Memorandum submitted by the Game Farmers'
Association
1. The GFA represents members throughout
the UK who rear gamebirds (mainly pheasants and partridges) for
release into the wild to supplement wild stocks used in sporting
shooting.
2. We have supported the concept of a proper
Animal Welfare Bill from the outset and Defra officials have met
with us on several occasions and have visited member's game farms
during their work on the Bill. As a result, we believe the current
draft is a reasonable starting point.
3. We are concerned, however, that aspects
of the Bill are very vague and leave much to interpretation by
the courts. Because game farming has its opponents, there is a
big risk of malicious prosecutions and the final text of the Bill
must ensure that offences are sufficiently clearly defined to
avert the risk of innocent game farmers being prosecuted.
4. The Government's intention, stated in
the papers accompanying the Draft Animal Welfare Bill, is that
game farming should in future be regulated by a Defra-approved
Code of Practice issued under the Bill.
5. We welcome this approach and in particular
the intention, also clearly stated in the papers, that such a
code should be based on the exiting Code for Game Rearing first
published by our Association in 1999.
6. Our Code (latest edition 2003) originally
drew from the Government's own Poultry Health Scheme is already
widely followed and has stood the test of time. It is practical
and reasonable and has been praised by Government and the veterinary
profession. The absence of any welfare prosecutions of game farmers
since its launch suggest that the code is working.
7. The Government has a manifesto commitment
not to restrict shooting in any way, so we ask the EFRA Committee
to recommend that our code be adopted without material change.
If this can be done, we believe game farming practice and animal
welfare will both be well served.
8. It is important that in transposing the
GFA Code no alterations or additions are made without taking into
account the views of the industry. In our view there is no reason
why the GFA Code should not be adopted as the basis for a Defra-approved
code unaltered.
9. The Draft Bill would confer a right for
inspectors to enter and examine game farms and other places where
gamebirds are kept. This would be a new departure and we support
the idea as bringing game farming into line with other farming
sectors.
10. We have strong views, however, about
who should be allowed to make such inspections. Our first preference
would be the State Veterinary Service or, failing that, a system
based on inspection by our own vets, who are visiting anyway during
the rearing season.
11. We are concerned that the Draft Bill
could allow Local Authorities to appoint unsuitable individuals
and organisations as inspectors. In this context the Secretary
of State's guidance to Local Authorities on who might make a suitable
inspector is crucial. It should be subject to proper Parliamentary
scrutiny.
13 August 2004
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