Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by the Rare Breeds Survival Trust

  1.  The Rare Breeds Survival Trust welcomes the Draft Animal Welfare Bill, and supports the wish to enhance the welfare of domestic animals in England and Wales. Welfare of livestock is a basic principle within the broader policy of the Trust's programmes for the conservation of animal genetic resources.

  2.  We note that the emphasis of the draft Bill is directed towards non-agricultural animals (eg fighting animals, pets), but nevertheless the principles embodied in the Bill, and the framework proposed for codes of practice, are relevant to all domestic livestock. The Trust's response will relate primarily to domestic farm animals.

  3.  The Trust opposes cruelty to animals, and supports the generality of proposals under section 1 of the Bill, but there are items which require more detailed definition.

  4.  The welfare of animals has been defined in terms of "five freedoms" and these approximate to the items detailed in 3(4). However, they should not be absolute requirements, but rather "a pragmatic checklist to identify the strengths and weaknesses of any husbandry system" (Prof J Webster). In each system of management, some freedoms will be fully expressed and others less so.

  5.  The Trust welcomes the recognition that welfare should allow for "a suitable environment in which to live" [3(4)(a)], and endorses the implied concept that adaptation to their environment is an important element of animal welfare, but questions the definition of "suitable". Some breeds are adapted to extreme habitats, which may fall outside conventional definitions of "suitable", but which are appropriate for those breeds. In particular, animals in extensive systems of husbandry may be subject at times to some stress, but they have considerable freedom to respond to stress and full freedom to express their normal pattern of behaviour.

  6.  The Trust recommends that extensive grazing systems should be subject to a different and appropriate code of practice that recognises their specific requirements.

  7.  Without detracting from support for the enhancement of welfare standards, some specific items must be questioned.

  8.  Clause 1(4)(c) states that "A person commits an offence if he permits the mutilation of an animal of which he is the keeper", but this needs to be evaluated in the context of clauses 1(3)(b) and (c). For example, dehorning cattle (especially those in extensive systems of management) might be regarded as an unnecessary mutilation that detracted from their functionality, whereas docking the tail of a sheep in lowland systems should not be regarded as mutilation because the operation is for the benefit of the sheep.

  9.  Clause 4 would make it an offence to sell an animal to a person under the age of 16 years. It is not clear whether this is intended to prevent ownership of animals by any person under the age of 16 years. Does it prevent gifts to such persons? Does it apply to such persons who already own breeding animals? The clause requires further clarification, with an understanding that many children of livestock farmers own livestock and acquire valuable experience of livestock in this way.

  10.  In conjunction with the Government, the Trust is concerned with the conservation of animal genetic resources as laid down by the Convention on Biological Diversity, and as guided by the UK Country Report. The development and monitoring of animal breeding programmes is an essential part of the Trust's work, and it views with concern and alarm the inclusion of clause 6(2)(o) "—regulations—may—make provision about the breeding of animals".

  11.  The Trust is concerned by the generality of sections 6 (Regulations to promote welfare) and 7 (Codes of practice), and by the potentially wide-sweeping powers that would be conferred. They penetrate into detailed areas of animal breeding and production, and have the potential to enmesh the livestock industry in further layers of bureaucracy. It is essential that full consultation with the industry takes place before the contents of sections 6 and 7 become more specific.

23 August 2004

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