Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by the RSPCA (F 59)

  The RSPCA is grateful for the opportunity to contribute a submission to the inquiry which the Agriculture Committee is undertaking regarding Organic Farming.

  The Society is concerned that organic farming is often perceived as being synonymous with high standards of farm animal welfare. However, this perception, as well as many of the claims about the quality aspects of organic food appear to be without foundation.

  This was highlighted recently by the Advertising Standards Authority, when claims that, "organic means healthy happy animals" was seen to be unfounded, as were some of the claims relating to the quality aspects of organic food. Indeed, the Head of the Food Standards Agency, Sir John Krebs was recently reported as saying that there was no evidence that organic food was healthier than conventionally produced food and that in his opinion, people were not getting value for money.

  In relation to specific animal welfare issues, the RSPCA is concerned that many of the organic standards as currently written are ambiguous in their wording, which leaves them open to subjective interpretation when implemented on the farm. Furthermore, it is often difficult to ascertain from which branch of science they have been developed as there are many examples where organic standards impose apparently arbitrary rules, some of which conflict with widely accepted standards of animal health care.

  The editorial comment in the most recent newsletter of the Animal Welfare Science Ethics and Law Veterinary Association (AWSELVA) expressed deep concerns regarding the welfare status of organically produced poultry, which are often portrayed by organic protagonists as being reared under the highest possible welfare standards.

  Although no farming system can claim to be perfect, when the moral high ground is used to substantiate apparent claims that one system is much better than the rest, as has been the case with organic production, it deserves further investigation. To this end the RSPCA welcomes the fact that the Agriculture Committee is examining this method of food production.

  A detailed appraisal of organic livestock production is beyond the scope of this brief submission but, as an example, if we consider organic egg production, the first general point to be recognised is that there is considerable variation within the present spectrum of organic standards. Standards for the various organic schemes range from those which differ very little from a conventional set of standards, for example the British Egg Industry's egg production criteria, to those which are much more stringent and nearer to the organic ideal of small units and low stocking densities etc.

  The details contained within organic standards should also come under much greater scrutiny. For example, it simply does not follow that a low stocking density inside the hen house in conjunction with the length of popholes required under the organic standards is in the best interests of the birds. There may be more room to dustbathe and generally for the birds to find their way around, but conversely, there may be problems with maintaining an adequate thermal environment and difficulties in maintaining litter quality. There is therefore greater potential for the welfare of the birds to be compromised, particularly as levels of aggression in small units can often exceed those in larger units.

  It is also slightly misleading to claim that birds are fully organic, when there do not appear to be any coherent pullet rearing standards, and that birds are therefore reared conventionally for the first 25 per cent of their life up to the point of lay. This is confusing, because the EU Regulation 1804/1999 states that poultry must be reared in open range conditions.

  However, when pullet rearing standards are eventually developed, there will be a number of important welfare issues which will need serious consideration. The organic philosophy of turning juvenile birds outside during the rearing phase, can in itself present welfare problems. The risk of exposure to viruses, bacteria and parasites as well as the risks from vermin and predators may increase levels of disease in these young birds. The natural corollary of this is that mortality rates may rise.

  The naive theory advanced by some sectors of the organic movement is that the birds will develop a natural immunity by exposure to these agents, but this may prove difficult to achieve in practice and an increase in serious conditions such as Marek's and Newcastle disease may prevail, if birds are not vaccinated. One factor which may help to reduce the incidence of Marek's disease other than vaccination, is avoiding undue stress on the birds. With a low stocking density and potentially poorer air quality and increased levels of aggression as noted above, this again may prove difficult.

  In the area of livestock nutrition, the recent decision by the United Kingdom Register of Organic Food Standards (UKROFS) to prohibit the use of synthetic amino acids in the diets of animals has the potential to compromise the welfare of monogastric animals, due to some of these amino acids being a limiting factor in these diets. The issue could be compounded if certain proteins such as fishmeal are also restricted. An example of the result of a deficiency of these essential amino acids are poor feather quality in poultry. Organic diets applied to some modern breeds of livestock may therefore be insufficient to keep the animals in full health and vigour; a basic principle of animal welfare.

  The increased sales and the influx of foreign organic products into supermarkets, further begs the question as to how some of these animals are being fed, ie is it possible that there is a less stringent implementation of the organic rules in other countries?

  Other animal health issues are also of great concern to the RSPCA. The EU Regulation 5.4b actually states that if the use of the above products (phytotherapeutic) should not prove, or is unlikely to be, effective in combating illness or injury, and treatment is essential to avoid suffering or distress to the animal, chemically-synthesised allopathic veterinary medicinal products or antibiotics may be used under the responsibility of a veterinarian.   The RSPCA believes that the area of veterinary medicine use in organic production requires a major review in the interests of animal welfare. It is unwise to consider using any treatment which is unlikely to be effective on a farm animal. Many health conditions of farm animals equate to immediate pain and therefore require a treatment which is proven. Any procrastination will compromise the welfare of the animal.

  Also, within this context, organic standards do not appear to specify any maximum number of alternative treatments which one may try before resorting to a conventional treatment. This may encourage some farmers to wait unnecessarily for the outcome of the alternative treatment, which may not be to the benefit of the animal.

  The second element to this problem is that, under organic rules, if a conventional treatment is used, there may be a withdrawal period associated with this treatment which is much longer than that required by EU and UK regulations before food may be marketed. To some farmers the associated economic penalties of losing the organic premium on the food they are producing may be unacceptable.

  The RSPCA has evidence to suggest that as a result of this, some farmers are not treating their animals as quickly as they should. One example of this is a case where a farmer was treating a cow for digital dermatitis. The planned treatment was a topical application of antibiotic spray. Instead of using this he decided to use an organic approved alternative remedy, because he did not want to withdraw his milk from the organic market because of the financial consequences. If this alternative remedy was to prove ineffective, the cow would certainly have suffered as a result.

  The epithet of "more is better" appears to run through many of the organic standards, but as noted above, longer withdrawal periods, more pophole space, more floorspace and the use of alternative therapies may compromise farm animal welfare. Whilst sales of organic products in supermarkets continue to rise, with a significant proportion of these products coming from abroad, it would appear prudent to scrutinise the animal welfare aspects associated with the production of these products in much more detail.

  In conclusion, the RSPCA would welcome an independent examination of organic standards and, more importantly, their implementation at the farm level to determine the extent to which animal health and welfare is being compromised by organic rules. Ideally, this review should be undertaken by the veterinary profession with the aim of advising on how organic rules should be amended in the interests of animal welfare.

2 October 2000

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