LORD TREES’ AMENDMENT 87 TO THE AGRICULTURE BILL ELICITS AN IMPORTANT CLARIFICATION FROM THE GOVERNMENT – A WIN FOR BOTH ANIMAL WELFARE AND THE SELF-SUSTAINABILITY OF THE RURAL ECONOMY.
On Thursday 16th July, in response to Lord Trees amendment, Minister’s confirmed that slaughtering would be recognised as one of the key ‘ancillary services’ eligible for public funds. The Amendment was supported by Baronesses, Lady Mallalieu, Lady Jones of Whitchurch and Lady Bakewell of Hardington Mandeville.
This will enable assistance to be given in an appropriate case to a licensed abattoir which, for example, provides a private kill service or enables slaughtering facilities in an area otherwise without adequate provision.
“I am delighted to say that we have had it confirmed that the definition of ancillary activities in Clause 1(5) covers slaughtering under either “preparing” or “processing”
Ministers closing remarks to Amendment 87 of the Agriculture Bill, 16th July 2020
The clarification was all the more welcome as we had reason to suspect that there had been reluctance to enable abattoirs to receive this support.
In the last few weeks VPRF and others had written a letter to the Secretary of State for Environment, Food and Rural Affairs George Eustice and had discussed the issue in detail with Lord Gardiner, the Parliamentary Under Secretary of State for Rural Affairs and Biosecurity.
These conversations and others allowed the government to clarify their position before the committee stage debate. We were very glad that at the last minute the Minister at the Dispatch Box confirmed that “slaughter” would be included in the list of “ancillary activities” eligible for support.
The proposed amendment was supported by evidence from a recent All Part Parliamentary Group (APGAW) inquiry; “The Future for Small Abattoirs in the UK”.
Lord Trees argued that:
“Given the key role that small abattoirs can play in improving animal welfare, enabling local food production and enabling the financial sustainability of livestock farming, while contributing to the wider rural economy and our national food security, I submit that there is a strong case for their eligibility for support, subject to conditions, under this Bill.”
“The amendment is not about subsidising abattoirs. It would merely allow as eligible for assistance certain abattoirs that recognise the higher regulatory standards rightly required for operations that are relatively low throughput and local.”
A selection of messages received:
Megan Perry, Head of Communications, Sustainable Food Trust, 17th July 2020
Gemma Chaters1; Alexander John Trees2, Gabrielle Laing3
1University of Glasgow; 2House of Lords; 3Veterinary Policy Research Foundation House of Lords
Certain dog breeds are increasing in popularity in the UK and there is growing concern for the health and welfare of some of these breeds due to their conformational deformities.
As a surrogate measure of lifetime health and welfare, we compared health insurance premiums for fourteen popular UK dog breeds. Premiums for French and English bulldogs were over four times higher than the lowest premiums. We suggest this is an objective, actuarial indication of the expected higher healthcare costs of these brachycephalic breeds, reflecting in general, their predisposition to ill-health related to their conformation.
There is growing concern from the veterinary profession and related bodies for the health and welfare of certain dog breeds in the UK because of the problems they have due to conformational defects. This concern comes at a time of increasing popularity of these breeds. Over the last ten years, the Kennel club has reported large increases in the registrations of brachycephalic breeds (dogs with less than 80% of their natural head depth) such as the French bulldog (up 3000%), pug (up 193%) and English bulldog (up 96%).
Brachycephalic dogs suffer a variety of clinical problems associated with their conformation including obstructive airway syndrome, gastro-intestinal disease, ataxia and lameness, eye disease, dystocia and spinal disease (1–6). For further references please see the Veterinary Policy Research Foundation fact file on Brachycephaly and other conformational disorders (7). It is of grave concern that a significant proportion of the pet dog population potentially endure avoidable ill-health and pain to satisfy human fashion.
A scoping study we did using market price comparison websites showed that the monthly cost for a cocker spaniel ranged from £8-14, compared to the pug £15-£22 and French Bulldog £28-£47. The policies for each breed were not directly comparable because the policy conditions (excess, limits, length of cover etc.) vary, however, they give an idea of the variations in cost. A further example of between breed price heterogeneity is that the cheapest monthly premium available that will cover vet fees up to £7000 was cheapest for the spaniel (£11) followed by the pug (£20) then the French Bulldog (£40).
For this investigation, to avoid introducing bias by comparing policies with different small-print stipulations, the authors contacted insurance company underwriters directly to get data that are comparable. We compare health insurance premiums between breeds, for identical quotes, hypothecating that these will be a surrogate measure for expected lifetime health and wellbeing, and may objectively highlight the predisposition to ill-health of certain dog breeds.
Three major insurance companies (collectively underwriting for companies that provide the insurance for over 75% of insured dogs in the UK) were requested to quote premiums for the most popular fourteen UK dog breeds (see Table 1) for a policy giving full lifetime cover, with an excess of £100, from each of three ages (fourteen weeks, four years and seven years of age), for a male dog, resident in the north-west UK (LA9 postcode).
A mixture of perceived risk from known health problems and a consideration of the magnitude of historic claims were given, by actuaries, as the basis for the setting of the premium. The companies quoted in units of one, where one was the lowest premium in all breeds and age categories. The data from each company were then combined to give a mean premium for each breed at each life stage (Table 1). Finally, a mean for the three age categories for each breed was derived to give a final ranking of costs (Figure 1).
There was a high level of agreement between the insurance companies for the ranking of breeds within and across each of the three age categories. Table 1 shows the mean relative cost (n= three companies) of the monthly premium for each breed for each age category and the mean across all age categories for each breed. The combined results from all age categories are shown in Figure 1.
Across all age categories the English and French bulldog premiums were over four times more expensive than the cost of the cheapest breeds (chihuahua and shih tzu). The pug and German shepherd were next highest with their premiums around double that of the cheapest breeds. All other breed premiums were, on average 1.7 or less, times higher relative to the cheapest.
Using strictly comparable quotes these results show that the French and English bulldogs, two popular brachycephalic breeds, have substantially higher insurance premiums compared with other popular UK dog breeds. This is an objective, actuarial indication of expected higher lifetime healthcare costs, reflecting the high pre-disposition to ill-health of these breeds. It is consistent with studies comparing the prevalence of ill-health and clinical signs amongst brachycephalic dog breeds (1-6).
The results have not been adjusted for breed size but although the smallest breeds (chihuahua and shih tzu) have the lowest premium costs, the premiums for most larger breeds are less than 50%
higher. This outcome shows that the effects of breed size on premiums are minimal in comparison to the effects of breed specific factors.
In the UK, we have been increasingly owning and breeding brachycephalic dog breeds for human pleasure, which the results of this study show incur higher health insurance premiums when compared to other popular breeds, suggesting a higher likelihood of ill-health and poor welfare.
It is incumbent on all concerned – pet owners, breeders, the veterinary profession – to promote and provide breeds less susceptible to ill health. A number of breeds suffer from ill health attributable to their conformation but prominent amongst these are the brachycephalic breeds. There have been a number of recent measures taken by various bodies which may be yielding positive results, with Kennel Club registrations falling for French bulldogs, bulldogs and pugs in the first half of 2019. Nevertheless, more needs to be done for the sake of animal welfare.
In 2014 the Dutch government introduced legislation prohibiting the breeding of animals “which possess a specific condition or appearance which may affect the health or welfare of the animal or its offspring” (8). Following this, criteria commissioned by the Dutch Ministry of Agriculture were published in 2019 outlining the severe health and welfare issues of brachycephalic dogs and a traffic light breeding system which guides breeders and vets towards creating a healthier dog population (9). In June 2019 it was stated that the Animal law, with regard to breeding brachycephalic dogs with poor health due to severe conformational disorders, would start to be enforced using the traffic light breeding system guidelines.
Similar legislation was introduced in the UK in 2018. It would help were there to be greater awareness of the fact that under the Animal Welfare ( Licensing of Activities Involving Animals) (England) Regulations 2018 – a statutory instrument of the Animal Welfare Act 2006 – Schedule 6 states that “No dog may be kept for breeding if it can reasonably be expected, on the basis of its genotype, phenotype, or state of health that breeding from it could have detrimental effect on its health or welfare or the health and welfare of its offspring”. This legislation is yet to be enforced in the UK and a test case would attract greater awareness to the issue.
It is important to note that neither of these pieces of legislation above refer to a specific breed and they allow for a variation in conformation within breed.
We gratefully acknowledge the cooperation of the following insurance companies: Agria Pet Insurance, Petplan and RSA UK. GC undertook this project as part of a work placement at the House of Lords funded by a BBSRC studentship at The University of Glasgow.
1. O’Neill DG, O’Sullivan AM, Manson EA, Church DB, Boag AK, McGreevy PD, et al. Canine dystocia in 50 UK first-opinion emergency care veterinary practices: prevalence and risk factors. Vet Rec. 2017 Jul 22;181(4):88.
2. O’Neill DG, Jackson C, Guy JH, Church DB, McGreevy PD, Thomson PC, et al. Epidemiological associations between brachycephaly and upper respiratory tract disorders in dogs attending veterinary practices in England. Canine Genet Epidemiol. 2015 Dec 14;2(1):10.
3. Packer RMA, Hendricks A, Tivers MS, Burn CC. Impact of Facial Conformation on Canine Health: Brachycephalic Obstructive Airway Syndrome. Ambrósio CE, editor. PLoS One. 2015 Oct 28;10(10):e0137496.
4. Kaye BM, Rutherford L, Perridge DJ, Ter Haar G. Relationship between brachycephalic airway syndrome and gastrointestinal signs in three breeds of dog. J Small Anim Pract. 2018 Nov 1;59(11):670–3.
5. Rohdin C, Jäderlund KH, Ljungvall I, Lindblad-Toh K, Häggström J. High prevalence of gait abnormalities in pugs. Vet Rec. 2018 Feb 10;182(6):167.
6. Liu N-C, Adams VJ, Kalmar L, Ladlow JF, Sargan DR. Whole-Body Barometric Plethysmography Characterizes Upper Airway Obstruction in 3 Brachycephalic Breeds of Dogs. J Vet Intern Med. 2016 May;30(3):853–65.
7. Veterinary Policy Research Foundation. VPRF Fact File – Brachycephaly & other conformational disorders [Internet]. 2019 [cited 2019 Nov 28]. Available from: http://www.vetpolicy.org
He took the opportunity to ask the Minister for further clarity on the rights of non-UK EU vets to continue to work in the UK post Brexit, he emphasised the role of vets in underpinning trade, sought assurances that animal welfare standards would not slip as a consequence of setting up new trading relationships and also spoke on the need to transpose medicines regulations into UK law to ensure that current and future medicines required for animal health are available. More generally he also asked the Minister if the Government have considered how financial inducements might be used to help to maintain animal welfare standards (e.g. during reform of farming subsidy payments) and to ensure that the EU Withdrawal Bill includes General Principles of EU law such as the Lisbon Treaty (Article 13) which requires the sentience of animals to be recognised in making and interpreting current and future laws.
Defra Minister, Lord Gardiner’s reply stated:
“In government we absolutely recognise the key role played by vets in ensuring high animal welfare and health standards. Indeed, the Prime Minister specifically made it clear that securing the status of the veterinary workforce is a top priority. It has been my privilege to meet many EU nationals who serve in our veterinary profession and I can say how important they are to us.”
He mentioned welfare standards several times, re-iterating the Government’s position that the UK’s current standards of animal welfare will be maintained post Brexit. He also stated that the Government plans “to replicate broadly the EU’s current schedule of WTO commitments” in its future trade agreements allowing tariffs to be maintained at current level but acknowledging that decreases in tariffs can adversely impact farmers, consumers and the food industry.
In response to concerns about the negative impact of cuts in Defra funding and reduction in the Defra workforce he stated that Defra have recruited 450 additional staff, comprising policy generalists and specialists to support their comprehensive exit programme. More than 350 have already taken up posts, with the remainder currently progressing through the pre-appointment processes.
He confirmed The Secretary of State (Michael Gove’s) recent announcement that the Government intends to publish draft legislation for consultation “around the turn of the year” to increase the maximum sentence for animal cruelty offences from six months to five years in prison.
He also referred to the Government’s manifesto commitment to “take early steps to control the export of live farm animals for slaughter” as we leave the EU as well as to require CCTV in every slaughterhouse in England.
A proposed change to the levy funding structure could have major implications for the future of equine veterinary research and education. The horseracing industry is heavily dependent on a levy collected from bookmakers but in recent years there has been a decline in levy funding associated with rapid increases in online and overseas gambling that are not subject to the levy. In response the Government have announced plans to modify the levy in order to widen the source of funding and ensure the sustainability of the racing industry (worth £3.5 billion to the UK economy) but there are concerns that the way the levy is modified could dramatically reduce the funding available for veterinary research and for the provision of specialist veterinary training programs.
The Horserace Betting and Levy Board (HBLB) currently collect and administer the funds that amount to approximately £70 million per year. Whilst the majority of this funding is used for the improvement of horseracing (primarily through its allocation as prize money) the levy also provides vitally important funding for equine veterinary research and education (approx. £1.8 million per year) and also for the preservation of rare-breeds of horses (approx. £115,000 per year). Several groups including the HBLB Veterinary Advisory Committee, the British Equine Veterinary Association and the British Horseracing Association have expressed concerns that these relatively small but highly significant forms of funding may not be fully recognized during the proposed modification of the levy funding structure.
Lord Trees took the opportunity of the debate last night to speak in support of the vital role that HBLB funding has played in improving the health and welfare of horses in the UK. A transcript of the debate is available here.
Lord Trees asked the minister representing the Government for reassurance that the level of funding for equine research and education would be maintained and that it would be administered by an independent organisation. We were disappointed that the minister did not give us the full reassurance we requested however it is likely that the Government will take the concerns raised into account particularly as the Lord Trees’ views were shared by several other Peers in the debate. We will continue to seek every opportunity to press the government on this important issue in order to ensure that the importance of maintaining the health and welfare of the horses is fully recognized by the new levy system that is expected to commence in April 2017.
EU regulation 1099/2009 on protection of animals at time of killing came into effect in 2013. The purpose of the regulation is to enhance protection of animals at the time of slaughter by establishing standard operating procedures to reduce pain and suffering of animals, improve training of personnel through the introduction of certificates of competence and regulate the use of equipment (including the use of stunning equipment). Annex I of the regulations include specific requirements for the stunning prior to slaughter based on a scientific review performed by the European Food Safety Authority.
For many slaughter houses in the UK, compliance with the EU regulations requires an increase in the currents used for electrical stunning of poultry in a water-bath. The parameters were set in an attempt to ensure that stunning is effective following evidence that at low currents birds are likely to remain conscious despite appearing to be stunned. However, there have been objections from the Islamic community that the higher currents are more likely to kill birds rather than stun them and prevent meat from being classed as Halal. There have also been objections from meat producers that the higher currents are likely to cause damage to meat.
The Welfare of Animals at Time of Killing (WATOK) regulations implement the EU Regulations in the UK. WATOK regulations were due to come into effect in England in May 2014 but were withdrawn at the last minute due to concerns over the impact of the regulations on religious slaughter. The legal requirement for EU recommended stunning methods to be followed for stunning prior to religious slaughter was removed and the new WATOK regulations came into effect on 5th November 2015. This contrasts with Wales and Northern Ireland where WATOK regulations do specify that the EU recommended stunning parameters must followed when stunning prior to religious slaughter.
The introduction of the English WATOK regulations were met with concern from the BVA over English poultry failing to be effectively stunned under the new regulations. This was reported on in the Veterinary Record and the Times newspaper.
We regard stunning as an essential means by which to reduce pain and suffering of animals at slaughter and would support efforts to ensure that stunning is carried out in all cases and is performed using means that are proven to be effective in safeguarding animal welfare. Almost a billion animals are slaughtered for food each year in the UK and we have a moral obligation to ensure that this process affords each animal the highest possible standards of welfare.
Animal welfare legislation: Does it work and is it effective?
On Tuesday, the Associate Parliamentary Group for Animal Welfare met to discuss ‘Enforcement of Animal Welfare Legislation’. The very packed room listened to a Metropolitan Police Status Dogs unit Officer, an RSPCA Chief Inspector and an Environmental Health Officer (EHO) share their alarmingly similar views on the subject.
Inspector O’Hara, for the Metropolitan Police Status Dogs unit, highlighted that he and his colleagues receive enhanced training when compared to most police forces. Whilst the police had historically relied on the RSPCA to lead on animal welfare law, he said ‘the sands are shifting’ and this was no longer the case. Elaborating further, he outlined several cases of interest and clarified that his unit have a good re-homing policy, with 118 dogs re-homed this year, where sensible and possible to their original home.
Mark Berry, a Local Authority EHO and member of the Companion Animal Welfare Forum, outlined the structure of service at his Local Authority, Stockton on Tees. He stipulated that his Local Authority (LA) provide a greater service than most LAs and are lucky to operate as a unitary body, rather than being spread across several departments. Mr Berry told us that statutory provision only covers stray dogs and animal licensing covering boarding, pet shops and breeding. Stockton on Tees also offer non-statutory services relating to dog-fouling, non-canine strays, unwanted animal handover, animal welfare issues including cruelty, abandonment, offences, nuisance complaints for all species, dangerous dogs, attacks on people/animals, microchipping, neutering and the promotion of responsible pet ownership. He re-iterated that many councils will only perform the first two statutory duties, yet the demand across the services in his LA is going up year on year since 2008. He believed that lack of suitably trained/qualified staff, facilities and resources, and the cost of instigating prosecutions were equally important factors behind the lack of effective animal welfare enforcement.
Dermot Murphy, for the RSPCA, stated that the three big costs for the charity and its finite resources were examination by a vet, boarding kennel fees and the cost of engaging a solicitor. He agreed with the previous two speakers that the enforcement across the country was patchwork and varied considerably from once LA and police force to another. Consequently, he felt there were currently substantial gaps in animal welfare enforcement.
In summary, all of the speakers felt that animal welfare enforcement could be improved if there were better guidance on precisely who is responsible for enforcement of the various different services outlined by Mr Berry. Furthermore, the provision of adequate resources, funding and experienced staff are key – none of which are likely to be a priority whilst the bulk of animal welfare services remain non-statutory. The question, posed by the RSPCA, of who ‘owns’ the Animal Welfare Act remains unanswered and until it is we will likely struggle on with the current patchwork cover.
Tuesday 4th November saw two interesting debates in Westminster Hall. In the morning Neil Parish MP moved a debate on Animal Slaughter (Religious Methods), and in the afternoon Chris Williamson MP moved a debate on Badger Culls (Assessment). I will focus on the animal slaughter side of things in this post.
Animal Slaughter (Religious Methods)
The animal slaughter debate was called following the publication of the APPG for Beef and Lamb’s inquiry into the welfare of animals slaughtered in accordance with religious rites. This report identified several areas in need of further research. During the course of the debate a number of matters were discussed, including the role of exporters subject to various conditions on slaughter, the use of CCTV in slaughterhouses, the effect of animal stress on meat quality, the labelling of meat (stunned vs non-stunned) and a call to accurately record all mis-stuns and mis-cuts. A lot of well-trodden ground was once again re-covered during this debate and ultimately it boils down to the question: Does the right to freedom of religious expression outweigh animal welfare considerations?
During his response, George Eustice MP, Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs said:
“Our position is that we would prefer that all animals are stunned before slaughter, but we recognise and respect the needs of religious communities, so we have always maintained this limited exemption, which is to be used only for meat produced for Jewish and Muslim communities. Last year, the Prime Minister made it very clear in a speech that the Government have no intention of abolishing religious slaughter in this country. However, it is equally important to note that none of the derogations that we have in place, which are set out through the Welfare of Animals (Slaughter or Killing) Regulations 1995, exempt anyone from the requirements of the Animal Welfare Act 2006, which requires all abattoirs to avoid causing an animal avoidable pain.”
“It is not that we believe that there is no difference between the two types of slaughter, nor that we believe shechita is a more welfare-friendly method of slaughter, but because we respect the rights of religious communities. That has been the long-standing position of every UK Government, going back some 100 years.”
– HOC Hansard, 4th Nov 2014, Column 168WH.
The Minister’s round up also included (another) new date for the publication of the European Commission report on labelling – now expected to conclude in December 2014.
Mis-stunning and mis-cutting
He briefly covered the issue of mis-stunning and -cutting. Historically, the Food Standards Agency only reported incidents observed by official veterinarians in the slaughterhouse. Following review, the FSA intends to monitor and record all incidents. He reiterated the point that a mis-stunning event does not always mean the welfare outcome for a particular animal will be dire as a second, back-up stun can be applied within seconds.
CCTV in slaughterhouses
Last, but not least, the subject of CCTV in slaughterhouses is an issue. The Minister clarified that the Farm Animal Welfare Committee is reviewing it as an option. The issue remains as to exactly who would monitor the CCTV footage were it made compulsory in slaughterhouses. Several supermarkets already demand that CCTV is taken in their slaughterhouses as a matter of course – perhaps the success/failure of this intervention could be investigated.
The British Veterinary Association hosted an afternoon tea briefing for parliamentarians on Tuesday 4th November at the Houses of Parliament. The briefing, hosted by honorary associate of the BVA – Angela Smith MP, was well attended and a number of MPs and Peers came along to pick up the BVA Briefing packs and chat to BVA Officers and staff of the BVA.
The popularity of this event is reflected in the high levels of attendance. Animal health and welfare are both important subjects for the British public. If you are interested in any of the BVA briefs please contact them directly or visit the BVA website.
· MPs who attended: David Amess, Sir Roger Gale, Barry Gardiner, Simon Hart, Julie Hilling, Anne McIntosh, Andrew Miller, Neil Parish, Andrew Rosindell, Andrew Stephenson, Bill Wiggin, Roger Williams, plus Anne Marie Adams (Laurence Robertson’s researcher).
· Peers who attended: Lord Boswell, Lord Curry, Lord Higgins, Lord Trees (and Hannah Jordan – Parliamentary Veterinary Intern), Lord Wigley.
Declaration of interest: This authors of this document declare they would wish to see all animals stunned before slaughter.
Statement of intention: This document is intended for the public, politicians and professionals and aims to present an unbiased, factual and up-to-date account of the current information available on non-stun slaughter.
Please download a copy of the latest VPRF Animal Welfare and Non-Stun Slaughter Factfile using the link below:
Record of Edits July 2014 – Initial document published
November 2015 – Updated to include new legislation (WATOK (England) 2015) and new estimates for numbers of animals slaughtered using stun and non-stun methods.
June 2016 – Further updates to include reference to result of EU referendum.
October 2016 – Update to include results of a survey of UK Islamic scholars on perception and acceptability of stunning
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