DEFRA's proposals for an EU Council Directive on the welfare of chickens kept for meat production come up for consultation and scrutiny. The analysis of problems is good, but evidence of arousing desistance and resistance in the shop and consequent action and example by government purchasers, animal welfarists, ordinary customers, and foodies is wanting. It is still time for a kindly presidential expression and leadership in Europe.
Re: Consultation on Proposal for a Council Directive on the Welfare of Chickens kept for Meat Production
1. Reversing the increasing consumption of poultry-products is the most effective means of reducing the ill fare in the industry. The changes intended for inclusion in a Directive need resolute expression of animal welfare interests by recruitment of enlightened consumer power in the fashion of the farm-to-fork concerns that are supposed to inform the Food Standards (not just Safety) Agency and any animal welfare organization demonstrating its own objectivity and example. The lure of supposedly cheap food is maintained as much by the pull of an unversed consumer demand as by the push of producers in a market dominated by price rather than value in a monstrous industry. Your despatch rehearses many shameful instances of the state of trade and of the conditions of the unfortunate birds. However, it declares no earnest in its immediate insistence to DEFRA and other government agencies and departments – as well as the Ministry of Defence – that adoption of your recommendations be applied forthwith in their relevant purchasing policies. This would really impress Europe and challenge the animal welfarists professing advice to examine their own determination and example to the public. we note the Royal Society for the Promotion of Health book on Essential Food Hygiene fort eh Food Industry attributes the rise in the reported cases of food poisoning from 1986 to 2002 to various factors of poor practices, - prominent among which are increased poultry consumption convenience meals, reduced use of preservatives and poor standards of hygiene in the domestic kitchen.
2. Reversal of rising consumption by 1% would spare 8 million birds a year exposure to the horrors retailed in your documents – in Britain alone. The reducing trend would begin an injection of respect into a food industry of appalling squalor and degrading work in the offensive trades in which uninspired consumers are accomplices. It would also appease environmentalists and others concerned with pollution of the atmosphere and waste of resources of land and sea – and the conditions dealt with in your review extend to most systems of poultry production involving several species yielding meat, eggs, and other commodities and farming practices with game. They also bear comparison with the fishing industry.
3. Within a human lifetime intensification of the farmer’s wife’s sideline of producing eggs and a boiling fowl for the table, with scratching birds retreating into barns or roosting in trees, has developed into a monstrous exploitation yielding a meretricious sense of convenience and overriding the passage of the seasons and any respect for the decencies of the FAWC’s Five Freedoms and the general intentions of DEFRA’s composite Animal Welfare Bill. Any proposals for reform of the poultry-industry will be wanting unless they are prefaced by a lament that the depression in demand variously dominated by all the c’s – cholesterol, Curry, campylobacter, and culling on an enormous scale (due to outbreaks and epidemics of zoonotic diseases, now augmented by the threat of avian flu) – is being reversed, against an enormous effort of tardy reforms and specious free-ranging definitions. No harm and probable benefit to human customers in Europe would accrue if production and consumption of poultry products were halved in quick order. Expeditious implementation of the proposals indicated in your despatch would thus be facilitated and improved. The food industry and retailers, together with DEFRA and the FSA, could then busy themselves with redoubled efforts at developing inoffensive alternatives and improvements to the diet.
4. We mooted at a relevant conference run by the University of Bristol’s Veterinary School an official Animal Welfare Warning on dubious products in the style of the Health Warnings applied on tobacco-derived commodities. This proposal was received without demur at the end of a conference lasting several days and attended by participants from many countries, officials from DEFRA, FSA, FAWC, animal welfare NGOs, farmers, producers, retailers, vets, and consumer organizations. (Three books published in June and July last year, have resulted from this 27th Poultry Science Symposium of the World’s Poultry Science Association (UK Branch), held in Bristol in July 2003. All have been published by CABI Publishing. They are: Measuring and Auditing Broiler Welfare, edited by C Weeks and A Butterworth, ISBN 0 85 199 805 4; Welfare of the Laying Hen, edited by G Perry, ISBN 0 85199 813 5; and Poultry Welfare and Welfare, by MC Appleby and JA Mench, ISBN 0 85199 6671). As a typical Welfare Warning we suggested the message Production of These Eggs Entails Cruelty to the Birds. That should alert consumers and customers to their responsibilities.
5. We recognize possible objections, already acknowledged in the Health Warning campaign, that disregard and familiarity with the notices, would blunt their message and hamper litigation by affluent activists, but the effects and sustainability of the Health Warnings point to an exemplary success. Further, the FSA’s labelling and condemnation of “junk” foods and poor standards indicate a will to tackle downturns in the output from sectors of the food and drinks industry.
6. We find further support in comparisons with the Meat Hygiene Service’s HAS scores in assessments of slaughterhouses and meat and cutting plants, which are publicly available, although this may entail naming and shaming. In the welfare mode therefore we rate WAS scoring as a feasibility to cover the food chain operated by the poultry industry. It would apply to production of imported poultry-meat, which accounts for much that is used for manufactured commodities. Scoring of foot and leg problems, as well as data on DOAs, mortality, and liveability, further illustrate the ptracticability of arriving at welfare assessments like those presented by the MHS (which includes welfare in its purview). Importations and transhipments of raw materials and derivatives, within the EU and from without, will require consular services in the style of veterinary supervision in South America to oversee imports to the UK of animal-derived material. These services should be paid for by levies mulcted from importers.
7. Poultry farming can do harm to other domestic species, in the spread of zoonotic pathogens and of multi-resistant bacterial species. Poultry litter finding its way into cattle-feed has transmitted anaerobic agents, such as clostridia, causing botulism, mainly owing to dead birds in the litter, having been smothered. Conscientious animal welfarists should be suitably warned when they are about to purchase by-products and co-products of meat-production, such as poultry litter sold in gardening centres as organic fertilizer. Such customers would also wish to avoid feather-and-bone products and mushrooms grown on media composed of poultry litter. The threat of avian flu and transmissions of environmental mischief (which would clobber organic and free range enterprises) indicated further reasons for keeping the discriminating customer informed at points-of-sale and on labelling data and warnings.
8. Your analysis of immediate problems and suggestions for urgent “fire brigade” reforms are, alas, good; implementations of the latter must not delay or override acceptance of the wider issues that we have identified. We would like to emphasize some points you have raised. We are assuming the standards will apply to the rearing of the birds and the killing and culling for all meat and derivatives and manufactured products imported from farms and premises supplying the trade in the UK (which might extend beyond foodstuffs and feedstuffs to materials used for manufacturing purposes such as feathers and for pharmaceuticals). Directives must obtain globally for production supplying materials used and consumed in the EU.
9.1. Methods of killing and culling must be urgently adapted to the best contemporaneous standards, which may change as research continues. This review therefore requires acceptance of the FAWC’s latest – and repeated – pronouncements on Jewish and Muslim methods of slaughter and the desirability of bans and of labelling that identify the site and methods of killing. All producers must furnish the authorities that they have in hand the means to ensure a swift “humane” cull of their total flock if a scourge such as avian flu overtakes production.
10. Inspections, monitoring etc.
10.1. Continuous monitoring of conditions such as temperature, humidity, light, and atmospheric composition must be ensured in well-maintained equipment. Inspections must be logged and inspectors must be able to walk through the flocks without causing injury, damage, or stress to the birds. CCTV may be used only as an auxiliary. Owners of the premises must attend and oversee all operations such as collecting birds or thinning flocks by their own staff or contractors, who must be duly trained, licensed, and registered. Transport to the slaughterhouse must be conducted with similar standards. Incentives should be provided for development of direct transfers of birds from rearing to slaughter while maintaining as little stress as possible and ensuring good standards of hygiene and avoidance of transferred contamination.
11. Training, licensing etc.
11.1. In all our consultations with DEFRA, FSA, and FAWC we require that all keepers and handlers of animals must be trained, licensed, and registered to relevant standards with a general intention of generating a consistent respect for all animal species, which includes our own. Work in the poultry industry is unpleasant and repetitious. Many of the jobs are low paid and attract workers provided by gangmasters or as illegal immigrants anxious to take a job of any kind. We have come across examples of bullying and “bagpiping” and horseplay endangering the workforce and the birds’ welfare. Overcoming these degraded standards and hazards means much stiffer supervision, within the ultimate supervision of state veterinary services, to rid the industry of its appalling reputation. Killing lines and inspection services need much more attention and be run with more care and at greater cost, lowered throughput, and less stress on the livestock and workers.
12. Buildings. Maintenance. Environment.
12.1. Fire can cause appalling cruelty in sheds and hangars housing flocks of thousands of birds. Stipulations on electrical conduits and monitored maintenance of equipment are essential. Emissions of gases, infestations with vermin, and disposal of excreta must be dealt with as part of good husbandry and consequent respect for welfare, within the premises and without. Nuisances from poultry units can be suffered in some areas where many of the workforce live locally and have been inured or feel compromised. We know of one local authority, having failed with protests to local EHOs, reduced to summer distributions of fly papers to residents living in the area. Free-range units offer opportunities for cross contamination with wildlife and endanger other livestock with zoonotic diseases. These violations of hygiene indicate poor farming practice and consequent risks to welfare and the environment. They also prompt our insistence that local councils or their equivalent must have rights of entry into premises in which animals are confined, over and above routine professional activities. The council would be responsible for the bona fides and behaviour of their nominees, who might be lay persons from within or without the locality, and could thus ensure assistance from accredited animal welfare organizations such as the RSPCA.
13. Indicators. Postmortems.
13.1. In our earlier dealings with MAFF and DEFRA we sought collaborations in funding assessments of information collected by the MHS on causes of rejections for human consumption of carcases and offals, from which good evidence could be gleaned on conditions and treatments the livestock had suffered before and at slaughter. Therefore we welcome now the intentions in your report to include such analyses among the evidence collected for other monitoring purposes. We insist too that all such information should be freely available, in the spirit of openness that the FSA proclaims.
14. Claims. Labelling.
14.1. Terms such as free range, barn, and caged are unreliable indicators of the relevant welfare and risks of mortality and compromised liveability. We and you have similar recommendations to offer on collation of indicators with relevance in these contexts, but – as we have repeated many times to the FSA – inadequate use is made of IT for publication – even in-store – of information that may need more space than can be accommodated on labels. If customers can buy broilers on line, they should be able to contemplate the objective information needed by the authorities, for instance, on space allocations, flock size and accommodation, rates of mortality, vaccinations, feedstuffs (e.g. organics, GM, home-grown), fortifications (e.g. with special fatty acids), and “top dressings” with antibiotics and “digestive enhancers”. Rates of dermatitis, bumble foot, bruising, blisters, hock burn, mutilations etc. must also be available and involved in systems of scoring. We see no reason for similar openness on conditions for elite and parent flocks, even if such birds have been transhipped. Our involvement with the concept of cruelty-free cosmetics and toiletries and the consequent sales in franchised market led some years ago to provisions at Body Shops of dossiers, available to customers, of details supplementing information on labels. Retailers in the food chain must demonstrate similar confidence in their products. Facilities offered by later IT systems extend the possibilities, including scrutiny on-screen at screen and printed off at home.
15. There can be no escaping that adopting your and our recommendations will raise the cost of poultry-meat, which will probably depress demand. Price is usually related directly with an animal’s welfare, and considerations of hygiene and welfare usually run together. DEFRA and the EU authorities cannot decently reject valuable reforms that must connote increased prices on the output of a reviled industry with excessive production of meretriciously cheap food.
16. Your commentary and Britain’s Europresidency is the opportunity for a show of kindly leadership. A timely press-release accompanied by a picture of a relevant shopper disdaining in the shop an oven-ready on which s/he has discovered hock burn would make a telling comment. The shopper could be the new chairperson of the name-and-shame FSA or a worthy of the RSPB. We would be happy to pursue this consultation with further suggestions, if necessary. Arousing informed desistance and resistance amongst consumers will admirably complement the aims for welfare that your proposals strive for.