SUBMISSION
TO THE POLICY COMMISSION ON THE FUTURE OF FOOD AND FARMING
FARM ANIMAL WELFARE AND THE FUTURE OF LIVESTOCK FARMING
Summary
of Recommendations
Recommendation
1
The provisions of the Welfare Codes should be enforced as the minimum
acceptable animal welfare standards in all livestock production systems.
Equivalent provisions should apply equally to all the food we eat, including
imported livestock products, and should take the entire process (from
birth to slaughter) into consideration. An effective labeling system should
be developed to identify food produced in compliance with these Welfare
Codes (and the absence of such labeling on some imported goods may be
taken to indicate non-compliance with these codes or their equivalent),
and to additionally recognise food produced to enhanced welfare standards,
in an honest, transparent and reliable way. (paras 4-9)
Recommendation
2
There should be a national system of welfare surveillance throughout the
food chain and better enforcement of the existing legislation. A system
of registration of livestock holdings is an essential administrative requirement
to underpin such enforcement action and should be introduced. A single
welfare inspectorate acting throughout the food chain should undertake
this surveillance and enforcement role. A system whereby a formal licence
has to be held in order to undertake livestock production has attractive
elements from the standpoint of animal welfare. Equally, compulsory membership
of a farm assurance scheme providing independent monitoring at each stage
of production could be a viable alternative. We recognise that important
practical issues would need to be overcome in each case. (paras 10-11)
Recommendation
3
There should be investment into raising the farm animal welfare skills
base of those responsible for livestock management in all production systems
through better training, appropriate recognition of demonstrable stockmanship
skills, and enhanced communication and delivery of advisory services.
(paras 12-15)
Recommendation
4
Government should press for reform of CAP to enable any support payments
to livestock producers to be linked to their implementation of the Welfare
Codes. Furthermore, pressure should continue to be applied on WTO to include
welfare standards in those negotiations. (paras 16-17)
Introduction
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.
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.
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.
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
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.
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.
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.
Recent trends in
rationalisation of slaughter capacity have raised new welfare problems
associated with the scale of operation. New technologies are required
for large, high throughput slaughterhouses to avoid animals being mistreated
as a consequence of scale. Long distance transport (within reasonable
limits) is not stressful in itself provided good quality vehicles and
well trained drivers are used and loading/unloading activities are professionally
performed. However, transport may often be part of a marketing operation.
The stress involved in moving animals for marketing is potentially high,
and therefore must be kept to a minimum. In traditional markets and
collection centres, the problems relate to handling and mixing. This
problems are not necessarily eliminated by 'direct selling' or virtual
(e.g. video) markets.
Risk assessments
should regularly be undertaken of the welfare implications of emerging
and existing production and processing systems. New technologies and
innovations must be developed to address the needs of changing systems
and to safeguard the welfare of animals at all stages throughout their
lives. Existing Welfare Codes need to be further developed and up-dated
in the light of FAWC recommendations new husbandry systems, new farmed
species and new scientific information on animal welfare.
Recommendation
1
The provisions of the Welfare Codes should be enforced as the minimum
acceptable animal welfare standards in all livestock production systems.
Equivalent provisions should apply equally to all the food we eat, including
imported livestock products, and should take the entire process (from
birth to slaughter) into consideration. An effective labeling system
should be developed to identify food produced in compliance with these
Welfare Codes (and the absence of such labeling on some imported goods
may be taken to indicate non-compliance with these codes or their equivalent),
and to additionally recognise food produced to enhanced welfare standards,
in an honest, transparent and reliable way. (paras 4-9)
Monitoring
and enforcement of acceptable welfare standards.
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.
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.
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.
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.
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 apprpriate
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.
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
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.
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
England has a potentially
excellent pool of farm management and stockmanship skills that needs
to be exploited in order to improve the image of the farming industry
and allow it to address steadily rising public expectations for the
way farm animals are kept. We have a framework of farm animal welfare
legislation supported by Welfare Codes. However these need to be better
monitored, through effective welfare surveillance, and enforced throughout
the production chain. We have excellent technical and research capabilities
but need to communicate the results of these more effectively to the
industry at large. We need to take a firm stance in relation to the
public's expectations of welfare in negotiations with our European partners
and in WTO.
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