AHWSSG Sheep Scab Task and Finish Group Paper January 2014
The challenge of eradicating sheep scab - a report of recommendations to the Welsh Government by the Sheep Scab Task and
Finish Group
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
Contents
Introduction ...... 3
Executive Summary ...... 4
Background ...... 5
Obstacles to Eradication ...... 9
Potential Risks ...... 12
Facilitation of Diagnosis ...... 14
Legislation ...... 16
Industry Activity...... 21
Mynydd Epynt Group ...... 23
Dyffryn Dyfi Group ...... 24
Funding ...... 27
Recommendations ...... 29
Annex I - Terms of Reference ...... 31
Annex II - Sheep Scab Task & Finish Group members ...... 32
Annex III – Outline for the operation of Sheep Scab Eradication Programme in an affected area ...... 33
Annex IV – Suggested Process Flow (text & diagram) for implementation of a Sheep Scab
Eradication Programme ...... 36
Annex V - „Stamp Out Scab‟ – England Training and Awareness Campaign ...... 39
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
Introduction
1. The Sheep Scab Task and Finish Group was established by the Animal Health and Welfare (AHWS) Strategy Steering Group to make recommendations to the AHWS Steering Group and Welsh Ministers on the eradication of sheep scab in Wales. The AHWS Steering Group is made up of relevant organisations, is facilitated by the Welsh Government, and aims to work in partnership to take forward the implementation of the Animal Health and Welfare Strategy1 in Wales. Sheep scab has been identified by the AHWS Steering Group as a key priority.
2. The Sheep Scab Task and Finish Group is made up of individuals from the farming unions, veterinary practitioners and other leading industry and stakeholder experts. A list of Sheep Scab Task and Finish Group members can be found at Annex II.
3. The terms of reference of the Sheep Scab Task and Finish Group can be found at Annex 1.
1 http://wales.gov.uk/topics/environmentcountryside/ahw/animalhealthandwelfarestrategy/?lang=en
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
Executive Summary
1. This is a summary of the key points relating to the development of the report and the associated recommendations:-
2. Sheep Scab is caused by a parasitic mite that lives on the surface of the skin. The principal features of the disease are:- It is a serious threat to sheep welfare. It can be extremely debilitating and, if left untreated, causes suffering which will eventually lead to a painful death. It is highly contagious and can spread quickly both within and between flocks. It causes significant economic losses to the sheep industry in Wales as a direct result of the debilitating impact of the disease on sheep welfare.
3. Sheep Scab was historically controlled by compulsory dipping up until deregulation in 1992. Since 1992 disease incidence has increased across Wales particularly in less favoured areas and in flocks grazing on common land. The group reviewed current legislation in Wales within the provision of the Sheep Scab Order 1997 and, for comparison, the Sheep Scab (Scotland) Order 2010 noting their respective strengths and weaknesses. It is estimated that the cost of sheep scab to the industry in Wales over a five year period could equate to in excess of £12m.
4. The group considered the challenge of accurate diagnosis, effective and sustainable disease outbreak management including highlighting preventative measures through health planning, good flock biosecurity and best practice at farm level.
5. The role of the various industry stakeholders was considered along with knowledge transfer delivery programmes and consideration of current local initiatives in Wales and those taking place elsewhere in the UK including in England. Funding options were considered with respect to the potential cost implications of implementing the recommendations to the industry, Welsh Government and other stakeholders.
6. The key recommendations made in the report are:- Eradication of Sheep Scab in Wales, Strengthen current legislation in Wales through amending the Sheep Scab Order 1997, Introduce a statutory requirement to report suspected disease, Compulsory treatment of infected flocks, Provision to inform flock keepers contiguous to affected premises, place movement restrictions and enforce treatment2, Authority to trace sheep movement on and off the affected premises,
2 unless adequate biosecurity exists and / or veterinary evidence is provided that scab does not exist on that contact premise
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
Complement legislative changes with industry and stakeholder initiatives promoting best practice, Establish an on-going monitoring and evaluation programme, Consider various funding vehicles to facilitate and support implementation of the recommendations; and Review the Environmental Permitting Regulations and their implementation in respect of waste sheep dip groundwater discharges.
7. There has been proactive engagement by members of the group with industry representatives including the Farmers‟ Union of Wales (FUW), National Farmers Union (NFU) Cymru, and the National Sheep Association (NSA).
Background
8. The Welsh sheep meat sector is an important primary production industry in respect of the rural economy and sustainable management of the landscape. Finished sheep and lambs contributed £255 million to Welsh agricultural output in 2011 (20% of overall agricultural output). The value of Welsh Lamb exports from the UK was worth £124 million in 2012. There are 14,700 sheep and lamb holdings in Wales3 and the total value of the red meat sector to the Welsh economy; taking into account the agricultural, processing and retail sectors; is estimated by the red meat promotion agency HCC to be in excess of £1 billion per annum.
9. Sheep scab is a major welfare concern to the sheep industry and is caused by a mite (Psoroptes ovis) that is transmitted by direct contact with infected sheep or objects. The scab mites live on the surface of the skin causing an allergy to their droppings and it is this allergic reaction that causes the sheep to scratch. Transmission of the disease occurs primarily from sheep to sheep contact but can also occur through contact with infected areas in the environment such as rubbing against contaminated posts, transportation or handler‟s clothing4. The disease is highly contagious and can occur at any time of the year. Infected animals will tend to scratch large areas of their fleece resulting in extensive bald patches.5 In addition to sheep, this disease is also known to infest goats, horses, camelids and rabbits6 with new incidences in cattle also reported in recent years7
10. Between November 2006 and March 2007 HCC undertook a survey of Welsh sheep farms to get an indication of the prevalence of ectoparasites in Wales8.
3 Hybu Cig Cymru (HCC) 4 Sargison et al., 2006a 5 Cross et al 2010., Preventive Veterinary Medicine 96 (2010) 252–262 6 Bates, 1999a 7 Mitchell,2010 8 HCC, 2008. The Influence of Ectoparasites on Welsh Sheep Farms. Welsh Assembly Government, Farming Connect, Hybu Cig Cymru.
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This survey indicated that 11.6%, 57.5%, 11.1% and 15% of Welsh farms were affected by scab, flystrike, ticks and lice respectively. In developing the HCC Parasitology Action Plan for Wales 20119, a survey was undertaken in 2010 which indicated that sheep scab was considered to be a problem for at least 39% of the 200 farmers interviewed, and lice for 42% of the farmers interviewed. Of the 30 farmers who were involved in the Farming Connect Red Meat Development Programme demonstration farms 2007 – 2010 all of which were interviewed; 44% said sheep scab is a problem; 44% said lice is a problem; 25% ticks; and blowfly for 97% of farms.
11. A paper by Bangor University published in 2010 on the use of a Randomized Response Technique to obtain sensitive information on animal disease prevalence was based on a study whereby farmers at several agricultural shows in Wales were asked to complete questionnaires according to the Randomized Response Technique during the summer of 2009. The survey results suggest that 30% of farmers did not routinely treat their sheep for scab. A further 36.5% of the surveyed farmers stated that they had experienced sheep scab in their flocks in the past 5 years. These estimates are both higher than obtained by some previous surveys which used more traditional questionnaire structures. Survey responses revealed a strong willingness to reintroduce compulsory treatment measures to control or eradicate the disease. 10
12. Fraser et al (2006) found 36% of farmers in south west England had problems with sheep scab. Given that there are regular movements of sheep each way between Wales and England it is important to recognise that both the problem of sheep scab and solution is likely to require consideration of a cross border approach. However, this should not prevent in any way action being taken to eradicate sheep scab in Wales.
13. Whilst sheep scab is considered to be a problem throughout Wales, incidence is likely to be greatest in the Less Favoured Areas (LFA) which accounts for 80% of the land area. This is partly due to the large proportion of Common Land in Wales which is located within the LFA where sheep flocks have a higher chance of coming into contact with each other due to the absence in some instances of fenced boundaries. The prevalence of sheep scab is also related to density of sheep, temperature and rainfall11.
14. The risks associated with the spread of sheep scab are most likely to arise from the following:-
9 http://hccmpw.org.uk/publications/farming_industry_development/animal_health_and_welfare 10 Cross et al 2010., Preventive Veterinary Medicine 96 (2010) 252–262 11 Rose et al 2009
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• Movement of animals on to the farm
• Contact with neighbour‟s animals
• Contact at markets/ in transit
• Common grazing
• Shearing and scanning contractors
15. In Wales, sheep scab has in the past been estimated to cost the sheep industry around £2.3m annually12. An updated figure over a five year period could equate to a cost to the sheep industry in Wales of over £12m. The cost of sheep scab to the UK sheep industry has been estimated to be in the region of £8 million per year13. The majority of disease costs relate to reductions in performance and the application of preventative measures and treatments. In terms of financial impact on farm, the cost of treating a 60kg sheep with a product such as Cydectin could be around £2.47 per animal. However, in one study, when the costs of a wide range of factors including increased lamb mortality, increased time to finishing, treatment costs and reduced fleece value were included in a full costing model, sheep scab infestation had the potential to turn a profit of £5.27 per ewe into an overall loss of £13.57 per ewe on a typical lowland sheep farm14. This specific flock example highlights the cost of a scab infestation on an individual sheep enterprise.
16. Financial statistics showed that the average Welsh hill sheep farm had a gross margin of £37.54 per ewe in 2011/2012 (Wales Farm Income Booklet, 2011/12 Results Source: Welsh Government). Figures derived from the above on-farm study shows that a scab infestation could potentially have a significant impact on Welsh sheep enterprise profitability.
17. An area of equal concern is treatment for sheep scab (ectoparasite), which very often is applied by farmers using a dual use product for both endo and ectoparasites. This is likely to increase the emergence of resistant nematode parasites. Unless the route to infection is addressed this is likely to have serious consequences for sheepmeat production in Wales.
The Effect of Legislation on the Success of Proactive Disease Control
Voluntary proactive animal disease initiatives are only as successful as the weakest participant. The extent to which livestock producers engage with voluntary disease initiatives will be dependent on a variety of factors and the
12 Armstrong, D and Evans L (2007) Veterinary Record 160 775-776 13 Nieuwhof and Bishop 2005 14 Stubbings, L (2007) Proceedings of the Sheep Veterinary Society 31, 115-117
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complex interplay between such factors and the strength of the associated behavioural response in the individual („motivational diversity‟) 15.
Livestock keepers who do not currently undertake measures to proactively prevent a given animal disease from proliferating on their premises are known to cite treatment costs, time and resource shortages, strict environmental compliance and lengthy withdrawal periods as some of the factors precluding participation in disease management. Furthermore, a fear of reprisals and an historic and lingering tendency for some producers to associate a disease outbreak with poor husbandry may also preclude some livestock keepers from engaging in voluntary disease programmes. Producers may also be reluctant to implement proactive control measures if there are no perceived disease losses and no change in the market value of proactively treated animals16. When considering the control of sheep scab in Wales, such individuals may be reticent in engaging with voluntary scab events and workshops and may also be less likely to engage with neighbouring farms upon discovery of a disease outbreak.
Non-participatory keepers have the potential to undermine voluntary initiatives and programmes by acting as a constant source of reinfection to other, more proactive, keepers. Several studies have now cited the importance of statutory mechanisms in successfully engaging those livestock keepers who do not actively engage in proactive disease control17,18,19. Voluntary disease programmes can be legitimised by subsequent legislation and, in many cases, the use of a statutory approach may be the only mechanism by which to engage the small minority of producers unwilling to participate in voluntary initiatives. Legitimate authority and coercive action20 have been shown to aid in securing compliance with disease programmes by increasing the cost of non-compliance above that of a voluntary programme.
Post-outbreak engagement, and treatment co-ordination, with neighbouring farms remains a fundamental component of a successful sheep scab eradication programme and it therefore essential that reticent keepers become participants in the Welsh sheep scab initiative. Given that the use of legislation can aid in increasing farmer engagement, its use as part of a Welsh sheep scab eradication programme is thus well warranted. Promoting awareness of future scab legislation to livestock keepers during the voluntary phase of the Welsh sheep scab initiative should aid in increasing farmer engagement. The subsequent use of scab regulation should then aid in „mopping up‟ those remaining producers that continue to resist engagement with this disease.
15 Hernandez-Jover et al. (2012) Preventive Veterinary Medicine. Volume: 104, Issue: 3-4 Pages: 258-270. 16 Gates et al. (2013) Preventive Veterinary Medicine. Volume: 112, Issue: 3-4, Pages: 285-295. 17 Hult and Lindberg. (2005) Preventive Veterinary Medicine. Volume: 72, Pages: 143–148 18 Lindberg et al. (2001) Preventive Veterinary Medicine. Volume: 51, Pages: 199-214 19 Truyers et al. (2010) Veterinary Record. Volume 167, Pages: 566–570 20 Ellis-Iversen et al. (2012) Annual Meeting of the Society-for-Veterinary-Epidemiology-and-Preventive-Medicine Volume: 93, Issue: 4, Pages: 276-285.
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Obstacles to Eradication
18. For the purposes of this paper, an „obstacle to eradication‟ is defined as „something that prevents or hinders the establishment of an holistic and workable approach to eradicating sheep scab in Wales‟.
19. Disease eradication or control programmes are only as effective as the weakest participant. Livestock keepers who do not currently undertake measures to actively prevent sheep scab in their flock are known to cite treatment costs, labour shortages and strict environmental compliance as some of the factors precluding participation in scab management21. Lengthy treatment withdrawal periods, a fear of reprisals and an historic and lingering tendency for some producers to associate a scab outbreak with poor husbandry may also preclude some livestock keepers from engaging in voluntary scab programmes. Such individuals may also be less likely to engage with neighbouring farms upon discovery of a scab outbreak and may be reticent in responding to industry or Government questionnaires or engaging in scab events and workshops.
20. Post-outbreak engagement with neighbouring farms remains a fundamental component of a successful scab eradication programme. Current UK licensed medicines for scab treatment and control can be either a dip formulation or an injectable product. These have differing lengths of „persistent protection‟ ranging from 21 to 60 days$. Moreover, the injectable products have differing treatment protocols which can mean that multiple injections at set intervals are required in order to complete a course of treatment. A lack of post-outbreak transparency and treatment co-ordination may mean that the period of persistent protection in one flock or premise may have elapsed prior to the treatment of a scab infection in a neighbouring farm. Such instances perpetuate a treatment – re-infection – treatment cycle, do little to improve sheep welfare and can potentially undermine the success of any regional or national initiatives.
21. The Sheep Scab (Scotland) Order 2010 (hereafter referred to in this section as the Scottish Order) places a legislative responsibility on sheep keepers and vets to notify Scottish Government Inspectors of any case of sheep scab or suspected cases of sheep scab and was in part a response to the failure of
21 Paul Cross, Gareth Edwards-Jones, Hussain Omed and Prysor Williams. The prevalence of non-treatment of sheep scab in Wales and the economic cost to the livestock industry. Final Report. School of the Environment, Natural Resources and Geography, College of Natural Sciences, Bangor University.
*To be defined
$ of known product persistent protection data
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voluntary measures to eradicate this disease (see section 6 for further details). The Scottish Order places a legal obligation on any person who knows or suspects that sheep or carcases in their possession or charge are infected with sheep scab to notify that fact to the AHVLA as soon as possible. However this Order does not contain a legal requirement for such keepers to notify neighbouring premises of an outbreak and a real threat of re-infection from boundaries therefore remains. Maintenance of disease free status is unlikely to be sustainable without the involvement of contiguous regions and this is a potential weakness in the Scottish Order. In order to ensure that the Welsh scab eradication programme is proactive and not reactive in its approach, any Welsh specific legislative Order should give consideration to a process which includes notification to, and treatment of, a contiguous premise.
22. The establishment of the Scottish Order was complemented by a campaign entitled „Silence Spreads Scab‟. This campaign was designed to reduce the stigma associated with a scab outbreak and to improve post-outbreak transparency. Although no quantitative data exists on the relative success of this campaign, it is logical to assume that a similar pan-Wales campaign would be of benefit as part of an over-arching Welsh eradication programme. If undertaken before the establishment of a legislative Order, a sheep scab campaign could promote and endorse legislation and could offer producers an opportunity to engage and address this disease prior to enforcement.
23. When considering moves towards a legislative approach to sheep scab in Wales, there remains concern regarding the relatively low number of scab products available and the associated lengthy withdrawal periods conferred by each product. Extended withdrawal periods have a detrimental impact on trade and can affect the marketing of lamb which is ready for slaughter; this is especially true in the autumn months. Current withdrawal periods for injectable products can be as high as 104 days and the current withdrawal period of organophosphate dips (OP) is 70 days. Whilst the various risks associated with OPs are fully accepted, properly administered OP dips still remain a viable and sustainable option in the treatment of scab. There remains a need to question the scientific basis under which current withdrawal periods are based. The doubling of withdrawal periods under organic protection standards further serves to discourage conscientious and proactive producers from engaging in a sheep scab treatment programme.
24. Plunge dipping with OP‟s can be a costly procedure. It requires extra labour, suitable handling facilities with fixed equipment and disposal of waste dip in a safe manner. Concern over the environmental impacts of dipping, the tight regulation of dip disposal and human health issues may preclude some farmers from using OP dips as a sheep scab treatment. However, OP dips
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have the added benefit of being licensed and effective in the treatment of both scab mites and lice. It is therefore the treatment of choice in some cases. Irrespective of the treatment in question, it is essential that sheep producers recognise, understand and apply the appropriate set-up with regard to effectiveness, health and safety, and the environment.
25. The spread of sheep scab will undoubtedly be exacerbated by animal movements and programmes which account for all possible routes of transmission will most likely achieve the greatest success. Previous studies have demonstrated that more than a third of farmers in south west England have had problems with sheep scab22. Given that there are regular movements of sheep each way between Wales and England it is important to recognise that a longer-term approach to sheep scab in Wales will likely require consideration of a cross border approach. The group is aware that in England RDP funding has recently funded a project aimed at addressing sheep scab, which is to increase awareness of the disease.
22 Fraser et al (2006)
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Potential Risks
26. For the purposes of this paper, a „potential risk‟ is defined as „something that has the potential to threaten or jeopardize the on-going success of a Welsh sheep scab eradication programme’.
27. Emerging resistance against anthelmintics and other antiparasitics serves to demonstrate the adaptive capacity of many commercially important parasitic species. In the absence of alternative control measures, high levels of drug resistance can have a significant and substantial impact on the productivity and sustainability of many livestock farms and the issue of drug resistance has received a wealth of attention in both academic research and animal health policy.
28. For sheep infected with the sheep scab mite, current treatment options are limited to injectable endectocides (macrocyclic lactones) and dipping in organophosphates. Inappropriate administration of treatment – such as incorrect dosing and inappropriate drug choice - may lead to resistance, is financially wasteful and can be detrimental to the welfare and productivity of infected animals. It is therefore essential that, following definitive diagnosis, the scab treatment chosen is administered strictly according to the manufacturers‟ instructions. The selection of a suitable treatment for scab may depend on integration into the flock‟s current worming strategy and it is important that any treatment regime is undertaken with the knowledge requisite to avoiding resistance in both the target species (P. ovis) and, in the case of multiple infections, non-target species such as helminth parasites.
29. Anthelmintic resistance is increasing in prevalence throughout the UK. Resistance to the 3-ML group of anthelmintics which is also the group of chemicals effective against sheep scab was reported as early as 2006 (Vet Parasitol. 2006 Apr 15;137:112-8). Further cases of resistance to this chemical group have been reported (Sustainable worm control strategies for sheep, 4th Edition, 2012) and there is concern amongst vets and industry advisors that the wide-scale use of these products for the prevention and treatment of scab will further increase the development of resistance. Current tests are for resistance to the 3-ML compounds are also limited to faecal egg count reduction tests only and given the need to further improve gastro- intestinal control on many sheep farms, the incidence of anthelmintic resistance is likely to be under-reported.
30. An additional concern to the increased use of 3-ML products is the time of year in which they are normally used. A major driver of the development of anthelmintic resistance is the use of a treatment at a time of year when there is a low larval burden on pasture. Low pasture challenges tend to occur in
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late autumn and over winter and it is at this time of year when treatments for scab are often given. The low pasture contamination means that any resistant worms which survive treatment are „multiplied‟ rapidly as there are few susceptible worms present on the pasture with which to dilute their number. From the perspective of worm control, this has led to the recommendation that adult ewes in good condition should not require an anthelmintic treatment pre-tupping. The use of these products for scab control will therefore directly impact upon the speed at which wormer resistance develops with the potential for major economic and welfare issues in the Welsh national flock as treatment options for susceptible lambs becomes further limited.
31. Given that a lack of skills or training may facilitate inappropriate administration of treatment, and thus drug resistance, it is essential that any scab eradication programme attempt to mitigate such risks by establishing appropriate scab workshops, open days, training days and best practise initiatives. Such initiatives should be „farmer-friendly‟ and should account for the scab mite life-cycle in their timing, geographical distribution and content.
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Facilitation of Diagnosis
32. Sheep scab is currently a commonly misdiagnosed skin condition of sheep in the UK. Due to similarities in the clinical signs and symptoms presented post-infection, infestation with sheep scab is often mistaken for infection with lice and vice versa. Two types of lice can infect sheep, these being sucking lice and biting lice. They can both cause similar disease and can be differentiated by examination of lice collected from infected sheep. For scab infestations, treatment options are currently limited to organophosphate plunge dipping or injection with macrocyclic lactones (see section 4 for further details). Injectable treatment products currently utilised in the treatment of scab mites can be ineffective against sucking lice. Thus, the attainment of a definitive diagnosis is an essential part of an effective sheep scab control programme.
33. Scab is currently diagnosed via skin scrapings and subsequent confirmation by examination under a microscope. Wool samples are not sufficient to diagnose sheep scab because the causative mite vector does not reside in areas which have suffered wool loss but instead resides in the edges of such areas. At present, definitive diagnosis is usually obtained by sending skin scrapings to a veterinary practitioner. Skin scrapings are normally taken by the veterinary surgeon and either checked by the veterinary surgeon or sent to a lab. The farmer normally takes an affected sheep to the veterinary surgeon for sampling. It is suggested that farmers should be discouraged from taking the samples as it could result in misdiagnosis if the sample has not been taken properly.
34. An increase in the number of definitive scab diagnoses may be facilitated by the employment of co-ordinated producer focused education and awareness campaigns. Industry and Government communications which stress the importance of undertaking skin testing to definitively ascertain the causative agent of any suspected outbreak would be of benefit if such campaigns function to reduce the potential for misdiagnosis. If sheep scab becomes a notifiable disease in Wales then any pruritic (scratching) sheep will need to be investigated.
35. Diagnosis of sheep scab via skin scrapings normally occurs following the onset of clinical signs. However, the sub-clinical stage of infection is known to last for several weeks and an infected sheep can act as a vector of infection during this time. Diagnosis before the onset of clinical signs could substantially reduce disease transmission and prevalence. For control or eradication programs to be successful it is crucial that all infected animals – including subclinical cases - are treated. Educational campaigns which warn
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producers about the early subclinical stage of infection may therefore be warranted.
36. An Enzyme-Linked Immunosorbent Assay (ELISA) test is currently being developed by the Moredun Research Institute. On an individual basis, this diagnostic tool can be used to rule in or out sheep scab infection when applied to animals that are suspected of having a scab infestation23. The optimised Moredun test could be used to determine exposure to sheep scab mites with 98.2% sensitivity (1.8% false negatives) and 96.5% specificity (3.5% false positives) in its standard format or, where 100% sensitivity is required (0 false negatives), the penalty for this level of sensitivity is 4.6% false positives (Nisbet and Burgess, unpublished). Trials demonstrate that a positive result using ELISA can be achieved within 2 weeks post-infection and can identify scab infection prior to the onset of any clinical signs. However, at present the Moredun ELISA cannot be used to distinguish between recently infected and currently infected animals. Moreover, the test is not suitable for pooled samples; thus, for an entire flock to be classified as negative for scab infection, each individual animal would need to be tested separately.
37. Comparative sensitivity of the ELISA test is currently being evaluated relative to the traditional skin scraping test. When commercially available, and when all trials have been successfully completed, the inclusion of the potential use of the Moredun ELISA test in any pan-Wales scab eradication programme would therefore be prudent.
38. Although not applicable to any pan-Wales eradication programme at present, on-going scientific research in the UK is currently working towards mapping the host response to scab infestation; with particular emphasis on early host- parasite interactions and lesion development. This research aims to identify novel methods of intervention, diagnostic candidates and potential vaccine candidates. Although vaccination is currently not a viable option in the control of sheep scab, such strategies may provide another „tool in the toolbox‟ in the longer term and should be re-visited when and if it is appropriate to do so.
23 Nesbit, Alasdair, pers. comm. 2012
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Legislation
39. The group reviewed legislation providing for the control of sheep scab and also compared and contrasted the Wales position with that of Scotland where different legislation applies. Discussions were held with George Milne of the National Sheep Association in Scotland and Professor Neil Sargisson, Senior Lecturer at the Royal School of Veterinary Studies in Edinburgh, to consider the general approach to tackling the problem of sheep scab in Scotland and to see how legislation had been framed to meet the wider strategy of eradicating sheep scab.
40. The legal basis for tackling sheep scab has evolved over time. Deregulation and the removal of compulsory dipping of sheep occurred in 1992. The Sheep Scab Order 1997 was subsequently introduced under the Animal Health Act 1981, giving Local Authorities the means to improve the control of sheep scab when owners of affected sheep did not take appropriate measures voluntarily.
41. The Sheep Scab Order 1997 came into force on 1 July of that year. The Order contains provisions for;
local authorities to issue a Notice of Clearance for sheep “…visibly affected with sheep scab” from common land
restricting the movement of sheep after the issue of a Clearance Notice
authorising local authorities to seize, detail & treat sheep on land specified in a Clearance Notice subject to certain provisions.
stopping the movement of sheep visibly affected by sheep scab, or any sheep from a flock containing one or more sheep visibly affected by sheep scab on, to or off any premises except under certain conditions.
requiring sheep keepers to treat visibly affected sheep as soon as practical and to provide inspectors with powers to require that sheep isolated and treat visibly affected sheep.
providing local authorities with the power to deal with sheep that are not treated, including provisions to take samples for analysis and to mark sheep.
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42. The provisions of the Order apply to sheep which are visibly affected with sheep scab as well as sheep that are visibly affected with sheep scab but which are being ignored and not treated voluntarily by the owner. Reports of sheep scab should be referred to Local Authorities who are responsible for the execution and enforcement.
43. In July 2009 the Minister for Rural Affairs agreed actions for the then Welsh Assembly Government to take forward to help tackle sheep scab in Wales. These actions were prioritised into short, medium and longer term actions.
44. The short to medium-term actions included the provision of specific guidance for Local Authorities on the enforcement of the Order; the production of a training leaflet on diagnosis and raising awareness generally. The longer term actions focused on the need for further consideration to be given to making changes to legislation.
45. The Office of the Chief Veterinary Officer (OCVO), Welsh Government issued the guidance to the Order to encourage a consistent approach to its implementation. It was made clear that the Welsh Government would like local authorities to take a robust approach when sheep scab was present or suspected and even to “use local intelligence and check for scab in sheep flocks that may be harbouring scab and acting as a constant source of reinfections to neighbours”.
46. The guidance provided a check list for inspectors and included an explanation of when sheep may be considered to be “visibly affected” with sheep scab, according to the order:-
Mild to excessive rubbing/scratching against fence posts etc. Mild to excessive nibbling and biting. Dirty areas of fleece due to rubbing and scratching; especially with the hind-feet behind the shoulder. “Nibble” (touch hypersensitivity) response, spontaneous or in response to handling or manipulation of a lesion. Tags of fleece on flanks due to biting or rubbing (similar to lice infestations). Tags of fleece in mouth due to biting of self. Clean areas of fleece due to licking/biting at or near lesions. Standing apart from flock, dull and depressed.
47. The guidance suggests actions to be taken by Local Authority animal welfare inspectors on farm and on common land and explained how sheep may be detained. Actions to be taken by inspectors at collection centres, marts during transport and at abattoirs were provided as well.
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48. Local Authority personnel therefore possess the powers to control the movements of scab infested sheep and impose the treatment of affected sheep and have clear guidance as to how to impose the requirements of the Order. However, Local Authorities require evidence that sheep are visibly affected to begin the process of isolation and additional veterinary evidence before treatment and possible enforcement action. Visibly affected sheep must, by definition, exhibit clinical signs of the disease and therefore at present, it remains difficult for local authority personnel to identify those premises and flocks that are affected with scab but are without any apparent clinical signs of the disease. For instance, the current Order allows no mechanism by which local authorities can act if scab affected sheep presented at market are asymptomatic for the disease, even though there may be reasonable grounds to suspect that they are affected. Without the power for an inspector to act where there is a suspicion that sheep scab exists, local authorities are hindered in their ability to formally activate the powers conferred to them under the Sheep Scab Order and there is currently a need to make changes to the current legislation in order to drive forward the work of Local Authorities.
49. Since deregulation in 1992, sheep producers have been able to choose the treatment regime that best fits their farm management practises in isolation, but this freedom may not be in the best interests of local or national level, holistic scab eradication programmes. At present, it is estimated that less than half of UK sheep producers treat sheep prophylactically for scab (Bisdoff and Wall, 2008)24.
50. Although there is currently a dearth of data on this issue, it is logical to assume that very few producers at present will voluntarily notify contiguous premises of a scab breakdown on their farm: discussions with farmers confirm that this is clearly the case. Moreover, very few producers will voluntarily arrange a treatment regime that coincides with a neighbouring farm and this can create a never ending treatment cycle in the community. Local authority staff do not possess the authority to enforce scab treatment on contiguous premises as the provisions of the Order only apply to sheep which are visibly affected. It is often the case that individuals attempt to deal with the disease in isolation without any outside assistance. The absence of legislation which places an obligation on any person suspecting disease exists to notify official bodies only adds to the treatment, and sometimes ineffectual treatment, of
24Bisdorff, B., and R. Wall. 2008. Control and management of sheep mange and pediculosis in Great Britain. Veterinary Parasitology. 155:120-126.
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individual flocks. This is a fundamental weakness of the current Scab Order and functions to prohibit both local and national level sheep scab eradication.
51. In Scotland, new controls were introduced in December 2010 when the Sheep Scab (Scotland) Order 2010 came into effect. Section 4 of the Scottish Order clearly establishes a legal obligation on any person who suspects that sheep in their possession or care have scab to inform Scottish Government inspectors as soon as possible: there is no comparable provision in the Sheep Scab Order 1997 that applies in Wales and England.
Sheep Scab (Scotland) Order 2010 – Section 4
“Notification of sheep scab or suspected sheep scab 4.- (1) A person who has possession of, or is in charge of, any sheep or carcase which the person knows or suspects has sheep scab must as soon as possible notify the Divisional Veterinary Manager of that knowledge or suspicion.
(2) A veterinary surgeon who examines any sheep or carcase which he or she knows or suspects has sheep scab must as soon as possible notify the Divisional Veterinary Manager of that knowledge or suspicion.
(3) When notice is given under paragraph (1) by a person other than the owner or (if different) the keeper of the affected sheep or affected carcase, that person must as soon as possible inform the owner or (if different) the keeper of the affected sheep or affected carcase that notification has been made.
(4) When notice is given under paragraph (2) the veterinary surgeon must as soon as possible inform the owner or (if different) the keeper of the affected sheep or affected carcase that notification has been made.”
52. Movement restrictions subsequently apply until the sheep are either treated or slaughtered, or a veterinary surgeon provides a negative diagnosis. Owners or keepers in Scotland who fail to take action on sheep scab can have movement restrictions imposed on their flock until the issue has been dealt with: they will also be liable for prosecution.
53. The Scottish Order therefore places a responsibility on sheep keepers and vets to notify Scottish Government Inspectors of any case of sheep scab or suspected cases of sheep scab that they come across. Restrictions on the movement of sheep with or suspected of having scab are included as well as
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provisions for their treatment, time allowed to complete treatment and reporting procedures back to Scottish Government inspectors. Where an inspector knows or suspects that there is sheep scab on premises, the Scottish Order provides for powers for an inspector to demand that a vet be asked to undertake an examination of the sheep to confirm the presence of sheep scab or otherwise. If scab is confirmed the treatment and reporting process then has to follow.
54. The Scottish Order has similar powers for clearance of common land as are applicable in Wales, to restrict movement, for seizure of sheep by local authorities, for the slaughter of affected sheep and for the marking of sheep. The Scottish Order however, has further powers to enable an inspector to demand that the affected premises be cleansed, including any machinery and equipment used by affected sheep.
55. The Sheep Scab Order (Scotland) 2010 was a response to the presence of disease and the failure of voluntary measures to deal with it. It is different from its Welsh counter-part in a number of ways. It specifies that it applies to sheep “affected or suspected of being affected with sheep scab” compared to the Welsh Order that applies to sheep that “exhibit clinical signs of the disease” and makes sheep scab a notifiable disease.
56. Both George Milne and Neil Sargisson considered the Scottish Order to be helpful in the strategy of eradicating sheep scab but noted that controls alone were not the answers. Early indications (March 2012) were that the new legislation had made a positive impact in that it has resulted in nearly 150 notifications to AHVLA Managers (who act as inspectors under the Order).
57. From a review of the legislation, it has to be concluded that further consideration needs to be given to changes in the current 1997 Scab Order that applies in Wales in order to promote, enhance and substantiate those activities currently being undertaken by both AHVLA and local authority personnel. Those changes will need to include a requirement to notify the authorities of incidences of sheep scab or suspected sheep scab in a manner similar to the provisions of the Sheep Scab Order (Scotland) 2010 and for giving notification to and provide for, the treatment of, contiguous premises.
58. In terms of developing and implementing legislation Annex III and Annex IV of this report include a suggested approach to be adopted in tackling sheep scab in the form of an:- Outline for the operation of a Sheep Scab Eradication Programme in an affected area (Annex III); and A process Flow (text & diagram) for implementation of a Sheep Scab Eradication Programme (Annex IV)
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Industry Activity
59. Farmers appreciate that they need to be proactive in any effort to eradicate sheep scab and a number of industry initiatives have been reviewed. It is clear that incremental steps taken by farmers can make a significant difference, a series of small changes that can add up to a substantial whole.
60. In reviewing current practice however, it is accepted that improvements need to be made by industry in a number of areas with the primary example that could make a real difference to scab eradication being improved health planning and biosecurity, especially in practising better isolation and quarantine of bought-in stock, separating them from stock already on the farm for a period of time. Enhanced biosecurity would result in improvement, not just in respect of sheep scab, but in regard to a number of other diseases that affect farms in Wales. Better biosecurity can be regarded as a holistic approach to disease management rather than an ad-hoc response to one particular problem.
61. The sheep industry has attempted to promote better management of disease such as scab for a number of years.
62. The „Stop every Drop‟ campaign has been promoting better sheep dipping practice. The farming industry and the Environment Agency have worked together through „Stop Every Drop‟ in order to reduce pollution incidents from sheep dip chemicals. The campaign provides sheep producers and contractors with the best practice guidance notes for the use and disposal of dips, as well as flock management advice to avoid pollution of natural water courses. Given that dipping is one of the more effective methods of controlling sheep scab, it is important to balance the danger of pollution on the one hand with effective control of scab on the other.
63. The role of veterinary surgeons and their relationship with farmers is regarded as exceptionally important in a scab eradication programme and examples of how vets and farmers can and have worked together have been evaluated. Proper diagnosis is clearly necessary and that can only take place with veterinary input, especially testing through sample skin-scrapings, a procedure that remains the primary tool of diagnosis which should be further promoted to avoid farmers jumping in with treatment which may be inappropriate.
64. Farmers have access to a wealth of information and support to tackle scab such as through SCOPS – the Sustainable Control of Parasites in Sheep scheme. The scheme is funded by Hybu Cig Cymru (HCC) and EBLEX and is directed by a steering committee chaired by the National Sheep
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Association (NSA). This includes representatives from farming unions, National Office of Animal Health (NOAH), Animal Health Distributors Association (AHDA), Responsible Use of Medicines in Agriculture (RUMA), Veterinary Laboratories Agency (VLA). SCOPS has provided industry with a guide to correct diagnosis of sheep scab and recommendations regarding sheep scab treatments.
65. The problem of sheep scab in Wales has therefore been the subject of considerable debate. It has been widely discussed and remained the subject of regular features in the media for some time. Farming publications have identified the options available to treat scab and manufacturers routinely advertise products to deal with it. Farming Connect is being used to deliver information on better management on-farm and in future, it may be worth placing even greater emphasis on animal health planning in general and treating scab in particular.
66. The industry clearly has a responsibility to raise awareness of the scale of the problem, to lead efforts to reduce the incidence of sheep scab by promoting and supporting best practice, to develop innovative schemes to promote treatment, to make every effort to minimise the impacts of outbreaks; and to maximise the effects of preventative action.
67. Funding support from government is considered to be an important element in any sheep scab eradication programme for Wales. There may be an opportunity to develop a new strand of support for farmers active in a sheep scab eradication programme or other animal health improvement scheme via Pillar 2, and alongside the agri-environment schemes and could even be made to fit under existing RDP axes. This could be a „public goods through livestock farming‟ approach with menu based points being awarded for a range of activities such as membership of a Scab Eradication Programme being rewarded with 3 points per Livestock Unit, for example.
68. There are clearly still opportunities for industry to develop innovative initiatives to promote better scab management. For example, one step could be for sheep breed societies that organise sales of breeding stock throughout the autumn to promote the sale of sheep including those that have been quarantine drenched for roundworms and treated against scab prior to sale. Such schemes could be backed up by a system of audit that would verify that sheep had been properly treated. Certification bodies that currently accredit farms against the provision of farm assurance schemes such as the Farm Assured Welsh Livestock scheme, FAWL, could undertake the work at the same time as their farm inspection visit. Certification bodies would monitor action taken by farmers to control sheep scab (including active measures to stop it spreading) and in this way, possibly create commercial reward for
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participants. When making arrangements to visit sheep farms, FAWL assessors could ask whether farmers wished to take part in a sheep scab monitoring scheme. If the reaction was positive, the applicant would receive further information. During a farm inspection, the assessor would check whether applicant farms had procedures in place to minimise the risk of getting the disease in the first place, paying particular attention to the farm‟s biosecurity arrangements and whether the sheep were being or had been treated for scab, be that as a preventative measure or as treatment for an outbreak. Such action would be cross-checked with the stock of medicines stored and the medicine records, (for example, proof of purchase of the required medicines or drugs) and a review of the medicine records to verify the date the animals had been treated.
69. An approach of this kind is considered to be worthy of consideration however, it is likely to be limited in its success without the holistic, proactive approach that a new more robust statutory protocol would have with the focus on eradicating as opposed to solely tackling sheep scab.
70. Two examples of how two different groups of farmers have approached the problem of sheep scab are considered relevant in terms of learning lessons and seeking solutions. One group farms on Ministry of Defence land on Mynydd Epynt while the other operates in the Dyfi Valley.
Mynydd Epynt Group
71. Mynydd Epynt is an upland area bounded to the south by the upper section of the valley of the river Usk, to the north by that of the river Irfon and to the east by the valley of the river Wye.
72. Farming Connect demonstration farmer Rob Powell, runs Blaenbwch, Maesmynis, Builth Wells, Powys with his wife Tracy and has a grazing licence for land on Mynydd Epynt, part of the Sennybridge Training Area, owned by the Ministry of Defence.
73. Blaenbwch Farm, an upland farm extends to 370 acres including the grazing licence. Mr & Mrs Powell also farm Rhosferig Farm (320 acres) six miles away and their farming operation is typical of those found in the area. Blaenbwch‟s livestock includes 1,800 breeding ewes run in three flocks including a flock of 550 Hardy Speckled and Welsh ewes which graze Mynydd Epynt. The family also have 200-250 Welsh Black sired cattle purchased as stores and finished for Waitrose annually.
74. Mynydd Epynt has operated as an army training area since 1940. It extends to approximately 31,000 acres, much of which is above 1,250ft. Around 90
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local farmers are granted licences to graze specific areas or „walks‟ with hefted flocks totalling 44,917 sheep. Mynydd Epynt entered the Glastir Commons Scheme earlier this year.
75. The control of sheep scab on Mynydd Epynt is an issue taken very seriously by the Ministry of Defence and they include regulations relating to sheep scab in the grazing licences issued to all graziers.
76. It is a requirement of the licence that all sheep are dipped or injected on dates agreed between the Graziers Committee and the Ministry of Defence. The Ministry of Defence also reserves the right to access the medicine records of graziers, certifying that dipping and/or injecting for scab has taken place.
77. Graziers are not permitted to graze sheep infected with sheep scab on the Training Area. Any flock found to be infected must be removed immediately and will not be permitted back until the condition has been cleared to the satisfaction of the MOD Land Agent and a Graziers Committee representative.
78. Rob Powell is one of the members of the Mynydd Epynt Graziers Association committee made up of representative graziers from each area. The committee has a key role confirming dates for compulsory hill clearances for shearing together with compulsory clearances and treatment as part of the sheep scab disease control programme each August and October. Dates are confirmed well in advance and graziers are advised via letter.
79. Rob Powell commented that “Graziers are advised of clearance periods together with a designated time when a secondary gather to collect up any strays can be undertaken. It is only through this level of co-operation that we are able to take active steps to prevent sheep scab in our flocks which is a significant cost to the industry – estimated to be £2.3m annually in Wales”.
Dyffryn Dyfi Group
80. The river Dyfi rises below Aran Fawddwy, and the Dyffryn Dyfi Valley flows south to Dinas Mawddwy and Cemmaes Road, then south west past Machynlleth to Cardigan Bay. It is relatively enclosed geographical area with natural boundaries such as the river itself and its tributaries as well as roads that can act as barriers to stock movement as well as to human activity.
81. There are over 100 sheep farms within the valley itself and a number of them are organic. Farms are enclosed with no open, common land. There is little of the custom of sheep gathering that is found in many upland areas of Wales,
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activities that bring groups of farmers to work together but the traditional spirit of community and good neighbourliness found throughout rural Wales is strong.
82. Following a serious outbreak of scab disease in the area in 2009, a group of farmers came together to try and tackle the situation. Grwp Ymgyrch Difa Clafr Dyffryn Dyfi, the Dyfi Valley Scab Eradication Campaign Group, placed an advert in local newspapers to ask farmers to attend a meeting to discuss sheep scab in the valley and to encourage them to come together to tackle the problem.
83. Twenty farmers turned up at that first meeting with two local vets in attendance. The farmers‟ flocks ranged in size from 400 to 1200 breeding ewes and all on farms that were well-bounded and fenced in a geographically manageable area. The fulcrum of activity was to be Maesllwyni and Maesterran farms in Penegoes, Machynlleth that had been affected on more than one occasion in the recent past.
84. The initial strategy was to persuade farmers to work together to tackle scab, to encourage cooperation in deciding when to treat sheep, how to treat them and what product to use. It was also made clear that participants would need to be open with others in the group and be prepared to talk about how scab affected them, if at all.
85. Agreement on the timing of treatment was one priority with some group members favouring September, others, especially organic producers preferring to wait until November after finished lambs had been sold, leaving breeding stock only to be tackled. Advice was sought on sensible options and a 42 day treatment window was agreed when all participants would treat their flock, later reduced to a 28 day window.
86. Some farmers favoured organophosphate dipping their sheep which has persistent action of up to 28 days. Other farmers favoured Cydectin 2% LA injection (registered trademark, Pfizer Animal Health), which has persistent action of 60 days.
87. In the three years since that first meeting, the incidence of sheep scab in the Dyfi Valley has fallen back but there are still a significant number of regular outbreaks. The group points to much improved cooperation between its members in that they are more prepared to discuss sheep scab with their neighbours now, informing them if their flocks become affected. The level of awareness of sheep scab and how to treat it is also much improved and the cooperation in the timing of treatment has been a positive element.
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88. However, there remains an unacceptable level of scab in the area. There are a number of famers who have steadfastly refused to cooperate and who cannot be persuaded to join. Other, mainly smaller farmers are difficult to contact with little opportunity for busy farmers to spend a lot of time managing the process.
89. The group has clearly made progress over three years but its members believe that their ambition to eradicate sheep scab will not be achieved without some power to force recalcitrant farmers in particular to act.
90. Dafydd Jones of Maesllwynni, Penegoes one of the group‟s leaders viewed with envy the ability of the Mynydd Epynt‟s graziers to enforce their rules on scab treatment. Mr Jones stated “I‟m pleased that we‟ve made some progress in tackling scab in the Dyfi Valley but it remains a chronic problem that we simply can‟t eradicate without having some control of those farmers that appear to just turn a blind-eye”.
91. The review of activity undertaken by the farming industry itself to deal with sheep scab and the various attempts that have been, are being, or could be made by industry and other stakeholders to eradicate it, clearly shows both the scale and breadth of those attempts. It has to be accepted though that the eradication of scab from Welsh sheep farms is as elusive as ever. The industry alone is not in a position to solve the problem.
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Funding
92. The focus of this report has been the eradication of sheep scab from Wales. It is an ambitious goal and the report‟s recommendations will have implications for Welsh Government its partners and stakeholders. That goal will be reached more readily if farmers are encouraged to work together to tackle sheep scab, supported by a strong regulatory framework.
93. One important concern will be the cost implications of some of those recommendations and whether support might be available to help implement them.
94. An area of opportunity in terms of encouraging farmer engagement would be to explore ways of reducing the financial regulatory burden on farmers by reviewing the costs associated with requiring individual farmers across Wales to arrange and pay for an environmental permit, authorising the discharge of waste water following sheep dipping. To protect the environment, the Environment Agency currently requires that disposal of waste sheep dip must only be carried out in accordance with an environmental permit (for a groundwater activity) authorising its discharge. The current annual subsistence charge for a small liquid discharge, less than or equal to 10 m3/yr is £153.90.
95. It is recommended that Ministers require a review to be undertaken of the Environmental Permitting Regulations in respect of sheep dip groundwater discharges to include ways in which the annual licensing charging system can be replaced by an approach which is risk based for example, introduction of a farmer declaration and spot check system. This could be a task for the new body Cyfoeth Naturiol Cymru / Natural Resources Wales, which now includes the functions of the former bodies known as the Countryside Council for Wales, the Environment Agency Wales, and the Forestry Commission Wales.
96. The Rural Development Plan (RDP) post 2014 is one avenue that will need to be considered as a vehicle for funding to facilitate the implementation of certain recommendations contained in this report including a focus on improving business efficiency.
97. It is understood that there is scope for the RDP 2014 - 2020 to make payments to support activities that relate to animal health and welfare, activities such as animal health planning, knowledge transfer or participation in a specific disease control or eradication programme. In this way, CAP funding would be directed at activities that have been identified as key priorities.
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98. One scenario envisaged is a „public goods through livestock farming‟ approach with a menu based points per livestock unit system providing financial support. Farmers would be rewarded for participation in a range of animal health and welfare activities such as membership of a scab eradication scheme. Support could also be channelled through other avenues such as the Glastir Commons and the requirement to establish a Sheep Scab Eradication Programme.
99. A wider option would be to set up a project under the RDP with its objective being the improvement of the health and welfare of farmed animals in Wales and a scab eradication programme (with the expected outcome of a scab- free Welsh sheep industry) being a single element. The expected cost of the project would need to be estimated.
100. The group recognises it is likely that monies under the RDP 2014 - 2020 will not be available in the form of grant funding until 2015.
101. It is important that officials are able to inform Ministers of how core Welsh Government programmes including the RDP are able to best be utilised to deliver activities arising from the recommendations of the group. It is also essential that the industry supports efforts to obtain support for improvements in animal health and welfare in the next round of the RDP, 2014 to 2020. Support for a general Animal Health & Welfare Scheme with provision of advice and funding for projects such as scab eradication, is considered important to achieve sustainable food production; particularly if there is flexibility to allow different disease priorities to be addressed. Farmers and industry organisations should also be able to develop specific projects that complement the strategic approach, with the aim of targeting funding where it is most needed.
102. The Animal Health and Veterinary Laboratories Agency (AHVLA) has recently worked with the Sheep Scab Task & Finish Group to deliver a high level, indicative costing to support the proposals for the eradication of Sheep Scab in Wales. This information is being submitted separately to this report
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Recommendations
The recommendations provide a practical working framework to address the serious welfare implications of Sheep Scab disease that currently exists in Wales. The debilitating nature of the disease, the ensuing production losses and the costs involved with treating the disease adds a significant financial burden onto the industry.
1. Strengthen current legislation and make sheep scab a notifiable disease in Wales.
2. Enforce the treatment of all sheep on premises confirmed as being affected with sheep scab.
3. Amend the current Sheep Scab Order 1997 to include a Provision which allows Animal Health & Veterinary Laboratory (AHVLA) to make notification to, and enforce treatment of, premises which are contiguous to an affected premise. The Order should make reference to the fact that movement restrictions will remain in place on contiguous premises until treatment has occurred. All sheep in contact with a confirmed case of sheep scab must be treated or slaughtered no later than 14 days after confirmation of the disease unless veterinary evidence is provided that scab does not exist on that contact premise and / or adequate biosecurity measures are in place25.
4. Amend the current Sheep Scab Wales Order 1997 to include a provision which authorises Animal Health & Veterinary Laboratory (AHVLA) to trace the movements of sheep on and off the affected premises for 14 days prior to confirmation of the disease. The amendment should include a provision which includes notification to inform premises identified through the tracing of on and off movements.
5 Amend the current Sheep Scab Wales Order 1997 so as to include a definition for affected animals, while removing the references to „sheep visibly affected with sheep scab‟. This definition should include animals “suspected of being affected” so as to allow actions on suspicion and not just confirmation. Additionally, amend the Order to also include definitions of infected premise and contiguous premise so that any contact premises i.e. those contiguous to an infected premise, are brought into the scope of sheep scab legislation.
25 Following a Council resolution in December 2013, the Farmers’ Union of Wales does not lend its support to any aspect of recommendation 3.
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6. To complement changes to legislation and two years prior to the introduction of legislation, establish an holistic „Sheep Scab Eradication Wales‟ campaign including workshops, seminars, open days, training days and best practice initiatives. The campaign should promote improved quarantine and biosecurity practices on-farm as well as mitigate current obstacles and risks such as incorrect dosing; inappropriate drug choice; misdiagnosis; and the importance of including sub-clinical cases in a treatment programme. These initiatives would be based on principles developed by Sustainable Control of Parasites in Sheep (SCOPS). In developing any campaign consideration should be given to the activity which is currently being delivered on sheep scab in England. This is funded under the Rural Development Plan for England (RDPE). An example letter invitation to a project meeting is included in Annex V.
7. Establish an on-going monitoring and evaluation programme to establish the effectiveness of the amended legislation and „Sheep Scab Eradication Wales‟ campaign.
8. Welsh Ministers to require Cyfoeth Naturiol Cymru / Natural Resources Wales to establish a Task and Finish Group with industry involvement to review the Environmental Permitting Regulations and their implementation in respect of waste sheep dip groundwater discharges. This new group should consider ways in which the costly annual licensing structure can be replaced by a risk based approach based on the Working Smarter agenda; for example, which includes the introduction of farmer declarations and system of spot checks. This should aim to enhance compliance and reduce risk resulting in a more sustainable approach all round.
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Annex I - Terms of Reference
AHWSSG Sheep Scab Task & Finish Group
Terms of Reference for the Group, as agreed at the inaugural meeting of the T&F group on 13 December 2011:
Group Objective: To recommend a strategy on the eradication of sheep scab in Wales for consideration by Welsh Ministers.
The group will endeavour to meet its objective by:
Reviewing legislation controlling sheep scab and considering legislation that may be required to support the objective of eradicating sheep scab in Wales; the level of enforcement that may be desirable and how it can be enforced. Considering obstacles that can block the process of eradicating sheep scab in Wales Assessing how industry & stakeholder organisations can contribute to achieving the group‟s objective Studying the potential risks that can arise from the introduction of policies intended to eradicate scab (for example, increasing the development of anthelmintic resistance through additional use of injectable treatments); Appraising the value of local initiatives for the medium term in the light of experience elsewhere; Examining how identification and diagnosis to aid correct treatment may be facilitated; Evaluating how any recommendations might be funded.
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Annex II - Sheep Scab Task & Finish Group members
Members
Helen Davies - National Sheep Association (NSA)
Peter Davies - National Farmers Union (NFU) Cymru (withdrew)
Lyndon Edwards - National Farmers Union (NFU) Cymru (replacement)
Dafydd Jones - Maesllwyni, Sheep Farmer
Moss Jones - Welsh Lamb & Beef Producers Ltd
Siôn Aron Jones - Hybu Cig Cymru (HCC)
Ifan Lloyd - British Veterinary Association (BVA)
Ian Millington - Welsh Local Authorities
Iwan Parry - National Beef Association (NBA)
David Pugh - Animal Health Veterinary Laboratories Agency (AHVLA)
Rachel Lewis - Menter a Busnes (MaB)
Hazel Wright - Farmers‟ Union of Wales (FUW)
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Annex III – Outline for the operation of Sheep Scab Eradication Programme in an affected area
Terminology used in the following explanation:
Notifiable disease: A notifiable disease is any disease that is required by law to be reported to government authorities as is the case with sheep scab in Scotland at present.
Confirmed case of sheep scab: Live Psoroptes Ovis found as skin scraping, diagnosed in a laboratory.
Infected Premises: An identifiable entity where a confirmed case of sheep scab is found: this can be an unit/holding/part or whole farm.
Treatment: Treatment of sheep with a licensed product.
Scheme Requirement:
All sheep in contact with a confirmed case of sheep scab have to be treated no later than 14 days after confirmation of the disease.
The area of land in question can be described as a treatment zone/area
If the treatment of sheep involves injectables, the animals need to be retained on the unit in question for 14 days as there may be a problem of re-infestation and timing of when mites are killed post treatment. Since the effect of any injectable on scab mites is not immediate, contact between treated-infected sheep and non-treated, non-infected sub flocks must be avoided until at least 12 days after the last treatment.
Practical issues need to be resolved at the start of any eradication programme. These can include issues such as the following:
Issue: Suggested Action to be agreed: Commoners will need to consider an annual period Common Land (agreed between commoners) to keep the common land free of sheep for a period of time. Everybody involved should make all possible efforts to keep sheep out of the forest. If sheep Forest Area are found in a forest and have no identification then deciding on ownership becomes difficult. The preferred option is that they should be disposed of. If stray sheep are found in treatment area and Stray Sheep have identification then they require treatment prior to being returned to home farm. If they
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have no identification, the preferred option is that they should be disposed of. There will be a need to trace sheep moved from or Tracing linked to a confirmed case to prevent the spread of disease It will be important for biosecurity principles to be adopted including on units with no evidence of Bio-security sheep scab (e.g. in respect of animals bought in) In transport areas – bio-security of vehicles involved with moving sheep. Where statutory regulations have been enforced it is very important that the situation is reviewed Annual Review between veterinary surgeons and farmers on an annual basis to monitor its success.
To illustrate the variety of situations that might arise if it were to become compulsory to treat sheep scab in Wales, the following scenarios of farming set-ups have been identified.
X• Y• 3• N• 2• Z• M• 1• A• Common L• 4• Land B• C•
Assumed: A is a unit, holding, part or whole farm where a confirmed case of sheep scab is found.
B and C are farmed in conjunction with A Common land linked to A
Farms 1,2, 3&4 are farms/units in direct sheep contact to confirmed case in A
L,M&N are in direct sheep contact to confirmed case of scab at 1
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X,Y&Z are in direct sheep contact to farm 3
Scenario 1
This is considered the most straight-forward scenario;
A is a single farm unit where sheep scab has been found. Consequently, all sheep in contiguous premises 1, 2, 3& 4must be treated.
Scenario 2
Scab is then confirmed to be present on units 1 & 3.
The treatment area will need to expanded under statutory legislation. If farm 3 believes that farm Z has a problem but there is no confirmed case, then farm Z does not need to be involved.
However, if there is a confirmed case on Z, statutory enforcement will be necessary.
Scenario 3
Farm A has two parcels of land at B&C as part of the overall farming unit.
There is sheep contact between A and B but no sheep contact between A&C and a veterinary inspection on C shows no clinical visible signs of sheep scab and bio- security on the unit is sound to support the conclusion that no sheep scab is present.
As there has been contact between A&B, sheep on unit B will need to be treated.
However, sheep on unit C should not need to be treated unless the bio-security measures on the unit are considered to be inadequate, creating a risk of the spread of disease.
Scenario 4
Farm A is connected to common land.
All sheep on the common land would need to be treated and it would be an opportune time to discuss with commoners that the land becomes free of all sheep for a certain period of time, annually.
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Annex IV – Suggested Process Flow (text & diagram) for implementation of a Sheep Scab Eradication Programme
On Farm Suspect
1. Farmer suspects Sheep Scab due to sheep scratching. Farmer at his own expense consults his own vet (OV) who visits farm or suspect sheep is taken to the practice.
2. OV (at farmer‟s expense) takes samples and either confirms diagnosis in his own laboratory or sends samples to a diagnostic laboratory. If an instant diagnosis cannot be made then the OV will serve a Restriction Notice on the farmer which will restrict any sheep movements off this farmer‟s premise.
3. If negative result for Sheep Scab then the Restriction Notice will be lifted and any further investigation will be agreed between the farmer and his OV. If positive then the OV will confirm with the farmer and instruct him to treat as well as issuing a Restriction Notice. A copy of the notice to be sent by the OV to Animal Health Veterinary Laboratories Agency (AHVLA) and Local Authority Trading Standards (TS).
4. Restriction Notice will instruct the farmer to treat all his sheep with an authorised product within 14 days of the confirmation and inform AHVLA/TS once treatment has been successfully completed.
5. On receipt of the Sheep Scab Notice AHVLA will arrange a farm visit to carry out an epidemiological investigation. At this visit information such as tracings on/off the farm as well as contiguous premises for all the affected areas of land will be gathered. This information will be acted upon by AHVLA who will issue Restriction/Treatment Notices and letters to all the relevant contiguous premises. Depending on the severity of the infection and factors such as stray sheep, AHVLA could extend the treatment area into a Treatment Zone which could cover all sheep premises within a 3 km radius of the confirmed premises. All these will have to treat their sheep with an authorised product unless adequate biosecurity measures are in place and / or they can produce a document from their own vet at the farmer‟s expense stating that the sheep on their client‟s farm are not affected with Sheep Scab. If this cannot be produced then all the sheep on the premises will have to be treated with the AHVLA/TS being informed in writing by the farmer of the successful completion of the treatment programme.
6. Once a signed treatment declaration has been received by AHVLA/TS the restrictions will be lifted.
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
7. If a treatment declaration has not been received within 21 days of the Treatment Notice date then TS will initiate an investigation which could lead to prosecution.
8. All tracings off the premises will receive a letter from AHVLA informing them of the positive Sheep Scab diagnosis on the farm of origin and advising them to treat the bought in sheep or treat the whole flock if these sheep have already mixed with the home flock.
9. Movements on to the farm in the weeks prior to the suspect being identified will be investigated. This could result in the farm of origin of the suspect bought in sheep being either visited by AHVLA or issued with a Treatment Notice.
Off Farm Suspect
1. If suspect sheep are identified off farm then a private veterinary enquiry will have to be set up. If this happens at a market it is the market owners‟ responsibility to call in a private vet who will carry out the investigation as above. The vet will serve a Restriction Notice on the sheep owner whilst the investigation is taking place. If the disease is confirmed the Restriction Notice will be reissued/amended to cover all land farmed by this farmer which has sheep. The suspect sheep will not be fit for sale and can either be licensed directly back to the farm of origin or direct to a local slaughterhouse.
2. If the samples are positive the farm of origin will have to treat as above
3. The sheep in the adjoining pens to the suspect sheep will be identified. If the diagnosis is positive then the sheep in these pens will be traced and a letter sent out to the current owners advising them of the diagnosis and recommending that the sheep involved or the group of sheep that these have mixed with are treated with an authorised product.
Suspected Sheep Scab on Common Land
1. The investigation will be carried out as above.
2. If confirmed then a Restriction/Clearance/Treatment Notice will be served on all the sheep owners of the common grazing. AHVLA will arrange a meeting with the graziers to discuss the implications and agree a treatment programme.
3. The common land to be clear of sheep for a period of 14 days from the date of the final removal of sheep off the common.
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
Treatment Zone Zone Treatment imposed Restriction / Restriction Letter Treatment sent
copy copy AHVLA/TS) Remove Notice Notice Remove ( Risk Assess Risk Assess other lands No contact No
Contact Negative
Remove/Amend Remove/Amend Notice
Enforcement Enforcement Action
No
Process Flow Process
Positive
Notify AHVLA/TS Notify Farm Suspect Farm Yes Declaration Receipt Receipt Declaration AHVLA/LA sent to Treatment Notice ALL ALL Notice Treatment Sheep Slaughter / Treatment
Vet Enquiry/ Sample/ Notice Sample/ Vet Enquiry/ Remove Remove Notice
Trace Contacts/ Letter
Home
Letter instructing/ instructing/ Letter treatment advise Trace Movements on & on Movements Trace days) off (14
/TS/PVS Off Farm Off Farm Suspect Licence Notify Notify AHVLA
Slaughterhouse
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AHWSSG Sheep Scab Task and Finish Group Paper January 2014
Annex V - ‘Stamp Out Scab’ – England Training and Awareness Campaign
The incidence of sheep scab has increased steadily since deregulation of compulsory dipping in 1992 and in some areas scab is now an endemic problem. The most recent estimates suggest that more than 10% of flocks experience one outbreak of scab a year and the situation seems to be getting worse. This is costing the industry millions every year.
This programme of training events has been organised to raise awareness and improve understanding of the control options – dipping in organophosphate or use of injectable endectocides, and the importance of flock security to improve disease control.
This is not only a farmer’s problem – those transporting, shearing, scanning, inspecting and selling sheep and those advising and selling medicines all have a roll to play.
We will provide clear and consistent guidance to the whole industry and need all sectors to engage in the training and take their share of responsibility for reducing the incidence of scab.
One of the most challenging aspects of control relates to the over-use of the injectable endectocides and further development of anthelmintic resistance.
This round of events is targeted at those who provide services to sheep farmers – e.g. shearers, scanners, Trading Standards officers, assurance scheme inspectors, RPA, animal health officers, auctioneers, pharmaceutical representatives, hauliers, field officers for markets and abattoirs etc. Events for farmers, vets and SQPs are scheduled later in the year (June/July onwards).
ADAS consultants and veterinary surgeons will be delivering the training on behalf of Eblex (AHDB). The project, funded by RDPE, will be delivered throughout 2013.
The short training course from 2 to 4 pm will include:
2.00 pm Sheep scab – impacts and implications – ADAS 2.30 pm Treatment options and challenges – Specialist Sheep Vet 3.30 pm Open discussion and will close with tea and coffee at 4.00 pm.
Key messages Flock security – keep the disease out! Diagnosis – accurate diagnosis - is it lice or scab? Treatment – use an effective product and follow the manufacturer‟s advice Consider the impact of treatment on anthelmintic resistance
Please join us at one of the events listed and learn more about how you can help „Stamp out Scab’. To book your place please telephone ADAS on 01432 820444 or email [email protected]
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