Bovine Viral Diarrhoea eradication scheme - phase 6: consultation summary report and analysis

1. Executive Summary

A consultation on Phase 6 of Scotland’s Bovine Viral Diarrhoea (BVD) Eradication Scheme ran from 15 November 2023 to 7 February 2024 and had 17 questions split between 9 proposals. There were 53 responses to the consultation, 12 of which were responses from organisations and 41 from individuals. One individual response was from a vegan farm sanctuary who advocated for a move to plant based agriculture with every response.

Respondents were roughly split in to three groups – one group wanted to increase BVD controls wherever possible, and suggested BVD controls above what was proposed (e.g. tissue tag all calves at birth). The second group wanted to keep BVD controls to a minimum, or at the least not extend them. The third group had mixed responses.

Question 17 (Do you think that all herds should be required to test high risk animals?) had biggest support from respondents with 92% of respondents in favour. Question 4 (Do you think that all cattle on non-compliant CBI holdings should not be allowed to move off the holding for any reason (including slaughter), regardless of individual BVD status?) had the least support from respondents with only 32% in favour. The most controversial question was question 13 (Do you think that all the requirements that currently apply only to breeding herds should apply to all herds?) which was tied at 47% for and against.

Please see a more detailed analysis of the responses below.

1.1 Proposal 1: Introduce minimum proportion testing for the BVD Check Test

Question 1: Do you think that a BVD check test should require a minimum of 10% of animals to be tested?

The majority of respondents were in favour of this proposal. Respodents thought that testing should be representative of herd size, so this option would be especially good for capturing testing in larger herds, and would simplify the process.

However, there was a concern raised by both those for and against the proposal that this would penalise larger herds, as they would need to pay for larger number of tests. Some respondents also thought that it would also penalise compliant herds, as they would be required to pay for more testing as a result of other herds not complying with the existing legislation.

Four respondents also explicitly said that check tests should be done away with altogether in favour of all calf testing.

Four respondents who selected No said that the current regulations should be good enough to effectively find BVD in a herd, if done correctly. They thought that there should be a focus on educating farmers and vets on correctly selecting the appropriate animals for testing for appropriate management groups, instead of updating the regulations.

SRUC Veterinary Services also raised the concern that it may be difficult for holdings that had year-round calving to identify the correct number of animals to test 10% of the eligible animals (e.g. those of the correct age, time on holding etc). And that there would also need to be animals tested from all management groups.

1.2 Proposal 2: Shorter Compulsory BVD Investigation (CBI) period

Question 2: How many months do you think that cattle keepers should have to complete their CBI? Please explain your views:

The majority of responses thought the CBI compliance period should be reduced, with 40% suggesting that it should be reduced to six months or less. 32% of respondents thought that it should be reduced to between seven and 12.5 months. Three respondents thought that it should be more than the current 13 months, with one respondent saying it should be 500 months (41 years and eight months) to comply.

Five responses indicated a range of results (e.g 2-3 months or 12-13 months). Where a range has been specified, the average has been taken for analysis. Four responses said that it should be reduced without giving a value. The two most common responses were 6 and 12 months, both selected by nine respondents.

Some respondents also said that different types of cattle businesses should have different lengths for compliance. For example, a representative from Argyll and Bute Council said that there should be a one month compliance period for dairy herds and a three month compliance period for beef herds.

1.3 Proposal 3: Veterinary certification after Compulsory BVD Investigation (CBI)

Question 3: Do you think that herds that have completed a CBI should be required to have veterinary certification after the “follow-on” calf testing period?

The majority of respondents were in favour of this proposal. Respondents thought that it would encourage proactive veterinary intervention and communication with keepers, helping to foster relationships between keepers and vets and ensure compliance with the scheme.

However, respondents that were against the proposal said that it would add an unnecessary layer of bureaucracy to the process, without adding value to the scheme. Six responses that were against the proposal, including the British Veterinary Association and British Cattle Veterinary Association (BVA+BCVA), were concerned that this proposal could put additional pressure and responsibility on vets. The BVA+BCVA suggested that instead a tripartite certificate involving the keeper, lab and vet would share the burden of responsibility between parties and ensure cross-party engagement.

1.4 Proposal 4: Increased consequences of Compulsory BVD Investigation (CBI) non-compliance

Question 4: Do you think that all cattle on non-compliant CBI holdings should not be allowed to move off the holding for any reason (including slaughter), regardless of individual BVD status?

Respondents who were in favour of this proposal said that it would give long term-noncompliant keepers a stronger incentive to complete the CBI. They also thought that it would protect other holdings from the potential BVD risks, e.g. from positive animals using shared transport and/or transport that had not been sufficiently cleaned. This would aid general biosecurity. Two respondents thought that it would simplify the process, as no animals could leave until the CBI was complete.

However, the majority of respondents were against this proposal. Nine respondents mentioned welfare issues, with concerns that not allowing any animals to leave would leave to further disease risk or overcrowding or bottlenecks when animals were allowed to leave the holding. There were also concerns that this would affect businesses and was a disproportionate measure. 15 respondents thought that all animals should be allowed to move to slaughter, and four said an animal with an individual negative status should be allowed to leave the holding.

Of the three questions regarding limiting movements from CBI holdings, this was the least popular option with respondents.

Question 5: Do you think that all cattle on non-compliant CBI holdings should only be allowed to move directly to slaughter, regardless of their individual BVD status?

The majority of respondents were in favour of this proposal. Eight respondents commented that any type of transport of animals from a long-term non-compliant CBI has a potential disease risk. They said if transport equipment is not properly disinfected it could transiently infect animals on the way to markets/ other holdings, and therefore only allowing animals to go direct to slaughter would protect other herds. They also said that it was a good motivator for businesses.

Most respondents who were against this proposal fell thought that it was too strict. Four respondents said that any individually tested animal should have freedom of movement. An additional two thought that this would lead to welfare issues. However, one respondent was against this proposal thought that this option was too lenient, and were in favour of no movement for those in a CBI. There was also a concern raised by one respondent that some cattle businesses are not set up to send cattle directly to slaughter if their usual practice is to send cattle to a finishing herd.

Of the three questions regarding limiting movement from CBI holdings, this was the most popular option with respondents.

Question 6: Do you think that female animals on non-compliant CBI holdings should only be allowed to move directly to slaughter, regardless of their individual BVD status?

Two thirds of respondents were in favour of this proposal. Nine respondents that were in favour of this proposal raised questions about Trojan cows (i.e. a moved-in negative cow that gives birth to a PI and introduces BVD to a new holding). However, one organisation that responded thought that this risk of Trojan Cows could be mitigated by sending automatic reminders to keepers who bought in in-calf females. Seven respondents were in favour of the proposal because it was a good incentive that eliminated the risk of improperly cleaned transport equipment that went to other holdings.

Respondents that were against the proposal cited a variety of reasons – welfare issues, business implications, that any travel could be risky, that any BVD positive animals should go to the knackery, or that restrictions should only apply to in-calf animals from CBI holdings.

One person also expressed that they did not wish to eat meat from an animal that had a disease. As BVD is not communicable to humans, this may highlight the need for public communication and/or education on BVD.

Question 7: Do you think that no cattle should be able to move on to a non-compliant CBI holdings?

The majority of respondents that were in favour of this proposal. 13 respondents said that this proposal it was a good incentive to complete the CBI, and eight thought that it would protect incoming animals from potential disease spread.

Six respondents that were against this proposal cited the business impacts as the reason that they were against this proposal, with a membership organisation saying that this could lead to cash-flow issues. Four respondents specifically mentioned the potential need to bring a bull on to the holding.

Question 8: Do you think that non-compliant CBI herds should be publicly listed e.g. on ScotEID?

A wide majority of respondents were for this proposal. 14 respondents thought that this would be beneficial purchasers as they would know if the holding that they were buying from had good BVD controls. 10 respondents thought that this would be good for neighbouring holdings to see if they needed to increase their biosecurity. Seven respondents also thought that allowing other farmers to see non-compliant CBI statuses would be a good motivator for people to complete their testing faster.

However, some of the respondents that were for this proposal made distinctions between holdings that were trying to get rid of BVD and those who weren’t e.g. those who deserved to be “named and shamed”.

One respondent that was against the proposal commented that sometimes a BVD breakdown can happen because of an illness/bereavement so these holdings should not be punished for this breakdown.

1.5 Proposal 5: Incorporating BVD compliance in to single farm payments

Question 9: Do you think that BVD compliance should be a conditional requirement for receiving single farm payments?

Three quarters of respondents were in favour of this proposal. Seven respondents thought that keepers had had “long enough” to comply with the regulations. Eight respondents thought that incorporating long-term BVD non-compliance in to single farm payments would be a strong incentive to comply. A representative from Perth and Kinross Council said that “incorporating it into single farm payment is the tried and tested way of getting farmers to take action”.

However, four respondents that were against this proposal thought that it would compound problems, for example a bereavement, that led to BVD non-compliance. One person said that they felt single farm payments were already hard enough to receive, and so adding additional conditions was disproportionate.

1.6 Proposal 6: Increased testing for calves of animals purchased in-calf (“Trojan cows”)

Question 10: Do you think that calves born from females purchased in-calf should be individually BVD tested by 40 days of age?

Most respondents were in favour of this proposal. Seven respondents that were in favour of this proposal thought that this was a good next step in the scheme, with two respondents saying that these animals were inherently risky. Two more thought that the cost of these tests were worth it to protect herds.

However, four respondents that were in favour thought that “Trojan cows” from negative accredited herds should not have to be tested as they are able to prove that BVD is not present in the holding of origin. Two respondents also thought that these animals should be isolated until a status was given. Two other respondents thought that all calves should be tissue tested, regardless of where they are born.

Three respondents who were against the proposal felt that animals from long-term negative herds should not need to be tested.

1.7 Proposal 7: Delaying BVD Positive herds restrictions

Question 11: Do you think that BVD Positive herds should be allowed 40 days to arrange optional confirmatory blood sampling of suspect PIs before imposing restrictions on animals moving in to the herd?

Only a slight majority of respondents were in favour of this proposal. Five respondents were in favour of the proposal as they thought that it was a good way to guard against false positives (which one respondent thought may become proportionally more important as there are less positive animals). Two respondents thought it would help ensure keepers cull the right animal(s) (e.g. if a keeper had both transiently and persistently infected animals). Other respondents had a range of opinions of what should happen while the test was being confirmed – from having movement restrictions, to not having any restrictions until confirmation, to allow certain animals to move under certain circumstances.

However, two respondents who were in favour of the proposals suggested that animals that have tested positive should be housed separately until the test is confirmed. The British Veterinary Association was in favour of this proposal, but only for if the animal was isolated and the second test was done in 21-30 days.

10 respondents that were against the proposal thought that it would put more a range of animals at risk of the virus – from animals already on the holding, to animals that may be brought in to the holding, or to any holding that animals might be moved to. Three respondents also thought that some keepers may wait the full 40 days to impose any restrictions, which would allow the virus to circulate. One respondent also said this approach may call in to question the validity of the results if we are encouraging retesting (rather than focusing on the fact that positive animals may be transiently infected and not persistently infected).

1.8 Proposal 8: No compulsory slaughter of PIs

Question 12: Do you think that Phase 6 of Scotland’s BVD eradication should include compulsory slaughter?

Only a slight majority of respondents were in favour of this proposal. Four respondents said that this was an important final stage of eradication, and that more proactive approach of removing these animals from herds was important. There was a differing of opinion of what form that this should take, with two respondents saying compensation should be given only if there were 2 or 3 positive tests. Respondents also differed in the amount of compensation they suggested, with one suggesting that it should be the full market value, another saying 75%, and one saying that there should be compulsory slaughter with no compensation given.

Respondents that were against this proposal had a number of reasons for this – two respondents said that there was already a financial incentive to get rid of PIs, another respondent said that it would be a bad use of resources, another said that tests may be false positive, and another said that it would be too much paperwork. One respondent said that there aren’t enough PIs left for this to make a difference and another said that it would be unfair to pay keepers at this stage to remove PIs as keepers have done this with no financial help up to this point.

1.9 Proposal 9: More obligations for non-breeding herds

Question 13: Do you think that all the requirements that currently apply only to breeding herds should apply to all herds?

This question was the most divided question of the consultation, with exactly 50% of respondents that answered this question both for and against this proposal. Both those for and against the proposal said that it was a proposal that would not work for all farm businesses. However, through questions 14-17, where each requirement that currently only applies to breeding herds was proposed for non-breeding herds, the majority of respondents were in favour of each measure. Therefore, the framing of this proposal, if it were to be implemented, would have to be considered.

Respondents were in favour of this proposal for a broad range of reasons: three respondents said that any herd could get BVD so should have the same requirements as breeding herds; two respondents were concerned about the spread of unknown BVD in holdings spreading to neighbours; one respondent was concerned that non-breeding herds could become breeding in the future, could buy in in-calf females, or have a small portion of breeding animals; one respondent thought that it would put pressure on breeding herds to ensure compliance. Two respondents also thought that there should be stricter rules for the scheme in general. Two other respondents said that all herds should tissue tag.

However, one respondent that was for this proposal said that these rules should not apply to fatteners or feedlots. There was a concern from one respondent that the high level of mixing in some non-breeding herds would mean that they are sites for disease spread. A membership that was in favour of this proposal thought that it would be expensive and therefore should only be a time-limited option, that brought Scotland to eradication, not a permanent solution.

Respondents that were against this proposal said that this would be a disproportionate measure as the risk in BVD is the creation of a PI, which would not happen in a non-breeding herd, which would make these proposals an “unnecessary” burden on non-breeding herds. Eight responses mentioned the risks being lower in non-breeding herds. Individual respondents also thought that it would be a burden on those who only kept dry stock/were a finisher / store herd. One respondent said that if the animals came from negative herds then there was no additional risk in non-breeding herds. However, one respondent said that cattle from non-breeding herds should only be able to go for slaughter if they did not have an individual status.

Those who did not answer the question wanted more information about how the requirement to test would work, as non-breeding herds would be unable to do a calf screen, and may not have the correct animals to do a check test.

Question 14: Do you think that the requirement to obtain and regularly update a BVD herd status should be extended to all herds?

A small majority of respondents were in favour of this proposal. However, of the four questions on extending individual breeding herd requirements to non-breeding herds, this was the least popular proposal.

There was also a wide range of reasons that respondents were in favour of this proposal. Respondents thought that this was a good next step in eradication, with the increased controls important for eradication (though one respondent said that this should be a time-limited solution), giving a picture of disease spread across all of the sector as any herd can get BVD, and so would be good for eradication. One respondent said that one set of rules is less confusing. However, respondents thought that this should be a lighter touch, and some were unclear how testing would work (e.g. no young homebred animals or calves to tissue tags).

Respondents that were against this proposal said that this would be an unreasonable burden on non-breeding holdings, compared to the disease risk, with respondents specifically saying that store and finishing herds should be exempt, and that testing animals on the holding would not eradicate BVD. One respondent also pointed out that an annual herd status would be meaningless in herds that turnover 50+ animals a week. One respondent also thought that declared non-breeding holdings should be subject to more controls, though not through an annual status.

Question 15: Do you think that all herds with a confirmed PI should be unable to move cattle in to the herd?

The majority of respondents were in favour of this proposal. 10 respondents that were in favour thought that bringing animals on to a holding with a PI would put those incoming animals at risk of contracting BVD, and therefore could lead to further welfare issues. Five respondents believed that restricting incoming movement would put pressure on keepers to remove PIs and speed up their removal. However, one respondent thought that two or three should take place before restrictions were put in place.

Three respondents who were against the proposal thought that exceptions should not apply to breeding bulls specifically, and one thought that calves should be able to move on. Two respondents thought that if an animal individually tested negative they should be allowed to move on to the holding.

Question 16: Do you think that the requirement to house PIs should be extended to all herds?

The majority of respondents were in favour of this proposal. 16 respondents thought that this was a good proposal as it was a good biosecurity measure which reduced the risk of BVD spread to other cattle in the herd, and reduced the spread of BVD to neighbouring herds. However, four respondents that were in favour of this proposal thought that housing was only the second best option, and thought that PIs should be sent immediately to slaughter or be euthanised. The BVA and BCVA were in favour of the proposal, however, were mindful that extended isolation can have an adverse effect on cattle health.

One respondent that was against the proposal made the point that some extensively reared cattle have little or no access to housing, so did not think that they should not be housed, but kept separate is some other fashion.

Question 17: Do you think that all herds should be required to test high risk animals?

Most respondents were in favour of this proposal. Respondents that were in favour of this proposal thought that action on high-risk animals needed to be taken, and that controls as a whole needed to be tougher. Respondents thought that this proposal would reduce disease risk in and between holdings, and one respondent saw this as a good first step to extending BVD controls to all herds. However, even those who were in favour of this proposal were mindful that this may increase testing costs for holdings, with one respondent saying that they were in favour of this proposal, but only after eradication.

Of the respondents that were against this proposal, one thought that it should be a consideration post eradication, and another thought that current testing requirements should be maintained.