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Exsanguination alone

240. This is done by tearing or cutting one or both gill arches and leaving the fish to bleed to death. The method results in convulsive movements and muscular spasms which continue for a considerable time. While convulsions at the later stages may occur after brain death through loss of blood, it is reasonable to assume that early convulsive movements are a reaction resulting from pain or distress caused by the method itself and conscious attempts by the fish to escape the environment of the bleed-out tank. This does not fulfil the criteria set out above, including the basic legislative requirement, and the practice should be forbidden.