In our response to a recent government consultation on fisheries conservation, we question why more animal welfare and conservation organisations do not take the initiative to comment
5th September 2003
Sea Fisheries Conservation Division
10 Whitehall Place
Re: Fisheries Technical Conservation Rules – Enforcement of Catch Composition Rules (dated 17th July 2003)
Dear Mr. Ryan,
Thank you for sending us documents for consultation. Some comments from us follow. We have no objection to their publication.
1. We are examining the controls, regulations, and enforcements in fisheries on the grounds of welfare (human and animal) and the environment. We regret the absence among the “interested parties” of many organisations with strong and informed opinions on these aspects of the welfare of fish and the conservation of marine and aquatic life. These considerations integrate with similar concerns within EU nations and particularly with DEFRA’s purports for a proposed Bill to construct a strategy for animal health and welfare. (Comments on the outline of this strategy are to be received by 31 October 2003).
2. Fishing at sea is a relic of hunting for food that is, like inshore fishing, becomingly increasingly intensified as a part of commercial farming – free-range or organic maybe, but still crude and barbaric on a grand scale. Sales of the products of fishing must fall in a hook-to-cook manner within the “plough-to-plate” purview of the FSA, and regionalisation of control and management reducing areas of the seas into farms (albeit with large areas of variably tenanted curtilages but with the beginnings of commercial and official concern, e.g. for dolphin-friendly tuna, bycatch and for wildlife) clinch the arguments for including fishing in controls increasingly familiar in the conduct of the exploitation of terrestrial animals for food (and sport).
3. We insist therefore that common effort by DEFRA and by ourselves should recruit a wider range of “interested parties” to these consultations: in particular, the government-appointed Farm Animal Welfare Council should be enlisted.
4. The Farm Animal Welfare Council has much experience in surveying procedures for the “humane” slaughter of livestock for food. Translating their reforms to killing and butchering fish onboard and in factory-ships for food, feed, and products for toiletries and pharmaceuticals is a major challenge that must engage DEFRA in anticipating and encouraging changes with increasing urgency and thus to be reflected in legislation on controls and policing. Imposition of such restraints should prompt DEFRA into truly humane alternatives that will relegate fishing into an enormity as bad or worse than slavery or child chimney-sweeps and prepare for a satisfactory rundown of an offensive industry.
Hon. Research Adviser