benyonr@parliament.uk, ps.lord.benyon@defra.gov.uk

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Dear Lord Benyon,

As the Minister responsible for the current bTB policy, can you answer the 13 areas below for me, in relation to Geronimo the Alpaca and your understanding of the current research on Deer and Cows, and how this relates to healthy Camelids that have not been primed with tuberculin beforehand.

1. In 2016, during a meeting between DEFRA/ APHA and stakeholders and representatives of the British Alpaca Society, it was minuted and acknowledged by Dr Shelley Rhodes that she had seen data confirming the observation that ”Alpacas that had receive more than 1 skin test (which includes an injection of tuberculin) in the last 12 months going inexplicably positive when tested with the Enferplex test”.

2. 13 eminent Veterinary Surgeons (including a couple of Professors) penned an open letter to the Vet Times that raised reservations on Geronimo’s positive diagnosis from 2017 (dated August the 23rd 2021  the link can be found-https://www.vettimes.co.uk/news/vets-pen-open-letter-on-geronimo-case/ HERE

3. The directors of SureFarm, who provide Enferplex testing also suggested the test results may have returned a false positive and I quote Alastair Hayton MRCVS, dated December 2017 Enferplex result “not suggestive of a progressive disease state” and “there is a very reasonable doubt, from a clinical and epidemiological perspective as to whether the animal is a true M.Bovis positive, we would continue to highly recommend caution in the interpretation of the results” I seem to recall reading that DEFRA were unhappy with this statement and questioned whether they could continue to use their tests.

4. Dr Eleanor Brown, a DEFRA bTB Specialist stated in the High Court as recently as August 2021 and 4 years after the event that ‘a randomised field trial would be needed to determine whether Alpacas that had received multiple Tuberculin injections were true bTB positives’ as Dr Shelley Rhodes, as per point number 1, suggested back in 2016, which also correlates with point 3 above.

5. The references that you and DEFRA have provided to interested parties are not related to validation studies in Alpacas that had received multiple bTB injections pretesting but actually relate to cows and deer (Ruminants), rather than Alpacas (Camelids). Indeed, the referenced study, carried out by Wates et al in 2015 in the US found no boost in antibody responses in bTB-free cattle and IM administration of tuberculin. This is the piece of research that Dr R de la Rua-Domenech directly referenced in his paper, published June 2021 when he said these results “could not be extrapolated to Camelids” (see point 8 below).

6. According to the literature on the classification and evolution of Camelids, they are different to Ruminants (Cow and Deer) taxonomically, physiologically, immunologically, and behaviourally, and from a Veterinary standpoint, Camelids and Ruminants differ in susceptibility to infections and parasitic diseases. Indeed, your own literature classify camelids are overspill species in relation to bTB. Modern palaeontologic and taxonomic Scientists clearly state that Camelids belong in a separate sub order Tylopoda in the order Artiodactyla, which is distinct from the sub order Ruminantia. Why would your experts assume these 3 species would respond in the same way to protocols when the Enferplex test is different for camelids compared to cattle?

7. You deem it unnecessary to carry out a bespoke field trial to specifically assess the effect of multiple Tuberculin injections in Alpacas prior to antibody blood testing, as suggested by Dr Eleanor Brown (point 4 above). Why exactly is that given camelids are a unique species?

8. You have continually referenced the document entitled ‘the anamnestic boost effect of the skin test to the antibody responses to Myobacterium in camelids – summary of evidence by Dr R de la Rua-Domenech but in it there is no reference to the Enferplex test and the author confirmed “it has not been possible to assess this in camelids” and strangely I am no longer able to find reference to this document in the public domain, it appears to have been taken ‘offline’.

9. Is there a specific piece of research that extrapolates/ correlates the results between Deer, Cows, and Alpacas as I cannot find any, although I do not have access the Veterinary research journals?

10. To the best of your knowledge, have there been studies into the effects of multiple tuberculin priming in healthy Cattle and Deer prior to Enferplex testing?

11. Is there any research you can share that shows the specificity of the bTB antibody test from a bespoke and randomised field trial on Alpacas that were not in a herd breakdown or within one mile of a confirmed bTB herd breakdown in cattle?

12. Are there any publicly available plans/ intentions to carry out a bespoke and randomised field trial to specifically assess the effects of tuberculin injections in Alpacas, a requirement clearly identified by Dr Eleanor Brown, a DEFRA bTB Specialist in the High Court in August 2021 and repeatedly asked for by the British Alpaca Society since 2016?

13. Why did you fail to recognise the relevance and uphold the significance of the highest biosecurity standards as acknowledged by APHA on Geronimo's farm since his arrival in 2017? Such a facility should be your aspiration for the future of farming because the possibility of diseases such as bTB spreading between species can and is fully prevented by the implementation of vector proof perimeter fencing and wide boundary margins. However, it was within this context that you denied the possibility that the only suspicion of disease had been created by DEFRA/APHA by the deliberate misuse of a test that has never been validated in healthy Alpacas that were not in a herd breakdown or within one mile of a confirmed bTB herd breakdown in cattle

 

yours sincerely 

 

(insert your name & address)