Memorandum submitted by the British Egg
Industry Council
1. INTRODUCTION
1.1 The British Egg Industry Council (BEIC)
strongly supports high standards of animal welfare, and the industry
which it represents has worked hard, and invested heavily, to
meet the increasing requirements brought by new legislation. Animal
welfare standards are therefore particularly high in our sector.
A back-ground briefing on the BEIC is attached in appendix 1.
1.2 The BEIC is concerned by the lack of
detail within the draft Animal Welfare Bill. This makes it difficult
to comment on much of the proposed legislation, and there is clearly
scope within it for significant new animal welfare measures to
be introduced affecting the agriculture sector, but which are
not detailed at this time.
1.3 Because of this lack of detail, there
is scope for it to be interpreted in ways that may not have been
intended.
2. SPECIFIC OFFENCES
RELATING TO
ANIMALS
2.1 Whilst the overall emphasis, particularly
in the media, has been upon non-farmed animals, it is clear that
it can and will also be enforced extensively in the agriculture
sector.
2.2 Producers in the UK take the welfare
of their livestock extremely seriously. The egg industry already
meets the very strict requirements of UK and EU animal welfare
legislation, which have increased substantially in recent years.
2.3 It is of concern that attempts may be
made to utilise the Bill to go further than existing legislation
intended. The BEIC is concerned that the imprecise nature of the
term "unnecessary suffering" could allow it to be used
against systems of production which are permitted by law, such
as laying cages, but that are contrary to the beliefs of an active
minority of the population.
2.4 The BEIC believes that areas of animal
welfare which are already covered by EU wide animal welfare legislation,
specifically Council Directives 88/166/EC and 1999/74/EC, should
not be subject to additional domestic legislation.
2.5 The draft Bill makes mutilation of an
animal an offence (clause 1 (4)). The BEIC believes that the Bill
should make clear that practices which may technically be described
as mutilation, but which are legal due to benefits they bring
to the animal's well-being, are not included in this offence.
As example, we cite provisions made in an amendment to the Welfare
of Farmed Animals Regulations (2002) to permit beak trimming of
laying hens until 2010 in order to prevent feather pecking and
cannibalism.
3. ENFORCEMENT
POWERS
3.1 The draft Bill provides a range of new
enforcement powers, and the rights to implement these through
entry with or without a warrant to farm premises. Whilst the BEIC
understands the need to ensure that the requirements of the legislation
are met, it urges that consideration be given to how these powers
are used in practice.
3.2 Nearly 85% of UK egg production is to
the standards of the Lion Code of Practice, which sets higher
standards of food safety and animal welfare. All stages of egg
production (breeding, hatching, rearing and laying) are surrounded
by strict biosecurity measures to protect poultry health. We believe
that there should be provisions within the legislation to ensure
that on entering any farm or hatchery, enforcement officers pay
due heed to the strict biosecurity measures of the Lion Code of
Practice. These requirements should also extend to inspection
of farm vehicles if they contain livestock or produce.
APPENDIX 1
The British Egg Industry Council (BEIC) is an
inter-professional organisation of 11 trade associations in the
UK, which cover all aspects of the egg industry—breeding,
hatching, rearing, laying, packing, egg processing and marketing.
Its principal function is to represent the interests of its Members
(the UK egg industry) in discussions with Government, MPs, the
European Commission, European Parliament, and other bodies. BEIC
also finances research and development. BEIC is recognised by
Government and Parliament as the representative voice of the UK
egg industry.
The 11 representative Trade Associations are:
— British Egg Association (BEA)
— British Egg Products Association
(BEPA)
— British Free Range Egg Producers
Association (BFREPA)
— National Egg Marketing Association
Ltd (NEMAL)
— National Farmers' Union (England
and Wales) (NFU)
— National Farmers' Union (Scotland)
(NFUS)
— Northern Ireland Poultry Breeders
and Hatcheries Association (NIPBHA)
— Pullet Hatcheries Association (PHA)
— Pullet Rearers' Association (PRA)
— Scottish Egg Producers Retailers
Association (SEPRA)
— Ulster Farmers Union (UFU)
The BEIC is funded exclusively by a voluntary
levy on a number of packers and producer/packers who between them
represent nearly 85% of egg output in the UK. These "Subscribers'
to the BEIC adhere to the "Lion" Code of Practice, and
are authorised to use the "Lion Quality" registered
trademark which is owned by the BEIC.
The BEIC supports high standards of animal welfare.
The "Lion" Code of Practice sets higher standards of
food safety and animal welfare than is currently required by UK
or EU law.
In free range and barn production, the animal
welfare standards reflect those of the RSPCA's Freedom Food scheme.
For all hens kept under the Lion Code of Practice, there are strict
controls on beak tipping, on the handling of hens, and a prohibition
on forced moulting.
25 August 2004
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