Memorandum submitted by The Shellfish
Network
INTRODUCTION
Shellfish suffer at all stages of processing
from trapping, transport and storage to killing. Legal protection
is needed at all of these stages.
1. (i) Trapping
Storms can leave traps, with animals in them,
lost on the seabed or washed up on inaccessible beaches, with
a risk of starving or being baked in the sun. If a number of animals
are in one trap there is the risk of mutual injury and cannibalism,
particularly with lobsters which are solitary animals prone to
aggressive competition for food and territory. This cannot be
dismissed as nature, rather than human interference, at work,
since nature is here being aggravated by an artificially stressful
environment imposed on the animals by humans.
1. (ii) This problem applies both to
traditional traps such as the creel and the inkwell and to the
more advanced parlour pot and the pot lock. Since these latter
have one, or sometimes two, inner chambers, escape is more difficult.
The solution may lie in fitting all traps with a biodegradable
escape panel which opens after a period of time. A device of this
sort has been a legal requirement for lobster traps in the US
State of Maine since 1990, not for humane purposes but to prevent
depletion of lobster stocks. These panels open after 60-90 days,
but humane considerations would require a much shorter period.
There is an urgent need for research into the use of suitable
biodegradable panels for all shellfish traps, possibly using similar
material to that employed in medical operations where stitches
are self-dissolving.
1. (iii) We understand from a source
in a UK Shellfishermen's Association that many of those who use
traditional traps would probably favour an outright ban on the
parlour pot and pot lock on the grounds of over-fishing and unfair
competition. As escape is so difficult, the operators can leave
these traps unhauled for longer periods, enabling more than one
set of gear to be worked.
2. (i) Transport
Traditional forms of transport often involve
overcrowding, with the animals tightly packed together to avoid
aggression. But, as with the traps, the aggression is the product
of an artificially stressful environment. With lobsters, there
is the further precaution of banding their claws, thus thwarting
their instinct to attack/defend.
2. (ii) We understand that Defra scientists
are researching the use of individual waterproof tubes for the
transport of shellfish as an alternative to densely packed containers.
One such tube was patented some years ago by a prawn exporter
in the Western Isles of Scotland. These tubes are put into the
hold of a ship equipped with the means to pump refrigerated seawater
around the hold. Though the tube is open, the prawn of its own
accord stays inside, treating it as a hole it would hide in on
the seabed. The Scottish Society for the Prevention of Cruelty
to Animals surveyed this transport method and passed it as much
more humane than the conventional one, with 1% mortality through
stress or injury, as compared with 40%. If it has not already
been undertaken, we would urge research into the feasibility of
adapting this process to road and other forms of transport.
2. (iii) If a tube can simulate a prawn's
hiding-place, it should be possible to scale this up for lobsters,
which hide in rocks, crevices and weeds, and for other larger
shellfish. This also should be researched.
2. (iv) We have heard of a suggestion
that if a lobster in an individual tube has its body temperature
reduced, it will go into a torpor. It does seem that the basic
idea of an individual space along with simulation of a refuge
and/or a sedating effect could be a humane way forward for shellfish
transport. For the industry there would be the advantage of the
animals staying fresh for longer periods. A closed tube with no
sedating or refuge effects would not be humane, as it would be
a marine version of a veal-crate.
2. (v) We urge that research into humane
transport is given high priority to allow for its mandatory use.
3. (i) Storage
Once the animals arrive at their destination
they should be kept in as humane an environment as possible in
the tank conditions recommended by the Fisheries Departments.
The practice in lobster storage of keeping them unfed for long
periods, presumably to prevent excrement polluting the water,
should be prohibited. Although they can survive for many weeks
without feeding, there must come a point where disregarding their
hunger would be cruel. If there is no other way to control the
excrement problem, then there should be legal limits on how long
they can be held in tanks and stock turnover should be planned
accordingly.
3. (ii) It has frequently been noticed
that lobsters are kept in tanks which appear to meet only the
minimum of legal conditions, if at all. This is the case in many
of our holiday outlets by the sea. We propose that the keeping
of live shellfish should be strictly licensed and unannounced
inspection undertaken regularly.
3. (iii) There should be consideration
of whether tubes, as described in the preceding section, could
be a humane advance in storage also.
4. Selling live to the public
Since the majority of the general public will
have no idea on the most humane ways of killing shellfish, we
suggest that such sales should no longer be legal. Only licensed
experts should be allowed to kill the animals, using our Guidelines.
5. (i) Killing of shellfish
We believe that traditional methods of cooking
are cruel and that the methods outlined in our Guidelines should
be mandatory, at the very least for lobsters, crabs, crayfish
and langoustines. These include the freezing method; placing the
crab or lobster in a plastic bag and placed in a deep-freeze cabinet
set at -20°C and left for two hours, or alternatively cutting
through the nerve centres, which must only be carried out by experienced
staff. The anatomy of the crayfish is like that of the lobster
on a small scale, and it therefore may well have a similarly complex
nervous system, although piercing nerve centres would not be practicable
as it is so small an animal. The freezing method would be necessary
in this case. We have heard from a scientist that langoustines
can take up to 30 seconds to die when boiled. Subjecting live,
conscious animals to cutting up, boiling, steaming or other cooking
processes should be banned and the killing only carried out by
competent experts. The Crustastun, mentioned in our Guidelines,
is an electrical stunning tank which has recently been developed
in prototype by scientists at Bristol University and the Silsoe
Research Institute near Bedford. This stuns crabs and lobsters
in a fraction of a second, and ensures that they remain insensible
to pain long enough to be cooked by boiling immediately. Once
the device is available it ought to replace all other methods.
5. (ii) Our Guidelines and Dr Sherwin's
Paper question the assumption that invertebrates, even very small
and simple ones, cannot feel pain or stress and we would therefore
hope that the definition of "animal" will include crustacea
and molluscs and that serious consideration should be given to
applying legislation to the smaller ones as well as to lobsters
and crabs. Although small crustacea are technically included in
the definition, any legislation should extend to them as well
as to lobsters and crabs.
6. Farming
Any legislation relating to fish farming should
include shellfish farming regarding the welfare of the animals.
7. Shell industry
There is an industry in using shells to obtain
pearls or to make ornamental products such as ashtrays, necklaces
etc. This type of industry should be frowned upon and information
could be issued to shops regarding this in terms of environmental
degradation and cruelty to the creatures involved, with, if possible,
a ban on such sales.
8. Compared with other animal welfare issues,
the treatment of shellfish has long been neglected and we would
be most grateful if you could do all you can to redress this.
9. Further information on the biodegradable
lobster traps used in Maine, USA as mentioned under para 1(i)
"Trapping", in our submission statement can be had from:
The director, Biological Monitoring Division
Department of Marine Resources
P O Box 8
West Boothbay Harbour
Maine 04575-0008
USA. Tel: (207) 633 9500 Fax: (207) 633 9579
9. (ii) The inventor of the individual
tubes used for transport of prawns under para 2(i) "Transport"
in our submission statement is Murdo Macaulay of South Harris
in the Western Isles of Scotland.
4 August 2004
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