Humanity, Reason, and Backbone in the Progress of the Animal Welfare Bill -
VEGA responds to another consultation on the Government's draft Animal Welfare Bill 1. Definitions(Page 9 et seq. and page 36)
1.1 Animal: The definition should be amplified to accommodate scientific and lay understanding; advances in the appreciation of sentience and animal behaviour should be accommodated- there seems to be no logical reason to exclude invertebrates- or to imply such omissions as shellfish (crustaceans, molluscs, etc), snakes, lizards, and insects. Further, certain species may suffer from unnecessary sub-division on the basis of purpose in human use rather than zoology: thus, a horse may qualify as a companion animal or a food animal and a rat as a pet, a subject for experimentation, or a pest. The animal’s welfare should be rated in the best level achieved for that and similar species. These considerations would apply to methods of killing, slaughtering, and culling, and would require consistency with procedures covered by the Home Office for scientific procedures, housing, feeding, and general care and respect.
1.2 Pain: Definition of cruelty is also blurred in the amount of suffering, pain, distress, and inanition is considered “reasonable and humane” when animal welfare clashes with the needs, convenience, and pleasure of the human species. How can it be reasoned that a humane arbiter can be an accomplice through his or her routine choice of purchases and consumption in the very practices animal welfarists expose and condemn and the proposed Bill attempts to oust?
1.3 Status(cf Page 37, paragraph 2): These observations also emphasize the varying respect paid to native, endangered, wild, domesticated and free-living commensals. In crowded islands with a dominant human influence these definitions are blurred, especially as some animals, being escapees from collections of introduced species and from human farming activities and laboratories, are adapting and mingling successfully with domesticated livestock. The Bill must assert a strong intervention in matters of hunting, shooting, angling, commercial fishing (an intensified relic of hunting for food), trapping, hare-coursing, snaring, and ferreting. Anomalies such as the different attitudes to foxes and badgers must be informed by equal rights to humane treatment.
1.4 The Fetus(Page 36, paragraph 54): As in the human element regard for the fetus and embryo (and larval stages) will develop as more is known of the physiology of pain and the influence in the long term of intra-uterine stresses. The same deference and exercise of respect should be granted to animals. The precautionary principles should apply. Collection of pharmaceutical products and practice of genetic manipulations (such as cloning and embryo transfer) must be controlled on the basis of the precautionary principle or of prohibition when doubt of cruelty increases to certainty. Conditions in parent breeding stock in poultry, especially in systems involved in the production of vaccines (i.e. fertilized eggs) and antibodies must be allocated to the clear control of the Home Office or DEFRA. Fetal calf serum may be produced in this country when BSE restrictions are lifted. In this process and occasionally in the slaughter of pregnant cows the calf may be born live by surgery on the cows but die by drowning. In another example of the unacceptable means of using fetal material the skins and wool of unborn lambs are used in the clothing industry- but not at the moment in the UK, as far as we know. Research and “pharming” for stem cells and the production of knock-out and knock-in animals and genetic mutants is increasing these dilemmas.
2.1 As a guiding principle (e.g. to the information on page 11 of the draft) the FAWC’s five Freedoms should be rehearsed as an objective.
2.2 Docking of tails and other mutilations must be controlled on a case-by-case consideration of systems and conditions that bring these issues to the fore (compare circumcision of males and infibulation in the female case). We cite examples of interventions that must be considered in drafting the Bill.
2.3 Disbudding and dehorning of cattle
2.4 Removal of supernumerary teats, dew claws and other appendages in farm animals, horses, and pets. Clipping of teeth (e.g. in piglets) is a form of dental interference rated to benefit the animals’ welfare.
2.5 Beak trimming in poultry and game (e.g. pheasants, in which bitting may be also be applied, as well as other devices).
2.6 Velvet from Antlers: This practice should stay banned. As with products derived elsewhere from practices outlawed in the UK, the writ of British and European law should run to a ban on imports of such objectionable commodities and substances (cf furs, ivory, and products from whaling).
3. Training and Licensing
3.1 The draft Bill must be strengthened to ensure that purchasers, owners, keepers, handlers, carers, and slaughterers and knackers possess evidence of training and licensing that is reviewed and renewed at stated intervals, and comprises certificates of general competence in the behaviour of animals, as well as specialized categories for certain species or jobs. Hauliers must have similar training and licensing. Loss of licence in one category may entail ineligibility to hold certification in any category.
3.2 Changes in the veterinary profession and its responsibilities are resulting in increasing devolution of technical jobs on to farmers and various contractors. Visits by vets to farms on any pretext are useful checks on the animals’ condition and welfare. The contractors must show evidence of general competence and of supervision by a responsible vet. The profession is becoming less attractive in large animal practice, so many vets will have gained little experience in this category; nonetheless, at times of emergency, such as BSE and FMD and other epidemics of disease in food-producing livestock and their commensals, a “territorial army” of suitably licensed and trained retired vets and practitioners dealing normally with pets and horses and in other services must be maintained. (It be may added that the training of vets in animal welfare and behaviour leaves much to be desired, especially in those brought in from other countries primarily to supervise hygiene in slaughterhouses. It should also be a requirement that “citizenship” modules in school curricula should include elements on the behaviour, care, use and welfare of animals.)
3.3 As proof of their responsibilities all owners and keepers of animals must provide evidence of adequate veterinary treatment in the event of illness and injury and of indemnification for “third parties” affected by such eventualities. The Government is at the moment relying heavily on charities to render these and other services. These arrangements need more consideration and devolve more responsibility on owners and they should enlist the reinforcement of policing by the insurance industry. Further, the consequences of bad husbandry, such as BSE, FMD, swine fever, and other bacterial and viral scourges and zoonoses, would be met by the industry and its customers rather than by belated feather-bedding subsidies that conceal severe violations of the elements of animal welfare and good husbandry.
3.4 Owners of all premises housing more than, say, five animals must be subject to a provision to allow the local authority access by, say, a couple of independent observers for whom it shall be responsible. This “neighbourhood watch” would be in excess of official visits. The observers could apply for the council’s permission or could be invited by the council; they could be local citizens or chosen for a special interest or instruction. This would continue local interest and responsibility in the planning and building of commercial buildings, sanctuaries and laboratories etc. Local authorities must also be provided at least with details, such as those collated by the MHS and charitable organizations and other official bodies, on the records of disease, culling, natal and perinatal morbidity and mortality, and mortality during a complete spell of production. This information should include data on the usage of drugs and analyses if effluents (the MHS is charged with welfare matters and could provide Welfare Assessment Scores as it does HAS’s).
3.5 Breeder units call for specific attention in the Bill. This would include farms, zoos, and laboratories dealing with the collection and sexing of semen and embryos, in which painful procedures are involved, e.g. electroejaculation.
3.6 Animal welfare considerations must reinforce present penalties for littering and dumping in towns and the country. Abandoned car batteries, plastic in many forms, broken glass, and old tyres are both environmentally objectionable and also harmful to animals. Penalties should take account of this. “Bringing country to town” is well-meaning but sometimes an ill-advised initiative that may mislead councillors, for it leaves animals, some hardly typical, unable to defend themselves against worrying harassment, and vandalism. Absence of 24/7 care and protection would be a punishable offence.
3.7 (Page 9, paragraph 1) Abandonment of an animal found in distress or as a victim of accident or crime must count as an offence. Report to the police should be made, who can then take appropriate action. In killing a casualty animal humane considerations must take preference over commercial factors, e.g. by administration of drugs rather than by delayed (and possibly inept) stunning, sticking, and bleeding out in the interests of catching the best market for meat and avoiding land-fill and rendering costs. Police marksmen and other shooters must be trained and licensed appropriately, augmenting the existing laws on the possession and use of firearms.
3.8 The veterinarian’s avowed mission to “do his utmost for the well-being of the animals in his care” must not be compromised in efforts at relieving suffering that may conflict with the run of the market for food animals (e.g. restrictions and withdrawal periods in recourse to proven therapeutic drugs) and in the method of slaughter. Expert evidence and advice furnished by the Farm Animal Welfare Council may be adduced in support of such decisions.