VEGA comments on a DEFRA consultaion on Animal Welfare Delivery Strategy
Consultation on Animal Welfare Delivery Strategy
1. We applaud the writing and scope of the DEFRA document dated 28 November 2006. We are also pleased to note that the British FSAs relate to Standards in food production, which we recognize as a purview broader than Safety focussed on the human condition. Increasing evidence discloses the distinction and its consequences in welfare and the environment and the farm-to-fork concept linking the land as the factory floor in primary commercial production and the integrating possibilities in joining the thrust of farming production outputs with the pull of customer choice. We are therefore working on the New Kinder Farming with the Portfolio of dietary and lifestyle practices deemed fit for the purposes of dietary and lifestyle practices deemed fir for the purposes of a good Quality of Life advocated by nutritionists and doctors. This combination of factors is reinforced by environmental considerations of global warming and conservation of resources – in fact, good husbandry and Salutary Sustenance from Salubrious Farming.
2. This understanding informed the Economist’s Dietary Advice in April 2005 that “a healthy diet is built on a base of grains, vegetables and fruits, followed by ever-decreasing amounts of dairy-products, meat, sweets, and oils…” and the declaration recently by Ben Bradshaw MP, a DEFRA Minister, that Britons should consume less meat and milk. The consequences of such policies, together with the objections to catching and farming fish, and the trends in consumption of human populations of meat-reducers and dairy-frees and a massacre of nearly a billion animals killed every year in British slaughterhouse, as well as a brisk market in plant-based alternatives, portend the most powerful remission of cruelty to the enslaved animals, even at an initially feasible conversion rate of 10% year-on-year. Recent outbreaks of BSE, foot-and-mouth disease, swine fevers, and other zoonoses, as well as the threats of avian flu and other viral diseases, are sacrifices to the altar of production that will generate increasing disgust form the public and little compensation from the Government to rescue an offensive industry and an affront to the dignity and respect due to animals of all species. No amount of free-range, organic euphemism, and dissembling can disguise the enormity. No enterprise in animal welfare can claim significance if it does not manifest practice and preaching in its interpretation of these factors.
3. Our answers to your questions follow:
4.1. The scope of the consultation is good, except that it should accept inclusion of all sentient beings, vertebrate or not, small and large, cuddly or even superficially loathsome (to our species). A rat is a rat is a rat whether it is a pest invading and marking our territory and defeating our attempts at killing it mechanically or by artificial poisons, a pet for kiddies who “love” animals, or victim of the “humane” experimentation that may be a form of torture applied in the interests of safety and convenience in “our” food and environment. We cannot blink some tricky challenges if we wish to assert an objective scientific analysis and the application of our wit and kindness to lessen the toll exacted in the territorial war for “lebensraum” that we inflict on the animal (including our own species) denizens and environment on our planet. Scientific endeavour must be informed and funded, especially in prosperous communities, for service to the quality of mercy. Unfortunately scientists are inept in presenting these matters clearly, the laws are inhibiting, and the market costive – but they are beginning to react effectively to relevant trends, finding welfare a factor in premium pricing, even it is a times a dubious form of VAT – Virtue Adding Tricks.
4.2. Drafting of laws and codes of practice must avoid qualifying adjectives and adverbs: cruelty to animals must be an indictable offence. Modifying words such as avoidable and needless are excuses that hamper application of correction and punishments: their very use indicates connivance in routine processes that inflict pain and suffering and should be ousted without obstruction or havering. Procedures for therapeutic purposes (for the sole benefit of the patient) do not count as cruelties routinely inflicted or as a consequence of deliberate unkindness or neglect).
4.3. Current concerns over the REACH project on the safety of household goods and tests involving fish and marine animals, as well as insects, may lull some commentators as a means of averting procedures on dogs and cats – or chimpanzees, who are much nearer surrogates for our condition – and illustrate the need for merciful applications of concepts of sentience. Recent events have disclosed the contributing and increasing activities of livestock farmers in breeding animals for ultimate tests and experimentation under the control of the Home Office. Maggot farming is an ancillary enterprise to angling for fish. Some forms of fishing cannot be excused even as a relic of hunting for food. Exemption of commercial fishing and killing from general applications of “humane” slaughter sees welfare and environmental considerations in a powerful alliance that still fails to prevail over commercial procedures for which science and technology must be favoured in the search for alternatives to cruelties both routine and avoidable. Massacres on the scale of commercial fishing will entail methods of offensive killing infringing the stipulations of humane slaughter and these procedures may earn producers grants in compensations. The trade must operate only if the merchants can prove that they have sounds means of indemnification. The aftermaths of FMD and BSE prove the price paid by the Government for the cheap food produced by an uncaring industry turning out “cheap” food. If insurers cannot be found, the industry must be shut. Public money can be better spent on fostering enterprise in production of good value in all terms.
4.4. A comprehensive Policy must embrace treatments of wildlife and game, dealing with conservation as well as with leisure activities and exploitation.
4.5. It must also consider the merits of a well-kept countryside to prevent wandering of livestock and consequent dangers and poisoning as a result of access to toxic plants and trees (ragwort, yew, rhododendrons etc) and plastic litter and discarded machinery and electrical equipment. Decomposing tires (from silage clamps) and plastic bags can cause serious distress in animals unfortunate enough to ingest such materials.
5.1. The Animal Welfare Bill defined carers, keepers, custodians, owners, and handlers of animals. It and the Act do not insist on rigorous training, licensing, and CPD for all carers and the penalties and restrictions imposed as a result of infringements of the various commitments. Due diligence entails competence with some special experience, e.g. in pet shops and handling of exotic animals in zoos, circuses, and collections in dealerships and markets and at petting farms. The training of vets (who are avowed to do their utmost for the wellbeing/welfare of animals in their care) must be overhauled to exercise them more in those functions: at the moment the profession is too much engaged in the production of meat, milk, and eggs – the very surfeit of which the DEFRA Minister is objecting to – without voicing strong objections to entrenched violations of the FAWC’s Five Freedoms: and, come to that, the FAWC’s members duck the implications of their research and testimony in advocacy and personal example for observance of the Minister’s pleas and the consequent effectual practice over years of preaching and costive reform.
5.2. The veterinary profession is at the moment troubled by a lack of independent members in farming practices. New entrants are taking work in the treatment of pet and companion animals, leaving farm animals and their lay carers bereft of due advice. Likewise, British vets – understandably trained and committed for the welfare of the living animal – are reluctant to undertake work in slaughterhouses, so duties there have to be contracted out to vets brought in from countries where respect for animals is weaker. Such duties must also fall on practitioners in other countries whose products from their live/deadstock industry are exported to the UK. Vets are also called upon to serve as assessors in the experimentation under Home Office control in labs, and on farms. These are weighty responsibilities, augmented by new advances in molecular biology and GM and in applications of less objectionable alternatives and non-invasive procedures. Rigorous training schedules and CPD must be set.
6.1. All the proposals are worthy and overdue. Our answers to previous questions indicate how their relevance might be overtaken, especially in the current conditions of an active market competing with lively and well-informed ideas as carrots rather than as legislative and necessarily slow reforms administered with sticks. Welfare labelling and warnings on foods and other animal-derived products are as suitable on foods and other animal-derived products are as suitable as health warnings on cigarettes: cruelty-free cosmetics, so why not cruelty-free foods, clothes, shoes? (Jewish and Muslim definitions relate the methods of slaughter, but are unreliable indicators of welfare – how can any practice in the slaughterhouse meet a comprehensive description of welfare or adherence to the FAWC’s Five Freedoms?). There are many calls for restraint in the intensification in the live/deadstock industry and the need for restraints. All eggs on the commercial market must be sold with repeated and refreshed Government warnings: Production of these eggs entails cruelty to the birds. It would apply for organic, Soil Association, Freedom Foods, and free-range stock. In all of these systems male chicks are gassed or “macerated” and spent hens have little value (and therefore receive scant kindness), except perhaps as material for pet-foods and exotics in zoos, circuses, and labs.
7.1. Our previous answers anticipate most of those required here. We concede the inadequacies and ineptness of commentators purporting to represent animal welfare/rights. It is our main mission to train effectual recruits to such endeavours. Raising the school leaving age offers opportunities for greater attention to citizenship and to interactions with other animals and the environment, generating a healthier respect, especially in the food chain, in the links and responsibilities from farm to fork.
8.1. Action has to be taken on an ad hoc basis, with local conditions and possibilities determining urgency and combination – as would happen if these slightly extended Five Freedoms were applied in the NHS for a species not known for stoicism. Awarding priorities for general application could retard resort, as occasion arises, to a more effectual special agenda.
9.1. Our earlier comments cover these questions.
10.1. We have mentioned and recognized standards and achievements that could be measured and scored, but nothing should obstruct the elements of nursing and kindness (or compassion) that should imbue attitudes and interactions in the spirit of the proposed Delivery Strategy. It is the spirit and example that counts. And at last a Minister of Agriculture and Environment has pronounced it! We should brook no more delays!
11. Q8. and Q9.
11.1. Awards pf assurances, sales of symbols and logos, and notices of sponsorships and claims and advertising, as well as labelling, are functions that the FSA must assess to guarantee standards of competence and means of enforcement and policing. Many NGOs lack fitness for such purposes: they have not the necessary resources.
11.2. Local authorities must always have rights of entry to any premises housing collections of animals, although such premises should be subject to routine inspections under national supervision. Results of such assessments must be in the public domain (cf recent hygiene stipulations for restaurants). Visits by local authorities should comprehend requests form interested parties outside their patch, at their discretion and at their decision on period of notice and possible commercial confidence (which could be overturned on appeal to magistrates).