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DEFRA announced on July 25 that it was undertaking a pilot study to assess the implications of using non-veterinarians to test cattle for bovine tuberculosis (TB). This would be allowed under the Veterinary Surgery (Testing for Tuberculosis in Bovines) Order 2005, which permitted trained and competent non-veterinary staff of the State Veterinary Service (SVS) to carry out the intradermal skin test under the direct supervision of a veterinary officer, and to measure and record the results. The pilot study would be used to determine whether lay TB testing should be introduced on a wider scale. The animal health minister, Mr Ben Bradshaw, said,‘The pilot is being introduced to ensure we have sufficient resources to meet the demand for TB tests.’
Veterinary surgeons might be forgiven if they were not aware of this Order, as it was laid before Parliament on the day the announcement was made. DEFRA has long made clear that it wants to have the option of using lay TB testers. The new legislation may be the start of the process by which it finally gets its way. DEFRA says that the purpose of the Order is to enable it to carry out the pilot study, although there is nothing in the legislation that might preclude lay testing being applied more widely. The minister’s comment and other statements from DEFRA (see Letters, pp 151-152) make clear that the purpose of the exercise is to increase testing capacity for the future.
DEFRA’s thinking on lay TB testing was set out in a public consultation document issued just over two years ago (VR, July 12, 2003, vol 153, pp 33, 34-35). Under its proposals, trained and competent non-veterinarians would be able to administer the tuberculin test and read the results. They would then report the results to an SVS veterinary officer or local veterinary inspector (LVI), who would be responsible for interpreting them. Interpretation of reactions to the tuberculin test is, DEFRA rightly pointed out, tightly prescribed by European legislation. However, it argued that administering the test and reading and recording the results was a technical act that did not require the professional judgement or diagnostic expertise of a fully trained veterinarian.
DEFRA argued that it would be valuable to have a cadre of lay testers in the event of disease outbreaks, and that lay testers could free up veterinary expertise for other tasks, especially during outbreaks of disease. More importantly, it said, lay testers would provide an additional resource in areas where the incidence of TB was high. It also noted that the SVS would wish to have a pool of its own testers to fill any gaps that might arise in testing programmes.
The consultation document sought to reassure the veterinary profession that the proposals were not a precursor to the SVS recruiting large numbers of animal health officers to take over TB testing. This point was reiterated by the animal health minister who, in a written answer to a parliamentary question in October 2003, stated: ‘There is no intention of depriving LVI practices of their routine testing and no practice will be required to use lay testers.’At the same time, it was clear from the consultation document that cost was a factor in DEFRA’s thinking; practices that chose to perform TB tests would continue to receive fees at existing rates, but a lower fee would be paid if a lay tester was used.
Both the BVA and the RCVS expressed concern about the proposals in the consultation document. The RCVS pointed out that EU legislation requires test reactions to be interpreted on the basis of clinical observations as well as the recorded increase in skin fold thickness and that, while the administration of tuberculin and measurement of skin thickness could be delegated to a suitably trained technician, a lay person could not readily be trained to carry out the clinical observation that was an integral part of the test. The BVA, for its part, argued that the proposals were uneconomic and inappropriate, particularly in the wider context of the Government’s Animal Health and Welfare Strategy (AHWS) and plans to improve on-farm disease surveillance.
The legislation introduced earlier this week defines ‘tuberculin testing’ as ‘administering a comparative intradermal test, including preparation of the site for injection, injection of tuberculin, and measurement and recording of results’, but specifically excludes interpretation of those results. This means that lay testers will not be allowed to interpret the test but, given that clinical observation forms part of the test, does raise the question of where measurement stops and interpretation begins. Splitting responsibility between a lay tester and veterinary officer raises practical as well as legal questions, which will presumably be assessed in the pilot study being undertaken by DEFRA. It would be quite wrong to pre-empt the results of the trial at this stage, although given what has gone before, it seems increasingly likely that lay TB testing will be ‘rolled out’ in some shape or form in the not-too-distant future.
In its comments on the consultation document in 2003, the BVA argued that TB testing provided an important – sometimes the only – opportunity for vets to get on to farms and to develop a constructive relationship with the farmer. Rather than introduce lay testing, it might be better to take advantage of this opportunity to improve disease surveillance and animal health and welfare generally. It is unfortunate that DEFRA seems not to be following this advice. As the AHWS recognises, animal health and welfare needs to be approached not just in terms of its component parts, but considered as a coherent whole.