Questions and answers about the TB Plan review

Page updated 28 July 2015

Why is the TB Plan being reviewed?

 

The Biosecurity Act 1993 (the Act) requires the Plan to be formally reviewed on a regular basis. Subject to the timing of a National Policy Direction under the Act, the Minister for Primary Industries is required to start a statutory review of the Plan by 1 July 2016.

 

Each review provides an opportunity for the Plan to be updated and improved in accordance with the wishes of funding parties and other stakeholders; and for the wider public to influence decisions about future actions under the Plan.

 

The Plan was last reviewed following notification of an amendment proposal by the Minister of Agriculture in September 2009. An Order in Council amending the Plan came into effect on 1 July 2011. Subject to the timing of a National Policy Direction under the Act, the Minister for Primary Industries is required to start a statutory review of the Plan by 1 July 2016.

Why is bovine TB an issue?

 

As a disease of farmed cattle and deer in New Zealand, if left unchecked, TB would cause unacceptable animal health impacts, and significant production losses. In New Zealand, TB is spread by non-native wild animals, including possums and deer.

What does control of TB actually deliver?

 

Effective control of TB in cattle and deer herds is important to:

 

  • prevent, avoid and manage animal health implications relating to TB infection;

  • prevent, avoid and manage livestock production losses and associated costs of TB infection to industry;

  • deliver upon and satisfy market and consumer assurance requirements;

  • maintain and build on the significant gains made in managing TB; and

  • realise cost-savings and gains in overall effectiveness from a single national programme – without duplication in separate industry or regional programmes.  This enables economies of scale in the design and delivery of operations.  It also enables a skilled workforce and wide-ranging organisation capability to be build and maintained, in order to address the challenges posed by TB across New Zealand.

 

Control of the non-native pest animals responsible for the spread of TB also contributes to the protection of indigenous biodiversity as effective control reduces the damage such animals do to native plants and animals.

How did the national TB Plan come about?

 

The Plan commenced in 1998 and was made under the Biosecurity Act 1993.  As well as enabling the use of statutory powers, the Plan is seen by affected industries (dairy, beef and deer) and government as essential to support:

 

  • long-term funding arrangements;

  • achievement of shared TB management objectives; and

  • a nationally co-ordinated approach.

What are the advantages of having a national TB plan?

 

As TB is spread by wildlife, control measures must extend well beyond individual farms. The plan enables controls to apply irrespective of land ownership, land use, or regional boundaries.

 

Industry costs and benefits can be shared in an appropriate manner and cost efficiencies achieved by co-ordinating activities and resources at a national level.

 

Nationally consistent regulations on livestock testing and movement, herd registration and animal identification, along with nationally-collated disease control records and information systems, are essential for management of in-herd infection and to prevent herd-to-herd infection. However, the Plan also supports a flexible approach where regional or local variations are appropriate (as with herd testing policies).

Who is leading the current review?

 

The review is being led by a ‘Plan Governance Group’ (PGG) established by funding parties and wider stakeholders. The PGG has an independent Chair (Chris Kelly) and independent Member (Russ Ballard).

 

Other members of the PGG include the Chief Executives of DairyNZ, Beef+Lamb, and Deer Industry NZ, the Chair of the Stakeholders' Council, and representatives from the Ministry of Primary Industries and OSPRI. 

What are the major issues being considered by the review?

 

The current review is looking to confirm whether eradication of TB from New Zealand is feasible and how best to go about containing the disease and/or achieving eradication over different timeframes. 

 

This involves taking account of matters, in no particular order, such as:

 

  • the general and specific benefits derived from TB control/eradication and vector control (including potential benefits for future generations);

  • the practicability and efficacy of disease and vector control options;

  • how eradication could be achieved within varying timeframes;

  • the annual and total overall costs of different options and timeframes;

  • ensuring fair, equitable, affordable and sustainable funding for ongoing Plan implementation;

  • international trade and reputational implications associated with TB control; and

  • the effects on the relationship of Maori and their culture and traditions with their ancestral lands, waters, sites, waahi tapu and taonga.

How can farmers and other interested people get involved?

 

During the review consultation process, to be held from the 23rd June to the 31st July 2015, there are plenty of opportunities for all interested parties to have a say. A discussion document is available on the website setting out the proposed changes, along with other supporting papers with further information. Written submissions are encouraged and can be made through the website, email or via post.

 

Plan review representatives will hold information sessions around New Zealand to discuss and explain the proposals and answer any questions that arise – see the timetable on the website.

 

Some targeted farmer surveys will also be carried out to ensure that a broad and representative range of farming views are captured and considered.

 

During August-September 2015 consultation outcomes will be analysed, final proposals will be prepared in light of those outcomes and the proposals will be submitted to the Minister.

 

The Minister must be satisfied that adequate consultation has been undertaken on the proposals and that issues raised during consultation have been considered. If the Minister believes that widespread agreement on the best approach has not been reached, then the Plan can be the subject of a Ministerial Board of Enquiry.

What has been done to inform review proposals?

 

A lot of work has been undertaken to ensure review proposals are based on sound science and the best technical evidence available. Particularly important pieces of work have focused on:

 

  • reviewing and improving complex epidemiological modelling and the assumptions that underpin modelling outputs to improve their accuracy and reliability;

  • an independent scientific review of the feasibility of eradication;

  • reviewing all the benefits that arise from the TB Plan such as trade and biodiversity; and

  • reviewing the investment in scientific research and identifying future research needs.

Will there be any changes to powers used to support Plan implementation?

 

There are no proposed changes to the general powers already set out in the Biosecurity (National Bovine Tuberculosis Pest Management Plan) Order 1998 - the powers conferred under the Act on the management agency and authorised persons.  

Will there be any changes to the management agency for the TB Plan?

 

TBfree New Zealand Limited, a fully-owned subsidiary of OSPRI New Zealand Limited, is the current management agency. It is proposed that TBfree New Zealand remains the management agency for the TB Plan.

 

All groups that are directly affected by the Plan, and contribute funding to it, are stakeholders. Stakeholders’ interests are well-represented through the company Directors, shareholdings, membership of the TBfree Stakeholders’ Council or by the Government.

What are the tasks completed by the management agency?

 

Management agency responsibilities include:

  • programme design and preparation and implementation of an Operational Plan (required by the Act);

  • contracted services and enforcement of the Plan rules;

  • providing farmer support, continuing education and communications; and

  • providing information and reports to the Minister, other interested parties and the public.

What are the implications of Regional Councils no longer funding the Plan?

 

Currently, the regions contribute around $6 million to Plan costs each year.  However, as the proposed new Plan costs are lower than the current Plan costs, it would not create a shortfall of funding.  The portion of funding that came from the regions has been incorporated into the industry and Crown funding shares.  It is also important to note that the removal of funding from regional councils will result in some cost savings and efficiencies – TBfree New Zealand will no longer have to spend time negotiating with each council for the funding each year.  The revised funding model will provide greater security of funding for the TB Plan.

Does the proposal rely on the aerial application of 1080?

 

Yes, all the options considered rely on the continued ability to aerially apply 1080 in some areas. Only around 10% of vector control is done this way, around 90% is done by ground control.

 

Under the proposed eradication Plan, the use of aerial 1080 would continue but is expected to drop away to virtually none by the early 2030’s.

How is the use of 1080 being improved?

 

There has been considerable improvement in baiting technology over the years.  The amount of 1080 applied/ha has been reduced from approximately 25kg/ha in 1970s and 1980s to just 2kg/ha in 2015 (equivalent to 4-6 baits being applied to the area the size of a tennis court). Trials are currently underway that aim to further reduce the application rate, these trials are showing promising results.

Cattle slaughter levy - why does OSPRI not collect this?

 

The Cattle Slaughter levy is collected at the point of slaughter as this is the most cost effective collection point.  The levy is deducted by the meat processor from the payment to the farmer. This is consistent with a number of other levies (eg NAIT, Beef commodities levy, Deer industry levy).

What are the current funding shares and the proposed new funding shares?
Why is surveillance carried out on possums?

 

Possums are used as a surveillance tool to find out what level of TB exists in wildlife, and also to understand the threat of reinfection of livestock from neighbouring areas. This helps to ensure that OSPRI is only targeting vector control at areas where there is incidence of TB, and doesn’t waste money on areas that don’t need control for TB.

What will happen with possum control in areas where TB has been eradicated?

 

Pest control carried out under the National TB Plan does deliver significant biodiversity benefits.  However, the control of possums and other pests is only carried out under the Plan where control contributes to the achievement of the Plan’s TB-related objectives.  As is already the case in many TB free areas, agencies with pest control roles (eg, regional councils and the Department of Conservation) and individual landowners will develop and fund their own possum control plans and programmes.    

Why are different cattle slaughter levy rates proposed for beef and dairy cattle and how will this work in practice?       

 

Beef sector funding for the National TB Plan comes entirely from the slaughter levy.  Dairy sector funding comes from both the slaughter levy and a commodity levy on milk solids.  Proposed Plan amendments and new funding shares mean the beef sector share will reduce while the dairy share remains about the same – hence the proposal to reduce the slaughter levy for beef cattle.

 

To be effective, this differential approach will require a quick and simple method for identifying dairy and beef cattle in the context of a wide range of farming practices.  Implementation options are still being considered and consultation feedback will enable the Plan Governance Group to decide whether and how to pursue the differential levy proposal.    

 

 

How will landowner funding for the Plan be collected if regional council and Otago land levy contributions cease?   

 

The proposed approach will mean that the annual negotiation process is no longer required and landowner contributions are effectively collected through the other funding streams, including the Crown contribution.  This also means that farmers will no longer be paying through regional council rates (or the Otago land levy) as well as through slaughter and/or commodity levies.

 

Under the current National TB Plan, regional funding and some of the Crown funding is required because landowners (including the Crown) are exacerbators of the TB problem.  ‘Exacerbation’ relates primarily to land harbouring possums and other TB vectors.

 

The annual process of negotiating, agreeing and collecting most regional landowner contributions from regional councils is challenging for all concerned and the outcome of the process is always uncertain.  Also, requirements for funds to be spent in the region from which they are collected do not enable or support an efficient national approach.   

 

 

 

Does Crown funding cover their responsibilities as exacerbators (because possums live on Crown owned land)? 

 

It is now proposed that landowners should be treated solely as beneficiaries of the Plan and not exacerbators – this applies to the Crown as well as farmers and other landowners. The rationale for this proposed change is important but detailed – essentially treating landowners as beneficiaries provides a more robust basis for ongoing funding. 

 

Exacerbator charges should incentivise exacerbators to take actions to avoid the charge (so that charges aren’t simply an unavoidable tax). Avoidable charges would not sit comfortably with the Plan’s implementation across large land areas. Given movement of possums, it would also be difficult for any single landowner to remain ‘clear’. It would also carry less legal risk; be a more positive footing for engagement with landowners about the Plan; and ensure a more coherent funding methodology focused on benefits and beneficiaries.

 

It is proposed that the Crown would fund the TB Plan on the basis of environmental, human health and economic benefits received by the New Zealand public – the result being an increase in the Crown’s share from 37% to 40%.  As the total cost of the proposed TB Plan is lower, however, the contribution from the Crown will reduce from $30 million to $24 million annually.

There is a continued problem with the illegal catch and release of wild pigs and deer around New Zealand which could spread TB, how will that be managed?

 

If TB-infected pigs are released into a TB free area and then die or are shot and butchered in the field, the resulting infectious carrion could be scavenged by resident possums or ferrets, thus establishing a new source of wildlife TB. For this reason it is an offence against the TB Plan (under the Biosecurity Act) to release pigs into the wild.  It is also illegal under the Wild Animal Control Act and is managed by the Department of Conservation on the conservation estate.

 

The proposed eradication programme includes an additional 15 year “tail” to prove that TB has been eradicated from all animals, including wild pigs and deer.  Once this is complete, national biological eradication can be achieved.

 

Advocacy and education has been, and will continue to be, directed toward the hunting community to discourage any translocation of pigs from TB risk areas. 

 

The proposed Plan will be reliant on NAIT data - is NAIT ready?

 

NAIT data is more complete and reliable than before – more than 95% of animals going to slaughter or to saleyards are tagged and their movements have been recorded.  Recording of farm to farm movements, however, is around 45% - this must be improved before NAIT can be used for risk based testing.  This is why there is a lead in time of 2-3 years before risk based testing can be fully implemented.  This is the time it will take for OSPRI to get those farm to farm movements being recorded.

 

How many beef cattle are there in New Zealand compared to dairy cattle? 

 

The Ministry for Primary Industries estimates the 2015 numbers at 5.18 million dairy cows and heifers, 3.67 million beef cattle, and 0.96 million deer (Situation and Outlook for Primary Industries 2015, MPI website).

 

What is the breakdown of infected herds between beef and dairy? 

 

 

 

What is the new information that has led to risk based testing?

 

The evolution of NAIT over recent years, and the availability of the data that it holds, has made this approach possible.  

Will farmers that get tested more often have to pay for the testing?

 

In most cases the answer is no.  There are two exceptions to this – firstly where a farmer has been noncompliant with the TB Plan and this means that more testing is required.  The other situation is where the farmer uses risky management practices, such as frequent movements into the herd and/or sourcing animals from a large number of other herds – in this case the farmer is contributing to the risk of the herd contracting TB.  In these situations the farmer may be required to pay for the additional testing.  Further details on this policy will be developed by OSPRI as part of the National Operational Plan, which will be available for public consultation sometime in the next 12-18 months.

What has triggered the decision to go for eradication now – why could that call not have been made sooner?

 

As per the objective under the current Plan, further ‘proof of concept’ work needed to be done in difficult areas to be certain that eradication was actually feasible.  The progress made over the term of the current plan, findings from the work completed to date in the difficult ‘trial’ areas and the outcome of science reviews commissioned by the PGG were what made the call possible now.  

What are the average costs on a ‘per farm’ or ‘per head’ basis?  This would be more meaningful to farmers than the large costs attributed to each sector.

 

It is challenging to calculate a per farm cost as there is significant variation in size and activity. However, individual farmers can estimate the impact on their own operations by using historical production information, any forward production plans, and the proposed collection rates for their particular sector, as below:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

* This excludes the cost of TB testing for deer which is largely met by the individual deer farmers directly. These testing costs are expected to fall close to zero in the first 1-2 years of the new TB Plan as the new approach to risk based testing comes in.

How are the average annual cost savings of around $20 million, compared to the current Plan, going to be achieved?

 

The cost savings would arise primarily from 

  • the proposed change in approach to vector control which will target vector control activitity more effectively (ie decisions on vector control will not be constrained by needing to leverage regional council funding), and 

  • the significantly reduced testing costs expected to be realised from the new approach to livestock testing. 

 

Other savings will come from ongoing efficiency improvements and the removal of restrictions on how contributions from various funders can be spent. 

 

Why are different cattle slaughter levy rates proposed for beef and dairy cattle and how will this work in practice?

 

Beef sector funding for the National TB Plan comes entirely from the TB Plan cattle slaughter levy.  Dairy sector funding comes from both the TB Plan cattle slaughter levy (~$10 million per year) and a direct contribution from Dairy NZ from the commodity levy on milk solids (~$14.5 million per year).  These funding share arrangements have been in place since 2004 when the size and value of the two industries were significantly different to what they are today. 

 

The TB Plan proposal recommends a reduction in the contribution to the costs of the TB Plan from the beef sector (from $18.5 million to $10 million in 2016/17) and for the dairy contribution to remain about the same. The PGG consider the proposed changes reflect the benefits each sector receives from the TB Plan, and the changes in the relative size and value of each sector since the funding arrangements were last reviewed. 

 

The proposed new funding shares require the cattle slaughter levy for beef animals to be reduced from $11.50/head to an estimated $6.25/head to ensure the appropriate share of funding is collected from beef farmers. If the lower beef cattle slaughter levy is also used for dairy cattle, as currently happens, the Dairy NZ contribution from its milk solids levy income would need to increase by $4.6 million to $19.1 million per year. However, if the cattle slaughter levy for dairy animals remained at the current $11.50/head there would be no need for Dairy NZ to increase the contribution out of its milk solids levy.  

 

To be effective, this differential approach will require a quick and simple method for identifying dairy and beef cattle in the context of a wide range of farming practices.  Implementation options are still being considered and consultation feedback will enable the Plan Governance Group to decide whether and how to pursue the differential levy proposal.    

 

 

How will landowner funding for the Plan be collected if regional council and Otago land levy contributions cease?

 

The proposed approach will mean that the annual negotiation process with regional councils is no longer required, with landowner contributions are effectively collected through the other funding streams, including the Crown contribution.  This also means that farmers will no longer be paying through regional council rates (or the Otago land levy) as well as through slaughter and/or commodity levies.

Is inflation taken into account in the proposed funding?

 

No, this has also been the case with the current plan since 2004.  There will continue to be a reliance on OSPRI to achieve ongoing efficiencies and other cost-savings that offset inflation.

What are the ‘worst case’ areas referred to in the workshop presentation that would become the priority targets under the amended Plan?

 

Precisely which areas would be targeted and when will be identified by OSPRI as part of its operational planning to implement the proposed changes.  This will also depend on the findings of surveillance about the actual TB status of vectors in different areas, where neither control nor surveillance have previously been undertaken.  However, parts of the West Coast of the South Island with significant vector-related herd infection, would be examples of places most likely to become high priority target areas.  

Does eradication mean eradication of possums? 

 

No – it means the eradication of TB disease, by suppressing TB vectors (possums) to low-enough density for the time required to ensure disease dies out of the possum population.  Once the TB disease is gone, the possum population may recover unless control is undertaken by others.

What will happen with possum control in areas where TB has been eradicated? 

 

Pest control carried out under the National TB Plan delivers significant biodiversity benefits.  However, the control of possums and other pests is only carried out under the Plan where control contributes to the achievement of the Plan’s TB-related objectives.  Therefore, as is already the case in many TB free areas, agencies with pest control roles (eg, regional councils and the Department of Conservation) and individual landowners will need to develop and fund their own possum control plans and programmes.    

 

OSPRI will still need to consider how to maintain good operational relationships with regional councils and others undertaking pest control work nationally.  The removal of regional council funding for the TB Plan may assist this process as some of the previous points of tension will no longer exist.

 

As there are only 12 infected herds in the North Island and most are not vector-related, why doesn’t OSPRI simply purchase and depopulate those herds?

 

This has been considered in the recent past but analysis indicated that both at programme and farmer level the costs signficantly exceeded the benefits at this time. At present OSPRI considers depopulation on a case by case basis, but as  as the number of infected herds fall closer to zero, there is scope for OSPRI to include depolulation in its operational policies and planning if OSPRI consider it to be an appropriate tool to achieve the Plan purpose.

 

Is there a risk of TB being spread from humans to livestock?

 

This highly unlikely given very low rates of human infection.  World-wide, confirmed cases of trasmission of TB from humans to livetsock are extremely rare. 

There can be a big impact on farm operations and material losses arising from a lesion being found on one animal when, in the meantime, stock has to be sold at a big loss.  What opportunities are there for compensation under such a scenario?

 

One of the change proposals is to introduce a sliding compensation scale for compensation (0 – 100 percent).  OSPRI would be able to develop compensation policies that take account of situations such as this.     

As there are only 12 infected herds in the North Island and most are not vector-related, why doesn’t OSPRI simply purchase and depopulate those herds?

 

This has been considered in the recent past for a couple of herds. Analysis indicated that, at both programme and farmer level, the costs signficantly exceeded the benefits of depopulation at that time. At present OSPRI considers depopulation on a case by case basis, but as  as the number of infected herds fall closer to zero, there is scope for OSPRI to include depolulation in its operational policies and planning if OSPRI consider it to be an appropriate tool to achieve the Plan purpose.

Currently it is possible to move some C1 animals into a C10 herd and they gain the herd status.  This herd classification approach is problematic - will it continue under the new plan?

 

This operational issue will be addressed in the National Operational Plan to be developed by OSPRI.  It is expected that the proposed new system of risk based herd classification will replace the current C1 – C10 approach as it comes in over the next 2-3 years. 

How will the individual herd risk rating work in practice? Will the risk-based approach to herd testing result in farmers with higher risk herds paying more than others?  

 

The details of how risk-based testing at herd level will be developed by OSPRI as it prepares the National Operational Plan to implement the proposed chnages to the TB Plan.  The new approach will likely be phased in over time (2-3 years).  It is not likely that farmers with high-risk herds will pay more – except where ‘bad’ or ‘risky’ behaviour has contributed to the higher-risk situation (eg, herds/animals from TB free areas that are moved in and out of vector risk areas and herds that are made up of animals brought in from many different areas – including higher-risk areas).

What would the maximum testing frequency be under a risk-based testing regime?

 

This has not yet been decided by OSPRI.  However, if a herd has a high-risk profile, then testing would likely be annual, or possibly more frequent, depending on the specific situation. 

Will post-mortem inspection of animals at slaughter will continue to be overseen by government?

 

This is likely to continue as is it is needed to meet trading partners’ expectations.

What is the status of the development of a new more reliable tuberculin?

 

OSPRI is currently trialling a new tuberculin that they hope will be more specific (i.e. will have less false positives than the current tuberculin) but they are still making sure that it is as sensitive (i.e. does not miss any more of the truly infected animals than the current tuberculin does) as the current tuberculin.

 

As the level of a disease drops then there is a reduction in the positive predictive value of a test. In other words it is not as “reliable” as it is when disease is at a higher prevalence. This is true of all tests not just TB testing – it is the nature of diagnostic tests. 

 

Is the TB test the source of infection in some break downs?

 

There is no evidence to suggest that tuberculin could be responsible for TB infections found in cattle in New Zealand.   The process of tuberculin manufacture involves chemical extraction of bacterial proteins and sterilisation of the product.  Testing of each batch of tuberculin is required to ensure that no living Mycobacteria is present.   The DNA strain type of Mycobacterium bovis used to manufacture the tuberculin that we use in New Zealand today is different to those types isolated from our livestock and wildlife.