Memorandum submitted by the British Poultry
Council
INTRODUCTION—BRITISH
POULTRY COUNCIL
The British Poultry Council (BPC) is the representative
body of British poultry meat producers. It covers the whole poultry
meat chain—primary breeding, hatching, rearing, slaughter
and processing of chickens, turkeys, ducks and geese and the slaughter
and processing of spent layer and breeder birds.
The British poultry meat sector is highly vertically
integrated, and processing is concentrated into relatively few
large companies. Around 60% of birds are hatched and reared on
the integrated companies' own hatcheries and farms and the remaining
birds are grown by independent growers under tight contracts to
particular integrators. The BPC is actively involved in promoting
high welfare standards within all aspects of poultry breeding,
rearing, transport, and slaughter. The draft Welfare Bill, therefore,
is directly relevant to the activities of BPC members.
THE DRAFT
WELFARE BILL
The BPC fully supports the aims of the draft
Bill. We see very little in the draft Bill which causes us concern.
Poultry welfare is already heavily regulated and subject to official
codes of practice, as well as other independent assurance codes.
The draft Bill does not appear to substantially change or add
to the existing regulatory framework in respect of poultry production,
except in the updating of powers following conviction.
Of most interest to the poultry sector will
be the detail of any proposed regulations to be issued under the
powers provided for in the draft Bill. Many of the circumstances
listed in Clause 6, Regulations to promote welfare, are already
the subject of UK regulations implementing EU animal welfare directives
covering farming, transport and slaughter or killing. It is the
strongly held view of the BPC that any welfare rules applying
to the commercial poultry meat sector should be on an EU-wide
and not UK-only basis.
In Clause 6(2) we note that, in the extensive
list of detailed circumstances in which regulations may be made,
there is no mention of prohibitions on the import and consumption
of food or products deriving from animals outside England and
Wales which have been not benefited from the protection of such
detailed welfare regulations or, in the case of several Third
Countries, from any welfare legislation at all. This would seem
to be a serious omission.
PERMITTED MUTILATIONS
Clause 1(4) of the draft Bill would prohibit
any mutilation unless it had been specifically permitted under
Clause 1(6) by way of a Statutory Instrument approved by both
Houses of Parliament. There are very few types of mutilations
undertaken in the UK poultry meat sector and relatively few birds
are affected. We would be very concerned, however, if the process
envisaged in Clause 1(6) enabled an individual MP or peer, for
whatever motive, to prevent approval of statutory instruments
permitting mutilations which are currently allowed.
RIGHTS OF
ENTRY—ANIMALS
IN DISTRESS
In the case of poultry breeding and rearing,
the extensive powers of entry provided for under Clause 14 need
to be exercised with due consideration for the protection of the
bio-security of the premises and birds concerned. To this end
we recommend that the guidance from the Secretary of State envisaged
in Clause 44(2) also include guidance on the approach by inspectors
in exercising rights of entry with particular reference to bio-security
of poultry premises and flocks.
On a minor point of layout, we think that Clause
14 should precede the current Clauses 11, 12 and 13, in that the
entry and search comes before taking possession, etc. of animals
in distress.
ENTRY AND
INSPECTION OF
FARM PREMISES
Our comments on Clause 14 above also apply to
entry and inspection powers under Clauses 38, 39, 40, and 41.
Subject to the few points above, overall, BPC
welcomes this draft Bill.
24 August 2004
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