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8 March 2007

FAWC Response to the Consultation on Responsibility and Cost Sharing for Animal Health and Welfare: Principles

FAWC welcomes initiatives to foster greater partnership between Government and industry stakeholders in developing and implementing future animal health and welfare strategy. It is important that responsibility sharing along the entire food supply chain is included (e.g. including food retailers).

However, the Consultation document is largely focused on livestock disease control and it is not clear how animal welfare might be included within a responsibility and cost sharing arrangement. Indeed, it is apparent from the document that little thought has (as yet) been given to animal welfare considerations. This is commented on further below.

In general, the ten principles are sound and appropriate in the context of responsibility and cost sharing for animal health and welfare.

Approaches to responsibility sharing should minimise the development of new bodies with further tiers of administration which impose an additional financial burden on scarce resources in Defra and the livestock sector. It is important to ensure ‘joined up’ management within the area of animal health and welfare and with other policy areas impacting on the livestock sector and government may be best placed to ensure this. In addition, there will remain aspects of animal health and protection of animal welfare that government will need to take ultimate responsibility for on society’s behalf.

Any approach to cost sharing through a levy must minimise administrative costs, ensure full representation of the levy payers in the management of collected funds and transparent accountability of expenditure.

Whilst it is reasonable to ask industry to bear the costs of measures which directly improve their business income, it is not realistic to ask them to accept the costs of animal welfare measures required by society, but will not improve profitability, unless passed on through product price. If increased product prices for higher welfare are not accepted by retailers or consumers, who have access to imported products which may be produced to lower welfare standards, the sustainability of the UK livestock industry will be called into question. Increased consumer awareness and the use of welfare labelling (see FAWC report on labelling) should help in this regard.

The stated key goals of Responsibility and Cost Sharing are given as: to help lower risk of disease, to improve policy making through an integrated Government and industry approach to disease prevention and control and to regulate better (2.1 page 6).

This is entirely disease focused and there is no mention of welfare. Although, Principle 4 (page 7) is titled ‘Sharing responsibilities so that achievement of animal health and welfare outcomes is effective and efficient’ and is the only one of the 10 principles to explicitly mention animal welfare, even under this heading there is only mention of disease control and no explicit consideration of animal welfare.

It is important that proper consideration be given to how animal welfare might be incorporated into any responsibility and cost sharing arrangements or indeed whether responsibility for welfare might be dealt with differently, with government continuing to play a major role. As noted above, producers and the livestock industries may have little incentive to improve animal welfare under current market arrangements.

Moreover, it is important that any consideration of animal welfare is linked to the Animal Welfare Delivery Strategy and to the Animal Welfare Action Plan that will be developed.

We hope you will find these comments helpful.

Professor Richard Bennett
Farm Animal Welfare Council