Guest blog – GWCT confused by Dr Ruth Tingay

ruth is on the right
Ruth is on the right

Dr Ruth Tingay is a raptor conservationist with field experience from North & Central America, Europe, Africa, Central and SE Asia. She studied the critically endangered Madagascar Fish Eagle for a PhD at Nottingham University and is a past president of the Raptor Research Foundation. She’s currently researching the illegal persecution of raptors & its link with driven grouse shooting in the UK uplands. Here’s her second report from the GWCT 10th North of England Grouse Seminar, 17th Nov 2015, Ripley Castle, Yorkshire (episode one here).

 

The following is part of a transcript from the question and answer sessions that followed the first two talks, chaired by Professor Nick Sotherton (GWCT’s Director of Research). Those asking questions were invited to give their name and affiliation prior to their question.

Mark Cunliffe-Lister, Swinton Estate: “My question is, you said there were two types of drugs, the Flu[bendazole] and the Fen[bendazole], is it possible you can alternate using them, or are they so similar?”

David Baines: “Mike Taylor, who’s going to be speaking next, is covering that within his talk, so if you can be patient he’ll do that”. [Mike Taylor did cover this in his talk and said alternating between the two drugs would be ineffective as they are so closely aligned].

Simon Bostock, Dallowgill Estate [past Chairman, Moorland Association]: “I’m one of the moors that underwent a grit holiday. I’m just adding to the debate by saying I was absolutely staggered when we reintroduced grit this year, how incredibly quickly and how very well worm numbers came down from a log mean of 600 to a log mean of 3”.

David Baines: “Thank you, Simon, it’s always good when somebody who’s actually doing this vouches for it and thank you for hosting that part of the trial”.

Adrian Thornton-Berry, [Dalesport Sporting Agency, Moorland Association committee member]: “Practically, counting your caecal eggs, everyone’s got their kits for counting their worms, ‘cos you guys haven’t got time to count the worms ‘cos Dave’d go mad, caecal egg counting, can that be done practically by gamekeepers themselves?”

David Baines: “Counting the caecal eggs is a little bit more tricky than counting the adult worms from shot birds. First and foremost there’s an art in collecting the right caecal, in that although grouse are depositing this caecal every night, you’ve got to have relatively fresh material or the eggs will hatch and larvae will develop from them, so you’ve got to keep an eye out for fresh caecal, you do that just by trained eye of recognising colour and texture, or you can actually catch your grouse at night, hold them in boxes with a gridded floor through which the caecal will drop and then not only do you know it’s fresh but you also know the age and the sex. The counting of the eggs is a little bit more tricky, you need a little bit more material, you need a microscope, you need a binocular microscope in order to do it. Like we did with many ‘keepers when we trained them to count adult worms, we’d be very happy to run simple courses if people want to do this, we can show people how it’s done. Alternatively, if your ‘keepers don’t have time and you’re prepared to pay for us doing the service, we do that as a paid advisory service”.

George Winn-Darley, Spaunton Moor [Moorland Association committee member]: “One of the concerns that gets raised when I have this conversation with people is that it’s a good idea to worm your grouse every spring because you get rid of tapeworms and anything else that might be lurking in there as well as the strongyle worms. Would you like to address that concern which I suspect that many people are harbouring?”

David Baines: “What, of worming as an insurance policy?”

George Winn-Darley: “Correct. Because it’s worming not just your strongyles but it’s also your tapes and anything else which might be in there, and it’s just generally a good policy, you know, if you were breeding from a dog you’d worm it before you went into the phase etc etc”.

David Baines: “It’s certainly a policy that we’re well aware that the majority of people adhere to, but it’s a policy that we would increasingly encourage you to turn away from. Worming grouse as an insurance policy, it may be beneficial to you in the immediate short-term but I think we’ve got to have a much longer medium and long-term perspective of actually being able to retain this tool and these worming drugs and avoid a build-up of resistance. So rather than going down the insurance policy of using medicated grit every year, I’d encourage you to actually spend a lot more time monitoring, with our help if you need it, the actual parasite burdens and then we can discuss with you whether you need wormers at all. We’re changing the way that we’d like to see things going”.

Robert Benson [Chairman, Moorland Association]: “Dave, two questions. First of all you’ve made it very clear only use it when it is needed. What you haven’t done I think is actually quantify at what point it is needed, so at what point, the worm burden, how high does that need to be before you advocate using it? And then my second question relates to the catching up and direct dosing of grouse, can you make a comment on that too, please?”

David Baines: “Some of the detail is supplied within our Best Practice leaflet which is downstairs, so please get hold of a copy. However, I would suggest that if you’re looking at when you should start to use wormers, it depends on what time of year, but anything that’s an average of over 500 worms, maybe a little bit higher, 500 to a thousand, you should be thinking, ‘Well, do I need to?’, and certainly if you’ve got that level in the autumn we’d recommend that you did spring counts of worm eggs. That’s a little bit slightly more mathematical in that there’s a conversion equation because you’re counting eggs not worms but there’s quite a robust equation to allow you to say what the worms will be. So people in that scenario, certainly we’d recommend spring counting of eggs if your worm burdens are 500 to a thousand in the autumn.

The second question was about direct dosing and I’m on thin ground here because I’m not quite sure of the absolute legalities, but I would say if you’re direct dosing for trying to reduce your worm burdens, I would say, ‘Well why?’ Medicated grit is a fantastic tool if used properly and I would have thought there’s very little need to actually go out and direct dose at night. You may have reasons that you do so, but I can’t understand what they are”.

Professor Nick Sotherton [Director of Research, GWCT]: “So, that’s a very good point and I’m afraid we’re a science organisation, perhaps Robert you can answer your own question, ‘What is the legality?’”

Robert Benson: “I think the short answer is I am not absolutely certain and hence the reason for the question but as I understand it, first and foremost you cannot take a grouse out of season, in other words if you’re going to do anything with that bird, catch it in a net or whatever it may be then it’s got to be done during the grouse season. To take a grouse out of season is, as far as I’m aware, illegal”.

Nick Sotherton: “Even if it’s for medication, even if you catch it, dose it and let it go?”

Robert Benson: “Yeah, yeah. Then the second point is I think in order to do a direct dosing or anything else it needs to be under a vet’s control, I think that’s how it should work”.

Nick Sotherton: “Yeah, this all stems from very helpful advice from Natural England, came out a few years ago, why they suddenly decided we needed to be told I don’t quite understand, but I think what it does it illustrates the timeliness of what we’re saying to you today, because I think this whole catching and/or medication of grouse is very much under the spotlight and there are people drawing the attention of it to the authorities in a way that I don’t believe is entirely helpful, so I think we need to be on the right side of the law and regulations because there are people looking to stop it, and we know that because there are conversations going on with the various authorities. So this is very, very timely and I think we need to think very carefully about what we’re doing, because there’s a very big risk that it’ll stop”.

Ian Cox [affiliation unknown]: “You’ve stressed the risk of under-dosing when you’re treating the birds, and in one of your slides you mention the use of standard strength wormer. Is there any merit at all in using double strength wormer on grit or not?”

Professor Mike Taylor: “As I understand it, there is a higher strength but it’s not licensed. The problem is always licensing products and you’ve got to be very careful. Again, as I understand it, the current thinking is the standard dose rate is stopping the incoming larvae but not necessarily killing the adult worm. You may have to think about, under veterinary advice, using a higher strength treatment when you’ve got a high worm burden, say in the autumn, to kill the adult worms. But it does have to be under veterinary supervision, it’s not licensed, you have to get a special licence, am I right?”

Nick Sotherton: “Yeah, these are questions that we’re not asking the regulator because I don’t really want to be bringing this to the attention of the regulator, ‘cos I suspect that they’re involved in [inaudible] so we’re trying to keep a lot of this under the radar, but we do know that questions are being asked”.

Richard Byas [Sandhill Veterinary Services]: “We have asked the regulator because obviously we are, having made the high strength grit, it has been approved, so when we do use it, yes, VMD [Veterinary Medicines Directorate, DEFRA] are aware that it is being used”.

Nick Sotherton: “That’s very helpful, thanks for bringing that up”.

 

This Q&A session surprised me in three ways. First of all, how unguarded the questions and answers had been. That did change later in the day and probably as a consequence of Amanda Anderson (Director, Moorland Association) pointing out me and my colleague to various GWCT staff and delegates (it wasn’t done very subtly!). Subsequent comments were, on the whole, a lot more guarded, although several delegates either didn’t get the message or chose to ignore it, as you’ll see in future blogs about this seminar.

The second thing that surprised me was the stupidity of some of the questions. I’ve always thought that there’s no such thing as a stupid question but I’ve changed my mind. If you’ve just spent an hour listening to two experts warning about the consequences of over-using medicated grit, why would you then ask whether routine use of medicated grit ‘as an insurance policy’ was a good idea?

What surprised me, most of all, about this session was the lack of understanding about the legalities of medicating red grouse and the GWCT’s unwillingness to ask for clarification from the regulator for fear of drawing attention to it and the consequences which may follow from that. Here is an organisation that promotes the use of anti-parasitic drugs and advises the grouse shooting industry on their use and yet it doesn’t know what’s legal and what isn’t. I found Nick Sotherton’s comments particularly shocking. On the one hand he was cautioning that people needed to be on the right side of the law and working within the regulations, but then admitted to being ignorant of the law and wanting to keep the issue ‘under the radar’ because if the authorities knew what was going on they may well put a stop to it.

As it turns out, the authorities may well want to take a closer look at what’s going on, particularly on the grouse moors of northern England. After the seminar I did a bit of research in to the legalities of medicating red grouse and the methods that can/can’t be used to administer the drugs.

In Scotland, the catching up of red grouse at night to direct dose with an oral wormer drug is covered by a specific General Licence. This licence permits an ‘authorised person’ to temporarily catch red grouse at any time of year except for the period between 16th April and 31st July (the breeding season), for the purpose of administering a veterinary drug. The methods permitted include the use of nets and lamps or other dazzling devices.

In England it seems to be a bit more complicated. I found a 2012 Natural England Technical Information Note (#TIN104) , which may well be the advice to which Nick Sotherton referred in his comment. According to this document (see page 4), the catching up of red grouse for the purposes of administering a veterinary drug is only permitted in the open (shooting) season. Catching birds during the closed season, or at any time using a net, cage-trap or spot-lights at night, requires authorisation from Natural England. However, the information in this TIN seems to be referring specifically to medication used to combat Louping-ill virus, a tick-borne disease. There isn’t any mention of medication relating to the use of de-worming drugs.

This technical information from NE seems to be at odds with the GWCT’s own advice, published in 2004 which gives a step-by-step guide to catching up red grouse at night for the purpose of administering a wormer drug, using lamps and nets and with no reference to requiring a licence!

It also seems a bit weird that a veterinary drug can be administered to red grouse during the open (shooting) season. What about the potential for that drug to be passed in to the human food chain if the treated bird is subsequently shot? Perhaps the oral drug (Levamisole hydrochloride) used in the direct dosing of red grouse isn’t of concern to the regulators? Although it appears that this drug is used as part of a suite of drugs in chemotherapy treatment, which sounds pretty toxic to me.

Perhaps someone from Natural England and SNH will read this and be able to clarify the legal position?

Failing that, some FoIs may be in order.

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20 Replies to “Guest blog – GWCT confused by Dr Ruth Tingay”

  1. FOI…have NE ever issued licences for out of season med administration? If so when and in how many cases?

  2. It always strikes me that FOI is a pretty blunt instrument and needs detailed specific well constructed questions in order to get answers to complex issues. The answer to CM’s could easily be; yes – 2008 – 17 etc.

    Why not just write to the Chief Exec of NE highlighting the above confusion and ask if they can clarify what their interpretation of the legal situation is? (SNH seem to be a fair bit clearer)

  3. The whole thing smacks of them being devious underhand and cynical. God forbid they should openly express their opinions or describe their practices eh!

  4. A fascinating blog from Ruth Tingay. Of marginal interest to her comments and those from delegates at the GWCT meeting, were two questions from the floor at the BTO annual conference this weekend.
    Firstly: Dawn Balmer outlined upcoming surveys for 2016, one of which is a survey of what she called in-bye land, this is that area of land immediately below the defined moorland edge to a distance of one kilometre in upland areas. A question from Prof. Ian Newton asked whether game management of adjacent land would be considered when assessing the results.

    Secondly: In a session devoted to the career and retirement of Rob Fuller, the speaker before Rob was Andrew Hoodless, Head of Wetland Research at the GWCT. His subject was “Waders in a changing world” He paid tribute to Rob’s huge contribution to understanding the changes in agricultural management over the last five decades and his collaboration with GWCT research. Andrew concentrated much of his talk on Eurasian Woodcock and tracking research on it’s migration. There was time for only one question from the floor (I missed the name of the questioner, I’m afraid) which was whether Woodcock were still legal prey species for shooters. Andrew confirmed that they were, and also Snipe. He finished with a comment that at two recent talks he had given to shooting audiences he was approached after the meeting by shooters who confessed they knew little about Woodcock and their migration and would not in the future shoot them.

  5. Snipe; They seem to have disappeared from marshes along the East Anglian coast. When do they get to low enough numbers to be taken off the shooting list? Who reviews this list? Is the RSPB making any representations?

    1. Andrew,

      Under the Wildlife and Countryside Act 1981, those species that can be ‘taken’ are listed in Schedule 2 of the Act. This includes woodcock and snipe. These Schedules are supposed to be reviewed once every five years by the Join Nature Conservation Committee (see http://jncc.defra.gov.uk/page-4630 for previous ones and the sixth, which is being determined is here: http://jncc.defra.gov.uk/page-6194).

      It is doubtful that these species will be removed from Schedule 2 imminently as to slightly complicate matters, the whole suite of nature conservation law has been reviewed by the Law Commission; with recommendations recently published (see http://www.lawcom.gov.uk/project/wildlife-law/).

      It is proposed to repeal the 1981 Act in entirety and replace it with a single new Act, the draft version (Bill) is produced here: http://www.lawcom.gov.uk/wp-content/uploads/2015/11/lc362_wildlife_vol-2.pdf. The new ‘Schedule 2’ which becomes Schedule 11 in the new Wildlife Bill retains snipe and woodcock.

      Thus the current quinquennial review going through, is not likely to remove both snipe and woodcock, as if it were, it would have made more sense to exclude them in the Law Commission’s recommendations. This said, of course, they are recommendations and new evidence, should legislators wish to heed this, could mean they are removed. I very much doubt this will happen.

      Richard

      1. Thanks Richard, I have just pointed this situation out to my MP. She probably has one of the highest birder members of any constituency.
        Mark keep up the good work. Thanks

  6. Regarding the use of Levamisole – as far as I am aware there is no licensed veterinary Levamisole product for use for parasite control (or any other reason – see http://www.noahcompendium.co.uk/Compendium-datasheets_by_species/Species/-22365.html ) in Red Grouse, and so products used would be “Off license” use of products intended for use in cattle or sheep.

    Where no licensed product exists for treating a specific condition a Veterinary Surgeon can prescribe a product not licensed for use for the specific species/condition according to a set of guidelines called “Cascade” ( http://www.noahcompendium.co.uk/Compendium/Overview/-45043.html )which would allow choice of a product intended for a different condition in the same species, then a product intended for the condition in a different species, then a product intended for humans and in some situations a product licensed elsewhere in the world under a special license.

    In the case of Levamisole there is a product available for grouse (Flubendazole medicated grit) presumably manufactured using Flubenvet 2.5% premix which does have a license for treating Trichostrongylus tenuis (Caecal worms) although the license doesn’t specifically state it is for grouse, so the Cascade route probably shouldn’t be used unless there is a medical (resistance to the licensed product; different species of worm) or physical (one bird needs direct treatment so medicated grit is inappropriate) reason for doing so.

    The diagnosis of a clinical problem (showing there are high worm numbers, resistance, different worm species) and the decision to use the ‘Cascade’ SHOULD both be made by a veterinary surgeon, who would supply the “Off license” cattle/sheep levamisole product with appropriate directions and in the appropriate quantity for the birds to be treated.

    There are 5 licensed cattle/sheep formulations currently available ( http://www.noahcompendium.co.uk/Compendium-datasheets_by_AI/Active_Ingredients/-24690.html ; the ‘Nilverm’ referred to in GWCT literature is no longer listed) and all are in the legal category POM-VPS which means they can be sold “Over the Counter” by ‘suitably qualified persons’ in addition to being sold by Vets and Pharmacists. ‘SQPs’ include staff at farm supply stores who have received special training in livestock medicine use and are therefore allowed to provide these medicines to sheep/cattle owners for the use intended. It is possible (though obviously unthinkable) that Grouse owners could simply lie and say they want to treat their sheep in order to get the medication for grouse without the hassle of a vet having to be involved.

    The 5 cattle and sheep formulations all have “withdrawal periods” (the period that must be left between administering the medication and slaughter of the animal for human consumption) of between 20 and 56 days. However under the Cascade regulations a veterinary surgeon should advise a minimum withdrawal of 28 days.

    1. Thanks, Ron, that’s useful.

      I’m familiar with the ‘cascade’ system as this is the route through which medicated grit (currently Flubendazole) is prescribed. Adherence to the statutory 28-day withdrawal period has not been monitored because the VMD says this falls under the cascade rules. In other words, they’re happy to trust the judgement of the prescribing vet.

      I’m also aware that a ‘super-strength’ medicated grit has been prescribed but because of its potency (ten times the permitted legal strength) it requires a special licence. The VMD has not been monitoring the use of this drug nor whether the 28-day withdrawal period has been adhered to, which seems perverse. Especially as, if I understand correctly, this super strength grit is produced AND prescribed exclusively by a single veterinary practice, which surely could lead to a potential conflict of interest.

      I would guess then that whatever drug is being used for direct dosing of red grouse, the statutory 28-day withdrawal period has also not been monitored, which is of big concern if NE is permitting the use of this drug during the shooting season, thus increasing the odds that a treated bird will end up in the human food chain.

      It’s all very strange!

  7. Dear NE….. can we please see the Habitats Regulations Assessment that was carried out before the use of medicated grit was allowed on the SPA?
    Oh and as it is clearly not necessary for the conservation management of the site…. can we see the full appropriate assessment along with the references?……. And don’t forget to tell us what the safe doses for Hen Harriers and Peregrines are- because without knowing this it would not be possible to allow the uncontrolled spreading within the SPA???

  8. Please let me look for these vet drugs and or lead in carcasses. I would need an HPLC and access to a good academic library. Sadly I have little free time to do it but would relish the job.

  9. This would very quickly become publishable material if analysis found wormer in for sale, dead birds. You could probably get it funded by the drug manufacturer too.

  10. Just curious but do the worming meds ever show up in the toxicology reports from poisoned grouse moor birds?

  11. I’m not sure quite what my question adds, other than perhaps to the confusion around leaving medicines out in the countryside but can wild birds living in the wild (not in rehab etc.) eg red grouse on a moor be said to be ‘in the care’ of a veterinarian?

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