Compassion in World Farming (CIWF) is extremely encouraged that the Agri Food 2010 Committee recognises that farm animal welfare is becoming increasingly important and recommends that Ireland must achieve and maintain the highest standards of farm animal welfare. However, CIWF disagrees with some of the statements made in the Agri Food 2010 Report. We would like to make the following observations which we hope the Minister will consider before giving his view on the report's recommendations.

15.4 ACHIEVING THE HIGHEST STANDARDS OF ANIMAL WELFARE

"Current standards of animal welfare in this country are generally high, and will improve further with the elimination of sow tethering and battery cages" [AF2010 15.4].

CIWF absolutely rejects this statement. The following points highlight the fact that farm animal welfare standards in the Republic of Ireland are not generally high in the case of pigs and poultry and indeed, in relation to the export of live farm animals, are not even compliant with minimal EU legislation.

Although sow tethering is currently being phased-out in the Republic of Ireland, the equally inhumane practice of confining pregnant sows in stalls remains perfectly legal. In both systems, the sows have so little space that they cannot even turn around, thus they are denied a basic need to exercise. It is generally accepted that confinement in stalls has detrimental effects on the welfare of sows both from the point of view of their physical health and also their behavioural and psychological well-being.

Indeed, a major report on Welfare of Intensively Kept Pigs produced in 1997 by the European Commission’s Scientific Veterinary Committee (SVC) concluded that "no individual pen should be used which does not allow the sow to turn around easily". The SVC also stressed that "sows should preferably be kept in groups" because "overall welfare appears to be better when sows are not confined throughout gestation". In the light of the SVC’s conclusions, CIWF believes that the EU should prohibit sow stalls and require sows to either be kept free-range or group housed indoors on straw or an alternative manipulable bedding. We therefore urge Minister Walsh to push for an EU-wide phase-out of sow stalls.

Broiler chickens

Each year, a huge number of broiler chickens suffer from painful, sometimes crippling, leg disorders. Due to selective breeding most broiler chickens now reach slaughter weight at just 6-7 weeks old. By this stage, their muscle has grown very quickly but the development of the birds' skeletons has not kept pace. Therefore, the legs have to support a great weight.

Indeed, a new report on broiler chickens by the European Commission's Scientific Committee on Animal Health and Animal Welfare (SCAHAW) states that the painful leg disorders "are a major cause of poor welfare in broilers". The SCAHAW makes it clear that the intensive broiler chicken industry's drive to ever faster growth rates leads to painful leg disorders, ascites and sudden-death-syndrome in the birds reared for their meat and severe food restriction and hunger in the breeding flock. The report also makes it clear that many broilers are kept in extremely overcrowded conditions.

Although this method of rearing poultry is perfectly legal, it could not by any means be described as a system where welfare potential is good. CIWF urges the Minister to push for proposals on a Directive for broiler chickens to address the serious health and welfare problems identified by the SCAHAW.

In recent times, it has become evident that the competent authorities in the Republic of Ireland are failing to enforce the EU legislation on the welfare of farm animals during transport. A recent European Commission investigation has shown that the Republic of Ireland is not properly enforcing EU legislation on the transport of live animals. The Commission veterinary mission to the Republic of Ireland found that a considerable number of road vehicles used for carrying livestock within Ireland were "either inadequate or completely unsuitable to a great extent". The Commission report also states that livestock markets were "not of the required standard" and route plans (for animals transported from the Republic of Ireland) were "often incomplete or incorrect".

We have shown that farm animal welfare standards in this country are below those required by EU legislation. CIWF therefore urges the Minister to immediately address the lack of enforcement of legislation designed to protect the welfare of animals.

However, even if the legislation was properly enforced, CIWF believes that long distance transport is in itself stressful for farm animals and should be avoided. Indeed, many well-respected bodies have echoed this approach. The European Commission’s Scientific Veterinary Committee has stressed that "live transport should be avoided whenever possible". They concluded that "the occurrence of poor welfare can be reduced considerably by slaughtering near the point of rearing and transporting meat".

As long ago as 1968 the Explanatory Memorandum to the European Convention on the protection of animals during international transport emphasised that "the ideal would be to restrict international traffic to carcass meat". More recently, a Recital to the EU Transport Directive has stated that "for reasons of animal welfare the transport over long distances of animals, including animals for slaughter, should be reduced as far as possible".

In line with the above, Compassion in World Farming urges the Minister to end the continuing animal welfare problems of the live export trade by replacing it with an export trade in meat.

 "The Committee recommends the establishment of an advisory forum which would bring greater focus to the issue of the welfare of farm animals" [AF2010 15.4].

CIWF would welcome the setting up of a forum which deals specifically with farm animal welfare (i.e. other animal welfare issues such as vivisection or hunting would be better handled by a separate forum), provided that there is fair representation of all interests involved, especially farm animal welfare interests, and provided that CIWF is given full representation on the forum.

We believe that CIWF must be represented on this forum as we are the only NGO in Ireland dealing solely with farm animal welfare. Furthermore, CIWF was the only animal welfare organisation to send a submission to the Agri Food 2010 Committee. We therefore believe that it is essential that CIWF is fully represented on any such advisory forum along with other animal welfare groups.

CIWF would also point out that animal welfare must be a separate grouping (i.e. not grouped along with consumer interests as the AF2010 report suggests) and that representation and decision-making powers must be equally distributed between all interests. CIWF wishes to be kept informed of any developments in this area and we are happy to comment on any draft proposals concerning the setting-up of such a forum.

"Ireland should be to the forefront of food safety and consumer protection, and should seek to be a model for other Member States" [AF2010 15.1]. "Preserving Ireland's reputation as a quality food producer is essential for the future of the agri-food sector" [AF2010 15.2].

In CIWF's view, high standards of farm animal welfare are inextricably linked with the production of safe, healthy and high-quality food. We believe that farming systems where animals can move around and have a relatively natural existence are more suited to the production of healthy, safe and high-quality food than intensive farming where animals are all too often kept in unnatural, overcrowded conditions and may be fed an unnatural diet.

In addition, CIWF believes that the intensive industry's over-reliance on the use of antibiotics poses a potentially serious threat to human health. In CIWF's view, it is no longer acceptable for the farming industry to risk the health of its customers, and cause suffering to the animals in its care, by rearing them in overcrowded and dirty conditions, and by administering to them artificial substances to encourage faster growth rates. We call on Minister Walsh to advocate that Irish farming moves away from intensive animal farming and instead focuses on farming systems where animals are reared in more humane (and healthy) conditions.

"Clear, honest labelling must be the norm in order to inform consumer purchasing decisions" [AF2010 15.1].

CIWF agrees that all food must be clearly and honestly labelled. For instance, eggs produced in systems where the hens are caged should be labelled 'Eggs From Caged Hens'. Many consumers mistakenly believe that eggs labelled 'Farm Fresh' or 'Country Fresh' are free-range eggs, whereas in reality most are intensively-produced. CIWF encourages the Minister to push for a review of the EU's Special Marketing Terms for eggs so that this issue is addressed.

We would point out that the labelling of intensively-produced animal products is not in itself a solution to the animal welfare problems of intensive farming. CIWF believes that intensive animal farming systems are not only damaging to animal welfare, but also to human health and the environment, and that ultimately intensive systems must be replaced with more welfare-friendly food production systems. Until then, we believe that there is an urgent need to incorporate process and production methods on food labels in the EU so that consumers are aware of how their food is produced.

CIWF would point out that good standards of animal health are best achieved by promoting the highest standards of farm animal welfare. For instance, a recent Teagasc paper on the behaviour of loose-housed sows states that a UK trial found that sows in groups were found to have "better muscular and bone development and improved cardiovascular fitness". The report goes on to say that "being more physically fit, group housed sows are likely to be more agile in the farrowing crate, with possible benefits to piglet mortality, and feeding behaviour. They may also have a longer productive life" [Behaviour of loose-housed sows; L Boyle and A Tergny, Teagasc, Moorepark]. CIWF would point out that we do not agree with the use of the farrowing crate. However, we assume that Teagasc's statement would apply equally to more humane systems of farrowing.

The European Commission is now due to review legislation on the welfare of breeding sows and also the special marketing terms for egg labelling. As sow tethering is currently being phased-out in the EU on animal welfare grounds, it is likely that the Commission will decide that the equally inhumane practice of confining pregnant sows in sow stalls should also be phased-out.

It is also possible that the European Commission will agree to put an end to the misleading labelling of battery eggs (i.e. battery eggs labelled as 'Farm Fresh' or 'Country all too often fool consumers into believing that they are purchasing free-range eggs) when the Special Marketing Terms for egg labelling come up for review. These, and other legislative developments (such as the EU's decision to phase-out battery cage egg production by 2012), could pose either a challenge or an opportunity to Irish farmers.

As consumers take an increasing interest in farm animal welfare issues, it is likely that those involved in the production and marketing of pigmeat and poultry products will have to adapt their products to meet consumer demand. This may mean, as the Committee suggests, that "in order to retain market share, it is likely that it will be necessary to apply [animal welfare] standards well above those provided for in legislation" [AF2010 15.4]. CIWF urges the Minister to ensure that improvements in EU animal welfare legislation in the pig and poultry sector are perceived by the farming community as opportunities rather than challenges. This can be done by providing financial aid and expert advice to enable Irish farmers to switch from intensive animal husbandry to more animal welfare-friendly systems.

CIWF notes that the Committee recommends the development of a 'Code of Good Farming Practice' to encourage environmental protection. CIWF would point out that UK scientists now believe that agricultural pollution, particularly from intensive farms, is as great a threat to air quality as emissions from power plants and factories (The Observer 25.07.99). In intensive animal farms, the animals are kept at a high stocking density, sending up pillars of warm air that can carry chemicals such as ammonia high into the air and into the surrounding area. These chemicals can form oxides in the atmosphere which then fall as acid rain. CIWF believes that intensive animal farming is potentially harmful to our natural environment. Indeed, CIWF would question whether a 'code of good farming practice' should be applicable to intensive farms where animals are not farmed in an animal welfare-friendly way.

The genetic engineering and the cloning of farm animals have so far proved to be disastrous in terms of animal welfare. Furthermore, CIWF questions whether Irish consumers would be happy to see milk and meat from genetically modified animals on the supermarket shelves. CIWF urges the Minister to prohibit farm animal genetic engineering and cloning on animal welfare and ethical grounds.

CIWF urges the Minister to put all Republic of Ireland legislation and other official documents relating to farm animal welfare on the Department's website.

CONCLUSION

CIWF is encouraged that that Committee has said that Ireland must achieve and maintain the highest standards of farm animal welfare. Furthermore, we are encouraged that the Committee recognises that "in order to retain market share, it is likely that it will be necessary to apply [animal welfare] standards well above those provided for in legislation".

The AF2010 Committee Report suggests a strategy for the development of Irish agriculture and food over the next 10 years. The task now at hand is for the Minister for Agriculture, Food & Rural Development to find ways of implementing this strategy - to decide how the Republic of Ireland can first of all achieve and then maintain the highest standards of farm animal welfare (our emphasis). CIWF would suggest that this can be achieved by:

Setting up a Farm Animal Welfare Advisory Forum with fair and equal representation and including CIWF and other animal welfare groups as full representatives

Pushing for an urgent EU-wide phase-out of sow stalls

Replacing the export trade in live farm animals with a trade in meat

Securing EU-wide agreement on the need for the highest standards of farm animal welfare during breeding, rearing, transport and slaughter of all farm animals

Securing an animal welfare-friendly reform of the WTO rules so that if cruel farming practices are banned in the EU on animal welfare grounds, the EU can prohibit the import of products produced in this way elsewhere

Pushing for an EU-wide ban on the genetic engineering and cloning of farm animals.

Compassion in World Farming has now been actively promoting high standards of farm animal welfare in the Republic of Ireland for almost 10 years. In this time, we have put farm animal welfare firmly on the political agenda in this country and have greatly raised awareness of farm animal welfare issues amongst the general public. As Irish farming moves into a new millennium and faces the challenges and opportunities ahead we believe that it is time that the Minister for Agriculture, Food & Rural Development met with representatives of Compassion in World Farming to discuss how Irish farming can be encouraged to take an animal welfare-friendly path forward.

We would welcome the Minister's response to this request for a meeting and to other issues we have raised in this submission.

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