This Bill has been passed to my Council for consideration and comment. Of course FAWC would normally confine its comments to aspects which relate directly to issues of animal welfare. However I feel it would be remiss of me to not mention the concerns held by many members of FAWC about the apparent widespread powers which this Bill would give your Department, and the possible implications of these powers.

The Bill raises ethical issues of depriving an animal of its life on which we have previously given advice (e.g. our advice in relation to the killing of unwanted progeny in the dairy industry. Several FAWC members would argue that this in itself, even if done humanely, is an injury that we should not routinely require humane people to perform. It would seem, therefore, that there will be a strong burden upon your Department to be able to prove, to the satisfaction of an independent and expert group, the necessity of any slaughter which may be performed under this Bill if enacted.

Over and above this ethical impediment, there are several possible welfare consequences of this Bill for which it would be important to have carefully prepared.

Should further episodes of large scale slaughter in the field become necessary it is imperative that the necessary research, technological development, training of operatives, and infrastructure have all been put in place well ahead of such an episode to avoid the welfare problems which occurred during the recent FMD outbreak. Indeed one might envisage a danger that the welfare problems might otherwise be exacerbated if the large scale slaughter is being performed without the whole-hearted support of the veterinary profession and farming industry. Underpinning the legislation with defined processes and clear guidance will be essential.

Secondly, we are concerned that this Bill may have a result of reducing the incentive to farmers to take responsible biosecurity measures in the event of an outbreak of disease if it was perceived that such measures would not influence the decision on whether culling took place. This is a very different issue from the deliberate introduction of infection that the Bill seeks to prevent.

Thirdly, with regard to vaccination, we commented during the recent crisis about our concerns that vaccinated animals should be allowed to enter the food chain in the same way as unvaccinated, and that without this assurance we would fear that the vaccinated animals would be vulnerable to abuse simply due to their perceived lower value. We therefore have concerns whether this Bill will further discourage farmers from vaccinating in the knowledge that vaccination might not help reduce their chances of being killed out.

Our welfare concerns with regard to the National Scrapie Plan also relate to an animal's inherent value. Once a tested animal is shown to be not of the desired genotype, it immediately has no economic value to the farmer. Indeed it is likely to incur a cost as long as it stays alive. The system must therefore ensure that there is a rapid move to slaughter to avoid any neglectful welfare abuse of such animals.

FAWC Chairwoman
December 2001