POULTRY REGISTRATION SCHEME

Thank you for your letter of 10 October enclosing the government response to FAWC’s recommendations for a poultry registration scheme.

As you know, FAWC proposed in November 1998 that you introduce a scheme for the registration of poultry keepers based on very clear animal welfare objectives. The poultry sector lacks a relevant information base and legislative control when compared to other sectors of the livestock industry and yet, as an essentially ‘intensive’ livestock production process, is a primary focus for potential welfare concern. When discussing the MAFF proposals on 12 October, the widespread view in Council was one of great disappointment that, after a wait of two years, the administrative scheme for locating poultry producers now proposed fails to capture the essence of FAWC’s recommendation.

The administrative approach set out in the note enclosed with your letter was given careful consideration but genuine concerns were raised about its effectiveness. It was felt that a straightforward registration process would have been a clearer and simpler procedure to adopt, and far more effective in meeting FAWC’s key objectives. Whilst recognising that the SVS does have information regarding the location of the major holdings, we have serious doubts whether a full and adequate record of poultry premises can be established and maintained solely by administrative means without any action on the part of the producers.

We understand the government’s general aim of minimising the regulatory burden on farmers, but we feel the simple requirement for enterprises to complete a registration record can hardly be seen as burdensome. Furthermore, it is difficult to reconcile the fact that registration is applicable to cattle, sheep and pig producers but not to the poultry sector where in many respects the need may be seen to be greater.

The scheme as we proposed would ensure a comprehensive list of poultry premises was established for the essential purposes of disease control and the distribution of literature such as welfare codes and advisory leaflets to all poultry keepers. Without it there can be no adequate sampling frame for undertaking welfare checks or monitoring changes in the production pattern, new housing construction, concentration of production capacity or changing management systems in the industry.

It is also a matter of serious concern that notification of mass mortalities will occur only coincidentally, and possibly long after the event, if it is dependent simply on reviews of records under the new Welfare of Farmed Animals Regulations. Occurrences of mass deaths amongst broilers are grave events in animal welfare terms, and the FAWC recommendation that they should be notifiable provided a means of enabling producers to be visited and given advice in order to prevent a repetition of such events.

While the administrative scheme does provide a framework where none now exists, FAWC feels nevertheless that it could have been given far greater effect at little cost. We welcome your assurance that a reliable and comprehensive database of poultry keepers can be compiled within current resources and note that the preparation of such a full record is estimated to take about six months. The onus must clearly be placed on AHOs to keep these records up to date. Furthermore, it will be important that the SVS has the necessary resources to enable flocks to be subject to inspections, as proposed by FAWC, at least every two years. The Council proposes to review the administrative scheme six to twelve months after the implementation date and report back to you on our assessment of its effectiveness in the light of our objectives.

I hope you accept that these comments aim to be constructive, but I would emphasise that if the government is serious about addressing the welfare concerns that are growing in society, resources will need to be put into schemes such as this. The Poultry Registration Scheme was a proposal with a potentially high welfare gain and very low resource cost, and I cannot avoid expressing the disappointment that Council feels over its apparent diminution in practice.