Farm Animal Welfare Council
   
 
 


 

Advice to Ministers on Welfare Implications for Low Value and Surplus Farm Animals

  • Summary and Recommendations
  • Background
  • Remit and method of investigation
  • The scale of the problem
  • Existing routes of disposal
  • Potential solutions
  • Appendix 1 - Letter of 23 September 1999 to Mr Morley MP
  • Appendix 2 - Letter of 18 October 1999 from Mr Morley MP
  • Appendix 3 - Letter of 28 October 1999 from Mr Ross Finnie MSP

 


 

1. This advice is intended to guide Ministers’ considerations of future methods of disposal of low value and surplus animals. FAWC tasked itself with providing advice on a long term strategy for humane disposal following an unfavourable response to its short term recommendations.

2. The difficulties experienced by the farming community in disposing of surplus calves and sheep in the summer/autumn of 1999 resulted in FAWC writing to Agriculture Ministers in September 1999. The letter recommended the implementation of short-term solutions to facilitate the humane disposal of such animals and the development of a long-term strategy to overcome problems in the future.

3. Ministerial responses indicated that the short-term solutions recommended - the introduction of a temporary cost neutral scheme for the disposal of cull ewes and a derogation to permit low throughput slaughter houses to exceed their current throughput limits to kill surplus calves - were incompatible with European Union (EU) legislation.

4. A FAWC working Group was set up in February 2000 to consider the issue further. The group gathered information on the scale of the problem and the existing routes of disposal in consultation with MAFF and the relevant organisations from the industry.

5. The valuable service provided by the knacker industry, the rendering industry and hunt kennels in relation to the disposal of casualty, emergency and fallen animals has been greatly reduced post BSE with the introduction and extension of SRM controls and the reduction in the value of salvaged by- products. Farmers, particularly those in more remote areas, have been faced with higher costs of disposal resulting in increased on-farm burial. It is anticipated that problems with disposal will be exacerbated when the rules governing on-farm burial become more stringent, as drafted in a proposed EU regulation which would replace the Animal Waste Directive. The current draft regulation, which is due to come into force in 2003, with an 18 month implementation period, would ban the burial of ruminants other than in defined remote areas (e.g. islands) under very tightly defined conditions.

6. Animal welfare is most likely to be compromised when market values fall to very low levels. FAWC recommends that Ministers and the livestock industry explore all possible avenues to assist the development of effective market solutions for this class of livestock.

7. FAWC recommends that a fully integrated and auditable national scheme be established for the collection and disposal of fallen casualty or emergency animals which is also capable of providing a disposal route for unwanted calves and cull ewes at times of depressed prices.

8. Ministers are advised to consider all available options for the funding of such a scheme, including a levy system, the provision of central funding and the introduction of specialised insurance policies.

9. FAWC recommends that the operation and funding of national collection and disposal schemes in other Member States be examined to consider if any provide an appropriate model for Great Britain.

10. FAWC recommends that, whilst on-farm disposal remains an option under EU legislation, farmers concerned are properly trained in the methods by which animals may be slaughtered humanely and are made aware of the relevant legal provisions.

11. FAWC recommends that an industry action group be established, co-sponsored by the relevant Government Departments (e.g. MAFF, Dept. Of Environment, Dept. Of Health, Food Standards Agency, etc.) to consider the issues raised by the disposal of surplus, fallen, casualty and emergency animals.


 

A. Background

12. In the late summer and autumn of 1999, it became apparent that farmers were experiencing difficulties in the disposal of surplus, old and low-value livestock. The removal of the Calf Processing Aid Scheme in July 1999, which had provided a payments system for surplus dairy calves, and a fall in cull ewe prices combined to create a situation which posed a serious threat to the welfare of these animals. The problems were exacerbated by the low prices received for cull ewes in the autumn of 1998 that resulted in farmers keeping animals for a further year in the hope that the market would recover. In the event, prices in autumn 1999 were even lower than in the previous year. The relative strength of sterling and the extension of SRM controls to include the spinal cord of sheep, from the beginning of 1998, reduced further the marketable value of poor quality animals.

13. It was difficult for FAWC to obtain an objective assessment of the extent of the welfare problems that resulted directly from the economic difficulties. However, it was clear that there were increased numbers of ewes in poor condition on farms and that many more farmers were resorting to on-farm killing and burial of calves and ewes. FAWC was concerned that such livestock faced an increased risk of being killed by unskilled persons and that some animals that should have been humanely killed were being left to die. There were reports of livestock being abandoned and also of an increased trade in cull ewes by market dealers who were buying up animals with a very low value and speculating on price increases. This was often to the detriment of their welfare. Welfare abuse could easily occur in similar circumstances with other species.

14. Ideally, a national collection and disposal system is required to ensure the humane disposal of the animals identified above. Farmers throughout Great Britain must have available a route through which they can guarantee the humane disposal of their livestock. This would enable them to cope with occasions when normal prices collapse and to deal with the regular problem of the disposal of individual fallen, casualty or emergency animals.

15. Whilst recognising the economic situation, and the significant aid package provided to the livestock sector, FAWC considered how best to offer advice on the animal welfare implications of the situation. In a letter sent to Ministers (see Appendix 1), the Council focused on the disposal of surplus sheep and calves and recommended, as a short-term solution, the implementation of a mechanism which would be cost neutral to the farmer to dispose of those animals with little, or no, market value. We also requested that a longer-term strategic plan be developed to ensure that problems of disposal did not re-occur.

16. Whilst the letter reflected FAWC’s initial thoughts and was a precursor to a more detailed study of the topic, we believe the comments made in that letter remain extant and Government may wish to revisit the suggestions made when considering this more detailed advice.

17. The responses from Elliot Morley and Ross Finnie demonstrated that European rules imposed severe constraints on FAWC’s initial proposals for short-term solutions to the problem (see Appendix 2). The Scottish Executive had wished to pursue a scheme for the disposal of cull ewes, and the National Assembly for Wales wished to explore a similar scheme in respect of calves. Both were considered to be incompatible with EU rules. Furthermore, we were informed that our request for a derogation to allow licensed low throughput slaughterhouses to exceed their permitted throughput limits in order to kill surplus calves would contravene the EU Fresh Meat Directive.

18. It was decided, in February 2000, to establish a working group to develop further advice as necessary. Whilst it was difficult for the working group to predict, with any great certainty, the likelihood of the problems experienced in the previous year being repeated, this report summarises our study and makes a number of recommendations.

B. Remit of working group and method of investigation.

19. The working group decided that it should concentrate on the welfare of unwanted or surplus stock, especially cull ewes and calves, in situations where it was impracticable to dispose of them through the normal channels and where it was unlikely that the sale of the animal would cover the cost of its disposal. However, it was clear that any recommendations would also apply to casualty and fallen stock.

20. FAWC is aware that other species also have problems of unwanted stock, notably spent hens (which will be addressed in a future report on the welfare implications of poultry slaughter) and unwanted male chicks in hatcheries, on which we have commented before.

21. Unlike most FAWC reports, this study did not require a wide consultation process. Members of the working group were able to provide a broad range of experience and information was gathered from a number of sources. We acknowledge the assistance given by the Ministry of Agriculture, Fisheries and Food (MAFF), the Licensed Animal Slaughterers and Salvage Association (LASSA), the United Kingdom Renderers Association (UKRA) and the National Farmers Union (NFU). Together with other appropriate contacts within the industry, this enabled the study to be undertaken and concluded within a relatively short time.

22. In considering our conclusions, we took into account proposed future change to the EU Directive on the disposal of animal waste.

A proposed Regulation will have implications for future methods of carcase disposal. In particular, a ban on the burial of ruminant carcases (with very few exceptions) has been proposed. Whilst FAWC is primarily concerned with the animal up to the point of slaughter, any changes to the available routes of disposal will have welfare implications. A recent EU Commission review of the Animal Waste Directive has proposed a number of radical changes and whilst discussions are at an early stage, they may have a profound impact on current methods of disposal. Therefore, FAWC strongly recommends that MAFF collaborate with other government departments to ensure that a ‘joined up approach’ is undertaken during the review of this Directive, in order to accommodate animal welfare, public health and environmental concerns.

C. The scale of the problem.

23. We sought to determine the scale of the problem in order to gain a better understanding of when difficulties occurred. Figures 1-3 show the cyclical variation but substantially declining prices for calves and, in particular, demonstrate the very low prices obtained for cull ewes in the autumns of 1998 and 1999.

Figure 1

Figure 2

Figure 3


24. It became clear that problems associated with the disposal of low value animals varied considerably throughout the country. The picture also varied from species to species and it was recognised that the Calf Processing Aid Scheme (CPAS) had produced an artificial market effect on the disposal of calves. It is worth noting that since the cessation of the CPAS, many dairy farmers have reconsidered their breeding strategies with the result of reducing the number of pure dairy breeds. Breeding strategies now appear to be more market orientated and this move towards a closer alignment with market needs is to be welcomed.

Existing routes of disposal

25. Currently, many livestock farmers in this country have access to a system that is peculiar/unique to GB and Ireland. The knacker industry and hunt kennels provide a service that, although disparate, is able to deal with many individual cases of casualty, emergency and fallen animals, provided that charges do not go beyond a level that producers will meet.

26. The knacker industry kills animals on-farm and also collects animals that have died on-farm, except in cases where a notifiable disease is suspected. It then salvages those elements that have a value, such as skins or hides and some meat for pet food, and passes on the remainder for specialist rendering. The rendering industry has a distinct and valuable role to play in the processing of animal waste.

27. However, since the advent of BSE, disposal costs have risen and the value of products that can be salvaged has fallen. The service provided by knackers yards and hunt kennels has been reduced as farmers have increasingly been faced with charges for the collection and disposal of stock. As a consequence, more farmers have resorted to on-farm burial.

28. A crucial requirement for livestock farmers is a ready and accessible route for the disposal of casualty and fallen animals; something which the knacker industry and hunt kennels provide. Unfortunately the availability of these facilities, particularly in remote areas, is not always consistent with the density of farm livestock. For example, in Scotland there are only four knackers yards and nine hunt kennels.

29. In animal welfare terms, the knacker industry could be considered to provide the ideal service for the disposal of casualty, fallen or unwanted animals. However, it evolved when animal by-products had a saleable value. With little or no financial return on these products, coupled with increased disposal costs (caused by SRM controls), knackers are in decline. The long-term future of this industry is uncertain and it is unlikely to be commercially viable to establish new independent knacker businesses in those areas where they do not already exist. This raises the question as to whether this existing route of disposal can be used, or adapted, to accommodate the slaughter and disposal of low-value or unwanted animals should a similar situation arise to that which occurred in the autumn of 1999.

30. During the autumn of 1999, hunt kennels were able to supply a useful local service to farmers with regard to the disposal of unwanted calves and provided humane slaughter by an experienced slaughterman. However, it was noted that many of these establishments reached saturation point and few were willing to deal with sheep.

31. The Burns Enquiry considered the implications of a ban on hunting on the fallen stock service provided by hunt kennels. They reported that the 200 hunts surveyed had handled 336,000 carcases in the previous 12 months although it was noted that it was not easy to say what proportion of the total business this represented. The enquiry recognised however, that the EU Waste Incineration Directive would introduce more rigorous controls for emissions from incinerators (reference paragraphs 35-38). The collection service offered by hunts is financed in a variety of ways ranging from direct charges for dealing with certain animals, fees related to the number of expected collections or the offer of a service in exchange for access to land for hunting.

32. The implications of the above is that, under present conditions, the knacker and hunt kennel avenues of disposal are unlikely to provide either a long-term or a national answer to the problems of fallen, casualty and low-value stock. As a result of poor economic conditions and the increased costs of disposal, there has been a trend towards killing and disposing of animals on-farm and this trend will increase if there is no ready market nor an efficient collection service. Purely in terms of animal welfare, on-farm killing offers an acceptable solution, provided it is carried out in a humane manner and in accordance with the law. However, it is recognised that on-farm carcase disposal has environmental, animal and public health implications. It is noted that the National Sheep Association (NSA), Humane Slaughter Association, Meat and Livestock Commission (MLC), MAFF and NFU and probably others, provided valuable assistance in the dissemination of information to ensure farmers were adequately briefed on the welfare implications of surplus stock disposal.

33. Strict controls already exist in regard to on-farm burial but it is noted that local authorities apply and enforce these with varying levels of vigour. Furthermore, unskilled people (who are not necessarily conversant with the requirements of the slaughter legislation) may carry out on-farm slaughter. Slaughter and killing are skilled techniques and to carry out the task in a humane manner requires appropriate training. FAWC is concerned about reports of untrained farmers using inappropriate methods to perform these activities.

34. The situation is likely to change when the proposed EU Regulation, which would replace the Animal Waste Directive, is implemented. It is proposed that the new Regulation should come into force on 1 February 2003 (and allow 18 months for implementation) and as currently drafted would ban the burial of ruminants, other than in defined remote areas under very tightly defined conditions. Farmers who currently use burial to dispose of fallen ruminants would face additional disposal costs in the event of a ban on such burial. Hunt kennels would be required to meet the standards that currently apply to knackers’ yards and any additional costs involved can be expected to be passed back to the producer.

35. The Department of the Environment, Transport and the Regions (DETR) has overall responsibility for planning policies in regard to incinerators. MAFF works closely with them during the preparation of national planning policy guidance and on the planning system in general.

36. Recognising the impact that measures proposed in the Waste Incineration Directive would have on the use of small incinerators (those with a capacity less than 50kg per hour) which are mainly operated on farms and hunt kennels, the Government obtained an exemption for such incinerators. This exemption was obtained on the basis that appropriate controls for these small incinerators would be introduced via the Animal By-Products legislation.

37. The Environment Agency does not regulate small incinerators, although all facilities handling Specified Risk Material (SRM) are licensed by MAFF. MAFF is currently assessing the risks to public and animal health from the use of small incinerators to dispose of SRM, mainly at hunt kennels, knackers and small abattoirs. The results of this study will help with discussions in Brussels on the Animal By-Products legislation and the future standards for the operation of small incinerators.

38. Larger incinerators could also provide disposal facilities for surplus stock. Planning difficulties for new incinerators are therefore an issue. The local and national authorities that process applications for incinerators where there are animal health and welfare implications should take these issues into account as well as those of public health and environmental concerns.

39. Concern was also expressed to the working group by some sectors of the meat industry that with current methods of disposal there was a potential risk of unfit meat entering the food chain as a result of malicious intent. The most effective way of reducing the possibility of malpractice would be to establish a national collection and disposal service.

D. Potential solutions

40. A strong demand for surplus animals through the market which sustains their value and hence the incentive to protect their welfare is one of the most effective ways of helping to secure acceptable standards of animal welfare in the long-term. The Government is advised to seek input from specialist organisations groups such as the NSA and the MLC on how to develop potential markets, particularly for the export of meat carcases from those animals that have traditionally attracted a lower market value in this country. For example, there might be marketing opportunities for the export of meat from cull ewes.

Recommendation

41. FAWC recommends that Ministers and the livestock industry explore all possible avenues to assist the development of effective market solutions for this class of livestock.

42. It will be seen from Section C that the current disposal network is fragmented and that some areas of the country are not well served. It is FAWC’s belief that animal welfare would benefit from having a fully integrated scheme for the collection and disposal of, not only the individual animal (casualty, emergency, etc.), but also for the disposal of calves and cull ewes in times where farmers are not able to sell their animals via the normal channels.

Recommendation

43. FAWC recommends that a fully integrated and auditable national scheme be established for the collection and disposal of fallen casualty or emergency animals which is also capable of providing a disposal route for unwanted calves and cull ewes at times of depressed prices.

44. During discussions with interested organisations it was suggested that the establishment of such a scheme is feasible provided:

  • the service operated 24 hours/day, 365 days/year and farmers were well informed as to whom to contact;
  • there was a network mapping system to identify the location of the farm from which the collector would be required to pick up stock;
  • there was uniformity of cost.

45. Options for the funding of a national collection and disposal scheme might include a levy system, the provision of central funds or the introduction of specialised insurance policies. Whilst farming organisations would favour a centrally funded service for the collection, disposal and rendering/incineration of surplus stock, FAWC believes that such a long-term financial commitment would be difficult to achieve. It is also important to recognise that all other industries pay for the disposal of their waste products. Furthermore, central funding for such a scheme raises questions relating to the application of EU rules concerning state aids.

Recommendation

46. FAWC recommends that the Minister consider all available options for the funding of a national collection and disposal scheme that might include a levy system, the provision of central funds or the introduction of specialised insurance policies.

47. Currently, several Member States operate national collection and disposal systems. Ministers should seriously consider the operation of such schemes and the mechanisms by which they are funded to see whether any provide an appropriate model for a similar scheme to be established in GB. We welcome the fact that the Commission will be preparing a report on how Member States fund disposal schemes.

Recommendations

48. FAWC recommends that the operation and funding of national collection and disposal schemes in other Member States be examined to consider if any provide an appropriate model for Great Britain.

49. It is recommended that, whilst on-farm disposal remains an option under EU legislation, farmers are properly trained in the methods by which animals may be slaughtered humanely and are aware of the relevant legal provisions.

50. As mentioned in Section B, we are conscious that changes to EU legislation take time but would urge that the Government gives careful consideration to the recommendations made in the Pooley Report, especially those relating to small, low throughput slaughterhouses. This is a matter that will also be considered by the FAWC Slaughter Working Group in its study on the welfare of livestock at slaughter.

51. FAWC would like all those with an interest in disposal of low value and other surplus livestock to have the opportunity to consider together the issues raised in this report.

Recommendation

52. FAWC recommends that an industry action group be established, co-sponsored by the relevant Government Departments (e.g. MAFF, Dept. Of Environment, Dept. Of Health, Food Standards Agency, etc.) to consider the issues raised by the disposal of low value, surplus, fallen, casualty and emergency animals.


 

Appendix 1

Letter dated 23 September 1999 from the Chairwoman of FAWC to Mr Elliot Morley MP, Parliamentary Secretary, MAFF, concerning ‘the disposal of surplus animals’

I am writing to express FAWC’s concern over the potential welfare problems which are being encountered in relation to the disposal of surplus sheep and calves, of which you will be aware. The Council welcomes the significant aid now earmarked for the livestock sector but we believe that the welfare of these animals could be increasingly compromised if further urgent action is not taken.

It is clear that the option for farmers to shoot surplus animals and dispose of them on the farm raises not only animal welfare problems but public health issues. Therefore, a solution must be found, which is preferably cost neutral, whereby animals which have no value can be disposed of humanely and in a sanitary manner.

We believe farmers would be willing to meet the cost of transporting animals to market, be they cull ewes or unwanted calves, provided they were assured that, in the case of a nil sale, the animals would be sent on for slaughter. I encourage your officials to promote discussion between auctioneers and local slaughter facilities or knackers to reach agreement that, at the end of a market session, unsold animals should be collected as a group for direct transfer to the place of slaughter. The cost of slaughter would normally be met by the sale of the carcase especially if supermarkets could be encouraged to take sheep meat for use as mutton mince. This is something that might warrant further consideration, in consultation with retail organisations.

With specific regard to calves, it is noted that the Ministry has prepared an aide-memoire to help farmers seeking advice on the welfare implications of ‘unwanted’ stock disposal and their legal obligations. Also, we recognise that the initiatives taken by the NFU, the MLC, the HAS and the Livestock Auctioneers Association have helped to a limited extent but it is likely the situation will worsen. The hunt kennels have offered assistance in some parts of the country but these outlets will soon reach saturation point.

Following the removal of the Calf Processing Aid Scheme, we understand that there is now spare capacity in the slaughter industry but it is not necessarily in the right geographical locations. Farmers need to be able to dispose of calves at local, low throughput slaughterhouses but many plants which could assist are now restricted to the killing of 20 livestock units per week for human consumption. We urge you to introduce a derogation for such plants to exceed this limit to allow them to kill surplus calves. The use of these premises would ensure that animals were humanely dispatched by trained and licensed slaughtermen, supervised by MHS personnel. Such controlled disposal also ensures that farmers are spared the onerous task of killing animals on-farm.

Additionally, FAWC believes that the use of the knacker system should be explored in greater depth, recognising that the movement of animals would be subject to the usual rules of transportation. If, for example, farmers were permitted to take live calves (and possibly cull ewes also) direct to the knacker for slaughter, this would provide a neutral cost system which is both humane and reflects public interests.

Finally, we have sincere concerns over the destiny of animals, particularly cull ewes, currently being sold for very low prices at market. We believe that often these animals may be purchased by opportunistic dealers. It should be made absolutely clear that the conditions of housing and husbandry of these animals must comply with the normal welfare standards.

These are initial thoughts and our proposals require development by your officials. However, the situation is changing fast and potentially could result in a welfare problem that FAWC would find unacceptable and I am sure you will. There is a need to reach a base position where welfare is not compromised and the Council asks you to consider both these issues seriously.


Appendix 2

Letter dated 18 October 1999 from Mr Elliot Morley MP, Parliamentary Secretary, MAFF, to the Chairwoman of FAWC concerning ‘the disposal of surplus animals’

Thank you for your letter of 23 September in which you highlight your concerns about the potential welfare problems associated with the current surpluses of sheep and calves.

We fully appreciate that the economic difficulties in the sheep and calf sectors could potentially lead to welfare problems. That is why we, through the State Veterinary Service (SVS), are closely monitoring the situation through welfare visits to farms, market inspections, liaison meetings, contact with Local Veterinary Inspectors (LVIs) and so on. Divisional Veterinary Managers are in touch with our Animal Welfare Veterinary Team in Tolworth about any welfare problems due to, for example, poor nutrition or failure adequately to control disease.

We have also asked the SVS, when visiting markets, to be alert to the possibility that cull ewes or low value calves may be bought by people without the resources or the interest to look after the animals properly. If necessary, Veterinary Officers will advise the buyers of their legal obligations towards the animals and arrange follow up visits to the farms where they are to be kept.

I also note your concerns about the possibility of low value livestock being purchased by opportunistic dealers. It is of course the case that all animals, irrespective of their market value, must be properly cared for in full accordance with the welfare legislation and must not be allowed to suffer unnecessary pain or unnecessary distress.

You will be aware that on 20 September Nick Brown announced a package of aid measures for farmers (principally cattle and sheep farmers) worth £150 million. This package did not include disposal schemes for calves and cull ewes, but nonetheless recognised the difficulties facing farmers in regard to such livestock by offering financial assistance:

  • £60 million in increased Hill Livestock Compensatory Allowances for the year 2000;
  • £44 million by deferring until April 2002 at the earliest the imposition of charges on abattoirs for the cost of enforcing controls on specified risk material; and
  • £45 million for deferring the proposed introduction of charges for cattle passports until April 2002 at the earliest.

Nick’s statement on this package included the following remarks as regards schemes for the disposal of livestock: "The devolved administrations have pressed for specific action to take surplus calves and cull ewes off the market. They accept that this would need agreement from Brussels and that it would be for the UK Government to launch any approach at a Community level. If the devolved administrations want an exploratory approach to be made, on the basis that the cost of these measures would be met from their budgets, I would be willing to facilitate this. They may however think that the approach that I have announced today meets their needs."

The Scottish Executive wished to pursue a scheme for the disposal of cull ewes and the National Assembly for Wales wished to pursue a similar scheme in respect of calves. The possibility of action on both has been explored with the Commission.

A ewe scheme would face great difficulties on state aid grounds. Recognising this and the long lead time before any scheme could operate, the Scottish Executive is not now pursuing it.

As to calves, Nick Brown is asking the Agriculture Commissioner to confirm our understanding of the position, namely that a proposal on the lines advocated by NAW would not be compatible with EU rules.

Farmers, by law are responsible for the welfare of their animals, must abide by the relevant legislation and welfare codes and expect enforcement action when they do not do so. It is perfectly open to them to kill animals on the farm provided this is done humanely and in accordance with the Welfare at Slaughter Regulations (1995).

Measures introduced as a result of BSE may be with us for some time and we have no way of knowing when and if the sheepskin and calf markets will recover to previous levels. Coupled with the fact that beef and lamb now face fierce price competition from other meats, it is important that these sectors adapt to these challenges and changing circumstances, including changes that have occurred to the market for cull ewes and calves.

As far as restructuring of the sheep sector is concerned, we are currently working with the National Sheep Association and the MLC Sheep Strategy Council to investigate the current and long term problems in the sector and possible solutions. We have also just commissioned a report from ADAS to investigate the balance of numbers of ewes in the hills, uplands and lowlands to see, amongst other things, what numbers are needed to support the breeding structure.

You ask whether a derogation could be introduced to allow licensed low throughput slaughterhouses to exceed their permitted throughput limits in order to kill surplus calves. I am afraid that this is not currently possible. The throughput limits are laid down in the EU Fresh Meat Directive (64/433/EEC, as amended) and implemented in GB by the Fresh Meat (Hygiene and Inspection) Regulations 1995, as amended. As such they cannot, legally, be exceeded as both the EU and domestic legislation stand at present. The only way to overcome this would be by securing an amendment to the parent Directive to permit the slaughter in licensed slaughterhouses of unwanted calves destined for non-human food use. The possibility of achieving this is highly remote given the Commission’s frequently stated opposition to the combined use of licensed slaughterhouses for the production of fresh meat for human consumption and for the slaughter of animals not destined for the human food chain, even with clear time separation between operations.

I appreciate that this reply is less positive than you might have wished. The Government is subject to many constraints which limit our room for manoeuvre. That said, I must stress above all else we are committed to maintaining and improving animal welfare standards and will always enforce welfare legislation regardless of market conditions.


 

Letter dated 28 October 1999 from the Office of Mr Ross Finnie MSP, Minister for Rural Affairs, Scottish Executive, to the Chairwoman of FAWC concerning ‘the disposal of surplus animals’

The Minister is well aware of the animal welfare considerations which can arise in relation to the disposal of sheep and calves which have little or no market value. In Scotland there have been useful market and other development in response to the cessation of the Calf Processing Aid Scheme at the end of July. As a consequence the industry has focused more on the position of older sheep which it is not financially worth transporting to auction for sale.

As you will know, in recognition of the sector’s difficulties and the animal welfare and public health implications of on-farm disposal which you highlight, the Minister proposed a temporary Cull Ewe Disposal Scheme to the European Commission to relieve producers of this problem. However, as you know, the Commission unfortunately refused to ratify the scheme on the grounds that it was incompatible with State Aid rules. The Minister was very disappointed with this decision and he raised the question of the disposal generally of spent animals with Commissioner Fischler when he met him recently in Brussels. This is an issue which the Minister believes will need further consideration in the future. However as a centrally run disposal scheme is not possible officials of the Scottish Executive Rural Affairs Department are liaising with the appropriate enforcement bodies on the guidance to be followed when producers apply for permission to slaughter and dispose of surplus sheep on-farm.

It is, of course, essential that any proposals for surplus disposal should have full regard to the welfare of the animals concerned. On-farm killing must be carried out within the requirements of the Welfare of Animals (Slaughter and Killing) Regulations 1995. Equally, animals must be adequately cared for at all points in the processing chain. Official inspectors on hand at the various pressure points, such as during transit, at market and at slaughter, are well aware of the possible temptation to cut corners. In these economically difficult and stressful times they are well placed to offer advice and to remind attendants of their legal obligations to the animals in their charge.

Regarding the movement of animals to knacker’s yards for slaughter, the definition of a knacker’s yard in Article 3(1)(j) of the Animal By Products Order 1999 is:

‘…any premises used in connection with the business of killing, flaying or cutting up animals the flesh of which is not intended for human consumption…’

You will note the definition specifies the killing of animals. Therefore, as longs as the knackery has proper facilities for the slaughter and complies with requirements laid down in Schedule 4 of the Animal By-Products Order 1999, there is no problem with transporting live animals for disposal, subject to compliance with transport and welfare regulations and guidelines. The current practice is for knackeries to charge farmers for any animals taken for slaughter.

Turning to your point about low throughput slaughterhouses. It may be helpful if I explain the rules governing the operation of such premises. Under the definition of low throughput in the Fresh Meat (Hygiene and Inspection) Regulations 1995, low throughput slaughterhouses have always been subjected to maximum limits as a condition of licence. The Regulations stipulate that throughput should be limited to not more than 1,000 livestock units per year at a rate not exceeding 20 each week. You suggested that a derogation be introduced to allow to allow such premises to operate at a higher limit to dispose of calves. In actual fact the Regulations do already provide for the throughput limit to be increased to a higher level of 1500 livestock units per year (30 units per week) if certain conditions are met. Premises meeting these conditions could therefore be used for calf disposal. Any low throughput operator who wishes to operate at this higher level should first contact his Veterinary Meat Hygiene Adviser who makes a recommendation to the Department. A decision shall then be taken based on the merits of each case.

There are a range of factors which have brought about this current situation whereby older ewes from remoter outlying areas have, essentially, no market value. The Minister has therefore commenced a range of initiatives to try and improve the future of the sheep sector and there have been some positive responses. For example your suggestion about retail interest in mutton has been taken up and a leading supermarket has indicated an interest in bringing this commodity back to its shelves. Also the Minister recently announced the appointment of a leading and respected businessman to review the industry’s general performance, with particular emphasis on the marketing of sheepmeat and lamb.

While there are no quick or easy answers to the problems of sheep producers I can assure you of the Scottish Executive’s objectives of preventing animal welfare and environmental problems in the short term, and contributing to finding lasting solutions for the industry in the longer term.

I hope FAWC find this helpful.


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