Farm Animal Welfare Council


11 August 2005

Proposal for a council directive on the welfare of chickens kept for meat production

Thank you for the opportunity to comment on the above proposals.

As you know, FAWC has had a keen interest in broiler welfare for many years. In our 1992 report, we highlighted a number of areas of concern related to broiler welfare. Many of these concerns have been addressed by industry and retailer-based assurance schemes and the 2002 Code of Recommendations for Welfare of Livestock: Meat Chickens and Breeding Chickens.

Unresolved areas for FAWC remain in relation to stocking density, lighting and leg weakness. Our concerns in relation to lameness have been somewhat overtaken by DEFRA funded work at Oxford and Bristol in the last few years and the FAWC Poultry Issues Group has maintained an active interest in this work. FAWC remains convinced that lameness is a significant welfare insult in a number of farm animal species and hence an area in which it wishes to maintain a watching brief. The broiler studies have shown large variation in the incidence of lameness between producers and farms. Therefore, it is hoped that the risk assessment approach of the Bristol work (which is nearing its completion) will identify significant contributory factors and lead to knowledge transfer and improvements in broiler leg health.

Alongside these concerns, and through the DEFRA funded work, has been the influence of stocking density on various aspects of broiler welfare. Whereas the Oxford work of Marian Dawkins has not concluded prescriptive maximum stocking densities for broilers, many of the welfare indicators assessed have shown adverse effects as stocking density increases.

FAWC Poultry Issue Group members have now had an opportunity to consider the proposal for a Council Directive on the Welfare of Chickens kept for meat production through circulation of the draft and recent discussions by the Group in London. I understand that the UK are keen to progress this draft during the UK Presidency and the objective is to bring a final document to the December Council of Ministers for agreement, subject to European Parliament agreement.

In our discussions at FAWC Poultry Issues Group, we have considered the following aspects of the proposal as the most significant and this advice has been endorsed by Council:

1. Stocking density

In our 1992 broiler report, we recommended “that 34 kg/m2 is retained as the maximum stocking density”, although we conceded that the “absence of scientific evidence leads us to recommend that further R&D should be undertaken into stocking density for broilers with particular reference to welfare.” FAWC will have difficulty in endorsing a stocking density above our previous recommendation without good reason. FAWC is pleased that R&D has been undertaken. This has led us to conclude that an upper limit on stocking density is still necessary. However, it appears that merely depending on absolute values for stocking density without a more holistic assessment of the farming operation and poultry unit is not sustainable. In many ways, therefore, FAWC welcomes the integrated approach adopted in the draft Directive, especially in terms of setting a targeted range for stocking density with producers having to justify (on the basis of key technical factors and indicator-based monitoring) stocking at the upper limits of the range. However, we still have some concerns about the practical implementation of such a system, the stocking density limits set and the welfare outcomes chosen in the draft (see later comments).

The adoption of a maximum stocking density above that originally recommended in our 1992 report might be sustainable if robust welfare outcomes can be used to confirm no significant damage to bird welfare in birds kept at the highest stocking density. FAWC members might be comfortable with the integrated approach and a robust audit system suggested, sufficient that an upper limit of 38 kg/m2 may be sustainable. However, the devil is in the detail. For example, it is unclear exactly what the penalty for exceeding the maximum stocking density may be. We understand that the individual poultry house will be the “unit” defined under the Directive. Given that broiler growing is a biological phenomenon, that mortality rates cannot always be predicted accurately, that thinnings will complicate the calculation and given the inherent inconsistencies that can arise in placing chick numbers in a poultry house, considerable resource may be expended on occasions where even the maximum stocking density is exceeded to some modest degree.

FAWC is attracted, by these factors and other practicalities, to suggest that the assessment of stocking density is made on an annual basis as a summary of average stocking density across the site over that timescale. Anything more prescriptive is unlikely to benefit animal welfare, unless individual houses exceed the maximum agreed stocking density by a significant margin, especially if accompanied by evidence from the indicator based monitoring that welfare has been compromised. It is imperative that any agreed rolling average must also be accompanied by an absolute density that cannot be exceeded in any crop.

In conclusion on stocking density, we are minded that the interpretation of Marian Dawkins work does not allow us to automatically conclude that a figure of 38 kg/m2 is “acceptable” but equally there is no evidence that stocking at this density must be unacceptable. FAWC may be in a better position to support the proposals in the draft Directive once the results of the Bristol project are available and Defra is able to give FAWC more detail as to how they see any programme of audit and approval working in practice. Definitive approval by FAWC for the stocking density range in the draft Directive would therefore be premature at this stage. FAWC is very keen to discuss this with you further in light of such information becoming available.

2. Mortality and culls

Accurate mortality rates should give a reasonably robust indicator of disease status in a poultry unit, and this is clearly one of a number of useful outcome-based assessments of bird welfare. Furthermore, culling rates can be an additional useful factor, especially as the majority of culling on broiler farms are usually categorised as “leg culls” giving potentially an assessment of lameness on a particular unit.

The draft proposal sets a limit that mortality must not exceed 1% plus 0.06% x slaughter age of the flock in days. By way of example, this calculation indicates maximum mortality figures as follows:

35 days (1% plus 0.06% x 35) Max mortality = 3.10%
36 days Max mortality = 3.16%
37 days Max mortality = 3.22%
38 days Max mortality = 3.28%
39 days Max mortality = 3.34%
40 days Max mortality = 3.40%
50 days Max mortality = 4.00%

These mortality limits are not generous but should be achievable as an average mortality rate on the majority of farms. However, as average figures then almost by definition 50% of results would be expected to exceed this limit! Furthermore, the pattern of mortality is significant in welfare terms. As an example, high early acute mortality due to yolk sac infection may be less severe than later protracted respiratory disease. In addition, yolk sac infection may reflect a problem independent of anything the individual producer can control and is clearly not relevant to stocking density.

Another significant aspect in relation to bird welfare is that these figures are expected to include those birds culled on site. As a result of this tight limit and the far more generous dead on arrival limit stated in the draft, it might reasonably be considered that culling rates on farm would fall to help meet the targets set above, which could not be considered to be in the interests of bird welfare. Culling policies that protect bird welfare should not be discouraged or penalised.

It may be necessary for further consideration to be given to setting slightly higher specific limits for both mortality and culling, whilst retaining some average target and absolute figures. As with stocking density, whereas a rolling average mechanism is attractive in logistical terms, an upper action limit needs to be imposed (say, 2 standard deviations of average performance) to avoid potential welfare problems being masked for particular crops. FAWC feels that this area requires further discussion and clarification, especially with industry, to achieve a practical and meaningful outcome.

3. Lighting

Annex 1 of the draft Directive sets out requirements applicable to all establishments covering requirements for provision of feeding and drinking equipment, and environmental control. FAWC welcomes the majority of these requirements as representing best practice.

One area that is not in tune with current industry practice is in relation to lighting patterns and especially lighting intensity. FAWC in its 1992 report recommended uniform levels of light in the poultry house and the provision of a dark period. Furthermore, we stated that “a suitable average light intensity is likely to be at least 20 lux throughout the house at bird eye height and the industry should be encouraged to adopt this level of illuminance: the absolute lowest average light intensity which is acceptable to the Council is 10 lux and this minimum should be introduced immediately.” This has been, in the main, incorporated into the DEFRA Code of Recommendations for the Welfare of Livestock: Meat Chickens and Breeding Chickens as “Chickens should be housed at light levels which allow them to see clearly and which stimulate activity. This should be provided by lighting systems designed, maintained and operated to give a minimum light level of 10 lux at bird eye height. Illumination of the house to at least 20 lux will further encourage activity.”

We also recommended that further R&D should be undertaken “to determine the optimum light intensity and pattern for broiler chickens which will minimise welfare problems.” A DEFRA funded project on lighting and visual perception (AWO225) at Silsoe appeared to confirm that the lighting environment specified in the Code of Recommendations are correct and can be justified scientifically in terms of the biological mechanisms tested in this project, although indeed this work was carried out in laying hens rather than broilers. We understand that further work in broilers is in progress, and this may help in further deliberations. In the meantime, FAWC would suggest that the proposals laid out in the DEFRA Code are appropriate and that the rigid implementation of “at least 20 lux” in the draft Directive is overly prescriptive.

In terms of dark period, the Bristol work seems to show a correlation with increasing length of the dark period and improvement in gait scores. Many observers agree that bird activity and leg health are improved by introduction of intermittent lighting patterns over and above the old “1 hour dark in every 24 hours”. However, the evidence for an optimal dark period does not appear available from current scientific evidence. FAWC are supportive of the use of longer dark periods, but whether this should be 4 or 8 hours is still open to debate. Whatever period is chosen it would seem that certainly an introduction of an 8 hour dark period at 3 days of age would be detrimental to bird welfare. The young chick is still needing to find feed and water at all times and we feel that bird development would be better served if such a lighting programme was not introduced until the birds are 7 days of age. Similarly, to improve welfare at catching, on the basis of best industry practice, reducing the length of the dark period in the last 7 days (rather than 3 days in the draft) reduces bird activity and damage during the catching process.

4. Welfare outcomes

During our discussions with Marian Dawkins on the conclusions of the Oxford research, FAWC Poultry Issues Group came to the conclusion that outcome based assessments of welfare are what is really needed to come to conclusions on the welfare impact of specific rearing conditions. The problem highlighted was determining an outcome that could be consistently recorded and categorised and realistic limits be set on maximum allowable levels.

The factor set in the draft Directive is that of the incidence of scored foot pad dermatitis. The choice of the Swedish system sets a rather “all or nothing” scoring system (absent, mild, severe). FAWC Poultry Issues Group is aware of industry concerns that mild foot pad dermatitis is seldom directly related to stocking density per se. On the other hand, severe footpad dermatitis (like hockburn) may be more useful in assessing litter condition and hence, indirectly, ventilation, control, nutritional aspects and husbandry factors in litter and drinker management. Therefore, the punitive action of reducing stocking density for flocks exceeding specified foot pad lesion scores may not address the underlying welfare problem unless the system of scoring truly reflects the severity of the footpad lesion. As a result, FAWC considers that if foot pad dermatitis is to be used as part of the indicator based monitoring system of flocks, the scoring system needs to be consistent and reproducible and the results used to alert the producer and his veterinary surgeon to the variety of factors involved, rather than simply concentrating on reducing stocking density as the solution. Further scientific research into the causes of footpad dermatitis and discussions with the industry would be advisable before confirming the exact system.

In conclusion, FAWC cautiously welcomes the draft Directive as an attempt to produce a more “interactive” strategy for health and welfare monitoring of individual broiler houses. Whereas there are a number of areas that require clarification and fine tuning, FAWC sees this holistic approach as innovative and if properly and pragmatically implemented, likely to improve broiler welfare.

I look forward to discussing this matter with you further over the coming months.

With kind regards,

Farm Animal Welfare Council

Last modified 22 August, 2005
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