern Iberian Peninsula (wild boar and red deer) and some
dpartements of France (wild boar and red deer in addition to badgers). However, the
existing evidence from wildlife surveys and quantitative risk models carried out by Fera in
GB indicates that in this country the badger remains the principal and possibly the only
wildlife maintenance host of M. bovis. Whilst M. bovis infection has been found in other
wild mammals in England (notably deer and more rarely wild boar, fox and some rodents)
the data on the prevalence of infection, pathology, abundance and ecology suggest that
fallow deer and possibly muntjac and red deer are the only other wild mammals that could
act as potential sources of M. bovis for cattle in the South West of England and Wales.
Even in these deer species the effect is localised and the risk of transmission to cattle
much lower than that posed by badgers, primarily due to differences in behaviour and
contact levels with cattle. Additionally, once detected, deer infection is often controlled
locally by additional culling.
30

31

32


30
Delahay et al. (2002) The status of Mycobacterium bovis infection in the UK wild mammals: a review. The
Veterinary J ournal, 164, 90-105

52
The Governments response to M. bovis infection in non-bovine species will be evidence-
driven and proportionate to the risk, in order to target efforts in areas where risk
management will make a real impact on bTB. Additional measures for badgers are
discussed elsewhere. Any additional measures proposed for other non-bovine species are
explained below:
South American camelids
The tuberculin skin test has limited sensitivity in SACs. As a result of research undertaken
for the SAC sector, the Government intends to introduce mandatory single intradermal
tuberculin testing supplemented by a combination of two antibody tests (in parallel
interpretation) as a condition for lifting movement restrictions from all SAC herds with
confirmed M. bovis infection. The Government intends to consult with a view to making TB
surveillance mandatory in SACs. In the meantime, it is working with the sector to
encourage voluntary pre and post-movement testing and surveillance of SAC herds using
skin and blood tests. Sharing of these voluntary surveillance results is essential for
disease control purposes.
There are no compulsory registration and identification requirements for SACs. As SACs
are considered spillover hosts for M. bovis, the Governments position remains that these
arrangements are proportionate to the risk. There are therefore no plans to introduce
compulsory identification and registration requirements for the control of TB in SACs in the
short term. In the longer term, however, it is possible that a new EU Animal Health
Regulation may include a requirement for Member States to regulate the registration and
identification of SACs. The Government will review the case for including SAC within such
a requirement in the context of negotiations on the European Commissions Animal Health
Regulation proposal published in 2013.
Other farmed mammals (e.g. captive deer, goats, pigs and sheep)
M. bovis infection in other farmed mammals is a relatively rare occurrence and improved
slaughterhouse surveillance introduced in 2011 has helped identify new TB outbreaks,
which will continue to be handled on a case by case basis using the tuberculin skin test as
required. All confirmed holdings will be placed under movement restrictions until testing or
slaughter surveillance has demonstrated absence of infection. Contiguous or radial
surveillance around these cases will continue. The Government will also continue to work
with the various sectors to raise awareness among farmers of the risks of M. bovis

31
Delahay et al. (2007) Bovine tuberculosis infection in wild mammals in the South West region of England:
a survey of prevalence and semi quantitative assessment of the relative risk to cattle. The Veterinary
J ournal, 173, 287-301
32
Ward et al. (2009) Estimating the risk of cattle exposure to tuberculosis posed by wild deer relative to
badgers in England and Wales. J ournal of Wildlife Disease, Vol. 45 No. 4,1104-20


53
infections in non-bovine species and the measures that can be taken to reduce these
risks.
Companion and zoo mammals
M. bovis infection in companion and zoo mammals is a relatively rare occurrence and
AHVLA and Public Health England will continue to monitor the results of scanning
surveillance and work with the sectors to raise awareness of the risks and of the measures
that can be taken to reduce these risks. AHVLA will continue to carry out epidemiological
investigations into all companion animal cases to assess any connection with local cattle
epidemics. Zoos and animal collections with confirmed incidence will continue to be placed
under movement restrictions until considered free of disease.
Wild mammals (other than badgers)
Wild deer surveillance is carried out by private stalkers who are aware of the need to
submit suspicious lesions for bacteriological examination. Where there is a suspicion of
deer-related infection in cattle, this surveillance can be intensified and additional radial
surveillance of cattle in an area can be initiated by AHVLA when considered appropriate.
AHVLA will continue to monitor the results of scanning surveillance in wild mammals.
Developing area risk-based strategies
The epidemiological rationale for, and the objectives of, sub-strategies tailored to specific
risk areas are explained below. These sub-strategies will be deployed geographically to
deliver the aim of staged achievement of OTF status for England. For example, we could
anticipate a movement in the deployment of Edge strategy westwards and southwards if
existing strategies are successful in reversing the geographical distribution of the disease.
Low Risk Area (LRA) strategy
Epidemiological rationale
The rationale for the LRA strategy is based on the following evidence and assumptions:
The area has a low bTB incidence. Where bTB does occur, it tends to result from
infected cattle that have been brought in from other parts of the UK. An analysis of the
prevalence of culture and/or lesion positive bTB breakdowns over the past six years
(up to 2012) demonstrated that, if only the indigenous breakdowns of bTB are
included in the calculation, the crude annual herd prevalence for the area remained
below or equal to 0.1 percent throughout the period. The proportion of OTF herds
remained above 99.9 percent throughout the period. These figures demonstrate that
the area has great potential to gain OTF status as defined in Council Directive
64/432/EEC. There is evidence to support the non-endemic nature of bTB in the LRA:
o The analysis of the genotypes of the mycobacteria involved in herd breakdowns in
England carried out on a continuous basis since 1996 by AHVLA, shows that there
are no established areas of specific genotypes of M. bovis isolated from cattle
within the LRA or near it;

54
o There is little evidence of local spread between cattle herds (this analysis continues
and is strengthened by the radial surveillance measures implemented in the LRA
from 2013);
o Recurrence figures are low and associated with re-introduction of disease by stock
brought in from the endemic area (a total of four recurrent breakdowns, within a
three year retrospective window, in 2009-2011; three of these were attributable to a
new genotype introduced by new stock purchased from the endemic area; one had
an unknown origin);
o Breakdown duration is shorter than in the endemic areas (14 percent of LRA
breakdowns ending in 2011 lasted more than 240 days; the same figure for GB was
33 percent and for Wales 53 percent); and
o Whilst previous, very limited road traffic accident based surveillance has found
occasional badgers infected with M. bovis in the LRA in the past, there is little
evidence of a significant reservoir of M. bovis in badgers in the area. AHVLA has
carried out badger surveillance measures around unexplained bTB incidence in the
LRA (1-2 surveillance zones established annually). In the seven years to 2013, this
surveillance has not yielded any positives results.
With the non-endemic nature of the disease in the LRA, it is considered important to
maintain the status quo, seek further and sustained reduction in breakdown incidence
and to seek OTF status for the whole or parts of the area as soon as this can be
justified within the current EU legislation. The target in the Strategy is to achieve OTF
status progressively starting in 2018. This would allow the LRA to be better protected
from disease occurrence, to align its cattle movements and marketing with other OTF
regions of the UK and to reduce the surveillance burden on cattle keepers and
Government. The resultant resource or financial savings could then be directed to
achieving OTF status for other areas.
The creation of the uniform four-yearly testing area in 2013 removed pockets of more
frequently tested areas. Farmers may not therefore be aware of disease levels
occurring in this area and we need to guard against a perception that there is no
disease threat in this area. Low risk does not mean no risk and the impact of an
increase in breakdowns could lead to whole counties being placed on more frequent
testing.
Objecti ves
To maintain or further reduce the very low incidence of sporadic culture and/or lesion
positive bTB breakdowns in the counties of the north and east of England (LRA) and
deal quickly and effectively with any incursions of disease in these areas, through the
application of proactive, risk-based surveillance and breakdown management;
To expand the current OTF region of the UK by moving towards similar OTF status
recognition for those counties (or groups of counties) in the north and east of England

55
that have maintained over a six-year period a very low incidence of indigenous (not
clearly introduced) culture and/or lesion positive bTB breakdowns, which is below the
threshold set out in Council Directive 64/432/EEC (0.1 percent annual herd incidence);
and
To continue to protect the LRA of England, by introducing additional measures to halt
the spatial spread of the disease (see below) and by introducing risk based cattle
trading strategies.
Edge Area strategy
Epidemiological rationale
The rationale for the Edge area strategy is based on the following evidence and
assumptions:
There are advancing disease fronts where bTB is spreading spatially across the entire
annually tested area of England, including within the HRA. The Edge Area strategy
focuses on those disease fronts that face the non-endemic areas of England. The
disease fronts, or areas where geographic spread of bTB has occurred, threaten areas
of high cattle density in the north west and north of England. It makes good disease
control sense and is cost effective to apply additional disease control measures and
increase farmer awareness of the disease spread risk in the Edge Area in order to:
o identify where disease is emerging and publicise this information locally;
o take effective measures to stamp out the disease when found; and
o prevent the disease from re-emerging by addressing the causes of breakdowns.
The Edge Area strategy applies to areas where the infection is potentially spreading
geographically and to areas that are at short term risk from such spread.
It is important to define the Edge Area where the control measures are applied in order
to deploy the measures and to measure their success in halting the spread.
The outer boundary of the Edge Area is a county boundary for administrative and EU
legal reasons. The inner boundary of the Edge Area is set based on previous research
work, surveillance data and knowledge of the local situation provided by the AHVLA
staff working within the Edge Area. This boundary will be subject to change, reflecting
the changing disease situation in the area. While there are local differences in the
disease occurrence in the Edge Area, it differs from the LRA and the HRA in disease
prevalence. Between 2006 and 2011 there was an increasing number of culture and/or
lesion positive bTB breakdowns in the Edge Area and the crude prevalence of herd
breakdowns reached just over 1 percent.
As the rate of disease movement is not uniform across the Edge Area and the areas
affected differ in their characteristics, a successful strategy to target disease spread
needs to be tailored to the local conditions. This flexibility can be achieved by using a

56
mixture of compulsory and discretionary control measures which can be applied with
local evidence-based veterinary discretion.
We currently know very little about the TB-infection status of badgers in the Edge Area.
Further research is needed to determine the respective roles of cattle and wildlife in the
spread of bTB in the Edge Area and whether or not the badgers there represent a
significant wildlife reservoir of M. bovis and/or drive the spread of the edge. This will
involve gathering information on the badger population density and prevalence of TB
infection in badgers in the Edge Area to inform future control measures.
Objecti ves
The short to medium term objectives for the Edge Area are to:
stop the geographic spread of the HRA; and
begin to reduce the incidence rate within the Edge Area.
The longer term objectives are to:
reverse the spread of disease; and
reduce the incidence rate of the Edge Area, working towards an OTF status for the
counties involved.
High Risk Area (HRA) strategy
Epidemiological rationale
The rationale for the HRA strategy is based on the following evidence and assumptions:
The South West and West Midlands have been recognised as a HRA for bTB. A
separate and epidemiologically distinct HRA is located in East Sussex. There is
evidence to indicate that bTB is endemic and that residual infection in breakdown
herds, cattle movements and the badger reservoir of M. bovis infection play a key role
in bTB epidemiology in these areas;
Due to the limitations of any single disease control measure, a multiple approach to
disease control in both the major hosts of bTB infection in the area, the cattle and the
badger, is required;
The epidemic in the HRA can be defined by home ranges of different genotypes of M.
bovis, suggesting a pattern of clusters that tend to expand and overlap and cannot be
explained by cattle movement alone;
Recurrence of herd breakdowns is a key epidemiological feature of the epidemic in the
HRA. In England and Wales, herds with a 36-month history of breakdowns were 6.3-
8.5 times more likely to have a breakdown in 2011 than herds without such a history.

57
Around 56 percent of herds with culture and/or lesion positive bTB breakdowns in 2011
had a history of a breakdown in the previous 36 months
33
;
There is evidence to suggest that a substantial proportion of herds have residual
infection left in the herd at the end of a breakdown. Data indicate that, in the worst-case
scenario, up to 21 percent of cattle herds may be harbouring at least one infected
animal when movement restrictions are lifted
34
. Furthermore, depending on the
modelling assumptions, the researchers estimated that 50 percent (3367, 95 percent
confidence interval) or 24 percent (1142, 95 percent confidence interval) of recurrent
bTB breakdowns could be attributed to infection missed by the short-interval skin
testing regime. This is likely to play a substantial role in the epidemiology of bTB in the
HRA, contributing to the high recurrence rate. This suggests improved breakdown
management will be important for disease eradication;
Whilst the contribution of cattle movements to the epidemiology of bTB in the HRA is
not quantified in the same manner as in the LRA, it must be assumed that it contributes
to disease spread in the HRA as well. Ninety-eight percent of movements of cattle from
holdings in the HRA to live on other holdings take place within the HRA. Thus there is a
need to apply risk-based trading practices in the HRA, perhaps even more so than
between the different risk areas;
In spite of the relatively high county level herd prevalence across the HRA, there is a
marked variation in this prevalence (0.7-15.7 percent of herds affected with culture
and/or lesion confirmed breakdowns in 2011). Forty percent of cattle herds in the HRA
in the ten years to 2012 did not have a bTB breakdown in this period. It is important
that the status of these herds is recognised and protected as part of the strategy,
particularly in terms of their potential contribution to risk-based trading practices in the
HRA;
A small proportion of often prolonged breakdowns with high numbers of reactors are
responsible for a disproportionate share of breakdown costs in the HRA. Evidence
suggests that, in any one year, 40 percent of breakdown costs arise in 10 percent of
breakdowns. Addressing these breakdowns more rigorously is an important part of the
strategy. AHVLA will launch a project in 2014 to tackle persistent breakdowns; and
As OTF status in the HRA will take decades to achieve, it is important to ensure that
the epidemic is closely monitored, the approach to eradication is flexible and short and
medium term targets are in place. It is also important that a flexible and adaptive
approach to the management of the strategy is adopted.

33
AHVLA (2013) Bovine tuberculosis, infection status of cattle in GB, Annual Surveillance Report for the
period of J an 2011 to Dec 2011 http://www.defra.gov.uk/ahvla-en/publication/pub-survreport-tb/
34
Conlan et al. (2013) Estimating the Hidden Burden of bovine tuberculosis in Great Britain. PLoS Comput
Biol 8(10): e1002730. doi:10.1371/journal.pcbi.1002730.

58
Objecti ves
The short term objectives for the HRA are to:
maintain a stable incidence rate within this area; and
establish an improved understanding of the epidemiology of bTB in the area in order to
introduce a more tailored approach to control measures.
The medium term objectives for the HRA are to:
turn the current trend of increasing herd incidence into a decline by addressing cattle
movement related spread, the residual infection and the wildlife reservoir,
strengthening and targeting cattle control measures and moving towards greater
stakeholder engagement on all control fronts; and
introduce targeted and localised strategies with clear prevalence targets.
In the longer term, the objectives are to:
achieve a continuous and sustained reduction in both herd and animal incidence of
bTB in all areas of the HRA, and
ultimately, to achieve OTF status.
Next steps to develop our risk-based approach
Table 2 provides a summary of the current measures applied in each area and the
additional future measures or options to develop our risk-based approach.
Developing new tools
Introduction
This section outlines the research programme and new tools under development, with a
view to deployment as part of the ongoing implementation of the Strategy. It also explains
why the Government is not developing therapeutics for treating bTB.
Defras Evidence and Investment Strategy
Defras Evidence and Investment Strategy
35
summarises the work that it is doing to
develop research programmes to support the development of policy. Defras Evidence
Plans provide a clear reasoning as to why Defra invests in evidence and how it makes
best use of all available evidence.

35
Defra Evidence and Investment Strategy 2010 to 2013 and beyond (PB 13471)
https://www.gov.uk/government/publications/defra-s-evidence-investment-strategy-2010-to-2013-and-
beyond-2011-update

59
The bTB research programme
The Government has spent a significant amount (over 155 million since 1991/92) on an
ongoing and wide-ranging bTB research programme. The content and direction of the
research programme is described in further detail in the Bovine Tuberculosis Evidence
Plan 2013/14 2017/18.
36
Further information is available in Annex E. The portfolio
comprises projects to increase understanding of the disease epidemic and to support the
development of new tools such as vaccination and diagnostics that can be used to tackle
the disease. Evidence needs to be multidisciplinary to provide a comprehensive
understanding of the disease epidemic. The research programme will continue to bring
together epidemiology, veterinary science, modelling, statistics and the social sciences to
generate integrated and innovative approaches to tackling the disease.
Developing new diagnostics tests for surveillance
(i) Tests to detect bTB in cattle
Tuberculin skin test
Under Council Directive 64/432/EEC, the cervical (i.e. applied to the neck) tuberculin skin
test is the only official EU standalone test for bTB in live cattle (i.e. for the purposes of
granting and retaining OTF herd status). No diagnostic test for bTB is perfect and the
tuberculin skin test is no exception. However, if performed correctly it remains the most
practical and cost-effective tool for detecting bTB. In areas (e.g. Scotland) where there is
no significant reservoir of M. bovis in wildlife, traditional cattle herd test and slaughter
strategies using the tuberculin skin test have proven efficacy in achieving OTF status.
For the routine programme of surveillance testing of cattle herds, we have used the
comparative tuberculin skin test (the single intradermal comparative cervical test (SICCT))
which measures the animals immune reaction to injections of both avian and bovine
tuberculin. At standard interpretation, fewer than 1 in 1,000 bTB-free cattle give a false
positive result (over 99.9 percent specific if the test is performed correctly) but the test
misses around 1 in 5 bTB-infected cattle (at best, 80 percent sensitive at herd level if the
test is performed correctly). Using a severe interpretation of the comparative tuberculin
skin test marginally reduces the likelihood of false negatives (i.e. increases the sensitivity)
whilst slightly increasing the likelihood of false positives (i.e. decreases the specificity).
A further option is to use the bovine tuberculin skin test (the single intradermal cervical test
(SICT)) which measures the animals immune reaction to injections of bovine tuberculin
only. The bovine tuberculin skin test increases the likelihood of detecting bTB-infected
cattle and the Government has therefore taken the decision to use it for pre-export testing
to safeguard trade. However cattle are exposed to a wide range of (non-M. bovis)
environmental mycobacteria which can potentially interfere with the assessment of

36
Defra Bovine Tuberculosis Evidence Plan 2013/14 2017/18 (PB 13909)
https://www.gov.uk/government/publications/evidence-plans

60
reactions to the bovine tuberculin skin test so use of the bovine tuberculin skin test for
routine or whole herd testing would be at the expense of a high proportion of false
positives. For example, a retrospective analysis carried out by AHVLA of 1 million cattle
tested in 2005 concluded that only one in every twenty-one additional cattle which would
have been removed by applying the bovine tuberculin skin test, would have progressed to
develop detectable bTB in the following four years; this would have resulted in the
slaughter of 24,100 cattle in addition to the 30,000 cattle slaughtered for bTB control in
2005. While some countries (e.g. New Zealand) apply the bovine tuberculin skin test in the
caudal fold of the tail (rather than in the neck) which allows for a quicker and safer
application of tuberculin, this technique is not permitted for trade purposes under EU law.
Interferon-gamma (IFNg) assay
Since 2002, Council Directive 64/432/EEC has allowed the more sensitive interferon-
gamma assay (a blood test which also uses tuberculin) to be used in parallel with the
tuberculin skin test to detect and remove additional infected cattle. Between 2002 and
2006, the Government used the interferon-gamma assay in the context of a field trial in
OTF status withdrawn herds and on an ad hoc basis elsewhere.
Since October 2006, the Government has deployed mandatory parallel interferon-gamma
assay in OTF status withdrawn herds in four-yearly testing (Low Risk) areas of England to
supplement the tuberculin skin test and improve the detection of infected animals.
In 2011, the Government adopted mandatory parallel interferon-gamma assay in OTF
status withdrawn herds in two-yearly testing parishes; in 2013 the test continued to be
mandatory in OTF status withdrawn herds in these areas after they had been incorporated
into the Edge Area as annual testing zones. Since J anuary 2014, the Government has
deployed parallel interferon-gamma assay across the Edge Area to supplement the
tuberculin skin test and improve the detection of infected animals; interferon-gamma assay
is mandatory for culture and/or lesion positive bTB breakdowns and discretionary for lower
risk bTB breakdowns, based on an AHVLA veterinary assessment of the herd.
The Government is considering making the interferon-gamma assay available for private
pre- and post- movement testing of tuberculin skin test-negative cattle moving between
OTF herds.
A European Food Safety Authority (EFSA) scientific opinion
37
on the use of the interferon-
gamma assay for the diagnosis of bTB published in 2012 concluded that the tuberculin-
based interferon-gamma assay could be included among the official tests for the purpose
of granting and retaining OTF herd status, but protocols for use should first be harmonised
across the EU. This opinion may result in EU negotiations on the future approval of the

37
EFSA Panel on Animal Health and Welfare (AHAW); Scientific Opinion on the use of a gamma interferon
test for the diagnosis of bovine tuberculosis. EFSA J ournal 2012;10 (12):2975 [63 pp.]
doi:10.2903/j.efsa.2012.2975 http://www.efsa.europa.eu/en/efsajournal/pub/2975.htm


61
tuberculin-based-interferon-gamma assay as a second official EU standalone test for bTB
in live cattle although no changes are envisaged before 2017.
Other tests
In the opinion cited above, EFSA advised that other tests reviewed (e.g. antibody detection
tests) should not yet be considered for use as official tests for the purpose of granting
official bTB-free herd status.
Given the limitations of current cattle diagnostic tests and the need to develop improved
tests, the Government will consider funding research when potentially useful new methods
become available. As new diagnostic tests become available, the Government will make
an assessment of their costs and benefits before deciding whether or not to deploy them.
(ii) Tests to detect M. bovis infected badgers
Ongoing research aims to develop additional diagnostic tests for use in potential
surveillance programmes. This includes tests to detect M. bovis either in individual infected
badgers or in their environment. Such tests could have many potential applications
including measuring TB prevalence in badgers, monitoring the effect of interventions such
as vaccination, and increasing understanding of the epidemiology of the disease and the
relative importance of different routes of transmission. Additionally, the availability of
suitable tests to identify M. bovis infection in badgers will inform the development of new
strategies for dealing with the risk of TB in badgers ideally focussed on removing from the
population only those badgers infected with TB.
Detection of infected, individual badgers can be done by post mortem examination of
dead badgers (identification of lesions and/or culture of M. bovis from lesions or of
certain predilection site organs). These techniques are highly developed and moderate
to high sensitivity and specificity of testing can be achieved. However, healthy
badgers would need to be killed for this methodology to be used for surveillance and
representative meaningful sampling is not straightforward. In live badgers, testing for
an immune response associated with exposure to M. bovis, such as the BrockTB
StatPak
38
or interferon gamma assay testing can be carried out. The former test could
be carried out in field conditions allowing animals to be restrained until results are
available, but it misses around 1 in 2 infected badgers (around 50 percent sensitive).
The latter test misses around 1 in 5 infected badgers (around 80 percent sensitive) but
requires laboratory analysis. Both these immunological tests require blood sampling of
live, captured badgers which can currently only be done under sedation by trained and
licensed staff. Defra has funded a research project which aims to develop methods of
taking clinical samples such as blood and urine from badgers without the need for
sedation. This would simplify the sampling of trapped badgers and could be used in

38
Commercial name for M. bovis serology test for badgers

62
conjunction with new serological diagnostic
39
methods and methods for testing urine
samples that are being developed. In the Republic of Ireland, polymerase chain
reaction (PCR) methodology is being tested to assess its sensitivity in detecting
infection in faeces samples from individual culled badgers. Results are expected in
2014/15.
Efforts to develop a suitable tool for testing badger setts have concentrated on
developing tests which can detect M. bovis in environmental samples taken in the
vicinity of setts, including from latrines. The analysis and interpretation of
environmental sampling is challenging. Infected badgers shed M. bovis intermittently.
The presence of M. bovis in latrines, soil or air depends on whether infected badgers
have been shedding the bacteria in the sample type collected, in the location being
sampled from, and in the sample that is taken. The methods which have been
assessed include PCR and immuno-magnetic separation (IMS)
40
coupled with a lateral
flow device. Defra started funding the development of a PCR-based test to detect M.
bovis in environmental samples at Warwick University in 2007. While the test performs
well at identifying spiked samples in the laboratory and is reproducible, it has been
less sensitive at detecting known infected social groups from faecal samples collected
in the field. Warwick University has led on Defra-funded research to optimise the
sampling regime with the aim of improving the performance of the PCR test in the
field. The IMS technique has the potential to increase the sensitivity of environmental
sampling strategies. Defra has funded a project at Queens University in Belfast to
develop this method. Defra is planning an inter-laboratory study (ring-trial) applying
different PCR tests and the IMS technique to badger faecal samples to identify which
test shows most promise for field use.
Developing deployable bTB vaccines
We have an authorised injectable vaccine for badgers. There are no bTB vaccines
authorised for use in other animals. Vaccination of cattle to control bTB is prohibited under
EU law (Council Directive 78/52/EEC) as it is not compatible with the provisions for testing
and herd qualification for OTF status (Council Directive 64/432/EEC).
(i) Cattle vaccination
A cattle bTB vaccine is likely to be a valuable additional tool in the fight to eradicate bTB
but vaccination of cattle with a vaccine such as BCG (Bacillus Calmette-Guerin) will
reduce but never eradicate bTB from the national herd, particularly if there remains an
ongoing spread of M. bovis from badgers.

39
Serological diagnostics is testing for antibodies in serum (serum is a component of blood)
40
Using antibody-coated magnetic particles to separate microbe cells from the rest of the sample in order to
concentrate them for better detection

63
The current best candidate vaccine to protect against TB in cattle is based on BCG. BCG
does not offer complete protection from infection with M. bovis. Research to date suggests
that the proportion of cattle protected or partially protected may be in the order of only 50-
70 percent although further research is needed to verify this. Vaccination of cattle with
BCG can cause them to test positive to the tuberculin skin test, the backbone of our bTB
control policy. This is the main reason for the EU ban on bTB vaccination in cattle. EU law
meets OIE standards for international trade. The OIE Terrestrial Manual 2012
41
advises
that cattle vaccination should not be used in countries where control or trade measures
based on tuberculin skin tests are in operation.
To use such a vaccine, a diagnostic test is required that can detect infected among
vaccinated animals (DIVA). Development of this DIVA test forms part of the ongoing
Defra-funded research programme and candidate diagnostic tests have been developed.
The most advanced is a modified version of the currently used interferon-gamma assay.
Following approaches from the Government, the European Commission acknowledged in
J anuary 2013 that the UK had invested considerable resources in developing a candidate
vaccine and accompanying DIVA test. The European Commission set out a tentative
timeline
42
of the steps to be able eventually to deploy a cattle bTB vaccine and associated
DIVA; cattle vaccination could only be deployed if it is demonstrably safe. These steps
include a field trial of the vaccine and DIVA test under EU conditions. Government
scientists are leading the world in developing a deployable cattle vaccine and have been
considering the design of a trial that will deliver the European Commissions objectives and
deliver the evidence necessary to secure a licensed cattle bTB vaccine and a validated
DIVA test. In 2013, EFSA published a scientific opinion
43
providing advice relating to the
design of field trials to test the performance of a cattle bTB vaccine along with a DIVA test.
Based partly on that advice, the Government has awarded a contract for field trial design
and is expecting this work to be completed by August 2014. The trial design work and
ongoing research is necessary to provide evidence to support an application for an Animal
Test Certificate to permit field trials of an otherwise unauthorised vaccine. Extensive field
trials are not expected to start until 2015. The cost of such trials is likely to amount to tens
of millions of pounds.
The European Commission estimated that it was unlikely that the EU ban on intra-EU
trade in bTB-vaccinated cattle would be lifted within ten years of successful trials starting;

41
Chapter 2.4.7, Bovine tuberculosis (version adopted May 2009) Manual of Diagnostic Tests and Vaccines
for Terrestrial Animals 2013 http://www.oie.int/international-standard-setting/terrestrial-manual/access-online/
42
Letter from European Commissioner for Health and Consumer Protection to the Secretary of State for
Environment, Food and Rural Affairs, 14 J anuary 2013 https://www.gov.uk/government/publications/bovine-
tb-eradication-programme-letter-from-the-european-commission-to-owen-paterson
43
EFSA AHAW Panel (EFSA Panel on Animal Health and Welfare) 2013. Scientific Opinion on field trials for
bovine tuberculosis vaccination. EFSA J ournal 2013; 11 (12): 3475, 35pp. doi:10.2903/j.efsa.2013.3475
http://www.efsa.europa.eu/en/efsajournal/pub/3475.htm

64
the European Commissions tentative timeline included the need to amend OIE animal
health standards for international trade.
The European Commission indicated that it might be possible to allow the vaccine to be
used under controlled conditions in the UK four to five years after successful trials started
but that bTB-vaccinated cattle would not be able to be traded within the EU until the wider
ban was lifted.
Research to develop other cattle vaccines (i.e. that are better than BCG or that do not
sensitise cattle to the tuberculin skin test) to improve the sensitivity of the DIVA test, and to
develop DIVA tests using alternative methods is ongoing but these are long-term goals
and will require scientific breakthroughs to achieve.
(ii) Badger vaccination
The Veterinary Medicines Directorate issued a marketing authorisation for an injectable
BCG-based TB vaccine for badgers (BadgerBCG) in 2010. There is scope to use data
from the English Badger Vaccination Deployment Project and the Badger Vaccination
Project in the Welsh Intensive Action Area
44
to understand better the long-term costs and
benefits of deploying injectable badger vaccination.
The Government has also invested considerable resources in ongoing research to identify
an effective and affordable oral badger TB vaccine which could make the vaccine much
simpler to deploy than the currently available injectable vaccine. Government scientists
have made progress in identifying a candidate edible bait. Further progress is dependent
on ensuring a consistent immune response to orally administered vaccine so it is not yet
possible to predict with any certainty when there will be a candidate vaccine which can be
taken forward for marketing authorisation. However, in the best case scenario an oral
badger TB vaccine might be deployable in the field by 2019. The Governments
independent vaccines advisory group (comprising vaccines experts from the human and
animal fields) has advised that additional investment would not accelerate the
development process.
Research into alternati ve strategies for dealing with risk of TB from badgers
In parallel to research to develop diagnostic tests to detect infected badgers and/or their
environment, consideration is being given to how such tests might best be used to support
the development, delivery and monitoring of strategies for dealing with the risk of M. bovis
from badgers, e.g. targeted culling, understanding local epidemiology, and monitoring the
effectiveness of badger vaccination at reducing infection. This work will inform where
future research and implementation effort should be targeted.

44
The Intensive Action Area in south west Wales is approximately 288 km
2
primarily located in north
Pembrokeshire but also including small parts of Ceredigion and Carmarthenshire. The five-year injectable
badger vaccination project is running alongside additional surveillance and controls for cattle and non-
bovines, and enhanced biosecurity. The project started in 2012.

65
Further research into alternative methods for dealing with the risk of M. bovis from badgers
(e.g. sett-based culling methods and non-lethal methods) has been considered. This
includes investigations into the use of gases such as carbon monoxide or anoxic gas-filled
foam as a sett-based means of humane culling. Anoxic gases are used humanely to cull
farmed animals such as pigs and poultry. The use of hydrogen cyanide gas to cull badgers
will not be considered.
The Government has also funded research into the application of fertility control using
contraceptives to manage badger populations. Two studies have looked at injectable
contraceptive, one in captive badgers and one in free-living urban badgers, and one study
has examined the potential to develop an oral contraceptive. This research is at an early
stage and it is not yet possible to assess the likely scale on which such an approach might
be deployed in future or the likely timescale.
The Government will continue to review evidence emerging from badger control strategies
and research in place elsewhere. For example, the Republic of Ireland Government has
operated focussed badger culling since 2000. Badgers are captured under licence by
trained contractors using specially designed body restraints and then killed, in areas where
serious outbreaks of bTB have been detected in cattle herds and an epidemiological
investigation has found that badgers are the likely cause of infection. In Northern Ireland,
the Department for Agriculture and Rural Development is proposing a five-year Test,
Vaccinate and Remove (TVR) research project starting in summer 2014. The research
would involve trapping and testing badgers in one or more 100 km
2
areas: badgers testing
positive for TB would be killed; badgers testing negative would be vaccinated and
released. A further 100 km
2
area would serve as a control. The limitations of tests on live
badgers and of the injectable badger vaccine are discussed elsewhere.
Research into genetic resistance of cattle to bTB
In the UK there is no clear evidence of differences between breeds in terms of
susceptibility to bTB. While there is evidence that dairy farms are more likely to experience
a breakdown than beef farms, this is not necessarily due to breed differences.
Pedigree analysis funded by Defra has shown evidence of genetic variation to bTB
susceptibility within Holsteins in the UK. Another study identifying genetic markers linked
to susceptibility saw no significant differences in the distribution of these markers across
UK breeds. Dairy Co has advised that it expects to be able to select Holstein bulls with
resistant genes in 2015 so their daughters would enter the milking herd from 2018. While
Dairy Co expects this to improve the resistance of the Holstein herd to bTB over the next
decade, it notes that it is unlikely that any animal has full genetic resistance so genetic
selection would need to be combined with other measures in order to achieve OTF status.
The Government believes that it is for cattle farmers to make business decisions on which
bulls they choose to use, taking into account genetic merit for resistance to diseases and
other desirable traits which may or may not be correlated with bTB susceptibility.
Why we do not use therapeutics to treat bTB in cattle

66
Therapeutic treatment of cattle to control bTB is prohibited under EU law as it is not
compatible with the provisions for testing and herd qualification for OTF status. There are
no drugs licensed in the UK for the treatment of bTB in animals.
To date, antimicrobial therapy of cattle believed to be infected with M. bovis has not been
a realistic option for the reasons set out below.
Treatment of TB with antibiotics is not universally successful, even in humans receiving
multiple drug therapy for several months.
M. bovis is naturally resistant to one of the first-line drugs used for the treatment of TB
in humans. In order to eliminate the risk of antibiotic-resistant strains of M. bovis
infecting the human population, where multiple-drug resistant strains of M. tuberculosis
are already a significant public health problem, it is critical to ensure that such strains of
M. bovis are not artificially selected in animal populations.
Most drugs used to treat TB in humans are inherently toxic and are poorly tolerated by
animals.
Therapeutic treatment of cattle for bTB would interfere with the detection of infected
animals, by suppressing the immunological reactions that are measured by the
tuberculin skin and interferon-gamma tests.
During treatment it would be necessary to consider infected cattle contagious for the
duration of treatment and to observe milk and meat withdrawal times during and
following treatment.
Governance, delivery and funding
The Government will develop proposals for governance, delivery and funding of the
Strategy in partnership with stakeholders. It will consult further on detailed proposals and
carry out impact assessments as appropriate. Any changes to governance or delivery
would need to comply with EU
45
and national law and take account of government policies
on public bodies
46
and wider impacts on the governments capability to respond to animal

45
Regulation (EC) No.882/2004 on official controls performed to ensure the verification of compliance with
feed and food law, animal health and animal welfare rules. On 6 May 2013, the European Commission
adopted a proposal to amend this legislation. The package is subject to consideration by the European
Parliament and the Council with possible entry into force in 2016, followed by a proposed three-year
transition period. http://europa.eu/rapid/press-release_IP-13-400_en.htm

46
Cabinet Office (2012) The approval process for the creation of non-departmental public bodies
https://www.gov.uk/government/publications/public-bodies-information-and-guidance

67
disease outbreaks. Any changes to funding would need to comply with HM Treasury rules
on managing public money
47
.
Governance
Defra Ministers have policy responsibility for bTB policy in England. In 2011, the
Government established the Animal Health and Welfare Board for England (AHWBE) in
response to the recommendations of the England Advisory Group on Responsibility and
Cost Sharing
48
. The AHWBE is the principal source of Departmental advice to Defra
Ministers on all strategic health and welfare matters relating to kept animals in England
49
.
It comprises appointed external members with the confidence and support of major
stakeholder interests, and senior government officials. The AHWBE is an innovative
approach to bringing those affected by government decisions into the heart of the process
in order to create a more direct link between those making Defra policy and those
experiencing the delivery of that policy. Establishing the AHWBE marked an important step
in sharing responsibility for animal health and welfare with animal keepers and other
interested parties. It aims to build trust between government and animal keepers and
strengthen arrangements for working together to develop a true partnership. Agreement on
how best to achieve practices that collectively and cost effectively reduce disease risk
leads to greater adherence to responsible practices and then to reduced animal disease
risk and improved standards of health and welfare. This benefits government, the public
and animal keepers. The Bovine Tuberculosis Eradication Advisory Group (TBEAG) is an
AHWBE sub-group, which brings together a range of interested parties who share the
desire to tackle bTB. This Strategy has been developed in partnership and discussion with
TBEAG.

The New Zealand experience shows that alternative governance and delivery models can
enhance bTB control. The New Zealand government has delegated management of the
National bTB Pest Management Plan, which is defined in law, to an industry-led
management agency
50
under the Biosecurity Act 1993. The management agency supports
a number of TBfree Committees to maintain effective links with the farming community and
stakeholders at a regional level. The TBfree Committees promote the programme in their
regions and are a source of feedback and advice to the management agency on policy
and operational issues. The National bTB Pest Management Plan budget has been co-

47
HM Treasury (2013) Managing Public Money (PU 1513)
https://www.gov.uk/government/publications/managing-public-money
48
Defra (2010) Responsibility and Cost Sharing for Animal Health and Welfare Final report (PB 13450)

49
Further information about the Animal Health and Welfare Board for England is available at
https://www.gov.uk/government/policy-advisory-groups/animal-health-and-welfare-board-for-england-ahwbe

50
On 1 J uly 2013, the role of management agency for New Zealands National Bovine Tuberculosis Pest
Management Plan transferred to a limited-liability company, TBfree New Zealand Limited
http://www.biosecurity.govt.nz/media/14-06-2013/new-agency-national-tb-management-plan

68
financed by industry and government with funding from central and local government,
statutory beef and dairy sector levies and deer sector grants
51
. The Government will
develop proposals for an enhanced partnership approach to the governance of the
Strategy in England.
Delivery
Delivery of bTB controls rests with government agencies such as AHVLA, local authorities
and the private and voluntary sectors e.g. veterinary and farming businesses, and wildlife
interest groups. Delivery approaches include services funded and provided by
Government, services funded by government and procured from the private and voluntary
sectors, and services funded and provided by the private and voluntary sectors.
The Government will continue to review delivery of bTB controls, ensuring a partnership
approach with government (i) delivering those services that only it can deliver, building on
the efficiency savings delivered to date whilst ensuring quality; and (ii) ensuring that any
services provided by the private sector and funded by government are procured in line with
legal requirements with robust contracts and effective audit to deliver value for money and
ensure quality services.
The veterinary profession is a key delivery partner for bTB controls. The Government will
develop a modern commercial relationship with private veterinary businesses delivering
bTB testing and controls. The Government will explore ways in which private veterinary
businesses can deliver local services currently delivered by government (the so-called TB
Plus model) in line with AHVLAs Veterinary and Technical Strategy
52
and mindful of the
outcome of the Welsh Governments Cymorth TB pilots due for completion in April 2014.
Funding
Tackling bTB carries significant costs to farmers and other taxpayers. These costs are not
sustainable. At the same time, it is clear that additional investment is required to bring the
disease under control and reduce the costs in the longer term. Furthermore, the
Government must demonstrate value for money in public funding as well as acting where
there are clear advantages and a need for government intervention to overcoming market
failure. Table 6 provides the breakdown of state-funded and privately funded areas in
2013/14.

51
Further information is available at http://tbfree.org.nz/
52
AHVLA (2013) Veterinary and Technical Strategy Securing a healthy future
http://www.defra.gov.uk/ahvla-en/publication/vet-tech-strategy/

69
Table 6 Breakdown of state-funded and privately-funded areas in 2013/14
State-funded areas Privatel y-funded areas
Routine bTB surveillance testing and
breakdown testing, mainly delivered by
veterinary businesses
Laboratory testing (e.g. bacterial culture and
gamma-interferon blood testing)
bTB breakdown investigations
Procuring transport and disposal of bTB
reactors
Statutory compensation for bTB reactors
(above the minimum carcase salvage value)
Badger Vaccination Deployment Project and
Badger Vaccination Fund
bTB research and development
Advice and guidance
Competent Authority functions (including
policing)
Handling facilities, staff and time away from
business for bTB testing
Pre-movement testing and export testing
TB testing of deer
Consequential losses (e.g. from movement
restrictions and compulsorily slaughtered
cattle)
Biosecurity measures (e.g. badger proofing
or double fencing)
Local badger vaccination deployment
Advice and guidance
Deployment of badger culling licensed by
Natural England
Costs of slaughter of TB infected non-bovine
animals (e.g. goats) without compensation
For the costs which fall to government, the budgetary pressure is expected to increase
through a combination of increasing costs and declining budgets; EU financial support at
current levels is not guaranteed to continue indefinitely.
Most of the Governments bTB budget is spent on bTB testing, breakdown management
and compensation. Almost 80 percent of testing and compensation costs are related to
managing bTB breakdowns. The cost of breakdowns is concentrated in a minority of
affected herds: about 40 percent of breakdown costs arise in 10 percent of breakdown
herds. Actions that significantly reduce the likelihood, duration and extent of these
breakdowns would have a major effect in reducing the overall cost of bTB management.
Farmers also bear financial costs of bTB both in terms of taking steps to minimise risk and
also when a breakdown occurs. These financial costs can be significant to individuals.
The Government aims to build a framework of modelling tools which could support the
production of a reliable estimate of cost of achieving OTF status for England; this will
require a credible assessment of the impact of policy options some of which are many
years away.

70
The Government will develop proposals for a sustainable model for funding the Strategy in
partnership with stakeholders. The experiences of both New Zealand and the Republic of
Ireland provide evidence of the success of co-financed bTB control strategies. Irish
farmers are responsible for arranging annual herd bTB tests with their veterinary
practitioners and for payment of testing fees. They also contribute towards 50 percent of
the cost of the bTB compensation via statutory Bovine Disease Levies collected in respect
of each animal slaughtered or exported from the country, and in respect of each unit of
milk delivered to creameries.
Funding options for the Strategy could include stakeholders paying more for bTB
measures such as bTB testing and deployment of cattle and badger vaccination;
government reducing its intervention in the market in terms of levels of compensation
payable; developing insurance options in partnership with the insurance sector; and the
establishment of a mutual bTB control fund co-financed by government and industry. While
any new compulsory contribution (i.e. charge) would need to ensure commensurate
benefits for those paying, access to additional services could provide an incentive for
farmers to contribute to a mutual fund.
The Government will keep bTB compensation and the funding of bTB testing under review;
savings to government could be redistributed to fund preventative measures, e.g.
transitional financial support for measures to reduce the risk of TB from badgers.
Failure to ensure a sustainable funding model will limit the future development and
deployment of full range of new tools.
Monitoring and evaluation of the Strategy
Figure 12 illustrates the monitoring and evaluation that can be applied to various strands
of the Strategy. It is a critical part of measuring progress made towards the stated aim
(and the various targets, outputs and activities that lead toward it) and allows action to be
taken as and when the disease situation changes and alternative approaches become
available.
The Government will monitor and evaluate the progress of the Strategy in line with best
practice
53
. In particular, focus will be placed on progress and delivery of the specified
targets and outputs that work toward the overall aim of OTF status for England. The
correct tools must be used to monitor and evaluate the effectiveness of the Strategy,
including epidemiological, economic and social analyses. The use of epidemiological
expertise is particularly important to inform ongoing decisions on tackling disease
appropriately at national, regional and local levels.

53
HM Treasury (2011) The Magenta Book - Guidance for evaluation (PU 1120)
https://www.gov.uk/government/publications/the-magenta-book

71
Figure 12 Logic chain
RESOURCES / INPUTS
Includes:
Key documents
Organisations, partners
and stakeholders
Defra and Agency
resources
MONITORING EVALUATION
SUMMARY OF LOGIC CHAIN FOR MONITORING AND EVALUATION OF STRATEGY
ACTIVITIES
Includes:
Surveillance activities
Control measures
Other interventions
Monitoring, for example of
disease, costs, behaviours
OUTPUTS
Includes:
Targeted, area and risk
based strategies
Compliance with EU law
Delivery of control and
other measures to
required amounts
Delivery of other
interventions
Sustainable funding base
Up to date data and
information
IMPACTS
Includes:
Environmental e.g.
Sustained reduction in
disease (to achieve OTF
status)
Economic e.g. reduction in
overall costs and a
sustainable industry
Social e.g. public
understanding
OUTCOMES
Delivery of stated aim i.e.
OTF for England
For example:
What impact has the delivery of the policy had?
Has the policy delivered its stated aim?
Was the actual impact and outcome as expected?
Does anything else need to happen?
What lessons are learnt?
For example:
Monitoring who is involved in delivering the policy
Tracking progress against targets and the health of the industry
Monitoring progress with the implementation and delivery of activities and measures
Collection, analysis and review of data and information
Monitoring the outputs that are produced
Monitoring costs on affected parties

Key tools include using the best available data to review the impact in terms of:
The health and sustainability of the sector
Media coverage and social impacts
Behaviours and attitudes of farmers and the public
Trade patterns, for example the number of cattle exported
Monthly laboratory testing result reports
M. bovis genetic typing home range alert system
Quarterly and annual epidemiological reports from regions
Monthly publication and analysis of national bTB statistics
Quarterly publication and analysis of non-bovine TB statistics
Annual surveillance reporting and associated analysis of outcomes
The Strategy will be carefully monitored and fully evaluated and the approach and forward
use of the tools will be adapted based on experience in the field and as new tools become
available. The Strategy will be regularly reviewed and refreshed accordingly.

72
Glossary
AFU Approved Finishing Unit, a biosecure unit used to channel cattle from bTB
restricted herds to slaughter
AHVLA Animal Health and Veterinary Laboratories Agency, an executive agency of
Defra
AHWBE Animal Health and Welfare Board for England
BCG Bacillus Calmette-Gurin, which is used to manufacture tuberculosis vaccines
Biosecurity security from transmission of infectious diseases
Bovine tuberculosis an infectious disease in cattle caused by Mycobacterium bovis
Breakdown detection of exposure to M. bovis infection in a herd (e.g. detection of a bTB
reactor or signs of possible bTB at post mortem). This is followed by breakdown control
procedures; the duration of a breakdown depends on the successfulness of the breakdown
measures to clear the infection from the herd
bTB bovine tuberculosis
Check tests cattle herd tuberculin skin tests carried out for a number of reasons,
including determining the herd disease status when there is a suspicion of infection, within
potential hotspot areas which have previously been free of TB, and for new or re-formed
herds.
CTS Cattle Tracing System, the national cattle identification and movements database
Defra Department for Environment, Food and Rural Affairs
Depopulation slaughtering all the animals in a herd for disease control purposes
DIVA a test used to detect infected among vaccinated animals
ECDC European Centre for Disease Prevention and Control
Edge Area the edge of the HRA where the disease is not yet considered to be endemic
and disease prevalence is lower than in the HRA but there is a great likelihood of further
geographical spread of bTB out of the HRA
EFSA European Food Safety Authority
Endemic a disease which is typically present in a specific geographical area
Epidemiology a study of disease in a population

73
EU European Union
Fera Food and Environment Research Agency, an executive agency of Defra. Feras
Wildlife Team transferred to AHVLA in April 2013
FSA Food Standards Agency
GB Great Britain, comprising England, Wales and Scotland
Genotype a genetically distinct strain of a specimen or species
Herd prevalence can be expressed in different ways but depicts the proportion of herds
that are affected by a disease/condition in a defined area
High Risk Area for bTB an area defined geographically in which cattle herds have a
greater likelihood of experiencing a bTB breakdown. It includes geographical areas in
which there is a relatively high herd prevalence of bTB
Home range the specific geographic area where a specific genotype of M. bovis is
typically detected
Host animals which can routinely become infected with M. bovis if exposed
HRA see High Risk Area
Incidence reflects the number of cases of infection or disease.
Inconclusive reactor an animal which gives an inconclusive reaction to the tuberculin
skin test as defined in Council Directive 64/432/EEC
Index the first infection in a herd or area.
Interferon Gamma Assay - a rapid (24 hour) whole blood in-vitro assay to detect immune
response to M. bovis infection for the diagnosis of bTB
IR see Inconclusive reactor
ISG Independent Scientific Group, which supervised the Randomised Badger Culling
Trial
Lesions Characteristic tubercles or larger abscess-like structures typically found in
lymph nodes and organs such as the lungs, liver and spleen.
Low Risk Area - An area defined geographically in which cattle herds have a lower
likelihood of experiencing a bTB breakdown. It includes geographic areas with very low
herd prevalence of bTB and where the disease is not believed to be maintained by
badgers and is primarily caused by cattle movements
LRA see Low Risk Area

74
MAFF Ministry of Agriculture, Food and Rural Affairs, replaced by Defra in 2001
Mycobacteria a family of bacteria which includes Mycobacterium bovis
Mycobacterium bovis (M. bovis) the bacterium which causes bovine tuberculosis
Mycobacterium tuberculosis (M. tuberculosis) one of the bacteria which causes
tuberculosis in humans
Natural England - an executive non-departmental public body responsible to Defra, which
administers applications for licences under the Protection of Badgers Act 1992
OIE World Organisation for Animal Health
OTF Officially Bovine Tuberculosis Free as defined in Council Directive 64/432/EEC.
OTF status may apply to herds, regions or Member States
OTFS Officially Bovine Tuberculosis Free status of herd suspended as defined in
Council Directive 64/432/EEC. This definition has been used for cattle herds where the
laboratory culture result is not positive for M. bovis but there is an increased likelihood that
the animal was infected
OTFW Officially Bovine Tuberculosis Free status of herd withdrawn as defined in Council
Directive 64/432/EEC. This definition has been used for cattle herds where typical lesions
of TB are found in a carcase of an animal and/or the laboratory culture result is positive for
M. bovis
OV Official Veterinarian, a private veterinarian permitted to undertake official controls
such as tuberculin skin testing
PCR See Polymerase Chain Reaction
Perturbation - disruption of badger social groups causes badgers to range more widely
than they would normally and come into contact more often with other animals (including
both cattle and other badgers). This is called perturbation
Pol ymerase Chain Reaction - technology to amplify a single of a few copies of a piece of
DNA in order to allow easier detection of a particular pathogen by its DNA
Post Movement Test a tuberculin skin test applied to an animal after it has moved
between premises
Pre Movement Test a tuberculin skin test applied to an animal before it has moved
between premises
Prevalence see Herd Prevalence
R&D research and development

75
RBCT Randomised Badger Culling Trial, a scientific study carried out from 1998-2005 to
quantify the impact of culling badgers on TB incidence in cattle
Reactor an animal which gives a positive reaction to the tuberculin skin test as defined
in Council Directive 64/432/EEC
Reservoir Host animals which can routinely harbour M. bovis infection
Routine herd testing the programme of routine surveillance testing of breeding cattle in
herds using the tuberculin skin test in line with Council Directive 64/432/EEC. Routine herd
testing is applied to four-yearly tested herds
RTA road traffic accident
SAC South American camelids, for example alpacas and llamas
Severe interpretation a more rigorous interpretation of the tuberculin skin test (than the
standard interpretation) in line with Council Directive 64/432/EEC
Short interval test the intensive testing of all cattle in breakdown herds using the
tuberculin skin test in line with Council Directive 64/432/EEC
SICT single intradermal cervical test. See tuberculin skin test
SICCT single intradermal comparative cervical test. See tuberculin skin test
SOA Sole Occupancy Authorities approved by AHVLA consist of a group of holdings
under the same farm management and control. Movements among holdings within a SOA
are not subject to the standstill restrictions that normally apply to livestock movements.
Spillover Host animals which do not normally become infected with M. bovis unless
they are exposed to relatively high levels of infection
Standard interpretation the routine interpretation of the tuberculin skin test in line with
Council Directive 64/432/EEC
Surveillance an effort to detect disease in a population by using diagnostic or clinical
methods. For bTB in England, formal surveillance is carried out with frequent whole or
routine herd testing, by pre-movement testing of all cattle over 42-days of age leaving
premises in the HRA and by inspecting all cattle carcases slaughtered commercially for
post mortem signs of bTB
TBEAG Bovine Tuberculosis Eradication Advisory Group for England, a sub-group of
AHWBE
Test Interval the period of time between tuberculin skin tests
Therapeutics pharmaceutical agents (drugs) licensed for use in treating human or
animal diseases

76
Tuberculin mycobacterial proteins used in tests to detect bovine tuberculosis
Tuberculin skin test measuring an animals reaction to injections of tuberculin carried
out in line with Council Directive 64/432/EEC. The single intradermal cervical test involves
a single injection of bovine tuberculin in the neck; the single intradermal cervical
comparative test involves single injections of bovine and avian tuberculin in the neck
UK United Kingdom, comprising Great Britain and Northern Ireland
VMD Veterinary Medicines Directorate, an agency of Defra
Whole herd testing the testing of all cattle in herds using the tuberculin skin test in line
with Council Directive 64/432/EEC. Whole herd testing is applied routinely to annually
tested herds and to breakdown herds

77
Annexes
Annex A Badger controls and population
Table 7 A chronology of badger controls
1971 M. bovis first isolated in badgers
M. bovis first isolated in a badger in Gloucestershire.
1973 The Badgers Act
Made it an offence to take, injure or kill badgers and commit offences of
cruelty.
1975-82 Gassing strategy
By 1975 there were concerns about the lack of controls on who could kill
badgers, so MAFF decided that only its own staff, or people under its control,
could cull. Gassing using hydrogen cyanide was permitted under The
Conservation of Wild Creatures and Wild Plants Act 1975.
1980 Zuckerman Review
Concluded badgers were probably a significant source of bTB infection and
that high density and close proximity of cattle and badgers in parts of South
West England made disease spread easy. Because disease seemed to have
spread since controls stopped at the start of the review, it advised that control
measures start again. As gassing was considered inhumane, cage trapping,
followed by shooting, became the culling method.
1982-86 Clean-ring strategy
Zuckerman advised that areas should be cleared of infected badgers and kept
clear. Under this strategy, social groups of badgers on and around breakdown
farms were identified, trapped and a sample of carcases from these groups
were examined. Where infection was found, all badgers in the social group
were removed. The ring extended out until groups with uninfected badgers
were found. Trapping took place in the cleared area for a further six months to
keep the area clean.
1986 Dunnet Review
Concluded that some form of badger control was unavoidable. Recommended
the use of an interim strategy until there was sufficient data from research and
badger removal operations for a further substantive review, and development

78
of a reliable live diagnostic test for TB in badgers.
1986-96

Interim strategy
Removal and culling of badgers only from farms where a bTB incident had
been confirmed and where, following investigation, it was thought that badgers
were the most likely cause of the disease. During the operation of the interim
strategy, the annual incidence of bovine TB increased in south west England
and occurred in other areas with no recent history of infection, including the
West Midlands and south Wales.
1991 The Badgers (Further Protection) Act
Conferred additional powers on a Court, where a dog had been used in or was
present at the commission of certain offences under the Badgers Act 1973.
1992 The Protection of Badgers Act
Consolidated and built on the 1973 & 1991 Acts. Made it a serious offence to
kill, injure or take a badger, or to damage or interfere with a sett unless a
licence is obtained from a statutory authority.
1994-96

Live test strategy
Trial of live badger diagnostic test, stopped due to poor sensitivity of test and
problems with trial.
1997 Krebs Review
Concluded that despite there being compelling evidence badgers were
involved in transmitting M. bovis to cattle, the development of a control policy
was made difficult because the effectiveness of badger culling could not be
quantified with the data available. Recommended a large-scale field trial be
set up to quantify the impact of culling badgers on incidence of TB in cattle,
and to determine the effectiveness of strategies to reduce the risk of a TB
cattle herd breakdown.
1998-2005 Randomised Badger Culling Trial (RBCT)
Saw both beneficial and detrimental effects of culling during culling period.
Hypothesised that culling disrupts badger behaviour to increase ranging and
therefore potential for infectious contact (perturbation) increasing disease
prevalence in badgers and subsequently that in cattle (the perturbation
effect). On-going post-trial analysis showed that once culling stopped, the
detrimental effects diminished quickly.
2013 Pilot of Badger Control Policy
Licensed badger culling pilots in Somerset and Gloucestershire to assess the

79
humaneness, effectiveness (in terms of badger removal) and safety of
controlled shooting of free-ranging badgers in year one. Licences also permit
cage trapping and despatch. Each licence has a four-year term. No control
operations can take place during specified close seasons.
Changes in the British badger population
Harris et al (1992)
54
concluded that there were approximately 250,000 adult badgers in
Britain in the 1980s with 172,000 cubs born each year. Annual adult mortality was
estimated to be approximately 61,000 animals, annual cub mortality 64,500 pre-
emergence and 41,500 post-emergence. The greatest single known cause of badger
mortality was road deaths (about 50,000 animals a year) with approximately 10,000 killed
illegally and 1,000 killed each year to control bTB. Defra funded a badger sett survey of
England and Wales in 2011-2013 (Defra Project SE3129) and a project to generate
estimates of typical badger social group size in different landscapes (Defra Project
SE3132). The badger sett survey estimated that the number of badger social groups in
England had more than doubled (from 31,500 +/- 3,900 to 64,000 +/- 5,000) since the
previous comparable survey was carried out in 1985-1988
55
. The social group size survey
will report results in summer 2014, allowing updated estimates of the total population of
badgers in England and Wales to be made.
J udge et al (2014) concluded that the implications of increasing badger populations are
numerous as badgers are the largest terrestrial carnivore in the British Isles. They eat
mainly soil invertebrates but will also prey upon ground nesting birds, hedgehogs and
other vertebrates. Evaluation of the ecological impact of badger culling during the RBCT
identified an increase in fox abundance associated with reductions in badger density while
reciprocal relationships between hedgehog and badger distributions suggest that
increasing badger numbers might have had a negative impact on hedgehogs.

54
Harris, S., Cresswell, W., Reason, P. and Cresswell, P. (2001) An integrated approach to monitoring
badger (Meles Meles) population changes in Britain. Wildlife 2001: Populations. Special Session 9. Pages
945-953. DOI: 10.1007/978-94-011-2868-1_72
55
J udge, J ., Wilson, G.J ., Macarthur, R., Delahay, R.J . & McDonald, R.A. Density and abundance of badger
social groups in England and Wales in 20112013. Sci. Rep. 4, 3809; DOI:10.1038/srep03809 (2014).

80
Annex B Enhancements of cattle measures since 2011
Table 8 Enhancements of cattle measures since 2011
2011 Introduced DNA tagging of bTB reactors to ensure they are
removed from farms.
2012 Reduced statutory bTB compensation for owners of herds with
overdue tests.
Tightened pre-movement testing rules including amendments to
exemption for movements to shows and movements between
holdings within the same Sole Occupancy Authority (SOA).
Banned new SOAs and applications to add new holdings to existing
SOAs.
Phased removal of Cattle Tracing System (CTS) links between
holdings in one/two-yearly testing parishes and holdings in
three/four-yearly testing parishes.
Banned new Approved Quarantine Units which sourced calves from
TB breakdown herds with existing Units closed by the end of 2013.
2013 Adopted county-based routine bTB surveillance testing with
significant extension of annual testing to herds in High Risk/Edge
Areas and four-yearly testing of herds in Low Risk Area.
Introduced radial testing of all herds within 3km of a lesion/culture
positive bTB breakdown herd in the Low Risk Area.
Cattle movements into non-lesion/culture positive bTB breakdown
herds only permitted after the first post-breakdown test and subject
to a satisfactory veterinary risk assessment (to align with policy for
lesion/culture positive bTB breakdown herds).
Pre-movement testing window for movements from bTB restricted
herds reduced from 60 to 30 days.
Increased auditing of Approved Finishing Units (which send cattle
to slaughter) and enhanced sanctions for non-compliance
Introduced risk-based bTB testing in Approved Finishing Units with
higher testing burden remaining in Units with grazing.
Enhanced the quality assurance programme for Official Vets
carrying out bTB testing.
Phased removal of CTS links between High Risk and Edge Areas.

81
Rolled-out a voluntary risk-based trading scheme in livestock
markets.
Introduced requirement for two consecutive clear herd tests (rather
than one) at severe interpretation for non-lesion/culture positive
bTB breakdown herds in Edge Area before restrictions lifted.
2014 Introduced mandatory parallel interferon-gamma assay for
lesion/culture positive bTB breakdown herds in Edge Area;
discretionary for non-lesion/culture positive bTB breakdown herds in
Edge Area.
Introduced radial testing of all herds within 3km of a lesion/culture
positive bTB breakdown herd in the Cheshire and Derbyshire Edge
Area.
Reduced Common Agricultural Policy Scheme payments for
overdue bTB surveillance or check tests.
Enhanced the approach for dealing with persistent bTB
breakdowns.
Introduced powers to remove cattle which are unable to be tested
for bTB.
Tightened pre-movement testing rules by removing exemption for
movements to and from common land.












82
Annex C Sources of evidence
Natural science
The following paper describing a project to provide a succinct summary of the natural
science evidence base relevant to the control of bTB is published in the Proceedings of the
Royal Society Biology http://rspb.royalsocietypublishing.org/
Godfray, H.C.J. et al. (2013) A restatement of the natural science evidence base
relevant to the control of bovine tuberculosis in Great Britain. Proc. R. Soc. B. 2013
280 1768 20131634; doi:10.1098/rspb.2013.1634 (published 7 August 2013) 1471-
2954
The project was commissioned and funded by the Oxford Martin School (part of the
University of Oxford) and though many groups were consulted, the project was conducted
completely independently of any stakeholder. Further information is available at
http://www.futureoffood.ox.ac.uk/news/bTBevidence
Socio-economic science
The following paper was authored by Professor Richard Bennett and Ian MacFarlane at
the University of Reading and Dr Gareth Enticott of Cardiff University.
Bennett, R.M. et al. Socio-economic science relevant to the control of bovine
tuberculosis in cattle. Report prepared for Defra, July 2013.
Surveillance reports
The Governments Bovine TB surveillance reports are available at
http://www.defra.gov.uk/ahvla-en/publication/pub-survreport-tb/
Statistical reports
The Governments Bovine TB statistical reports are available at
https://www.gov.uk/government/collections/bovine-tb

83
Annex D Bovine tuberculosis in Europe
Figure 13: Official bovine tuberculosis status of EU member states in April 2012

(Source: European Commission Annual Report Bovine and Swine Diseases 2012)
Table 9 EU member states declared officially bovine tuberculosis free in Commission
Decision 2003/467 (as amended) in 2014
Belgium Estonia Luxembourg Slovenia
Czech Republic France Netherlands Slovakia
Denmark Hungary Austria Finland
Germany Latvia Poland Sweden
Table 10 EU member states with specific regions (number) declared officially bovine
tuberculosis free in Commission Decision 2003/467 (as amended) in 2014
Italy (12) Portugal (1) United Kingdom (1)

84
Annex E Defras bovine tuberculosis research programme
Background
Defra has funded a wide-ranging bTB research and development programme including:
The development of a vaccine for bTB (for potential use either in cattle or badgers);
Developing improved diagnostic techniques (both for bTB in cattle and badgers);
Epidemiological studies on factors influencing the prevalence and persistence of the
disease in cattle and wildlife;
Analysis of data from the Randomised Badger Culling Trial & associated research;
Investigating transmission routes between and within species;
Investigating risk factors contributing to the development of the disease in cattle; and
Economic, epidemiological and social scientific analyses of bTB control strategies and
impact of the disease.
Between 1991/92 and 2012/13 Defra and its predecessor MAFF, funded over 110
individual research projects and invested approx 108 million in its bTB R&D programme
plus a further 49 million on the Randomised Badger Culling Trial (RBCT). Defras Animal
Health and Welfare research budget covers England, Wales and Scotland.
Research spend by scientific area
Figure 14 shows the research expenditure in the following scientific areas (excluding the
RBCT) since 1991.
Ecology and Husbandry
Epidemiology, Economics and Modelling
Pathogenesis/Genomics/Immunology
Cattle Vaccines
Badger Vaccines
Cattle Diagnostics
Badger Diagnostics
General Diagnostics (those projects which cover badgers and cattle and/or other
species)

85
Figure 14: Defra bTB research spend by scientific area to 2012/13

Further information on Defra-funded research projects is available at
http://randd.defra.gov.uk