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DEFRA may be failing in its duty of care to audit badger cull procedures

It is in farmers' and the public's interest that reasonable effort is made to control bovine TB and this includes ensuring that appropriate standards are met when badgers are culled to reduce the badger vector. Although DEFRA has assigned the task of culling badgers to culling companies1, DEFRA is still responsible as a public authoritory to carry out checks to ensure that procedures which are being followed by these companies meet standards to ensure the job is being carried out properly.

During the second year of culling DEFRA decided not to take up the Independent Export Panel's (IEP's) recommendation2 of continuing (and actually increasing) the use of cull-sample-matching to estimate cull effectiveness. In Reference 4 (see Section 4.4.14 on Page 17) the IEP concluded that protestor activity may have biased down population estimates in the capture-mark-recapture analysis but is unlikely to have introduced bias into the cull-sample-matching method. In fact, the IEP considered cull-sample-matching to give the most reliable way of measuring the proportion of badgers culled in an area. This decision by DEFRA not to take up the IEP's recommendation to continue the use of cull-sample-matching increased the need to carefully monitor the number of badgers which were being culled so that the proportion of culled badgers could be estimated.

In the Executive Summary of the Audit Reort in Reference 3, the following is stated.

It should be noted that the auditor did not have access to the culling data held by contractors conducting the cull on behalf of the NFU. Therefore an assessment of the processes followed and data collected for this integral part of the project did not form part of the audit and its data quality was not assessed.


In my view, this apportioning of responsibility to unaccountable cull companies coupled with omission to audit processes being followed by

(a) cull companies who managed contractors and
(b) contractors who culled the badgers,

implies to a certain extent that DEFRA failed in its duty of care to monitor what was going on and to check that standards were being met.

Of particular concern is that no indication of how effort was distributed throughout the cull zones appears to have been reported.6 This leaves it open to speculation as to whether or not large accessible areas in any of the cull zones were left untouched. This is a particular worry in view of the abandonment of cull-sample-matching which the Independent Expert Panel recommended to use in future badger culls to estimate cull effectiveness.5


  1. Procedures which contractors need to perform before receiving payment for culling badgers. DEFRA. Response to a FoI request supplied 19 November 2014.
  2. Defra response. Pilot Badger Culls in Somerset and Gloucestershire: Report by the Independent Expert Panel. April 2014.
  3. Audit report for the 2014 badger control project. Conducted and prepared by: Independent Principal Auditor Dr. Martine Wahl, Clinical Research & Communication (CRC). Submitted to: Bovine TB Programme, Defra 16/12/2014.
  4. Pilot Badger Culls in Somerset and Gloucestershire. Report by the Independent Expert Panel. Chair: Professor Ranald Munro. Presented to DEFRA Secretary of State Owen Paterson MP, March 2014.
  5. Why did DEFRA decide not to adopt the IEP recommendation of continuing to use cull-sample-matching?
  6. Bovine TB: Distribution of effort in badger cull pilots Year 2. Reply from DEFRA to a FoI. ATIC0507. 21 January 2015.
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