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DEFRA consultation on the Animal Health and Welfare - 00/00/0000
Read VEGA's response to the government consultation on preparing a combined strategy.
Preparing an Animal Health and Welfare Strategy for Great Britain - A consultation document by UK government, the Scottish Executive and the National Assembly for Wales.

Some comments follow, comprising a response to the booklet product code PB 7857. They complement our commentary dated 30th April 2002, on the Consultation on an Animal Welfare Bill, which was addressed by e-mail to Phil Alder, of the Animal Welfare Division, DEFRA, Room 606, 1A Page Street, London SW1P 4PQ. Previous commentary available here.

We have no objection to publication of those comments and of the following additions. Thank you for your invitation to add these further remarks.

1. While a consistent policy for animal health and welfare, aimed at the highest common denominators, is desirable, its practicability is questionable and may lead to chronic compromises and hesitation in dealing with practices over which public attitude ranges from obscurantism, ignorance, indifference, cruelty, and callousness to unversed sentimentality and excesses of “kindness” that reach to abuse and treatment of animals as living toys and therefore with dubious respect for their dignity and wellbeing. The veterinary profession’s uncertain interpretations of its vows illustrate these predicaments, and the controversy and politicking accompanying proposed legislation over hunting provide grounds for assessing the history of piecemeal reforms against proposals for comprehensive strategies that could rapidly fragment into competing causes urging rapid attention to single causes. The vets’ expressions of concern over the welfare of the animals in their care are muted by service to their clients and to intimidation in the exploitations in which they are implicated.

2. We applaud a comprehensive strategy, but insist that a charter (e.g. such as the FAWC’s Five Freedoms) and an intensive program of education, example and of objective appreciation of animal behaviour should be implemented. Training of animal handlers and owners and licensing and supervision must be increased: in particular, standards and control must involve much more participation by independent vets and allow access by concerned citizens (and especially to animal welfare organizations such as the RSPCA) to farms and units keeping and trading in animals, the costs of which (as for the MHS) being met by commercial levies. Veterinary inspectors must profess understanding of animal behaviour: bonding, for instance, is a cruelly-violated aspect of welfare in the everyday working of the dairy/beef/veal industry with an appalling nemesis in the threat of BSE to the health of many animals and people and the consequent demand for courses of offensive experimentation on other species.

3. The chapter informing the strategy could draw usefully on chapters, e.g. for farming and draught animals, from religious texts, such as the Old Testament and the Qu’ran, which teach elements of respect, dignity, and kindness, but are continually overlooked.

4. Animal health is often measured by corollaries in zoonotic repercussions in threats to productivity and consequences in disease to people, for whom questions of supposedly high standards of living and liveability dominate over the quality of life. TSEs can now be added to the evils of intensified bad husbandry, and viral scourges receive far more attention at the fork end of the FSA’s activity than at conditions and threats on the farms and units for the livestock. Pestilences such as CSF, FMD, and avian flu have seen sacrificial massacres of millions of animals in precautionary measures to protect the live/deadstock industry and customers of cheap food. The strategy must ensure that the full economic costs are borne by the trade and by consumers, and that exploiters running the risks must indemnify themselves and their customers accordingly, with no recourse to stealthy subsidization. Appropriate insurance would stimulate earnests in prevention and reduce cruelty to animals on a wide scale. It would also add another layer of policing and means of expelling offenders of good practice.

5. The strategy must imply increased prices for products of animal origin. Recent costs of bad husbandry have run into billions of pounds and the time is ripe for tactics to avert further disasters and to remind consumers of the true costs of the meat, milk, and eggs (and derivatives) they (and their favoured pets) consume. Differential elevation of VAT rates would nicely redress the appalling insults to animal welfare in products of objectionable husbandry (such variations in VAT on foods are practised in other countries in the EU and in “free-trade” areas such as the USA, where it may be called a sales-tax).

6. Submissions such as ours to the Curry Commission on farming and food have emphasized these messages by pitching the advantages to consumers’ health by lowering consumption of animal-derived products. About 1 billion (thousand million) livestock are reared and slaughtered annually to supply consumption in Great Britain, so a reduction of 10% in demand could reduce the toll of ill-treatment and compromised welfare (which are recognized year-in year-out by the FAWC and departments of DEFRA) for 100 million animals every year. Instantaneous pre-slaughter stunning, as required by FAWC, cannot be guaranteed for more than 99% of the animals, even if the specifications of manufacturers of the equipment and apparatus can be achieved, so 10 million “faults” and pain are inflicted at least – and this is after 70 years “humane” killing and countless worthy exposures and needs for continuing reform. Appreciation of the facts by customers must amplify the force of enacted strategy; and such appreciations must be reinforced by the benefits of alternative lifestyles.

7. This acknowledgement has to comprehend the suffering farm animals have to undergo at the altar of concerns for human health and the consequences of drug residues in the meat if they were “put down” or euthanased by the procedures by which the vet “euthanases” the pet cat, dog, rabbit, or horse and by which the RSPCA and other animal shelters have the objectionable duty of destroying unwanted strays. Evidence from meat inspections (e.g. of rejections and conditions such as PSE and DFD spoilage) bear witness to the agitation of the livestock and cruelty at and just before slaughter.

8. The strategy must increase independent veterinary supervision on farms and at livestock markets and on animals in transit. The value of an animal (and thus of its meat, milk, semen, embryos, offspring, and breeding) operates to its benefit in handling and rearing. Particular attention should be paid to the treatment of culls and other livestock of low value, such as spent breeding animals, greyhounds, laying hens, and thinnings and poor doers generally. Massacres during epidemics of disease require means of “instantaneous” loss of consciousness prior to “immediate” killing: neck-wringing of poultry, for instance, does not fulfil theses conditions, and the history of the latest epidemic of FMD has revealed serious shortcomings. Fallen stock, casualties and downers must be treated mercifully and expeditiously.

9. Livestock are denied facilities for nursing and analgesia deemed fitting for veterinary attention to animals of other species. Quarantining and precautions over bought-in stock on farms are inadequate. Cattle and sheep (and goats) suffer cruelties and corollaries in tagging in the interests of traceability that are spared other animals (e.g. horses and pets) being moved for commercial or companion reasons. This discrimination must be removed in efforts at consistency in the best standards of care.

10. Nutrition and water supplies for kept animal are – as with human beings – important aspects of health and welfare. Poor standards may conduce to boredom, stereotypy, and comfort eating, with corollaries of obesity, diabetes, and other metabolic disorders, as well as of vices such as feather-pecking, cannibalism, and lowered liveability. Farmers condemn their animals to poor outcomes due to ill-judged feeding or excessive growth-boosting and pet-owners indulge their animals unwisely. Keepers must be expected to display greater competence. Pregnancy-toxaemia (twin-lamb disease), dehydration and exposure in young lambs and dystokia in several species are ills that must be overcome by any strategy that comprehends welfare. Labelling of feeds and soil-testing of farms must ensure that the stock do not succumb to deficiency diseases (illthrift) due to elements such as selenium, iodine, cobalt (vitamin B12), and copper, and imbalances (e.g. milk-fever) due to levels of calcium, magnesium, and phosphorus. The importance of feeding in avoiding conditions such as lameness, bloat, and poisoning due to mycotoxins and certain plants (e.g. ragwort, yew, and rhododendrons) must be impressed on keepers of livestock, as well as the freedom of the premises and pastures from rubbish, discarded plastic, and barbed wire that may cause lead-poisoning, gut blockages, and other forms of avoidable suffering.

11. Strategy must encompass tactics in the prevention of adversity and improvement of the lot of animals by factors such as housing, bedding, ventilation, and prevention and treatment of disease (and of fundamental causes of harm). Such research must be commissioned in the animals’ interest and be seen to stimulate reform. Anticipation of developments in genetic modifications and breeding and production artifices must be in place to prevent miscarriages that could accompany cloning and resort to QTL (quantitative trait loci), e.g. for double-muscling (culards). These possibilities increase as the relevant genomes are established. Appraisal must assert critical and creditable standards: past and present advances and withdrawals in humane killing and slaughterhouse practice are disconcerting and humiliating. Farming of animals and fish for experiments and tests may increase to a diversification on a scale considered more apt for DEFRA than the Home Office. Control must be exerted to maintain and improve conditions at all stages. DEFRA’s attitude to exterminate the ruddy duck at the behest of the Royal Society for the Protection of Birds does not augur well for a robust hybrid of natural genetic modification and evolution. Here is an example of the exercise of compassion.

12. Mutilations are applied for various purposes for domesticated animals, for reasons ranging from the better accommodation of those kept in artificial conditions and thus perceived to be for their benefit to animals merely prettified to conform to fashion. Many animals in commercial farming are manipulated surgically or by drugs or feeding regimes to stimulate production and maintain liveability in systems of bad husbandry otherwise unsustainable. The strategy must tackle the significance and necessity of these interventions and the competence with which they are carried out. Mutilations must be assessed in terms of fundamental husbandry, infringements of the Five Freedoms, and of symptoms of distressful conditions of housing, boredom, agitation, vice, production, or display rather than as therapeutic devices for the animals’ benefit (e.g. surgery by a vet to remove ingrowing horn). Beak-trimming, tail-docking, tooth-clipping, and wing-reduction are issues much in contention at the moment.

13. Labelling and in-store information on all animal-derived products must carry details for consumers on sources and methods of husbandry and slaughter. This requirement must extend to feeds and pet-foods. Such information would be objective, educative, and challenging and involve customers more in the aims of the strategy. Its general application would remove objections to supposedly unfair and discriminatory revelations on, say, meat and poultry derived from animals slaughtered without a prior attempt at stunning.

14. Labelling and descriptions must be monitored to expose questionable assurances, some of which are based on dubious attempts at premium-pricing and value-adding. Free-range, organic, and traditional are a few of the assurances that can foster in consumers delusions of animal welfare.

Development of a DEFRA strategy must heed the special reservation on the welfare of farm animals, for purchasers of products, as well as policy-writers, politicians, veterinarians, and commentators are implicated routinely as accomplices in the acute and chronic abuses they purport to overcome. Opposition to issues such as experimentation and hunting can be voiced by a public with no obvious involvement nor personal benefit nor amusement from the practices they can blamelessly abhor. The lot of farm animals must be expressed uncompromised with an objective voice that must be the duty of the strategy to amplify and heed. The cost of cheap food and intensified farming extort an intolerable burden on the animal kingdom DEFRA purports to administer.


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