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
4.17-25 – Ref. 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.
0
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.