Farm Animal Welfare Council

1.The Farm Animal Welfare Council (FAWC) has maintained a close interest in this subject for a number of years and gave evidence to the Banner Committee in 1993. Many of the comments made at that time are equally relevant today; yet FAWC is concerned that relatively little seems to have been done to address them. The main points made to the Banner Committee by FAWC were that we regarded the ASPA as a sound Act, particularly because the principle of cost: benefit analysis was applied to proposals, thereby assessing ahead of the event the extent of suffering to animals weighed against the potential benefit to Society and to other animals. We regarded this as being important in helping change the attitude of researchers towards experimental animals. However, we pointed out that there was no comparable legislation to protect animals once they, or the techniques applied to them, entered commercial farming practice.

2. FAWC also argued that the application of new technologies should be defined, not by method but by consequence. FAWC proposed that an independent body should be established which would deal with specific procedures by reviewing the costs and benefits of their commercial applications.

3. We welcomed the publication in 1994 of the report by the Banner Committee. It provided an excellent overview of developments in biotechnology at the time and, more importantly, produced a number of recommendations that FAWC supported. We subsequently participated in a series of meetings with representatives of the Animal Procedures Committee. These meetings considered further developments in biotechnology and their potential welfare consequences as well as considering the apparent gaps in the regulatory/control processes. These liaison meetings continue.

4. FAWC's involvement in this general area continued with the publication in 1998 of its Report on the Implications of Cloning for the Welfare of Farmed Livestock. This report was produced at the request of Agriculture Ministers, largely as a result of the publicity surrounding the production of the cloned sheep (Dolly) early in 1997. FAWC recommended that "the general principles as prescribed by the Banner Committee should be accepted as a framework within which present and future uses of animals should be assessed". We went on to make a series of recommendations which were specific to the welfare concerns surrounding cloning technology. It is of concern that FAWC has still not received a detailed response to its recommendations from Government.

5. Since both the Banner Committee and FAWC invested considerable time and effort in preparing the reports and in the consideration of appropriate recommendations, FAWC advises that these reports are revisited with a view to, (i) considering which, if any, of the recommendations have been progressed, (ii) investigating the decision-making process within government with regard to which recommendations are accepted or rejected and, (iii) consider the practical problems with regard to the implementation of recommendations.

6. This latter point is particularly important. For example, how in practice can the ethical principles set out in the Banner Report be applied? Could a cost: benefit analysis be made to the application of biotechnologies in commercial farm practice? Who could actually do this? What range of skills would be needed? Should a body with responsibility for this work be advisory or have certain statutory powers? A further question that arises is what information would be required by such a body to make informed decisions? For example, would it be necessary for any new technique or a genetically modified animal to be subjected to a rigorous and appropriate testing procedure before it could be considered for commercial application (in much the same way as a drug might be tested prior to being given a licence)? These are far from simple questions, but ones that need to be addressed.

7. The following identifies some particular areas of concern, which were considered by FAWC at a recent meeting of its Research and Development Working Group. We hope that these will serve to illustrate the urgent need for control measures to be introduced. Because FAWC is primarily concerned with welfare, the examples tend to focus on the potential negative consequences of the application of new technologies. It is important to recognise, however, that any new technology might, in itself, be regarded as neutral and having the potential for both positive and negative influences on welfare. It is the application of such technologies that is important. Indeed, some techniques being developed, for example the use of sexed semen and other gender selection techniques, may have very clear welfare advantages in reducing the number of unwanted purebred male offspring of dairy herds or preventing the production of large numbers of unwanted male offspring in hatcheries producing chicks for laying hens.

8.Many of the most serious welfare problems in agriculture are the outcome of a lack of balance in genetic selection in past breeding programmes. In its last two annual reports FAWC has highlighted this subject as being the most important area for research. Techniques currently being developed have the potential to accelerate greatly the trend towards the development of adverse welfare consequences. Examples of current problems are the modern broiler chicken, where there is evidence to link selection for fast growth with increased leg weakness and cardio-pulmonary problems, and in the dairy cow where it is known that selection for milk yield is associated with reductions in fertility and an increased susceptibility to lameness and mastitis. It is clear that there can be a significant impact of breeding on an animal's biological functioning and fitness. In some cases, for example leg defects in broilers, recognition of problems by breeding companies has led to changes in selection programmes. However, the extent to which these changes in breeding goals are improving welfare is not clear. Furthermore, management methods are constantly adjusting to modern genotypes, hence apparent improvements noted on the farm may be the result of management changes rather than a direct effect of changing breeding goals. It is FAWC's view that there is an urgent need for research directed towards assessing the changing incidence and nature of welfare problems, and also to determine the respective genetic and environmental contributions. It is essential that such research be properly established in order to provide a base line to determine the consequences of the new breeding technologies.

9. If the experience of suffering is the central issue in considering animal welfare, it remains equally important to understand the effect of changing genotypes on issues such as pain, hunger and fear. For example, within the broiler chicken there is now evidence that birds showing physical evidence of leg weakness and walking abnormalities are experiencing pain. Therefore, in order to direct future changes in breeding programmes, it is essential to determine whether the side effects of selection result in experiences such as pain and discomfort. Given the substantial commercial interests involved in livestock breeding (irrespective of the techniques being used), evidence that breeding is influencing suffering will be essential in developing an ethical case for changes in current practices. Such research should consider not only the direct impacts of breeding (e.g. the effects of selection on leg weakness) but also the indirect effects, such as the need for food restriction to maintain reproductive performance. FAWC has requested that Government support a substantial research effort in these areas.

10. There appears to be an explosive interest in the potential of gene mapping to 'improve' livestock. Therefore it also has the potential to exacerbate the problems identified above should it be applied in an inappropriate way. FAWC acknowledges that its application to selective breeding programmes may be used to rectify some of the problems identified. For example, by selecting for specific health traits such as increased leg strength in broilers. However, concerns remain that, with the considerable commercial competition between breed companies, the primary focus of attention will be for production-related traits. In the case of the broiler chicken this may be for faster growth rate, improved feed conversion ratio, or greater breast muscle.

11. An example in pig production is the current work on gene mapping by the Pig Improvement Company with the aim of selecting sows with a genetic make-up to produce high litter sizes. Although this work is being promoted in the farming press, there may be negative welfare consequences that have not received sufficient attention. For example, large litter size can be linked with a higher incidence of piglet mortality and it is also possible that there may be consequences for the welfare of the sow.

12. Other research groups are using gene mapping for the selection of animals with greater levels of disease resistance. For example, salmonella resistance in poultry. Whilst this would, at face value, appear to have real welfare advantages, there is also the possibility that the development of such breeds may be used to cover up poorer quality housing and lower standards of stockmanship.

13.Similar concerns to those expressed in the previous section apply to the application of genetic modification technology in livestock breeding. The introduction of "foreign" genetic material, however, raises additional problems with regard to the regulating processes and the difficulties of predicting and evaluating welfare impact on the animals involved. Selected examples to illustrate FAWC's concerns are as follows.

14. Work in Canada has already produced pigs that are genetically altered to enable them to utilise cellulose in their diet. At the present time these are confined to the laboratory and the pigs outwardly appear fit and healthy. Irrespective of the ethical issues this work raises, the practical difficulty arises as to how the welfare implications of such a genetic change may be assessed and how the pigs will cope in the commercial situation where diet and management will not be controlled to the same extent as in the laboratory. Similar work is currently under way with sheep where research is aimed at enabling them to utilise plant material that is currently toxic to them.

15. A paper published in January 2001 reported the development of transgenic mice which exhibited substantial resistance to an intramammary challenge of S.aureus (the major contagious mastitis pathogen which accounts for approximately 15% to 30% of infections in dairy cattle). The paper concluded that the results in mice demonstrated clearly the potential of genetic engineering to combat the most prevalent disease of dairy cattle. As previously mentioned, increased levels of mastitis have been linked to selection for higher milk yield in dairy cows, so work of this nature could, on the one hand, be taken as a mechanism of overcoming this adverse side-effect of conventional selective breeding. Alternative views, however, might be (i) that the root cause of the problem should be addressed by incorporating a wider range of traits in breeding programmes (see FAWC Report on the Welfare of Dairy Cattle 1997) or, (ii) that work of this nature might be used as an alternative to proper housing and management.

16. Temperament has been an important component of livestock breeding since animals were first domesticated. Concerns have been raised, however, at proposals to genetically modify animals for this purpose. For example, in the USA it is proposed that the removal of genes associated with aggressive behaviour in pigs could result in the production of animals that could be kept at higher stocking densities. Work of this nature raises serious ethical questions. Furthermore, characteristics such as aggression are not fully understood. It is possible that the nature of the perceived change in the animal might be in the manner in which animal feelings are expressed, rather than the nature of the feelings themselves. For example, it does not necessarily follow that a dog left on its own for long periods which does not destroy the furniture in the house is coping with a situation of isolation any better than the dog that is destructive!

17. The amount of work with genetically modified animals going on in different parts of the world will raise challenges in the future with regard to controls on importation. If genetically modified animals become incorporated into mainstream agriculture in another country, how could the importation of such animals into the UK be regulated when it may not necessarily be apparent that such breeds had been genetically modified?

18. It is our understanding that no guidance or regulations currently exist to control the importation of such animals, unless for scientific research under the Animals (Scientific Procedures) Act 1986. Indeed it appears that MAFF would not necessarily be aware of such importations occurring.

19. In December 1999 there were reports in various scientific publications of work by medical researchers in Houston who had used gene therapy technology to make pigs grow 40% larger and faster. The reported quote from the lead scientist of the group was that, "We think that over the long term, this is going to be a defining technology that will change the face of how agriculture is done". Essentially, the research involved injecting into the legs of pigs, plasmids carrying GHRH which acts on the pituitary gland to stimulate the production of pig growth hormone. It has been claimed that two months after the piglets were injected (at 3 weeks of age), they were 40% heavier compared with untreated piglets and could be reared to market weight using between 20% and 25% less food.
20. Because of the potential commercial benefits, developments such as these are likely to become commonplace in all species of livestock. There is a need for all such developments to be subjected to complete evaluation with regard to safety, welfare implications and ethical considerations.

21. In the previous sections we have detailed our significant concerns over the lack of controls which exist to regulate the modification of animal genotypes in mainstream agriculture. Clearly the techniques used to develop such modifications may also have potential welfare consequences although we believe these to be well controlled, at least in the UK, by the existing controls of the use of animal in research.

22. However, we are also aware of other techniques that may arise out of research performed in other countries, which are then introduced into UK agriculture without any control. In the broadest sense, these might be termed biotechnologies. Historically they have ranged from novel breeding techniques (such as those considered by Banner) to novel methods of immobilisation and/or anaesthesia of animals (such as electroimmobilisation techniques that have since been outlawed in this country). There may be other types of techniques that have not yet been encountered or even imagined.

23. The above examples demonstrate that there are serious welfare concerns, as well as ethical issues, surrounding the current development of new techniques in animal breeding, production and husbandry. Besides the questions posed in the introduction to this submission, two additional issues about which FAWC is concerned are, who is actually monitoring developments and the application of new technologies to farm animals and would it be possible to put in place control processes which are proactive rather than reactive?

Farm Animal Welfare Council

Welfare Implications for Farm Animals of Developments in Biotechnology and the Application of Such Developments into Commercial Farming