Consultation outcome

Summary of responses and government response

Updated 5 November 2018

1. Introduction

This document summarises responses to Defra’s public consultation on extending the use of para-veterinary professional Approved Tuberculin Testers (ATTs) to perform tuberculin skin testing of cattle in England, which ran from 24 July 2017 to 7 September 2018. Defra received a total of 63 responses to the consultation. 60 were via the Citizen Space portal and 3 were emailed to the bTB engage mailbox.

39 responses were received from individuals and 24 were from organisations. The organisations are listed in Annex A.

A summary of the consultation responses is included in section 3 and section 4 sets out the government’s plans going forward.

Copies of the responses (with the exception of those where the respondent requested that their response should not be released) can be obtained from:

Cattle Measures Team
Defra, Bovine TB Programme
Area 5D Nobel House
17 Smith Square
London SW1P 3JR

2. Background

Bovine TB is one of the most significant animal health threats to cattle keepers in England. The government is committed to delivering the 25 year strategy for achieving Officially Bovine Tuberculosis Free status for England by 2038. The timely testing of cattle herds is a key disease control measure and an important part of that strategy.

Currently most bovine TB testing in England is carried out by veterinary surgeons working for Veterinary Delivery Partners (VDP) under contract to APHA. The consultation set out a proposal to extend the use of ATTs in England so that private veterinary businesses would have the option of deploying them to carry out some TB skin tests.

3. Summary of responses

Q1. Do you consider that the use of suitably trained, competent ATTs as part of a veterinary led team in private veterinary practices to carry out TB skin testing is an acceptable option within the current TB surveillance regime?

All 63 respondents answered this question. The breakdown of responses is:

Agree – 65% Disagree – 33% No view – 2% Not answered – 0%

Most respondents, including a number of representative groups, agreed with this proposal although some attached caveats. The National Farmers’ Union (NFU) said:

…veterinary engagement is integral to the success of the proposal’ and ‘success of the proposal is totally reliant on the ATT having sufficient expertise and experience.

And the British Veterinary Association/British Cattle Veterinary Association (BVA/BCVA) said

Expanded use of ATTs could mean better utilisation of veterinary surgeons’ but emphasised the importance of having adequate “regulation” and “safety training” for the ATTs.

The National Beef Association (NBA) felt that the proposal would help ensure “timely” testing is provided. And the Royal Society for the Prevention of Cruelty to Animals (RSPCA) agreed with the proposal provided training was in place to achieve the same level of competency for ATTs as the OVs.

12% of respondents who agreed with the proposal suggested that veterinary nurses would be suitable ATTs.
A number of the minority who disagreed with the proposal felt that the government’s primary objective in proposing the increased use of ATTs was to cut costs and that there would be a reduction in the wider on-farm benefits of having vets perform all tests.

One respondent commented:

Vets can potentially pick up on other health problems when testing.

Others questioned whether adequate quality assurance would be in place and were concerned about the professionalism of ATTs.

Veterinary supervision

Q2.What would you consider would be the maximum number of ATTs that any single AVS could supervise:

2a. to the required level in training?

2b.have oversight of once qualified?

55 respondents answered 2a and 52 responded to 2b. Out of those that made specific suggestions the breakdown of responses is that the maximum should be:

Maximum number of ATTs that a single AVS can supervise to the required level in training (2a)

Maximum number	0	1	2	3	5	4	8	10	12	15	No maximum
Percentage	17%	15%	17%	9%	13%	4%	4%	7%	4%	3%	3%

Maximum number of ATTs that a single AVS can have oversight of once qualified (2b)

Maximum number	0	1	2	3	4	5	6	8	10	12	15	20	25	No maximum
Percentage	13%	7%	4%	7%	9%	22%	7%	2%	13%	4%	2%	4%	4%	2%

Less than half of those who answered 2a and 2b provided additional comments to support their response. One respondent who suggested a maximum of 2 ATTs for 2a and 5 ATTs for 2b said:

The number of ATTs supervised by a single AVS would depend on a number of factors, including practice size and geographical location.

This was a view echoed by the NBA who felt that numbers should be restricted to 3 or 4 whilst ATTs are being trained to ensure farmer confidence and once qualified it would depend on the size of the veterinary practice. In terms of numbers of ATTs, the NFU felt it would be a matter for the veterinary profession to agree with Defra, adding:

The focus should always be on providing sufficient supervision to ensure that the testing is carried out in a timely, professional and accurate manner and that standards remain consistently high pre-and post-qualification.

The BVA/BCVA commented:

The proposed pilot project should be developed to inform the maximum figures.

Test types

Q3. Are there are types of TB tests that you believe ATTs should not be permitted to carry out and why?

63 respondents answered this question. The breakdown of responses is:

Yes - 51% No – 41% No view – 8%

39% of respondents who answered yes thought that ATTs should not be permitted to carry out any type of TB testing with one respondent saying:

There are no tests that should be regarded as “less important

A number of respondents said that ATTs should not be authorised to carry out tests for EU export purposes or tests that could potentially result in a herd regaining Officially TB free status following a TB breakdown test. Other tests that respondents didn’t think ATTs should be allowed to perform included retesting of inconclusive reactors (IRs) and those for herds on four yearly surveillance testing.

Representative organisations who supported the principle of ATTs being permitted to carry out all types of TB tests included the NFU, BVA/BCVA, RSPCA and NBA. The NFU said that beyond intra-EU trade it was unnecessary to restrict the types of tests eligible for ATTs to undertake.

The BVA/BCVA said:

To ensure consistency in the delivery and audit processes it would be advisable to allow the same tests for APHA employed ATTs and those employed through private practice.

This view was shared by a number of respondents who felt that provided ATTs were sufficiently trained there was no reason to restrict the types of test they could perform .One respondent suggested that restricting test types would undermine confidence in a para-professional approach to the delivery of TB testing in England.

The RSPCA stated:

If ATTs are not permitted to carry out certain tests then we would not want them carrying out any tests on the grounds that all tests should be carried out by a suitably trained and competent individual.

Audit

Q4. Do you agree that using ATTs as part of a veterinary led team under the current delivery framework would help ensure high TB testing standards are maintained?

The breakdown of responses is:

Agree – 57% Disagree – 39% No view – 4%

The majority of respondents including most representative organisations agreed with this question though some caveated their support. For example, the NBA agreed that high TB testing standards would be maintained so long as:

the auditing procedure is independent, robust and strictly adhered to

Other respondents including the NFU agreed provided that ATTs were adequately supervised. There were few substantive comments from those who disagreed with the question. Two respondents were concerned that replacing qualified, experienced vets with ATTs would make it more difficult to maintain high TB testing standards.

The Tenant Farmers Association (TFA) disagreed with the question and said:

We are worried about the efficiency and professionalism of tests carried out by non-veterinary professionals.

Management of ATTs

Q5. If the use of ATTs is agreed, do you think their use should be:

5a. limited to practices working under the VDP contracts only or

5b. extended to any practice that can provide a supervising OV (AVS)

60 respondents answered this question. The breakdown of responses is:

48% agreed the use of ATTs should be restricted to VDP practices 32% felt their use should be extended to all practices 20% expressed no view

The NBA and RSPCA both supported option A. The most common reason for supporting this option was because of perceived concerns about the quality and standard of testing offered outside of VDP contracts.

The RSPCA stated:

Their use should be limited to VDP contract practices. These are the practices that are directly responsible for maintaining standards of bTB testers currently and therefore the ATT’s would be overseen by those vets directly involved with delivering bTB tests of high quality. By allowing subcontracting to OV’s at other practices there is the risk that standards could slip gradually and remain undetected, potentially resulting in many herds being affected.

A number of respondents were concerned that practices outside of the VDP contracts would not be subject to the same robust audit requirements with some respondents suggesting this could lead to a slip in testing standards.

One respondent who supported option A commented on the benefits of the VDP contracts from a farmer’s perspective which they said were:

working well to provide a cost effective, efficient and high quality service and shouldn’t be eroded by setting up parallel schemes.

The NFU and BVA/BCVA were in favour of option B. The most common reason for supporting this option was that it would enhance industry capability, both in terms of meeting increasing TB testing requirements and ATT’s career development.

The BCVA/BVA said:

ATTs have the potential to fulfil a useful role within a vet-led team offering a fulfilling career option as well as expanding the veterinary practice offer. Therefore, if veterinary practices wish to take up the option it should be made available across all practices.

One respondent who supported option B did so provided that all practices were subject to the same high standard of audit.

Q6. How do you suggest that monitoring and auditing is implemented if ATTs are permitted to work outside of the VDP?

43 respondents provided comments but few directly answered the question and provided suggestions on how monitoring and auditing could be implemented. Most respondents did not express a view or disagreed with the proposal. The NFU said:

Whilst the NFU cannot comment on how monitoring and auditing is implemented it is vital to maintaining professionalism and support for farmers.

Among those that did directly answer the question seven respondents suggested that APHA should be responsible for monitoring and auditing, primarily through random spot checks. One of these respondents was the BVA/BCVA who said:

Currently, APHA are responsible for auditing those practices not under the VDP. That is where the responsibility should also lie for ATTs working outside the VDP’

Two respondents suggested that the existing VDP audit system could either be extended or modified to cover practices outside of VDP contracts.

The RSPCA said they would not support ATTs working outside of the VDP.

Q7. Do you support the implementation of a Pilot project under the direction of APHA to assess the feasibility of the use of ATTs in private practices?

All 63 respondents answered this question. The breakdown of responses is:

Yes – 59% No – 40% No view – 1%

The BVA/BCVA, NFU, NBA and RSPCA all supported the implementation of a Pilot project but some attached caveats. The BCVA/BVA said an appropriate pilot should:

Incorporate different practice sizes and models,different geographies and cover the experience of the high-risk area, edge area and low risk area where the testing regimes have diverged

The NFU highlighted the need for careful stakeholder management, particularly in terms of managing farmers understanding and expectations and also said that if the pilot was unsuccessful there would need to be:

…a clear strategy for handling questions of result reliability, especially where test reactors had been found and culled during the pilot.

The RSPCA agreed with the proposal so long as:

…data is collected to assure the general public that the use of ATTs will not affect the validity of the Single Intradermal Comparative Cervical Tuberculin test (SICT).

Three respondents questioned the need for a pilot on the grounds of time, additional expense and the proposal being nothing new and suggested that APHA should just go ahead and roll out the extended use of ATTs.

4. The government’s response to the consultation

Defra is grateful to those who responded to the consultation.

Overall the responses were positive to the idea of extending the use of ATTs in England to give private veterinary businesses the option of deploying them to carry out some TB skin tests. Accordingly, APHA will proceed with plans to roll out a pilot project in late 2018 to trial the use of ATTs in private businesses. The pilot will act on advice and address concerns raised by those for and against the proposal. Progress will be closely monitored and feedback from the pilot will be used to inform final decisions on veterinary supervision, test types, auditing and management of ATTs ahead of any wider roll-out.

Annex A: List of organisations that responded to our consultation exercise

Belmont Veterinary Centre

Black Sheep Farm Health

Bridge Veterinary Clinic

British Cattle Veterinary Association/British Veterinary Association

Clevedale Veterinary Practice

Friars Moor Veterinary Clinic

Kernow Veterinary Group

May Farming Partnership

National Beef Association

National Farmers Union

Royal Society for the Prevention of Cruelty to Animals

Scarsdale Veterinary Group

Shropshire Farm Vets Ltd

Smith & Son Veterinary Practice

Strand Veterinary Practice

Synergy Farm Health

Tenant Farmers Association

Torch Farm Vets

Towcester Veterinary Centre

Wern Vets

Westpoint Farm Vets

XL Farmcare UK Ltd

Ystwyth Vet Practice