Council would agree that a more strategic approach to animal health and welfare is required. Many of the points made in our submission to the Curry Commission are relevant to this consultation and I include the text of this at Appendix 1 for ease of reference.

FAWC would like to be assured that the strategy is truly for both animal health and welfare and not driven by the former with welfare included as an aside. Attention to animal welfare within the strategy is important in its own right, and not just because of its links to health.

FAWC would question some of the terminology used when referring to animal welfare within the consultation document, since it might be taken to have a specific meaning which is not justified. For example, a general objective of " improving standards" implies that existing ones are insufficient; and seeking to achieve "consistently high standards" begs the questions What is high? and Consistency across what? (all livestock types? over time? etc). Our submission to the Curry Commission stated that "The level implied by the Welfare Codes is above (the) legal minimum and represents a norm considered appropriate by the public at large." Compliance with the Codes is an attainable and measurable target. (Curry submission recommendation 1)

The scope and objectives of the strategy need to be realistic. There must be a clear connection between aspiration and achievability to ensure acceptance by farmers and the ancillary industries, including the food industry. We also believe it is essential to consider delivery along with objectives when drafting such a strategy and not leave it to a separate exercise. While it may be attractive to compile lists of issues to address, resources will eventually determine what it is possible and proper to deliver. Reference to resource availability is essential in defining priorities; while the welfare of pets and wildlife species is not unimportant, from a functional standpoint it is in relation to the welfare of farmed animals that the greatest problems arise. We need to keep in mind, too, that a great deal of animal welfare legislation now originates in Europe and the strategy must be able to inform and affect negotiations at that level.

The strategy should be forward looking but retain the ability to react where necessary. It should be subject to process checks via implementation, audit, review and re-definition at regular intervals. Such a long term plan as envisaged should be subject to measurable milestones along the way.

Much delivery of the strategy will rely on the veterinary profession, both State and private. A successful partnership between the SVS and private practice will be required in which each has confidence and sees benefits. Communication and co-ordination will be key. There may also be a case for the veterinary reserve recommended in our report on the 2001 Foot and Mouth Disease outbreak. Other agencies with responsibilities for enforcement and advice on animal welfare, e.g. local authorities and the Meat Hygiene Service, will need to take their role in the delivery of any Animal Health and Welfare Strategy.

Veterinary surveillance will be vital to set baselines for animal health and welfare policies and monitor effective implementation (Curry submission recommendation 2). While disease surveillance is recognised as essential, animal welfare surveillance is equally important and should have its own priorities and resources allocated to it. Disease surveillance should cover endemic as well as exotic diseases. Concern has been raised about the privatisation of veterinary laboratories and the subsequent drop in referrals to them on the basis of cost. Much valuable information must have been lost to surveillance.

The strategy identifies the need to define responsibilities for animal health and welfare. It is clear that Government should continue to bear the costs of unforeseeable outbreaks of exotic diseases but that farmers should give sufficient resource to risk assessment and avoidance on their holdings. This assumes that the farming enterprise is sufficiently profitable for, notwithstanding the widespread commitment among farmers to the welfare of their livestock, experience shows that their ability to sustain that commitment is severely constrained when farming incomes are under pressure. There must be a sense of proportionality about the split of responsibilities and a mutually beneficial partnership between government and industry is the way to ensure this at local, regional and national levels. Better communication will help to reconnect the parties.

It is incumbent on Government to use economic or other support appropriately and with an eye to the effects on animal health and welfare (for example, financial incentives that may lead to unnecessary animal movements). We welcome moves in the CAP reform negotiations to include welfare criteria as part of cross compliance (Curry submission recommendation 4). We believe this creates a new opportunity to achieve increased recognition by all sections of the industry, as well as retailers and consumers, of the value of appropriate welfare standards as well as the opportunities of enforcing them. The separate arms of Government should work together when implementing policy with potential to affect animal health and welfare, e.g. identification requirements with welfare implications. An animal welfare impact appraisal should be carried out where necessary.

FAWC believes that education and training are major elements of any Animal Health & Welfare Strategy, with objectives being achieved by day-to-day management rather than by regulation and external intervention. Our recognition of the need to improve management and husbandry knowledge and skills in the livestock sector, and thereby raise animal welfare awareness, has already been emphasised (Curry submission recommendation 3).

FAWC sees additional stakeholders to the strategy to those identified in the document. Animal charities and other groups in society with an interest in animals should be able to have a say. So should those in the research community who seek to understand animal health and welfare better and inform the wider world via the trainers and educators. Those providing farm assurance schemes should also have input into a strategy affecting the health and welfare standards they set for their members.

The formulation of a considered and holistic animal health and welfare plan on every livestock holding would, in principle, be a great step forward in ensuring adequate standards on the farm. We recognise the practical difficulties in many cases, such as those where only a few animals/birds are kept, but believe that the bigger the unit, or more complex the operation, the more vital they become. Health and welfare plans would provide a structure to ensure that a veterinarian visited every holding at least once a year (or more regularly) to assess performance and agree a plan of action with the livestock keeper. This should be realistic for all farmed animals but probably not for companion animals (but why not for horse yards and animal parks/attractions as well). Is it realistic that the strategy overall should spread its net over such a wide base as to include wildlife (unless they are vectors of farm or companion animal disease)?

Although economic incentives, especially in less favourable times, can lead to the exploitation of animals as producing units, it should not be presumed that an Animal Health & Welfare Strategy is required in order to ensure that standards across the industry as a whole are adequate (or that 'a strategy' could actually achieve that aim). It is those on the margins of the industry - in terms of management skills, profitability, commitment to the livestock husbandry ethos, etc - with poor records on animal health and welfare that should be targeted. An objective of the strategy should be to reduce substantially the numbers of unsatisfactory performers (in terms of animal health and welfare) in the industry.

There is a need for a new culture in the farming industry, and beyond, on the issue of biosecurity. Much of the awareness raised during the outbreak of Foot and Mouth Disease is being eroded over time. It is vital that adequate efforts are made to prevent the passage of disease from farm to farm locally and between regions and nations. Strict disease prevention measures on farm and during the movement of animals and meat locally, regionally and nationally are essential. For example, the transfer of bovine TB to Cumbria could have been prevented by the requirement to test cattle used for restocking before they moved.

The most important thing to ensure in terms of emergency preparedness is that contingency plans are monitored, tested, modified appropriately and communicated in a transparent manner to the stakeholders.

END

Appendix 1

FARM ANIMAL WELFARE COUNCIL
SUBMISSION TO THE POLICY COMMISSION ON THE FUTURE OF FOOD AND FARMING

FARM ANIMAL WELFARE AND THE FUTURE OF LIVESTOCK FARMING

Summary of Recommendations

Recommendation 1
The provisions of the Welfare Codes should be enforced as the minimum acceptable animal welfare standards in all livestock production systems. Equivalent provisions should apply equally to all the food we eat, including imported livestock products, and should take the entire process (from birth to slaughter) into consideration. An effective labeling system should be developed to identify food produced in compliance with these Welfare Codes (and the absence of such labeling on some imported goods may be taken to indicate non-compliance with these codes or their equivalent), and to additionally recognise food produced to enhanced welfare standards, in an honest, transparent and reliable way. (paras 4-9)

Recommendation 2
There should be a national system of welfare surveillance throughout the food chain and better enforcement of the existing legislation. A system of registration of livestock holdings is an essential administrative requirement to underpin such enforcement action and should be introduced. A single welfare inspectorate acting throughout the food chain should undertake this surveillance and enforcement role. A system whereby a formal licence has to be held in order to undertake livestock production has attractive elements from the standpoint of animal welfare. Equally, compulsory membership of a farm assurance scheme providing independent monitoring at each stage of production could be a viable alternative. We recognise that important practical issues would need to be overcome in each case. (paras 10-11)

Recommendation 3
There should be investment into raising the farm animal welfare skills base of those responsible for livestock management in all production systems through better training, appropriate recognition of demonstrable stockmanship skills, and enhanced communication and delivery of advisory services. (paras 12-15)

Recommendation 4
Government should press for reform of CAP to enable any support payments to livestock producers to be linked to their implementation of the Welfare Codes. Furthermore, pressure should continue to be applied on WTO to include welfare standards in those negotiations. (paras 16-17)

Introduction

1. To guide the Commission's consideration of animal welfare in the future livestock industry, FAWC was asked to give some thought to the medium and long term solutions which could be envisaged. The following paper is the result of this process. In this submission, FAWC makes a number of comments relevant to the English remit of the Policy Commission, but which it considers would apply equally to the other parts of Great Britain.

2. The standard of farm animal welfare is an integral element in the acceptability of all livestock production systems and needs to be considered in a holistic way from the point of production to point of slaughter. Farming is a diverse industry, both regionally and sectorally. In addition to the farm level production unit, livestock are subject to additional processes which have significant welfare impact throughout the production chain (transport, marketing, slaughter, etc.). When considering welfare characteristics of livestock products, whether from the UK or overseas, it is important to look at the entire lifetime of processes to which the animals are exposed.

3. Regardless of how the structure of agriculture may change as a result of the adjustments now taking place, farm animal welfare can be safe-guarded as long as minimum acceptable welfare standards are set, adequately monitored and rigorously enforced. Experience shows that livestock enterprises which are financially viable will generally adhere more reliably to welfare standards. Any move toward rationalisation may be expected to affect some livestock systems more than others. Low value animals at the end of the farming process, for example, e.g. cull sows and ewes and spent hens, become increasingly vulnerable to welfare abuse as agricultural systems are "optimised" in terms of commercial parameters.

Definition of minimum acceptable standards and recognition of welfare.

4. Figure 1 is a conceptual model showing the relationship between the level of animal welfare (as perceived by humans) and livestock productivity ('intensity'). Initially welfare may be improved by provision of a domesticated environment with protection from predators and with an accompanying increase in productivity (as indicated by the move from point A to point B). However, beyond a certain point (indicated by point B), the drive to achieve progressively further productivity gains comes at increasing cost in terms of the animal's welfare (e.g. increased intensification which may decrease the animal ability to express normal behaviours). In principle the animal's productive potential could be pushed so hard as to be unsustainable, resulting in the animal's death and the collapse of its production. The minimum level of welfare acceptable to a society is defined by law (e.g. the 1911 Protection of Animals Act) below which it is regarded as 'cruelty' (indicated by point C). The level implied by the Welfare Codes is above this legal minimum and represents a norm considered appropriate by the public at large. Above this is a range of enhanced welfare standards which are attractive to different groups of consumers or individuals with particular ethical standpoints concerning the treatment of animals.

Figure 1

5. Absolute compliance with legislation and regulations relating to farm animal welfare (e.g. 1911 Act; Agriculture [Miscellaneous Provisions] Act 1968, Welfare of Farmed Animals Regulations) is a fundamental public requirement and must be enforced. However, since the Welfare Codes are designed to reflect the standards considered acceptable to a welfare conscious and civilised society, there is a public expectation that the provisions within the Codes are, in practice, the minimum standards to which the livestock industry should adhere. Making the Codes more enforceable would ensure this is achieved in the public interest.

6. In addition to this, an increasing sector of the public wishes to have the choice to consume products deriving from systems with enhanced animal welfare standards. Claims made about such products must be transparent, honest, auditable and enforced. Effective labelling, with full traceability linked to quality assurance schemes, will be an essential for this sector.

7. Those addressing the welfare of farm animals must consider the process as a whole, from the place(s) of birth and rearing, through transport, marketing and slaughter. The sum of welfare conditions to which each animal is exposed throughout its life is an explicit and distinctive element of that animal and is thus a quality characteristic of its provenance as food.

8. Recent trends in rationalisation of slaughter capacity have raised new welfare problems associated with the scale of operation. New technologies are required for large, high throughput slaughterhouses to avoid animals being mistreated as a consequence of scale. Long distance transport (within reasonable limits) is not stressful in itself provided good quality vehicles and well trained drivers are used and loading/unloading activities are professionally performed. However, transport may often be part of a marketing operation. The stress involved in moving animals for marketing is potentially high, and therefore must be kept to a minimum. In traditional markets and collection centres, the problems relate to handling and mixing. This problems are not necessarily eliminated by 'direct selling' or virtual (e.g. video) markets.

9. Risk assessments should regularly be undertaken of the welfare implications of emerging and existing production and processing systems. New technologies and innovations must be developed to address the needs of changing systems and to safeguard the welfare of animals at all stages throughout their lives. Existing Welfare Codes need to be further developed and up-dated in the light of FAWC recommendations new husbandry systems, new farmed species and new scientific information on animal welfare.

Recommendation 1

The provisions of the Welfare Codes should be enforced as the minimum acceptable animal welfare standards in all livestock production systems. Equivalent provisions should apply equally to all the food we eat, including imported livestock products, and should take the entire process (from birth to slaughter) into consideration. An effective labeling system should be developed to identify food produced in compliance with these Welfare Codes (and the absence of such labeling on some imported goods may be taken to indicate non-compliance with these codes or their equivalent), and to additionally recognise food produced to enhanced welfare standards, in an honest, transparent and reliable way. (paras 4-9)

Monitoring and enforcement of acceptable welfare standards.

10. Current levels of welfare surveillance are inadequate to ensure problems and trends will be reliably noticed and appropriate enforcement action taken. This is due both to a serious lack of resources, insufficient emphasis placed on the enforcement role, and inadequate co-operation between the relevant agencies (SVS, MHS, VLA, local authorities, etc.). Likewise enforcement of current welfare regulations is both inconsistent and inadequate. Problems of inconsistent enforcement apply to entire industries (e.g. the acceptance of transporting lame broilers to slaughter when this is not permitted for other species such as sheep) as well as to specific situations (e.g. particular farms where significant welfare problems may be present and yet effective prosecution is not pursued). It can be argued that basing the surveillance and enforcement responsibilities within the same department that is responsible for agricultural production creates an unacceptable conflict of interest.

11. A registration system is an essential minimum to ensure that the proposed surveillance system can locate holdings throughout the industry as a basis for monitoring welfare standards in practice. Over and above this, a licensing system for holdings has the theoretical advantage of offering an enforcement option, i.e. removal of the licence, that might be used to maintain the standards which are defined as acceptable in farming. This would help the good farmers to be recognised and improve as well as to sift out and exclude the not so good. However, the administration and enforcement costs of implementing this, the difficulty of including all livestock keepers regardless of size of operation, and its focus on only livestock farmers within the UK, and the resultant impact on competitiveness, make the introduction of such a scheme a challenging prospect at present. In its 2001 Interim Report on Farm Assurance, FAWC recognised the potential of such schemes for independent evaluation of farms, including standards of welfare. Farm Assurance Schemes, if compulsory, might offer a viable alternative means of ensuring compliance with welfare standards. However a credible inspection/ surveillance system is an absolute necessity, whatever the administration arrangements under which livestock farmers operate.

Recommendation 2

There should be a national system of welfare surveillance throughout the food chain and better enforcement of the existing legislation. A system of registration of livestock holdings is an essential administrative requirement to underpin such enforcement action and should be introduced. A single welfare inspectorate acting throughout the food chain should undertake this surveillance and enforcement role. A system whereby a formal licence has to be held in order to undertake livestock production has attractive elements from the standpoint of animal welfare. Equally, compulsory membership of a farm assurance scheme providing independent monitoring at each stage of production could be a viable alternative. We recognise that important practical issues would need to be overcome in each case. (paras 10-11)

Improving professionalism in the farming industry.

12. There is an unfortunate public perception of modern farming as a low status industry that does not care adequately for the animals from which it profits. There is a need to alter this perception by fostering wider public understanding of livestock farming processes, by increasing professionalism throughout production systems and communicating this professionalism to consumers. However, it is important that livestock farmers also appreciate that the right to farm is not an automatic right but one which must be conditional on accepting a responsibility towards the way animals are kept.

13. The human element, in the form of farm management and the labour force, are crucial factors in a livestock enterprise - both in terms of the efficiency of the process and the welfare of the animals involved. The quality and quantity of husbandry inputs are vital to the welfare of the livestock kept. Stockmen and women should be required to demonstrate competence with the species of livestock they keep and the systems within which those animals are managed. Likewise, the rewards of such a skilled labour force should be performance related, both in terms of monetary and social recognition.

14. Training is vital to develop this competence. Continuing professional development, and personal training plans (in the spirit of the Investors in People scheme) should be actively encouraged. There should be recognition of appropriate standards of competence achieved through professional qualifications. Quality Assurance (QA) Schemes should monitor each individual's competence as well as the processes in place to validate his or her capabilities. The development of on-farm indicators of welfare will help to facilitate the objective assessment of welfare outcomes at farm level in terms of stock quality. Such indicators should become part of routine QA on all livestock farms.

15. The communication of information about legislation and best practice to farmers is an important element in ensuring minimum welfare standards are maintained or surpassed. The presumption that IT solutions are the way forward may not be correct for farming communities. Defra's move towards a whole-farm approach for advisory visits is a step in the right direction by providing one-to-one advice on husbandry matters. Demonstration farms should be developed to trial and demonstrate the effectiveness of new methods; local co-operation between farmers to benchmark welfare standards should also be encouraged as well as assisted access to veterinary advice related to welfare matters (through similar schemes to those which provide assisted business advice to farmers).

Recommendation 3

There should be investment into raising the farm animal welfare skills base of those responsible for livestock management in all production systems through better training, appropriate recognition of demonstrable stockmanship skills, and enhanced communication and delivery of advisory services. (paras 12-15)

Support payments and Free Trade

16. Support payments that are made to livestock farmers should be targeted at production methods in such a way as to encourage good welfare and should not be provided simply as across-the-board headage payments. We recognise that changes in the subsidy payments system to link them with welfare compliance will require amendments to the CAP, but are convinced that these changes are essential.

17. Pressure should also continue to be applied to ensure welfare considerations are included in the negotiations of WTO. This need not be considered in any way anti-competitive since such recognition would provide opportunities rather than threats to all farmers seeking to comply with openly defined welfare standards. Likewise, the proposed labelling of food produced in compliance with Welfare Codes need not require changes to WTO. It can initially be introduced as voluntary labelling enabling consumers to make informed choices based upon a transparent understanding of the welfare provenance of the food they choose to purchase. In this way, retailers would be enabled to source their produce, whether home produced or imported, on welfare grounds which reflect society's wishes and to declare that provenance as brand information. This would enable individuals to make informed purchasing choices based upon welfare provenance.

Recommendation 4

Government should press for reform of CAP to enable any support payments to livestock producers to be linked to their implementation of the Welfare Codes. Furthermore, pressure should continue to be applied on WTO to include welfare standards in those negotiations. (paras 16-17)

Conclusion

18. England has a potentially excellent pool of farm management and stockmanship skills that needs to be exploited in order to improve the image of the farming industry and allow it to address steadily rising public expectations for the way farm animals are kept. We have a framework of farm animal welfare legislation supported by Welfare Codes. However these need to be better monitored, through effective welfare surveillance, and enforced throughout the production chain. We have excellent technical and research capabilities but need to communicate the results of these more effectively to the industry at large. We need to take a firm stance in relation to the public's expectations of welfare in negotiations with our European partners and in WTO.

Farm Animal Welfare Council
November 2001