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Consultations on permitted/exempted procedures

11 January 2007

Dear Sir/Madam

Since its establishment in 1979 the Farm Animal Welfare Council (FAWC) has expressed its opinion that, on ethical and welfare grounds, the mutilation of livestock is undesirable in principle (Advice on the Need to Control Certain Mutilations on Farm Animals, 1981). However, it is acknowledged that some interventions might be necessary to prevent greater suffering being caused if they were not carried out.

This principle is carried through in many of the reports produced by the Council, including those species specific reports where particular interventions are discussed and recommendations made for controls (Welfare of Sheep 1994, Welfare of Turkeys 1995, Welfare of Pigs Kept Outdoors 1996, Welfare of Farmed Fish 1996, Welfare of Laying Hens 1997, Welfare of Dairy Cattle 1997 and Welfare of Broiler Breeders 1998).

These reports call for livestock producers to consider carefully the necessity of performing any mutilation, but where they are carried out makes it clear that the methods, materials and training of operators must protect as far as they can the welfare of the animals. This must be considered in terms of pain or suffering caused by the initial mutilation process, as well as any chronic pain experienced subsequently.

Consideration should be given to the current scientific evidence on pain perception in all farm animals (Ref. work by research groups in Edinburgh and Glasgow Veterinary Schools, Mellor (New Zealand) and Weary and Fraser (British Colombia) and in very young (but non-farm) animals Fitzgerald (London)). Specifically, evidence that young animals experience pain as much as, if not more so, than adult animals should be considered in respect of any exemptions or permitted procedures.

Appropriate use of pain relief, i.e. anaesthesia at the time of the mutilation and then peri-operative analgesia administration, should be considered. If there are species differences that result in differing protocols, then these must be scientifically based. Any procedures should be assessed primarily for their likely impact on animal welfare. Practices more related to convenience of the owner/keeper alone, tradition or marketing requirements should be reassessed and challenged. A risk analysis may highlight practical difficulties related to individual animals, the welfare of the rest of the herd/flock and the keeper that will then have to be justified in terms of not causing ‘unnecessary pain or unnecessary distress’.

FAWC recognises that the new legislation essentially reads across from the current requirements contained within a variety of earlier domestic or EU legislation. The short consultation period necessitated by the legislative programme does not allow for detailed consideration by FAWC of the various procedures, but we hope that these general comments are helpful in your considerations.

Docking of dogs’ tails is outside FAWC’s remit.

FAWC has already commented on infra-red beak treatment applied to broiler breeders, and published its advice on its Website (www.fawc.org.uk). Further advice on this aspect of laying hen welfare will follow in the Spring. We do note that beak trimming may only be allowed for flocks of more than 350 birds when the effects of pecking and cannibalism can be just as severe for individuals in small flocks.

A FAWC report on the welfare implications of castration and tail docking of lambs is in the final stages of drafting and should be forwarded to Ministers and published in Spring 2007. This will update the 1994 Report on the Welfare of Sheep in these particular aspects.

FAWC Secretariat