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FAWC Comments on the draft Animal Welfare Delivery Strategy.

16 February 2007

FAWC welcomes the opportunity to comment on the draft Animal Welfare Delivery Strategy.  This Strategy is necessary to strengthen the animal welfare component of the Animal Health and Welfare Strategy.  It is important that this element, along with the rest of the Strategy, is taken forward and developed in a partnership approach.  Clearly a more detailed Welfare Action Plan will be necessary as part of the Implementation Plan of the AH&W Strategy.  It seems appropriate that at an early stage there is stakeholder involvement and we would suggest that this could include a one-day conference of stakeholders to discuss the Animal Welfare Delivery Strategy and the key components of an Action Plan, in addition to the usual consultation exercise that Defra would undertake.

It is important that the Delivery Strategy and the subsequent Action Plan are not seen merely as Defra policy to be imposed on other stakeholders.  Both the Strategy and Action Plan need to have wide ownership across stakeholders and should be seen as having been developed and subsequently implemented in partnership.  The issue of working in partnership could be more imbedded within the Delivery Strategy.

Specific comments on the draft Animal Welfare Deliver Strategy are outlined below:

Section 1 – The Summary is a confusing title since it is not a summary of other parts of the document but presents some important key ideas (for example, it explains what is meant by ‘welfare’ in this context). It would be better re-titled more appropriately.

Question 1

i) Does the scope proposed cover the right ground?         

Yes, the proposed scope covers the right ground.

ii) Is it right that it applies only to vertebrate animals?  Which if any other groups of animals should be included and why?

It should apply to those invertebrates where there is evidence, either directly or by analogy, of sentience, or where there is a reasonable uncertainty.  This could be updated as new research informs the debate.  (see: http://www.efsa.europa.eu/en/science/ahaw/ahaw_opinions/1286.html)
Furthermore, an argument could be made that, regardless of sentience, the dignity of all complex animals should be respected.  In legislation in other countries this may be covered by the term ‘respecting the intrinsic vale’ of animals.  The value of animals can be abused regardless of sentience.

Question 2

i) Is the vision sufficiently challenging/aspirational?

The Vision is not sufficiently aspirational or inspiring.  The EFRA Select Committee quote contained in the AH&WS states “If the animal health and welfare strategy is not ambitious it will not be worth signing up to”.  This is an opportunity to be more ambitious.

This section could read:

‘Everyone in society has responsibilities towards animals be they animal keepers, consumers or others involved in the food supply chain.  Our Vision for society is to work in partnership to protect and improve the welfare of all kept animals by taking account of their interests, avoiding unnecessary suffering (as outlined by the Five Freedoms) and by promoting positive animal welfare to achieve a good quality of life for all kept animals.’

ii) Is the word ‘care’ used here sufficiently strong?

The word ‘care’ is consistent with its use in the Animal Welfare Act.  It is important that the meaning of the term ‘duty of care’ is clearly explained here with reference to the AW Act otherwise there is a danger that ‘care’ might be interpreted incorrectly as it implies that only those who care (i.e. have a moral concern) have certain responsibilities.

iii) Is the emphasis on the individual responsibility of animal keepers right?

Those that interact with animals also have a duty of care not just animal keepers.  The term ‘Keeper’ needs to include those employed to act on his/her behalf.  See suggested text in i) above.

The emphasis solely on keeper does not highlight other parties’ responsibilities that can influence standards.  Although the day-to-day care provided by individual animal keepers does have a critical influence, the fundamental design of the husbandry systems may also have a critical influence.  For many sectors, such as laying hens and pigs, these husbandry systems are largely defined by the marketplace i.e. consumers and the food chain.  The same argument applies to any animal kept for commercial purposes, for example, pet shops and circuses.  A useful addition could be: “Where animals are kept for commercial purposes, all consumers and those directly involved in their production and retailing, use their influence to improve animal welfare standards.”  This mechanism is included in the Strategy but it is so fundamental it should surely be included in the vision.

Question 3

i) To what extent will the proposed new approach help to improve achievement of good standards of animal welfare?

The proposed approach could help to improve achievement of good standards of animal welfare considerably, if the skills and knowledge are well delivered to all stakeholders, and informing the public.

ii) Which of the proposed alternative delivery mechanisms would be most successful, in your view?  Can you suggest any others?

None of the delivery systems should be seen as mutually exclusive, all these strategies should be implemented.  Education in schools, from primary upwards, and in relevant university courses (the provision of teachers and future industry and other stakeholders) should also be encouraged.

For farm animals motivating producers to make husbandry improvements is the most important criteria.  A demand for higher welfare standards that incentivise producers is therefore likely to be very effective.  Incentives may need to be based on either premiums for welfare-friendly husbandry systems or rewarding better important welfare outcomes (such as lameness).  Delivery mechanisms should include informing the consumer – rather than just relying on an already “informed consumer”, as these are relatively few.  The other delivery mechanisms mentioned are essentially classic information transfer approaches which have limited effectiveness.  DEFRA and stakeholders should apply principles of the participatory approaches that have been used in developing countries to encourage ownership and positive participation.  These initiatives drive demand for knowledge from the bottom up rather than imposing knowledge from the top down.

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 which will not improve profitability, unless these costs can be successfully passed on through product price.  If resulting increased product prices are not accepted by retailers or consumers, who have access to unregulated foreign product, the sustainability of the UK industry will be called into question.

Question 4

i) Is the proposed balance of responsibilities between Government and stakeholders right?

Seems appropriate but needs stakeholder ‘buy-in’.

ii) Would you add or exclude any specific responsibilities from any of the groups?  (please indicate to which group your suggestions refer).

Suggest adding a responsibility for users of, and interactors with, animals to gain the necessary training and skills.

iii) Are the responsibilities proposed by Defra reasonable expectations for all animal keepers, including those individuals who purchase and care for their animals on a non-commercial basis (for example pet owners)?

Yes.

iv) Is it reasonable to require consumers of animals and animal products to ‘have regard to’ the welfare provenance of their purchase?  Here ‘have regard to’ is used to mean ‘consider’.

Yes. 
EU law refers to the need ‘to pay full regard to’ the welfare requirements of animals and this may be worth reiterating here. 

Question 5

Which of these principles are the most important (e.g. can you give a top 3?)

The intensity of the welfare problem as well as the duration needs to be taken into account.  All of the principles are relevant and should be taken on a case by case basis.  There is also the concept of ‘avoidability’ that is missing.  If some welfare problem is easily corrected or easily avoided, then that has to be taken into account.  If, on the other hand, the problem would require considerable sums of money to correct, or is impractical, then that too has to be considered.

Whether something is measurable or not may not always be the point.  It may only be possible to assess qualitatively e.g. very hungry, as opposed to hungry etc.  The standard could be based around how far an animal has deviated from normality to assess the degree of a welfare problem e.g. body weight, body condition, fractures, area of wounds and so on.  Disease may mitigate these estimates e.g. a dog with diabetes or exocrine pancreatic failure may be very happy but be painfully thin.

Question 6

i) To what extent will improving the quality, coverage and penetration of information/training/education available to animal keepers help drive improvements in animal welfare?

Considerable.

ii) Is the approach appropriate for all types of animal keepers, including non-commercial owners?

Yes, it is part of responsible stockmanship and animal ownership.

Question 7

Do you agree with the supposition that there is no shared, robust data with which to baseline existing standards?

No. 
There are already standards set out in current guidance, Codes and legislation and appropriate health and welfare risk assessments have been done, albeit at a qualitative level (but none the worse for that).  See for example the EFSA Scientific Opinions, and before that the Opinions of the SANCO AHAW Committee and before that the Veterinary Scientific Committee.  The Council of Europe has also set out standards for farmed, companion and research animals, and with the latter some very detailed guidelines.  For companion animals there is less shared guidance but from the animals’ viewpoint perhaps its use is not relevant and so dogs should have exercise whether they are used for research, companions, show, sport and so on.  The requirements of pet rodents may be no different to those used for research.

The question may relate more to compliance and implementation.  There is much room for improvement and for development in this area.  Guidance needs to be given on what is meant by robust.  In the future, more welfare standards are going to be as a result of the analysis of good data, but the manner in which that is collected and particularly the data points leave much to be desired.  The government has a role to play in experimental design that meets the ultimate use of such data.

Question 8

This is a very important goal and FAWC agrees with the general sentiments expressed.

i) Will the provision of more comprehensive and standardised information on welfare provenance facilitate consumer selection of animals and products on welfare grounds?

It certainly should do if presented in the right way.  It could apply to companion animals (and research animals) as well.

ii) Can you suggest how better use could be made of assurance schemes and/or labelling?

The government should set an example and ensure that it sources meat for its catering, e.g. armed forces, hospitals, prisons, staff canteens and so on, from farm assured produce.  They could then choose the standards it wishes to see others use.  See FAWC Report on Welfare Labelling (2006).

Question 9

i) Is there room for greater self monitoring/regulation by stakeholder organisations?  If so, how?

Yes there is and this should be a priority.  Let the industry set its own standards and then have the government approve them having taken advice from bodies such as FAWC and CAWC.  One could then monitor and audit the industry’s own standards. If the industry fails to produce any or suitable standards then they should be drawn up from the Implementation groups after suitable advice and consultation.

ii) Can you suggest other ways of reducing the burden of compliance with legislation on animal keepers?

Animal keepers have to shoulder that burden, it is the responsibility they assume as moral agents when they look after a vulnerable sentient being.

Question 10

Should non-Governmental and stakeholder organisations have a role in representing the UK in international fora?  If so, how should these organisations and Government work together to get the best results internationally?

Yes.
The concept of “National Platforms” should be encouraged and adopted.  They comprise government, industry and animal welfare groups to help determine standards and to promulgate national standards and press for similar standards internationally.  Ongoing contact with international bodies, such as OIE, on welfare standards is essential.

Question 11

i) Is the focus of these 5 Goals right?  Do they cover the most strategically important areas?  Is anything missing?

Yes, they are the most important.  However, there is an overriding tone of ‘burden’ in the document as opposed to ‘benefits’, and no mention of the assessment of positive welfare of animals.  Perhaps there should be a section on the benefits and their assessment so that the burdens can be weighed against the benefits.

ii) Should the 5 Goals be put into a priority order?  If so, in what order would you list them?
 
No, they are all complementary and need to be pursued concomitantly.

Question 12

i) Does the proposed structure of the action tables cover all of the important issues?

2.7 para 3: It may not necessarily be true that: “Responsibility sharing on welfare should not involve significant additional costs or burdens for stakeholders.”  Sometimes it might do so and the benefits may be there to compensate for that.  One also has to differentiate between short and long term gains.

ii) Can you suggest any specific actions that your organisation is/could commit to taking forward as part of the Action Plan?

Both FAWC and CAWC should be consulted when drawing up strategies, action plans and standards,  as well as aims, goals and objectives, and monitoring and auditing of standards.

Question 13

Do you have any other general commitments not reflected elsewhere in your response?

It would be good to have some logos from other stakeholders on documents such as these to show stakeholder involvement, partnership working and ‘ownership’.

We hope you will find these comments helpful.

We have copied this letter to officials in the Scottish and Welsh administrations for their information.

Farm Animal Welfare Council