Memorandum submitted by the Universities
Federation for Animal Welfare
1. We welcome this Bill which will effectively
modernise much existing animal welfare legislation.
2. Specific comments:
2.1 Section 3(4)(c): "the need to
be able to exhibit normal behaviour patterns". It is not
specified here whether this should be some, most, or all normal
behaviour patterns. We suggest that some guidance would be valuable.
It would not be appropriate for animals to exhibit all normal
behaviour patterns since these include normal behaviours to escape
from predators and other potential harms. Also, although reproductive
behaviour patterns are eminently normal, society accepts that
a proportion of animals should be prevented from performing these
behaviours (eg by spaying, castration, keeping sexes separate,
or by other means).
The Secretary of State's Standards
of Modern Zoo Practice (March 2000) refer to "Provision of
the opportunity to express most normal behaviour" (Section
4, page 14). One possible fix would be, in line with these Secretary
of State's Standards, to refer to "most normal behaviour".
Alternatively the wording could be more specific, eg: "the
need to be able to exhibit those normal behaviour patterns prevention
of which would be likely to lead to harm or distress".
2.2 Sections 13(2), 16(2)(f), 17(1)(c)
and elsewhere: these refer to killing and slaughtering animals.
Slaughtering specifically involves killing by bleeding (and generally
applies to farmed livestock being killed for human consumption).
The reason for the use of the term "killing" in Section
13 but "slaughtering" in Sections 16 and 17 (and subsequently)
is not apparent. This should be made consistent throughout the
Bill (except where some distinction is intended), perhaps by using
"killing or slaughtering" or "humane killing".
2.3 Section 30: Here the term "destruction"
is used. Is a different meaning than killing or slaughtering intended
here? If not, we would advocate one word or expression throughout
for consistency (see above).
3. Typographical error: Section 13(4), first
sentence: vetinary (veterinary.
24 August 2004
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