The following is the text of a letter to Renate Lowres, Defra's Animal Identification and International Trade Division, dated 11 June 2001, in response to consultation on proposals to introduce a 20 day standstill period following movements of sheep, goats and cattle.

Introduction

FAWC readily acknowledges the impact that multiple movements of sheep appear to have had on the recent spread of Foot and Mouth Disease (FMD) and agrees that such movements need to be controlled. However, we are very concerned that a rigid 20 day standstill, as proposed, is likely to undermine the viability of good sheep husbandry systems. This has the potential to create significant welfare problems for the animals trapped within a non-viable system.

Furthermore, it is clear that effective methods of individual identification of animals, particularly sheep, are essential before any system of standstill periods can be reliably implemented and enforced. We also believe that remarkable improvements in welfare and disease control could be gained through tighter enforcement of the existing markets and transport legislation. However, this would require additional resources. Licensing of dealers should also be seriously considered, and much of the incentive for sheep movements would be removed by abolishing headage payments and replacing these with acreage payments or similar.

FAWC comments in detail

Below we seek to provide comments on the questions raised in the consultation.

1. It is clear that a system that provides for better control and the slowing down of sheep movements is required. Previous experience of self certification would suggest this to have a high risk of abuse with high attendant costs of control and enforcement. Local licensing also comes with high administrative costs and the same control and enforcement requirements. The sheer volume of movements would also preclude the use of these systems. The alternative, while still coming at high initial cost but with running cost scale economy and enhanced tracing capability, would be a central control based on individual animal identification and movement registration. The success of the Cattle Tracing System has shown how such a system could operate. We would expect enforcement of such a scheme to be largely implemented at a local level.

2. A standstill for sheep and goats is being proposed with the aim of preventing the spread of disease. It would appear that 20 days has been suggested simply on the basis that this is already in place for pigs. Guidance should be sought from the veterinary profession as to what period of standstill is correct for each species and in mixed farm scenarios. The main problem with the current outbreak is the extent of multiple marketing, multiple contacts and the spread of those contacts far and wide. The alternative of preventing multiple movements by restricting the number of times that a particular animal can be moved in any given period should be considered. A control framework already exists for calf movements. To ensure such a scheme is effective requires individual livestock identification and centralised data recording and monitoring for the same reasons as stated in a above.

3. The same issues arise for cattle as are given above for sheep. The most appropriate standstill period should be ascertained in line with cattle husbandry and the incubation periods of various diseases, which such a measure would be designed to control.

4. Option one would obviously give the better control. While it may requires more attention to farm planning this should not be insurmountable. Option 2 would give less control particularly if any future disease strain targeted cattle as distinct from sheep.

5. An exemption from the standstill period for movements direct to slaughter seems reasonable but should not become a loophole to be exploited. For example, it could be claimed that the intention was for animals to be moved for slaughter when they were in fact moved to other markets using the excuse that demand at the first slaughterhouse was not as predicted. Once more, individual identification is an essential element to enforcement.

6. Exemption for animals returning to a holding from an exhibition or show also seems reasonable provided these animals are isolated for a given period on the home premises so as not to pose a disease risk to other animals in the flock/herd.

7. If markets are exempted from the 20 day standstill (which they would have to be in order to continue to operate) then there is nothing in place to prevent multiple marketing; animals going from one market to another and mixing with other groups. It is essential to control this practice, perhaps by introducing a rule that once animals had been exposed for sale in a market they must either go direct to slaughter or to another holding where they must remain for a given period. Enforcement of the existing welfare at markets legislation should be tightened.

8. A multi-species disease such as Foot and Mouth Disease would seem to dictate that all animals be affected by a standstill. An additional weapon against introduction of disease would be isolation of incoming animals. Comments about tailored standstill periods made under b apply.

9. Comments as for h.

10. We suspect that there will be considerable opposition from sectors of the farming community but, as with the introduction of cattle passports, once a scheme has been in place for a period, management adapts to the new requirements. With regard to the costs, logic would indicate that the removal of multiple journeys and dealer profits from the current marketing system should allow these costs to be re-distributed within the food production chain.

11. For sheep and goats the proposed standstill system cannot possibly be enforced unless there is individual identification of animals. A flock mark identifying the holding of birth is insufficient. It is clear that, with livestock coming into markets from various locations and being moved on in mixed groups, possibly to another market where more mixing can take place, the current system of batch identification makes tracing of movements and enforcement of transport legislation impossible.

Reading ear tags in individual sheep would prove impossible in many industry scenarios, e.g. large volume sales. The only alternative is a practically effective form of electronic identification that will provide for rapid reading and dissemination of identification and movement data. We recommend that MAFF should urgently commission studies of technologically promising methods of identification (including electronic tags and retinal identification) to establish the applicability of such methods to practical livestock industry conditions.

The criteria for selection of an appropriate system should include

1. to be efficiently operable in all necessary industry scenarios;

2. to provide unique and reliable animal identification;

3. to be able to relate an identification event to a particular time;

4. preferably to be able to relate an identification event to a particular place;

5. preferably to spread the cost of identification across all who benefit from the system rather than solely placing the burden on the producer.

Finally, we believe that improving the enforcement of existing legislation relating to welfare during transport and in markets would have a significant effect in reducing the potential for spread of disease. Tightening enforcement of journey times and rest periods would go a long way towards slowing down livestock movements.

It is also important to ensure that trading of livestock is conducted in the public eye. The activities of dealers, agents, hauliers, markets, etc. should be regulated to ensure transparency, and be more closely monitored. This may be best achieved through a licensing system for dealers as well as a better definition of the curtelage of markets to avoid transactions at the margins which are not recorded. We would also continue to press for headage payments to be abolished in favour of acreage or similar payments. This would, at a stroke, remove much of the incentive that currently drives multiple marketing of sheep.

Conclusion

Overall, we are convinced that any policy of imposed standstill periods for livestock should be carefully thought through, with all the practical problems addressed in detail, to ensure that real welfare benefits will be the result, and that unforeseen welfare problems are not inadvertently introduced.