Farm Animal Welfare Council
   
 
 


 

FAWC's response to Defra consultation on Sustainable Food and Farming - Working Together.
(28 July 2002)

Introduction

The Farm Animal Welfare Council (FAWC) considers that the publication of the report of the Policy Commission on the Future of Farming and Food (the Curry Commission) entitled "Farming & Food; a sustainable future" marks a major opportunity for UK food production to meet the standards of animal welfare sought by the majority of the public whilst moving into a level of profitability which will ensure its ability to thrive successfully in the future.

We were, however, very disturbed at the time the Curry Commission was established at the apparent absence of in-depth welfare expertise in its membership. FAWC’s offer to fill that gap was readily accepted by the Commission and we prepared a carefully argued paper which concluded with four recommendations: that the Welfare Codes should be adequately enforced as minimum acceptable standards for UK production; that there should be reform of the CAP to link support payments to Code compliance; that a nationally co-ordinated and effective welfare surveillance system should be put in place; and that there should be investment in raising the skills base of those responsible for livestock management. We consider this submission so important that it appears in its entirety in our Annual Review (recently published and copy enclosed) and we attach a copy to this response to the Defra consultation at Annex B.

The Curry Commission incorporated the spirit of our recommendations into its Report but omitted to relate them directly to welfare. We are very concerned that this lack of prominent mention of welfare issues may give the impression that welfare is unimportant in the eyes of the public when compared with environmental and food safety issues. This is clearly not the case. Yet this Defra consultation document, issued in response to the Curry Report, falls into the same trap and places only marginal emphasis on welfare.

We are very disturbed that animal welfare appears, in both the Curry Report and the Defra document, to have become "subsumed" within environmental and food safety matters. Animal Welfare requires a fundamentally different and separate level of consideration. Indeed, there are potential conflicts between the objectives of these three aspects of food production. For example, environmentally friendly extensive livestock systems may raise new welfare problems; food safety considerations may encourage minimal social housing systems with associated welfare problems.

Furthermore, it should be realised that minimal acceptable welfare standards are not the aim of a niche market but rather an absolute requirement and expectation on the part of all UK consumers. It is merely enhanced welfare standards which appeal to niche markets, rather as is the case for organically produced foods.

Nevertheless, we consider the Curry Report offers a positive opportunity to achieve progress in welfare standards in parallel with enhancing environmental management and food safety. One of its major messages, "reconnecting the supply chain" is fundamental to ensuring that the focus of our producers is targeted at the needs and desires of consumers.

Indeed, the concept of "reconnecting the supply chain" sits entirely in harmony with the strategy FAWC announced two years ago to enable us all, as consumers, to express our concerns about the welfare provenance of the food we eat through informed purchasing choices. We have called this concept "Welfare Standards of the Food We Eat" and we have taken the opportunity to clarify our views on this important matter in our Annual Review (see enclosed copy and Annex C).

We believe this paper provides perspective, validity and policy relevance in what is now clearly a demand driven food system in this country. The paper also makes it clear that FAWC considers the welfare provenance of the food to be a more critical attribute than country of origin. Thus we would support the welfare labelling of products from other countries provided they are produced in full compliance with UK animal welfare standards (as in Welfare Codes), including standards of transport and slaughter.

The following response to the specific questions in the Defra consultation document particularly focuses on the areas where we consider it essential for welfare to be brought into the forefront of government’s thinking in relation to the food chain. We relate our comments to individual questions as well as to the recommendations in FAWC’s submission to the Curry Commission. In addition, in Annex A, we have listed the relevant recommendations from the Curry report to which our comments apply.

Farming and the food chain

Q 4.7 – Ref. to recommendations 1 & 2 of FAWC’s submission to the Policy Commission (Annex B). A new Agriculture Development Scheme (ADS) should support Assured Food Standards (AFS) to put emphasis on improving the quality of the auditing of farm assurance schemes including enhanced training of auditors in order to ensure standards of animal welfare are maintained. Sanctions for serious failings should be made clear. In terms of animal welfare the codes of recommendations for the welfare of livestock should be the benchmark minimum standard. Animal welfare has not been covered well in the report and it is important that this opportunity is not lost to ensure it is fully taken on board in future decisions. From the point of view of the Welfare Standards of the Food We Eat (Annex C), FAWC would support compliance by other EU countries with UK animal welfare standards in order to supply UK retailers. The emphasis should be on whole chain assurance including assurance during transport and at point of slaughter as well as on farm assurance.

Q 4.10 – Ref. to FAWC recommendations 1 & 2. FAWC would encourage the promotion of enhanced animal welfare products by business. There is a limited but significant market for welfare enhanced products. However, Government should not lose sight of its obligation to ensure that minimum standards are set and adhered to by all livestock producers. In this case we recommended that the minimum standards should be the requirements of the Welfare Codes. We do recognise that many of the Codes need to be updated and that the conditions set out in them should be enforceable. We have called for a commitment from Government to carry out such a review. Government and business could facilitate streamlined farm audits by sharing information and combining their effort.

Improving the performance of farmers and other land managers.

Q 4.17-25Ref. to recommendation 3 of FAWC’s submission to the Policy Commission (Annex B). Specialist Land Based Colleges throughout the UK are the predominant providers of full and part-time further and higher education, as well as training at all levels to support continuing professional development. Institutions have a wide geographical spread and include some institutions engaged primarily in Higher Education, but not ‘traditional’ Universities. In excess of 120,000 learners per year are able to benefit from the collective provision of colleges. The range of learning opportunity available reflects the extent to which colleges have diversified provision in response to changes in the rural sector and those involved solely in food production represent a smaller but crucially important proportion of the total. Colleges and other providers are seeking to ensure that the curriculum reflects the changing needs in respect of culture and mindset of those pursuing a future in production of food and stewardship of the land. Innovative attempts are also being made to reach those who traditionally have not engaged in formal training activity but whose needs in responding to dramatic change are particularly acute.

It is very clear that the future of agriculture is more dependent than ever on high calibre, knowledgeable and continually trained personnel. The existing knowledge base, skill and expertise of many involved in livestock production and management, with particular reference to animal welfare, disease prevention and control needs to be improved.

While conscious of sensitivities in respect of the regulatory framework, there may be a need to give some consideration of the extent to which statutory powers will be required to ensure adequate levels of competence in respect of specific occupational standards.

Many issues relating to animal welfare require more training opportunities and a better understanding of risk management and problem solving. It would seem appropriate that any future strategy for enhancing knowledge and skills should be targeted at all levels from senior managers, owners, tenants to technicians and other workers. Fundamental in this issue is the development of ‘stockmanship’ as a key driver to improved animal welfare. No matter how otherwise acceptable a system may be in principle, without competent, diligent stockmanship, the welfare of farm animals cannot be adequately catered for. The part that training has to play in the development of the stockman’s awareness of welfare requirements cannot be over stressed.

The links between the husbandry system and stockmanship components which influence animal welfare can only be developed effectively through education and training. At the new entrant level these requirements are significantly dealt with by the training providers of which Colleges will deal with the greater proportion. There remains however a significant training gap for those already in the industry and particularly for those who work within a micro-employer context where training opportunities are limited. The cost and practicalities of delivering staff development for this group is high and existing funding streams are not sufficient to allow such work to genuinely make a difference in the context of the skills or knowledge transfer.

There is a need for further research to improve our understanding of many aspects of training and stockmanship, to ensure the basis for sound educational/training/motivational packages for delivery through continuous professional development.

Resource protection.

Q 4.34-37 – We note throughout the Curry Commission Report the concentration on the environment. Similar questions to these need to be asked about animal welfare and health.

CAP reform.

Q 4.42-45 – Ref. to recommendation 4 of FAWC’s submission to the Policy Commission (Annex B). – Government needs to explore the move away from support payments aimed at production, particularly headage payments, and towards linkage to audited animal welfare standards. Much of this may require EU negotiation. It is important to bear in mind however that recommendations for removal of subsidies from the agricultural sector would not work without a market situation that would sustain the UK Agriculture Industry. Animal welfare would be compromised if withdrawal of funds led to markedly lower manning levels to care for the same number of animals. There should be different levels of subsidy for achieving the animal welfare baseline (based upon the Welfare Codes) and for enhanced welfare standards (which address niche requirements). Any changes to CAP should have an animal welfare risk assessment before implementation, involving FAWC in these assessments. For example, there is potential for subsidies paid for environmental targets on hill farms to cause welfare to suffer since income will become reliant on satisfying the environmental objectives and these may not relate to the successful production of a marketable livestock product, i.e. the animals.

Rural development and diversification.

We are disappointed that there was no mention of the potential impact of diversification on animal welfare. Diversification can lead to novel animal production systems that may bring with them inherent welfare problems. This should be considered before embarking on any new livestock system. It is important to ensure that countryside stewardship should address the animal welfare issues. Farmers who do not fully embrace the organic philosophy and lack the skills to run organic farms properly should be discouraged from entering this area as it takes a higher level of management to ensure animal welfare is protected. In this respect, we are very concerned that the "broad and shallow" approach applied to organic production will attract the wrong individuals to this sector. This will lead to welfare problems when, for example, therapeutic treatment of livestock is minimised without effective prophylactic measures being put in place.

 

Regulatory framework.

Q 4.64-70 – Ref. to recommendations 1 & 2 of FAWC’s submission to the Policy Commission (Annex B). Whether by farm assurance schemes, or another method, there should be an audit of baseline animal welfare requirements (these are quality standards in the same way as environmental issues) and higher welfare standards for niche market standards, including organic production. Information from these audits should be fed into the welfare surveillance system.

We see compliance with baseline welfare standards (i.e. the Welfare Codes) as a basic expectation from the consuming public which should be confirmed with transparent and reliable labelling. We also recognise that niche demands, such as enhanced welfare production or organic production, should be available to those consumers who wish to choose them via an informative and equally reliable labelling system.

Herd health plans aimed at incremental improvement of the welfare and health of the animals on the farm are an essential part of a whole farm plan. Realistic health plans must have veterinary involvement. As we recommended in our report on the Welfare Implications of the Foot and Mouth Disease outbreak (published January 2002), provision of veterinary advice as part of a farmer’s subsidised business advice package should be readily available to farmers.

A vastly improved biosecurity culture at farm level should also form part of the whole farm plan.

Q 4.68 – A certificate of conformity signed by a vet could get round issues of confidentiality re. inspection of herd health plans. This is an example of how, with professional input, confidentiality can be ensured. The Royal College of Veterinary Surgeon (RCVS) places an onus onto its members to respect the confidentiality of information acquired from clients in all but very exceptional circumstances. We believe that enforcement of confidentiality through the RCVS Guide to Professional Conduct would provide adequate confidentiality.

Q 4.69 – Ref. to recommendation 3 of FAWC’s submission to the Policy Commission (Annex B). The transfer of knowledge via demonstration farms and local co-operation between farmers to benchmark welfare standards should be encouraged. Proactive communication through all type of media, including Press, television and radio, should be considered to cater for farmers who do not have access to web-based services.

Animal welfare and health.

Q 4.87-90 – The lack of prominence given to animal welfare in the Commission’s Report is mirrored by the limited mention of welfare in the Defra consultation document. There needs to be a change of mind about the importance of animal welfare within the structure of agriculture in the UK otherwise we are fearful that welfare will be neglected while other issues take centre stage. The impact on animal welfare of many of the changes being suggested has not thus far been sufficiently considered.

The implication of the consultation document is that health is the predominant issue, and welfare is a subset of health. In fact, the opposite is the case. Health is a part of welfare and, whilst issues of biosecurity are important, it is equally important that there should be a cohesive national welfare and health strategy. The health side of this should focus not just on zoonoses and exotic diseases, but also cover other important endemic diseases which have severe welfare implications such as lameness and sheep scab. There is a need for national and local levels of surveillance of welfare as well as animal health. The SVS is not of sufficient size to offer the local level of monitoring but the State Veterinary Reserve recommended in FAWC’s FMD report could provide this service. There would need to be clear and transparent contracts with private veterinary practices to define what was required of such a reserve, including provision of regular data to the SVS on welfare surveillance as well as disease surveillance. All surveillance data acquisition should be evaluated using risk-based methodologies. Potential conflicts with the vets’ commercial practice should also be addressed but should not be seen as being insuperable. We suggest early discussions with RCVS to establish guidance on this.

Q 4.88 – Stakeholders are all those involved in the production of food from the farm upwards. As well as the farming industry, groups such as vets, training providers, consumers and the welfare organisations have an interest and should be consulted.

Q 4.89 – The cost of disease control for exotic diseases such as FMD should fall to Government. The FMD outbreak in 2001 was without doubt imported and was thus largely outside farmers’ control. Indeed the cost of all notifiable diseases where slaughter is required should fall to Government. There may be a place for insurance for lesser conditions including endemic diseases. Insurers should be encouraged to set minimum standards of biosecurity as part of a compulsory health plan as a prerequisite for insurance.

Q 4.90 – Ref. to recommendation 2 of FAWC’s submission to the Policy Commission (Annex B). Animal health plans should be compulsory with input from vets. Training for those coming into the farming profession must contain a significant element about animal welfare and its links to good farm management and profitability. Farm assurance schemes can provide a link to the consumer which both ensures baseline (or enhanced) animal welfare standards and communicates these up and down the food chain. Farmers not wishing to join a farm assurance scheme should be licensed and reliably and competently inspected to a similar standard.

There is some suggestion that the market can provide for animal welfare needs rather than Government. We believe that animal welfare can be marketable with minimum impact on profitability but only if there is market recognition (i.e. through labelling). If a system which achieves this is not put into place, then basic animal welfare standards (compliance with the Welfare Codes) has to be provided as a public good.

Please do not hesitate to contact me if you seek expansion on any of the points made in this submission from FAWC. May I confirm that FAWC sees much that is very positive in the Curry report and wishes to promote its implementation. However we consider it essential that full recognition is given at all levels to the importance of welfare as a feature of the sustainability of a livestock production system, alongside consideration of the environment and food safety. These are the three legs of the stool, and all three are essential to the sustainability of the system.

 

Annex A.

Recommendations from the Curry Commission’s Report

Recommendation 5 – We are concerned at the declining proportion of animal welfare research in the Defra funding. Funds can be diverted too readily from welfare research to areas of major disease concern such as TSEs. This is not acceptable. A Priorities Board should either have adequate animal welfare representation and focus or alternatively funding for welfare research should be ring fenced.

Recommendation 6 – FAWC would support co-ordination of research funding between government, levy bodies and others to avoid duplication.

Recommendation 15 – National biosecurity/import controls need to be strengthened as we recommended in our Foot and Mouth Disease Report.

Recommendation 17 – Our comments on labelling are contained in the attached policy document "Welfare Standards of the Food We Eat" (Annex C). We would also refer to Recommendations 1 & 2 of our submission to the Policy Commission (Annex B). We are content that an improved Red Tractor Scheme could provide baseline assurance – for the purposes of welfare assurance, this means full compliance with the Welfare Codes in order to participate in such a scheme. Also it is important that the systems of audit and validation are enhanced to ensure reliability and transparency in such a label. We welcome the appointment of Professor David Morton, Professor of Biomedical Ethics at Birmingham University, to the Board of AFS and call on him to give robust support to reliable animal welfare standards monitoring within AFS.

Recommendation 34 – We have concerns about the impact on animal welfare of some identification methods for livestock traceability. We have requested through Defra’s Electronic Identification Steering Group, but not yet been shown, evidence of an adequate welfare risk assessment into the impact of administration of electronic boluses, particularly in young animals. We are also aware of welfare problems associated with ear tags. We understand that recent studies on the practical use of retinal identification have been promising. We believe that the EU needs to come to a decision on this issue, based on the best possible information, which should include animal welfare assessments.

Recommendations 51 – 54 & 56 – Ref. to FAWC recommendation 3 (Annex B). We have highlighted the need for increasing professionalism in the farming industry and communicating this professionalism to consumers.

Recommendation 63 – Ref. to FAWC recommendation 4 (Annex B). Support payments made to livestock farmers should encourage good welfare. We recommend that Government proposals for CAP reforms should include the linkage of such support payments with implementation of the Welfare Codes.

Recommendation 66 – As we have mentioned in the main text of this submission, there is the potential for conflict between environmental and animal welfare goals. Welfare risk assessments need to be comprehensively performed.

Recommendation 69 – It is essential that the proposed whole–farm audit programme should include animal welfare considerations.

Recommendation 75 – An animal welfare assessment of organic livestock production is required before wide acceptance of organic production as part of any environmental scheme. We see grave danger in adopting the "broad and shallow" approach to expanding organic production. This may encourage less competent and committed farmers to attempt this type of production, which could lead to severe welfare problems associated with poor husbandry and disease management.

Recommendation 79 – Later this year, FAWC hopes to issue a report on Animal Biotechnologies in Agriculture making specific recommendations about the control of emerging technologies before their introduction into commercial agriculture. This will be complementary to the forthcoming AEBC Report on Animals and Biotechnology.

Recommendation 86 - FAWC is not opposed to country of origin labelling. However we believe it is more important to have informative labelling which assures consumers of quality aspects of the production system, which should include welfare standards during production, transport and slaughter.

Recommendation 88 – The potential zoonotic risks need to be fully considered before a school visits a farm. However, we do not believe these risks to be insurmountable. We also believe that society as a whole needs a greater understanding of how agriculture works and this may be partly achieved by such visits. Welfare issues need to be addressed as part of any such visit

Recommendation 90 – FAWC wholeheartedly supports this recommendation of the Policy Commission. Ref to FAWC recommendation 1 (Annex B). There needs to be a proper evaluation to identify and assess how many farmers operate below the acceptable minimum standards (as per the Welfare Codes) and mechanisms used to either improve their standards or remove them from the industry.

Recommendation 91 – Ref to FAWC recommendation 2 (Annex B). We agree with the Commission that farms that are not part of an assurance scheme should be licensed and inspected to the same standards (i.e. at least according to the standards in the Welfare Codes).

Recommendation 96 – We are not aware of evidence that links less intensive systems to reduced zoonoses. We believe that it is more important to focus on the quality of management of the system, whether it be intensive or extensive.

Recommendation 97 – We are concerned that any drive towards low or no drug farming systems will lead to significant welfare problems amongst the stock of those farmers with poorer stockmanship skills and who are less able to manage animals without medication. This problem has already been experienced in some parts of the organic sector and would be likely to lead to animal welfare problems.

Recommendation 100 – Ref. to the Welfare Standards of the Food We Eat (Annex C) and to our Interim Report on the Welfare Implications of Farm Assurance Schemes. We would encourage a minimal welfare baseline (i.e. compliance with the Welfare Codes) to be included in all Government procurement contracts. We are seeking evidence from the mass catering and food processing sectors for our second Farm Assurance Schemes Report and expect to be supporting this concept in our recommendations in due course.

 

Annex B.

Submission to the Policy Commission on the Future of Food and Farming: FARM ANIMAL WELFARE AND THE FUTURE OF FARMING & FOOD

This paper comprises the submission that FAWC delivered to the Policy Commission on Food and Farming (the Curry Commission) in November 2001. This input was prepared at the invitation of the Commission, recognising the relative absence of specific welfare expertise amongst its membership. FAWC, as the welfare advisory body appointed by Government, was the natural partner to fill that gap.

FAWC believes that the content of this submission, and its four recommendations, are crucial to the effective realisation of consumer-lead animal welfare standards in the future. We wholeheartedly support the need for "reconnection of the supply chain" as advocated by the Commission. FAWC will be pressing for implementation of these recommendations in parallel with the more general recommendations of the Commission.

Summary of FAWC’s 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 labelling system should be developed to identify food produced in compliance with these Welfare Codes (and the absence of such labelling 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.

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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. These 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 labelling system should be developed to identify food produced in compliance with these Welfare Codes (and the absence of such labelling 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. The UK 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 needs 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.

 

Annex C

The Food We Eat; connecting Animal Welfare, Food Quality and Consumer Satisfaction

A key message from the report of the Policy Commission on the Future of Farming & Food (the ‘Curry report’) published in January was ‘reconnection’. This relates to the difficulties, inherent in the modern complex food supply chain, in linking farmers with the consumers they ultimately serve.

Most consumers have little knowledge of what goes on in farming, yet their developing preferences for the qualitative characteristics of the food they purchase needs to be articulated back down the supply chain to the farms where the food raw materials are produced. These quality characteristics cover origin, nutritive value, residues and safety, environmental credentials and – crucially in the case of livestock products – the welfare standards associated with the food producing animals.

FAWC had recognised this ‘connection’ issue some time ago, and at our Open Meeting in June 2000 we highlighted the principle which now guides all our thinking – namely, that the welfare standards under which farm animals are kept are carried through to become a quality aspect of the resulting food products (whether home produced or imported). The recognition of this principle is of fundamental importance, both to policy and to the way FAWC frames its advice to Ministers.

It means, for example, that animal welfare considerations are an integral part of food consumption, not simply a farm-level concern about how animals should be treated. Further, it implies that the animal welfare standards with which UK society feels comfortable do not relate solely to the way we keep livestock in this country. If they have any meaning, those standards must logically apply to all livestock-derived food products we consume, from wherever they are sourced – from UK farms, other EU member states or the wider international market place.

It means, too, that the increasing number of consumers who wish to satisfy their preference for food products which have an appropriately high welfare provenance need a means of expressing that preference back down the food chain to domestic and overseas livestock farmers. They also require a dependable framework of information to know that the products they buy actually do meet their preferences. In other words, the consumer needs ‘connecting’ to the farmer.

FAWC has pursued this issue with a clear focus. It has emphasised the need for specific and unambiguous product labelling relating to animal welfare, and is undertaking a major enquiry into the role and ability of Farm Assurance Schemes to provide consumers with information and confidence in the welfare standards of the food they eat. These are crucial elements in the ability of people to connect with the way their food is produced, and to feel comfortable with the livestock husbandry methods their purchases are supporting.

There are a number of obvious implications of treating animal welfare standards as not simply technical on-farm issues, but as being embodied in the resultant food products.

First, while farmers are at the beginning of the food chain it is the processors, retailers and food service (catering) sectors that provide the connection through to the consumer. Hence it is essential for companies in these areas of the system to convey consumer preference signals back to their farmer suppliers, and to carry forward information about the welfare standards of the products they are supplying.

Indeed, given their power in the market place, they are potentially far more influential in determining the welfare standards of the food we eat than are farmers. FAWC recognises this, and in its enquiry into Farm Assurance Schemes it is looking for far greater leadership from these post-farm sectors. The food service sector in particular, which has a substantial and increasing share of final food expenditures, could more explicitly consider (and declare) the welfare provenance of the products it offers.

A second implication is, as FAWC emphasised when first enunciating this concept, that the animal welfare standards that UK society wishes to espouse must apply to all food products that are sold here. It is inconsistent and illogical to recommend welfare standards that British livestock farmers must meet and not insist that imported products equally should meet them. Otherwise, FAWC’s recommendations to Ministers would simply create inequality between domestic and overseas producers to no purpose – and that is not its intention nor wish.

More positively, FAWC’s standpoint and consequent advice to Ministers provides a clear basis for leadership in negotiations on welfare standards within the EU, and a defensible basis for arguing, for example in the WTO, the validity of animal welfare criteria being applied in international trade. Until that position is accepted internationally, we maintain that effective voluntary welfare labelling, clear and transparent, will enable consumers to exercise informed choice in their purchasing decisions.

The principle that animal welfare is a characteristic of the food we eat, not just the food we produce, is the major cornerstone in all the work that FAWC now undertakes. It provides perspective, validity and policy relevance in what is now clearly a demand driven food system in this country, requiring that demand preferences – for farm animal welfare and other aspects of production – are satisfied in the way food is produced. FAWC’s guidance and recommendations are developed in the light of this need.

Last modified 6 July, 2005
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