VEGA's response to the consultation
1. The Strategy should be named an Animal Health and Animal Welfare Strategy: the emphasis in the Implementation Plan dwells too much on Human Health and Human Welfare in which animal health and animal welfare are compromised on grounds that can be faulted scientifically and thus legally.
2. Many potential stakeholders are compromised in ways that we explained earlier and were adopted in the questioning of witnesses to the BSE Inquiry: they were asked what advice they offered consumers and caterers and adopted themselves at the height (and before) of the BSE epidemic (and since) in the manner of consequent change. Similar questioning and responses must be required of potential stakeholders on their responsibilities in the FMD outbreak. These were just two recent events that illustrate the incompetence and lack of purpose in the proposed strategy of commentators with a record generating discontent among animal welfarists, and their increasing influence in resisting abuses and obstruction in trades of usage, exploitation and inability to police and indemnify
themselves that must brook little sympathy from the Government and distributors of public monies.
3. The Strategy must therefore anticipate, like the BSE Inquiry, much more involvement in the workings of the "cheap" and intensive food industry and emphasise that the S in FSA means Standards, not just Safety to the human consumer – in true plough-to-plate style in which animals are the primary producers with prime interests.
4. "Humane killing" was introduced 70 years ago when pole-axing was outlawed as a means of slaughtering animals – massacre would be a more apt word – from the live/deadstock industry. Cruelty remains and grants still have to be made to deal with the tragedy in this euphemism, as well as in achievement of the FAWC’s Five Freedoms; the Government is faced with advice from potential stakeholders and so-called animal welfarists who have manifested no practicable resistance, nor even desistance, from complicity in an enormity they lamely chronicle.
5. The Strategy must profess the Five Freedoms in its animal welfare intentions, reinforced by the Home Office’s mission over the use of animals for experimentation and testing – the 3 Rs of Reduction, Refinement and Replacement. These principles must be applied more generally, e.g. for zoos, breeding, circuses and entertainment.
6. Such initiatives fit well with the efforts of the DoH and FSA to reduce demand for foods, many of animal origin. Present levels of production and consumption are wasteful and harmful: the R of Reduction must be combined into manifestation on several counts. The dairy industry is also in trouble with the quotas, and the CAP’s intentions of decoupling and diversion of subsidies from production to environmental purposes, among them the R for Replacement, is expressed in the industrial enterprise for "cruelty-free" non-dairy alternatives. The Strategy must exhibit urgency in exploiting such possibilities in bringing relief to animals from avoidable cruelty.
7. Consumption of hen’s eggs had been falling for some years, but a recent rise in demand has led to claims from the industry that 3 million more eggs per week are being sold this year than last. Experts conferring last year agreed that no system of domestic production nor used for imports came near to fulfilling the FAWC’s Five Freedoms; therefore an R for Reversal of this trend would represent an effective and practical expression of animal welfare. The Strategy must emphasise the cruelty behind this overproduction and over-consumption. Introduction of Welfare Warnings, like the Health Warnings on cigarettes, would prove that DEFRA was in earnest in reducing the toll taken of the hens. Production of these eggs entails cruelty to the birds would tell the truth and engage consumers and farmers in the means of following kinder diets. Such policies were rehearsed a couple of years ago in submissions to the Cabinet Office’s Curry Commission.
8. We point out a few subjects for which more work is needed in progression of the Strategy.
a. Livestock markets and direct short-journey farm to slaughter schemes. FMD revealed yet again the stress, hurt, and risk of spread of disease entailed particularly in the sales, dealing, and marketing of sheep. These activities call for more attention and solutions.
b. Training and licensing for all owners, keepers, and handlers of animals. Vets should have more training in animal behaviour and the attractions of practice in farming and pet care should be redressed to encourage greater presence by veterinarians on farms, zoos and pet shops, as well as breeding establishments, and racing enterprises need special attention. Restrictions on hunting cannot yet be taken for granted. By analogy with the MHS (which is charged with welfare aspects in the adverse conditions in slaughterhouses and their immediate environs) and its HAS scoring, WAS ratings for Welfare must now be applied and published to all commercial premises, sanctuaries, shops, and veterinarian’s surgeries and compounds. Like the MHS these monitoring services by the SVS should be funded by levies imposed on applicants for the required registration and licensing.
c. Angling and commercial fishing need more attention in the Strategy. Treatment of game, wildlife, reserves, habitats, and sanctuaries must be included in the deliberations.
d. Movements of animals and people favour the spread of zoonotic diseases, viral and bacterial. Vectors such as ticks may play roles, but movements of wild bird populations need special supervision, as the history of flu and flu-like pandemics illustrate. Watch is also needed for exploitation of such factors by terrorists and saboteurs. Research on vaccines, for use by people and other animals must be promoted to avoid the appalling culls recently undertaken in various countries involving farmed pigs, birds, cattle, and sheep. The farming industry and ultimately the customer must meet the costs of prevention and indemnification. A territorial corps of vets must be raised for urgent enlistment as threatening epidemics such as FMD are identified, or when ‘Acts of God’ such as flood, drought, or fire call for urgent and overriding action.
e. DEFRA and army veterinary bodies must take responsibility for the welfare of animals in zones affected and occupied by military action by British forces.
f. Veterinary consulates must be established in countries (notably non-EU) supplying the UK with live animals or their derivatives. Hygiene and welfare must be surveyed consistently in methods of rearing, farming, transport, and slaughter. This would entail interventions with environmentalists on trades in bushmeat and ivory and in fur production and whaling. The objectionable exportation of sheep from Australia to the Near East illustrates the need for surveillance of this sort. Imports into England of animal-derived foodstuffs from South America, Thailand, and India, as well as countries such as Poland and Hungary not yet fully integrated into the EU, are set to increase.
g. Horses and their welfare must be protected in EU decisions on their treatment and status as agricultural animals destined for the meat trade or not; loss of the minimum-value regulations has also removed controls on the transport and slaughter in Europe of ‘vanner’ horses. Means of restoring this protection – and for other farm animals – must be established.
h. The status of vets and designated charitable bodies such as the RSPCA needs definition. The variable resources and competence of such well-intentioned organisations are inadequately recognised, assessed, and recompensed for services taken for granted and often cited in unreliable assurances over monitoring and policing. Rights of entry and status accorded to such agents must be defined.