Memorandum submitted by the Meat and Livestock
Commission
The has been considered by a group of senior
staff at MLC and our comments are restricted to how the provisions
of the draft Bill relate to the farmed red meat species.
1. The Meat and Livestock Commission (MLC)
was set up by the Agriculture Act 1967 to promote greater efficiency
in the livestock industry whilst taking into account the interests
of consumers. The MLC aims to improve British livestock and promote
British meat. MLC's work includes activity designed to lower the
costs of production for livestock farmers, to improve the eating
quality of meat and promotion and advertising to raise the profile
of British meat to consumers.
2. The Commission is responsible to Parliament
and its policies are agreed after extensive consultation with
industry organisations. It is financed through the collection
of levies on cattle sheep and pigs plus money earned from its
own commercial work. The MLC receives no direct support from Government
and is not part of any Ministry.
3. The MLC works with the whole of the industry—Government,
the EU, livestock farming, auction marketing, retail, communications,
economics, exports, health, schools and colleges and industry
services.
4. The introduction of an Animal Welfare
Bill to bring up-to-date important legislation and the decision
to consolidate the existing law within one overarching piece of
primary legislation is welcome on the grounds of reducing confusion
and improving clarity.
5. The British livestock industry has adopted
welfare measures that are among the strictest in the world and
uniquely through its network of farm assurance schemes can assure
consumers of compliance. The British livestock industry is generally
in advance of its counterparts in other countries. British producers
have made significant investments in developing systems to improve
welfare but this has rarely been reflected in returns. The red
meat industry promotes the adoption of the five freedoms that
the Farm Animal Welfare Council (FAWC) defines as ideal states
rather than standards for acceptable welfare. Welfare is a priority
for the livestock industry and the Animal Health and Welfare Strategy
has been welcomed as an initiative. There is strong support for
the concept of Government and industry working together constructively
to improve health and welfare.
6. The draft Animal Welfare Bill provides
for the protection necessary to prevent all farm animals suffering
from cruelty, unnecessary pain and distress and poor welfare conditions.
It is accepted that the responsibility for the welfare of their
animals rests with those who keep them.
7. It would be an offence under Section
1 subsection 4 to carry out certain procedures such as tail docking
of piglets and lambs unless there is an exemption under subsection
5. There is a strong case for such an exemption for the docking
of tails of piglets and lambs to prevent the serious welfare insults
of tail biting and fly-strike respectively. A similar strong case
can be presented for an exemption for castration of livestock
to prevent unwanted pregnancies and aggressive behaviour of males.
8. The definition of welfare in section
3 closely follows the five freedoms that the Farm Animal Welfare
Council (FAWC) defines as ideal states rather than standards for
acceptable welfare. The red meat industry actively promotes the
adoption of these freedoms and recognises that there is a duty
of care of animals to meet the needs outlined in Section 3 subsection
4 in an appropriate manner as defined in Section 3 subsection
5. It should however be recognised that meeting needs inevitably
involves striking a balance. For example for pigs the need to
be able to exhibit normal behaviour patterns is best achieved
in straw-based housing systems but this can be at the expense
of an increase in the risk of disease. Similarly tail-docking
of lambs involves a trade-off between some pain for many and excruciating
pain for those affected by fly-strike.
9. Sections 6 to 9 making provision for
regulations and codes of practice promoting the welfare of animals
are supported on the basis of appropriate consultation with the
industry and impact assessment.
10. Wilful cruelty to farm animals is rare
but humans are fallible and welfare can be compromised as a result
of ignorance or external stress and pressures eg economics. The
outbreak of classical swine fever (CSF) in August 2000 and of
Foot and Mouth Disease in February 2001 represented the largest
compromise welfare in British livestock in modern times.
11. Animal welfare standards are constantly
being improved in the UK and the EU both by operation of law and
also through a range of voluntary schemes. These improved standards
will generally involve increased production costs and hence higher
prices. This makes EU farmers vulnerable to cheap, low welfare
imports from third countries, as WTO rules prevent the EU from
restricting the import of meat or eggs derived from animals reared
in systems which are prohibited in the EU on animal welfare grounds.
Every effort should be made to amend the WTO rules must be relaxed
so that when the improved welfare standards are adopted, it is
possible to prevent the import of produce coming from animals
reared to lower standards. Without such safeguards, EU producers
are placed at an unfair competitive disadvantage and could well
experience both a significant fall in income and loss of market
share.
12. It is important that the Government
presses for similar welfare standards to be uniformly applied
for livestock throughout the EU. The pig industry experienced
unfair competition, when the UK ban on sow stalls came into effect,
and imported pigmeat coming from stall systems has undoubtedly
played a large part in the contraction of the British pig industry
since 1998. In the rest of the EU tethers will not be banned until
2006 and sow stalls not until 2013. Consistent labeling principles
are required that allow consumers choice on the basis of welfare
standards.
13. In response to an earlier consultation
it was noted that the welfare provisions of the Agriculture (Miscellaneous
Provisions) Act 1968 were not listed as a candidate for inclusion
in the new Animal Welfare Bill. The provision within the draft
Bill to treat the existing codes on the welfare of farmed animals,
prepared under section 3 of the Agriculture (Miscellaneous Provisions)
Act 1968, as if issued under the Bill is welcomed.
14. Enforcement of the legislation must
be consistent. This is currently a problem with EU welfare legislation,
which is not uniformly applied in all Member States. Enforcement
of existing legislation is fragmented with different enforcement
bodies being responsible for different aspects of animal welfare
legislation, eg police, local authorities, Defra, etc. Defra should
have a remit for ensuring consistent national enforcement.
15. Prosecution and punitive sanctions should
be seen as the failure of the system to deliver welfare to animals.
However, an approach based solely on compliance for fear of prosecution
creates conditions in which seeking help at an early stage is
discouraged and the opportunity for appropriate early remedial
action is thereby lost. Education, training and research to design
systems that help to prevent welfare insults, to make them detectable
so they can be intercepted, and to provide means of mitigation
if they are not intercepted should be the main focus in creating
a culture of good welfare.
The Meat and Livestock Commission (MLC), Hybu
Cig Cymru (HCC), Quality Meat Scotland (QMS) and the English Beef
and Lamb Executive (EBLEX), will continue to support and promote
high standards of animal welfare. MLC would be prepared to submit
oral evidence if invited and will take note of the passage of
the Bill through Parliament with interest.
August 2004
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