Thank you (Ben Bradshaw) for your letter of 28 June 2006 setting out
the Government’s reasons for authorising ventilation shutdown (VSD)
for controlling diseases, such as Avian Influenza (AI).
FAWC understands that the Government’s stated priority in dealing
with a notifiable animal disease “must first be to ensure that public
health and the health and safety of poultry workers is protected, particularly
where, like with some strains of avian influenza virus, there is a real
risk of human infection”. This priority could, though, in certain
circumstances be at odds with high standards of animal welfare, including
humane death. While the Council’s remit is to advise Government
on farm animal welfare – implying that the animal’s interests
are to the fore – we accept and appreciate the difficult political
and ethical judgements that Government has to make.
In general, FAWC approves the contingency plans that have been made by
Government to deal with an AI outbreak in these exceptional circumstances,
but we have some comments that may lead to further improvements in their
effectiveness. Notwithstanding the need to protect public health and the
health of poultry workers, it is important that the highest possible standards
of animal welfare are achieved, albeit under difficult circumstances and
given certain constraints.
1. It is of concern that recruitment of catchers was
difficult in the recent outbreak of low pathogenic AI in Norfolk. FAWC
would be keen to learn of solutions to this problem, though we understand
the difficulty in securing suitable labour in an emergency where there
was a perceived immediate risk to staff health.
2. Notifiable diseases, such as highly pathogenic
avian influenza (HPAI) and velogenic Newcastle disease, may be highly
contagious and highly virulent. Poor control of the spread of such infections
risks significant animal suffering and poor welfare in its own right,
as well as requiring large numbers of healthy animals to be killed as
part of a firewall control strategy. This, in addition to the undoubted
public health significance of certain HPAI strains, does require the
competent authority to have in place techniques for rapid killing of
(substantial) flocks.
We encourage the urgent development of practical systems of mass emergency
killing, e.g. by gas or foam, that obviate the need for catchers to
enter the house. Research on these and other alternative control methods
should continue apace, as their need may well be imminent.
3. It is known that in hot weather situations where
there is ventilation failure in houses with birds close to slaughter
weight that high mortality through suffocation and heat stress can occur
rapidly, especially in large, well insulated buildings. However, for
younger birds, breeders, caged layers, etc., especially in cooler weather
or in older buildings, anecdotal evidence suggests that death may be
less rapid, and hence more traumatic, with no guarantee of a rapid,
complete kill. There is an urgent need for further work on the effectiveness
and practicality of VSD.
4. We are also concerned about the potential heterogeneity
in physical conditions throughout an older building that may mean that
not all birds are killed sufficiently quickly.
5. FAWC will always wish to consider the consequences
of its advice to Government and we can envisage a scenario where there
is no option but to compromise the welfare of a particular flock for
the greater benefit of the national flock and public health. FAWC notes
and approves the requirements in the Statutory Instrument that you have
prescribed for the use of VSD, e.g. the written authority of the Secretary
of State.
In addition, FAWC would need to be assured prior to any use of VSD
that:
- the benefits were substantial and clearly outweighed any harms;
- VSD would only be used in situations where expert assessment indicated
that death would be reasonably rapid and no alternatives were available;
- an available backup method was in place to destroy humanely those
birds found not to have been killed by VSD; and
- any use of VSD was well documented and results fed back rapidly
to inform future decisions and to improve the contingency plan.
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