Memorandum submitted by Vegetarian Economy
and Green Agriculture (VEGA)
1. DEFINITIONS
(PAGE 9 ET
SEQ AND
PAGE 36)
1.1 Animal: The definition should be
amplified to accommodate scientific and lay understanding; advances
in the appreciation of sentience and animal behaviour should be
accommodated—there seems to be no logical reason to exclude
invertebrates—or to imply such omissions as shellfish (crustaceans,
molluscs, etc), snakes, lizards, and insects. Further, certain
species may suffer from unnecessary sub-division on the basis
of purpose in human use rather than zoology: thus, a horse may
qualify as a companion animal or a food animal and a rat as a
pet, a subject for experimentation, or a pest. The animal's welfare
should be rated in the best level achieved for that and similar
species. These considerations would apply to methods of killing,
slaughtering, and culling, and would require consistency with
procedures covered by the Home Office for scientific procedures,
housing, feeding, and general care and respect.
1.2 Pain: Definition of cruelty is also
blurred in the amount of suffering, pain, distress, and inanition
is considered "reasonable and humane" when animal welfare
clashes with the needs, convenience, and pleasure of the human
species. How can it be reasoned that a humane arbiter can be an
accomplice through his or her routine choice of purchases and
consumption in the very practices animal welfarists expose and
condemn and the proposed Bill attempts to oust?
1.3 Status (cf Page 37, paragraph 2):
These observations also emphasize the varying respect paid to
native, endangered, wild, domesticated and free-living commensals.
In crowded islands with a dominant human influence these definitions
are blurred, especially as some animals, being escapees from collections
of introduced species and from human farming activities and laboratories,
are adapting and mingling successfully with domesticated livestock.
The Bill must assert a strong intervention in matters of hunting,
shooting, angling, commercial fishing (an intensified relic of
hunting for food), trapping, hare-coursing, snaring, and ferreting.
Anomalies such as the different attitudes to foxes and badgers
must be informed by equal rights to humane treatment.
1.4 The Fetus (Page 36, paragraph
54): As in the human element regard for the fetus and embryo (and
larval stages) will develop as more is known of the physiology
of pain and the influence in the long term of intra-uterine stresses.
The same deference and exercise of respect should be granted to
animals. The precautionary principles should apply. Collection
of pharmaceutical products and practice of genetic manipulations
(such as cloning and embryo transfer) must be controlled on the
basis of the precautionary principle or of prohibition when doubt
of cruelty increases to certainty. Conditions in parent breeding
stock in poultry, especially in systems involved in the production
of vaccines (ie fertilized eggs) and antibodies must be allocated
to the clear control of the Home Office or DEFRA. Fetal calf serum
may be produced in this country when BSE restrictions are lifted.
In this process and occasionally in the slaughter of pregnant
cows the calf may be born live by surgery on the cows but die
by drowning. In another example of the unacceptable means of using
fetal material the skins and wool of unborn lambs are used in
the clothing industry—but not at the moment in the UK, as
far as we know. Research and "pharming" for stem cells
and the production of knock-out and knock-in animals and genetic
mutants is increasing these dilemmas.
2. OBJECTIVES
2.1 As a guiding principle (eg to the information
on page 11 of the draft) the FAWC's five Freedoms should be rehearsed
as an objective.
2.2 Docking of tails and other mutilations
must be controlled on a case-by-case consideration of systems
and conditions that bring these issues to the fore (compare circumcision
of males and infibulation in the female case). We cite examples
of interventions that must be considered in drafting the Bill.
2.3 Disbudding and dehorning of cattle.
2.4 Removal of supernumerary teats, dew
claws and other appendages in farm animals, horses, and pets.
Clipping of teeth (eg in piglets) is a form of dental interference
rated to benefit the animals' welfare.
2.5 Beak trimming in poultry and game (eg
pheasants, in which bitting may be also be applied, as well as
other devices).
2.6 Velvet from Antlers: This practice should
stay banned. As with products derived elsewhere from practices
outlawed in the UK, the writ of British and European law should
run to a ban on imports of such objectionable commodities and
substances (cf furs, ivory, and products from whaling).
3. TRAINING AND
LICENSING
3.1 The draft Bill must be strengthened
to ensure that purchasers, owners, keepers, handlers, carers,
and slaughterers and knackers possess evidence of training and
licensing that is reviewed and renewed at stated intervals, and
comprises certificates of general competence in the behaviour
of animals, as well as specialized categories for certain species
or jobs. Hauliers must have similar training and licensing. Loss
of licence in one category may entail ineligibility to hold certification
in any category.
3.2 Changes in the veterinary profession
and its responsibilities are resulting in increasing devolution
of technical jobs on to farmers and various contractors. Visits
by vets to farms on any pretext are useful checks on the animals'
condition and welfare. The contractors must show evidence of general
competence and of supervision by a responsible vet. The profession
is becoming less attractive in large animal practice, so many
vets will have gained little experience in this category; nonetheless,
at times of emergency, such as BSE and FMD and other epidemics
of disease in food-producing livestock and their commensals, a
"territorial army" of suitably licensed and trained
retired vets and practitioners dealing normally with pets and
horses and in other services must be maintained. (It be may added
that the training of vets in animal welfare and behaviour leaves
much to be desired, especially in those brought in from other
countries primarily to supervise hygiene in slaughterhouses. It
should also be a requirement that "citizenship" modules
in school curricula should include elements on the behaviour,
care, use and welfare of animals.)
3.3 As proof of their responsibilities all
owners and keepers of animals must provide evidence of adequate
veterinary treatment in the event of illness and injury and of
indemnification for "third parties" affected by such
eventualities. The Government is at the moment relying heavily
on charities to render these and other services. These arrangements
need more consideration and devolve more responsibility on owners
and they should enlist the reinforcement of policing by the insurance
industry. Further, the consequences of bad husbandry, such as
BSE, FMD, swine fever, and other bacterial and viral scourges
and zoonoses, would be met by the industry and its customers rather
than by belated feather-bedding subsidies that conceal severe
violations of the elements of animal welfare and good husbandry.
3.4 Owners of all premises housing more
than, say, five animals must be subject to a provision to allow
the local authority access by, say, a couple of independent observers
for whom it shall be responsible. This "neighbourhood watch"
would be in excess of official visits. The observers could apply
for the council's permission or could be invited by the council;
they could be local citizens or chosen for a special interest
or instruction. This would continue local interest and responsibility
in the planning and building of commercial buildings, sanctuaries
and laboratories etc. Local authorities must also be provided
at least with details, such as those collated by the MHS and charitable
organizations and other official bodies, on the records of disease,
culling, natal and perinatal morbidity and mortality, and mortality
during a complete spell of production. This information should
include data on the usage of drugs and analyses if effluents (the
MHS is charged with welfare matters and could provide Welfare
Assessment Scores as it does HAS's).
3.5 Breeder units call for specific attention
in the Bill. This would include farms, zoos, and laboratories
dealing with the collection and sexing of semen and embryos, in
which painful procedures are involved, eg electroejaculation.
3.6 Animal welfare considerations must reinforce
present penalties for littering and dumping in towns and the country.
Abandoned car batteries, plastic in many forms, broken glass,
and old tyres are both environmentally objectionable and also
harmful to animals. Penalties should take account of this. "Bringing
country to town" is well-meaning but sometimes an ill-advised
initiative that may mislead councillors, for it leaves animals,
some hardly typical, unable to defend themselves against worrying
harassment, and vandalism. Absence of 24/7 care and protection
would be a punishable offence.
3.7 (Page 9, paragraph 1): Abandonment of
an animal found in distress or as a victim of accident or crime
must count as an offence. Report to the police should be made,
who can then take appropriate action. In killing a casualty animal
humane considerations must take preference over commercial factors,
eg by administration of drugs rather than by delayed (and possibly
inept) stunning, sticking, and bleeding out in the interests of
catching the best market for meat and avoiding land-fill and rendering
costs. Police marksmen and other shooters must be trained and
licensed appropriately, augmenting the existing laws on the possession
and use of firearms.
3.8 The veterinarian's avowed mission to
"do his utmost for the well-being of the animals in his care"
must not be compromised in efforts at relieving suffering that
may conflict with the run of the market for food animals (eg restrictions
and withdrawal periods in recourse to proven therapeutic drugs)
and in the method of slaughter. Expert evidence and advice furnished
by the Farm Animal Welfare Council may be adduced in support of
such decisions.
24 August 2004
|
