DEFRA's draft codes of recommendations, compiled by its Animal Welfare Division, still imply the need for cruelty in commercial production and output from poultry. The turkeys are already being reared for their year's end fate in the rituals.
Dear Mr Davies
Re: Code of Recommendations for the Welfare of Turkeys
Thank you for sending us for consultation the above draft code of recommendations. Our few and general comments follow, in accordance with instructions in your despatch dated 7 June 2004. We have no objections to publication of our comments. Inclusion in your consultation list of organizations such as the FAWC, FAWN, HLA, RSPCA, CIWF, UFAW, and University of Bristol indicates essential agreement on many points; however, we are surprised by the absence of the Real Meat Company and the Soil Association from this list. Our status and interests appear on our website.
1. Unnecessary Pain or Unnecessary Distress
Causing an animal pain or distress, unless for therapeutic reasons for ultimate benefit, is cruelty and must be an indictable offence, especially if it is routinely practised for, say, purposes of production of meat or eggs (or milk- this reservation applies generally). The phrase “causing unnecessary pain or distress” implies, correctly, that the exploitation of turkeys (and other animals) is cruel and may be exacerbated by practices that seem likely to provide more comfort for lawyers than relieving the stress inflicted on animals. Therefore the Code should be forthrightly entitled as Recommendations for the Reduction of Cruelty and Illfare in the Treatment of Turkeys.
The code does not take sufficient account of the breeding practices for the hybrids and the demands from the markets for egg-laying and production of meat in various categories.
3. Training and Licensing
We have made the point in several contexts in animal welfare consultations with DEFRA that all keepers, owners and handlers of animals should be trained, re-trained and appropriately licensed for their calling. This would require a general knowledge of animal behaviour and specific competence for species and range and duration of tenure. Offences involving removal of a licence might be applied to licences and applications for other species.
4. Seasonal Killing
Seasonal small-scale and on-farm kills of poultry, especially turkeys, are traditional rituals and are often incompetently carried out and beyond the close attention of the MHS, EHOs, TSOs etc. Goodwill to the birds must be expressed in stricter control over these festive sacrifices.
The Codes must allow for advances prompted by UK and/or EU directives for changes on welfare grounds to traditional practices. Procedures for gassing and neck- wringing (dislocation) are still subject to misgivings over unnecessary cruelty and the need for replacement.
We repeat comments we’ve made elsewhere in comments to DEFRA on the labelling of commodities with details on traceability and means of production and killing to enable consumers with enhanced IT to reach their own conclusions on the pain, suffering, and distress to which their purchases may make them accomplices. The power of the law would thus be reinforced by the strength of the market and the choices of well-versed customers. If hygiene can be assessed on HAS scores, then welfare can be rated on a WAS scale. If cigarettes and foods are to carry health warnings, products derived from animals should carry welfare warnings; or scores based on comparison with the Five Freedoms could be applied.
Hon Research Adviser
Dear Mr Davies
Re: Code of Recommendations for the Welfare of Ducks
Thank you for sending us for consultation the above draft code of recommendations. Our few and general comments follow, in accordance with instructions in your despatch dated 7 June 2004 on the draft code. Our remarks in our reply of today’s date on the Code of Turkeys apply for Ducks. We will not repeat them in this reply. We note that the consultation list for ducks is longer than for turkeys, but significant omissions remain.
Provision of water for ducks in commercial production of meat and eggs is an example of clashing requirements of hygiene and welfare and infringements of the FAWC’s vaunted Five Freedoms. Normal behaviour in ducks surely requires provision of water of suitable depth and extent, augmenting the birds’ means of protection and avoidance of predators. The water must be suitably free from harmful substances and the bottom must be adequately aerated to prevent danger from botulism. Denial of such means of expressing freedom of natural behaviour indicates stress and cruelty that must be indicated absolutely, whether or not it is deemed necessary for malign human purposes.
Hon Research Adviser