APPENDIX 39
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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