Viva!’s Submission to the Government’s Consultation
on Welfare at Slaughter
When, in April 2004, the
Government responded to the 2003 Farm Animal Welfare Report
on welfare at slaughter, it invited comments from bodies and organisations
an interest in the issue. In theory, it could change the policy
it announced as a result
of the consultation process, although in practice this is rare.
Viva! submitted the following document to the Government as part
of the consultation
For more information about the Farm Animal Welfare Council and to download
a copy of their report, The Welfare of Farmed Animals at Slaughter or Killing.
Part One: Red Meat Animals, see their website, www.fawc.org.uk
To see the Government’s “draft response” – which
our submission comments on - see http://www.defra.gov.uk/corporate/consult/fawc-slaughter/index.htm
Viva!’s area of concern and expertise in relation to this consultation
is that of farmed animal welfare. Our fundamental belief is that
the farming of animals for food is morally unacceptable, carries substantial
risks for human beings and represents a catastrophically inefficient
and destructive use of land and resources. Viva! opposes all animal slaughter. We recognise, however, that these objections will not be considered relevant
to the current consultation and will thus confine our comments to the welfare
implications of the Government’s response to the FAWC report.
Viva! welcomes the Government’s acceptance of many of the Council’s
recommendations. In this document we shall comment only on the Government
responses we consider to be unsatisfactory and conclude by examining the
wider context in which these questions arise.
Recommendation 33: electric goads
The use of electric goads is indefensible in all circumstances: a system
which requires the direct infliction of pain to function is unacceptable.
Furthermore, good design and practice should obviate any “need” for
the use of goads. A ban will force abattoirs to improve handling standards
overall. Viva! supports the proposed EU ban.
Recommendation 46: approval of equipment
The provision of effective, suitable equipment is essential for animal
welfare. If the Government is unable to introduce a mandatory system, it
must ensure that there is a centrally-maintained, regularly-updated register
or list of approved equipment, including exact specifications for its use.
Use of approved equipment should be considered in granting and renewal
of licences to slaughterhouses.
Recommendation 52: aversive gases
Evidence suggests that argon or high argon/low CO2 mixtures are effective
in inducing unconsciousness with minimal distress and could provide a solution
to a number of problems relating to handling and stunning in slaughterhouses.
The evidence that CO2 and high CO2 mixtures are aversive, however, is compelling.
The use of aversive gases is morally unacceptable and the Government must
make active provision to end their use. Commercial questions such as throughput,
cost and capital expenditure must not be permitted to override animal welfare.
Viva! believes that the use of aversive gases in fact violates the WASK
requirement that no “avoidable” pain, excitement or distress
should be caused to animals. The Government must commit itself to banning
the use of aversive gases.
Recommendation 53: effectiveness of stun
Although the Government have accepted the recommendation that OVSs should
monitor tong placement and effectiveness of stun, it does not appear from
the draft response that they see a need for any increase in level of monitoring
or audit of this critical stage in the slaughter process. It is clear that
current standards are wholly unacceptable, leading to a very large number
of animals being improperly stunned. One UK study, for instance, found
that 36 percent of pigs were stunned using incorrect tong placement (Anil & McIntyre
1993) and FAWC themselves identify “serious deficiencies” in
the accuracy of tong placement. Each occasion on which tong placement is
incorrect carries a serious risk of ineffective stunning. Due to the huge
numbers of animals slaughtered daily in the UK, even a very low level of
inadequate stunning would represent an enormous welfare problem. This issue
must be addressed with urgency.
OVSs are present at only a fraction of stunnings and it is clear that
this level of monitoring is failing significantly to ensure that animal
suffering is minimised. Monitoring of every stun should be required by
law; stunning effectiveness should be subject to regular audit and legal
penalties should be employed if performance falls below 100% effectiveness
in any but the most exceptional of circumstances. Records should be kept
of every individual operative’s performance and retraining or disciplinary
measures mandated as appropriate.
Recommendation 60: wounds of non-stunned animals
Viva! believes that slaughter without prestunning should be banned (see
below) but in the absence of a ban, it is essential that all slaughter
without prestunning takes place under the direct supervision of an OVS.
At present, no records are kept which identify specific welfare problems
or violations arising from slaughter without prestunning (source: letter
to Viva! from Meat Hygiene Service) but it is absolutely clear that slaughter
without prestunning carries the highest possible risk of additional severe
suffering in the event of poor practice or technique. Anecdotal evidence
shows that a proportion of animals slaughtered without prestunning do remain
conscious and active for some time after throat-cutting (Gellatley, 2003).
Such occurrences clearly violate the WASK regulation that avoidable pain
or distress should not be caused to any animal at slaughter and it is essential
that all possible measures to prevent – and to monitor – such
occurrences are introduced. If slaughter without prestunning is still to
be permitted, OVS supervision of all such slaughter should be mandated
Recommendation 61: slaughter without prestunning
Note: all figures are extrapolated from the MHS Animal Welfare Review
2003. The Review quotes figures for a single week – in the absence
of any definitive figures, we have multiplied them by 52 to arrive
at an annual estimate. We regret that no more precise figures are available.
Viva! welcomes the Government’s acceptance of FAWC’s conclusion
that animals slaughtered without prestunning are likely to experience very
significant pain and distress. We therefore find it inexplicable that the
Government is unwilling to take any meaningful direct action to address
this severe welfare problem. We find the Government’s arguments unconvincing
and believe that they misrepresent the nature of this problem and the Government’s
options for solving it. We believe that slaughter without prestunning can
and should be banned absolutely. We further believe that if the Government
remains unwilling to impose a ban, far stronger action can be taken than
the Government has indicated it is willing to pursue in the draft response.
We shall now examine the Government’s arguments.
Firstly, the Government’s characterisation of the situation as “certain
religious groups in the UK are constrained from eating meat from animals
that are stunned at the time of slaughter” does not acknowledge the
diversity and fluidity of the attitudes of Jewish and Muslim people to
this issue. As the Government knows, the MHS 2003 Welfare Review found
that over 90 per cent of animals killed for halal meat were prestunned
during the week it took place. It is clear that the vast majority of people
in the Muslim community take a flexible approach to this issue and that
there is no contradiction between being a Muslim and eating meat from pre-stunned
animals. As the Government also knows, definitions of what constitutes
halal vary and in both the UK and abroad – for instance in New Zealand – halal-certifying
bodies accept that stunning and halal are consistent with one another.
Some Muslims dispute this but they are not a “group” – they
are individuals who have a particular interpretation of Islamic law.
Similarly, opinion and practice is divided within the Jewish community.
While it is true to say that hostility to prestunning is generally firm
within the Orthodox community, many Reform and other Jews do not oppose
it and eat meat from stunned animals. Viva! notes that Shechita UK’s
website entitles their statement on the Government’s draft response, “Summary
of the Jewish Community’s standpoint.” This is simply not true:
Shechita UK do not represent all Jews. In the case of both communities,
bodies and individuals who represent or claim to speak on behalf of their
coreligionists may be vocal in their opposition to slaughter without prestunning
but the strength and forcefulness of their opposition must not be mistaken
for unanimity or similar strength of feeling within those communities.
Finally, there is no religious requirement to consume halal or kosher
meat. Muslims and Jews have the option of not eating meat if they are unwilling
to eat it from animals slaughtered without prestunning. As there is a divergence
of opinion on this issue within religious communities and as the consumption
of meat from animals slaughtered without stunning is not obligatory for
Muslims and Jews, a ban would not constitute an infringement of religious
practice and would prevent no one from following their religion.
It is also not clear that such a ban would violate the Human Rights
Act 1998. On the subject of religious freedom, Article 9 of the
Freedom to manifest one's religion or beliefs shall be subject only to
such limitations as are prescribed by law and are necessary in a democratic
society in the interests of public safety, for the protection of public
order, health or morals, or for the protection of the rights and freedoms
A ban on slaughter without prestunning may be permissible under the “moral” clause
of this Article: if slaughter without prestunning is likely to cause very
significant pain and distress then there appears to be a clear moral case
for its prohibition. As the Human Rights Act acknowledges, the principle
of religious freedom is not superior to other principles and the UK rightly
proscribes a number of practices considered to be justified by religious
law in other nations and cultures.
The argument that a ban on slaughter without prestunning in the UK would
simply lead to the “export” of the problem is not sustainable.
Firstly, if this form of slaughter causes severe suffering, Britain has
a moral responsibility to legislate against it: in similar circumstances,
the Government has banned fur farming in the UK despite the fact that fur
may still be imported. Secondly, repealing the current exemption would
not necessarily lead to the entire current demand for “non-stunned” halal
and kosher meat being met by imports. There is no evidence that this has
happened in other countries in which slaughter without prestunning is banned,
such as Norway and Sweden. As many Muslims and Jews already eat meat from
stunned animals, it is likely that in the event of a ban, others who do
not feel strongly about the issue but at present eat meat from unstunned
animals would choose meat from stunned animals instead.
The sale of religiously-slaughtered meat in the ordinary meat market effectively
subsidises the practice. There is no justification for a system in which
consumers who do not agree with slaughter without prestunning are unwittingly
providing financial support for it. Even if the Government does not intend
to outlaw religious slaughter, it can and should take action to ensure
that the cost of this practice is borne solely by those on whose behalf
it is undertaken. By increasing the cost of religiously-slaughtered meat,
the introduction of compulsory labelling may also contribute towards a
decline in its consumption, which will effectively reduce the welfare cost
paid by animals.
Secondly, consumers (including Muslim and Jewish people) have a right
to information which will allow them to make an informed choice on this
issue. Shechita UK maintain that such labelling would be unfair if it was
applied only to religiously slaughtered meat. Viva! certainly supports
full and detailed labelling about slaughter method on all meat but disputes
this argument. Religiously slaughtered meat is exceptional – the
law makes an exception for it in permitting slaughter without prestunning.
Shechita UK’s argument is also disingenuous. If they believe that
traditional Shechita is a high welfare system, why should they object to
advertising that fact to consumers?
The Government states that it “would wish” stakeholders to “consider” the
options for a voluntary labelling system. It is clear from Shechita UK’s
statement that they oppose this idea and have no interest in addressing
the practicalities of introducing it. Without extra incentive they, and
also some halal producers, simply will not implement such a system. The
Government has a responsibility to ensure that the current wholly unacceptable
situation does not continue and the passive language employed in the consultation
document indicates no such willingness on its part. Nor must the “independent” status
of the Food Standards Agency be permitted to allow the Government to disclaim
responsibility for the issue. Viva! believes that in the absence of a ban
on slaughter without prestunning, a labelling system enforced by meaningful
sanctions is absolutely essential. The Government must take whatever steps
are necessary to ensure universal uptake of any system.
Slaughter without prestunning is a major welfare issue and one in which
hope of voluntary improvement is marginal. While slaughtering for halal
is now overwhelmingly conducted with prestunning, over eight million animals
a year are still subjected to the unimaginably severe trauma of having
their throat cuts while conscious for halal meat and many Muslims continue
to support the practice. In the case of kosher meat, although numbers of
animals involved are smaller, the situation offers even less hope of progress:
resistance to change is absolutely intransigent. Viva! does not doubt the
sincerity and integrity of those who believe that prestunning is unacceptable
for religious reasons – sadly, it is for precisely this reason that
hope for voluntary progress is small. The Jewish and Muslim people who
oppose slaughter without stunning hold firmly to a belief that is simply
incompatible with animal welfare at slaughter: they will not be swayed
by scientific evidence, reasoned argument or even their own genuine concern
for animal welfare. Viva! also accepts that many who oppose prestunning
have a genuine belief that halal and kosher methods are more humane than
conventional slaughter but their fundamental position on this issue is
determined by their religious faith and their interpretation of religious
law, not considerations of animal welfare. Because many Jewish and Muslim
people now consider the consumption of meat from stunned animals totally
consistent with their faith, it is also clear that those who do not are
the least likely to change their view. Simply put, if the Government does
nothing, nothing will be done.
Recommendation 62: post-cut stunning
Post-cut stunning is an essential welfare measure for both cattle and
sheep where pre-stunning does not occur. At present, MHS figures suggest
that over 900,000 sheep and lambs are slaughtered without any form of stunning
and 20,000 cattle. The evidence that cattle retain consciousness for periods
measured in tens of seconds and even minutes is the most compelling and
unambiguous of all the evidence of animal suffering arising from slaughter
without prestunning. While sheep take less time to lose consciousness,
even 5 or 10 seconds of severe wound pain and shock secondary to exsanguination
remains a profound welfare insult. It is absolutely clear that severe suffering
of this kind is both intolerable and “avoidable”: in the light
of current knowledge and existing law, it is unacceptable that it should
still be permitted.
In the case of cattle, almost all slaughtered for halal meat are now prestunned
with the tiny remainder given a post-stick stun. Post-cut stunning already
takes place in half of Shechita cattle slaughterings and so it is clear
that opposition to it reflects not universal opinion within the Jewish
community but a sectional view. The Government must not allow the conservatism
and intransigence of any group or body to override the compelling need
to address the profound suffering of cattle undergoing this form of slaughter.
MHS figures suggest that introducing post-cut stunning for all cattle would
affect just 20,000 animals per year – barely 0.2% of the total number
of animals slaughtered without prestunning – but although numbers
of animals are relatively small, such a measure would address the single
most severe welfare problem to arise from religious slaughter. Again, however,
voluntary action is doomed to failure. Shechita UK, for instance, have
painted themselves into a corner on this issue: for them to accept post-cut
stunning would be to concede that there is a welfare problem arising from
Shechita and it is now absolutely clear that they will not do this. This
situation can only be solved by action at governmental level.
To fail to introduce a measure that would have so insignificant an impact
on the prevalence and practice of religious slaughter but would so substantially
reduce the severe suffering of tens of thousands of individual animals
would be a total dereliction of the Government’s responsibility to
protect animal welfare. It would also act as a sign that the Government
will capitulate to any level of opposition arising from religious quarters,
however detrimental in its consequences and however small in scale the
issue at stake. If the Government remains unwilling to impose a ban, Viva!
implores it to take the absolutely minimal step of mandating post-cut stunning
by whatever means will prove effective.
Recommendations 63 and 64: bleeding within sight of conspecifics and stun-to-stick
Stun-to-stick times are critical in ensuring that stunned animals do not
regain consciousness before knifing. The margin for error when electrical
stunning is likely to induce unconsciousness lasting for considerably less
than one minute in sheep and pigs (Cook et al 1995) is very small. Viva!’s
examination of this problem indicates that millions of red meat animals
each year regain consciousness before slaughter (Smith, 2000). The most
recent MHS figures indicate that stun-to-stick times of over 15 seconds
occur in many abattoirs – for instance, in 24 abattoirs slaughtering
fat pigs during the 2003 welfare review – and it is clear that a
substantial number of animals will regain consciousness before death. The
prevalence of this problem indicates an urgent need for a measure which
will ensure stun-to-stick times of the shortest possible duration. Although
WASK mandates loss of consciousness lasting until death, OVSs are not able
to monitor every slaughtering and animals may in any case regain consciousness
after sticking without this being detectable to an observer. A maximum
stun-to-bleed time of 15 seconds laid down in legislation would provide
a measurable and thus enforceable mechanism to minimise the possibility
of recovery. Such a measure must be introduced.
Recommendation 65: severing of carotid arteries
If severing of both carotid arteries is not legally permissible for meat
hygiene reasons then stun-to-stick times must be revised downwards to take
account of the longer bleeding time.
Recommendations 70, 71 and 72: slaughter of deer
In responding to these recommendations the Government appears to be working
on the principle that deer’s specific needs are secondary to the
commercial considerations of slaughterhouse provision. The principle should
instead be that where facilities suitable for slaughtering deer do not
exist within the local area, deer should not be reared. It should be the
responsibility of the producer to ensure that suitable facilities for slaughter
are available and the Government should embody this principle in any legislative
changes it introduces.
Recommendation 72: ratites
Ratites are barely-domesticated, dangerous animals, wholly dissimilar
physiologically to any other animals killed for food in the UK. Evidence
about their welfare needs is insufficient to ensure that they can be safely
and efficiently slaughtered in a manner which protects their welfare. In
the absence of sufficient skill and knowledge, ostriches should not be
slaughtered – and thus not be reared - in the UK.
Recommendations 80, 81 and 82: training and licencing
Poor practice in such areas as handling and stunning can and does have
a profound impact on animal welfare (see Recommendation 53). A formal system
of training, assessment and licencing is essential for raising and maintaining
standards. OVSs’ monitoring of practice is not systematic or centred
on individuals and therefore not an adequate substitute for formal systems.
Recommendations 87, 88 and 89: animal welfare officers
Welfare has no central role within slaughterhouses – which exist
to process meat as efficiently and profitably as possible – and attention
devoted to it comes at a financial cost. The OVS’s primary responsibility
is to enforce existing law rather than promote welfare. It is therefore
essential that at least one designated individual who is employed
by the establishment is given formal responsibility, by law, for promoting
ensuring animal welfare and is formally trained in the subject.
Recommendation 93: OVS auxiliaries
While auxiliaries are no substitute for fully trained and professionally-accountable
veterinary surgeons, they could clearly contribute to a raising of standards.
Funding for the training of auxiliaries should be provided by Government
or from a levy on abattoirs.
The Government’s acceptance of the majority of the Farm Animal Welfare
Council’s recommendations is very welcome. In many cases the Government’s
acceptance does not, however, amount to a firm commitment to take substantive
measures and we hope that the processes of “consultation”, “exploration” and
so on will not prove to be a substitute for meaningful action. Nevertheless,
it is clear that animal welfare at slaughter should improve as a result
of the Government’s response to the report.
Unfortunately, there are a number of major issues on which the Government’s
response is unsatisfactory: chief among these are slaughter without prestunning,
the use of aversive gases and inadequate stunning. In common with lesser
but still significant issues such as training and the handling of deer,
it seems clear that the principle guiding the Government’s response
has been narrow pragmatism rather than animal welfare. Acceptance or rejection
of FAWC’s individual recommendations appears to depend on the ease
of taking action, rather than any value each may have in reducing animal
Aversive gases cause animal suffering. CO2 is used in preference to argon
because it is cheap and allows a faster throughput of animals. Accordingly,
the industry likes it and has no desire to invest in more welfare-friendly
but expensive techniques. The Government is unwilling to take any action
that would accelerate change towards gas stunning/killing methods which
will cause less animal suffering, despite the large numbers of animals
involved and the substantial welfare benefit achievable.
Similarly, accurate, skilled stunning and minimal stun-to-stick times
are the central mechanism for ensuring that animals do not suffer in the
most severe way at slaughter. Thorough, comprehensive and verifiable monitoring
of these parts of the slaughter process would, however, be a relatively
complex and potentially costly step for producers and the MHS. The Government’s
response to this problem has again, therefore, been to take no effective
action, despite the substantial welfare benefit that would accrue.
Lastly, slaughter without prestunning affects an estimated ten million
animals including around one million red meat animals per year. The Government
accepts that it is likely to cause very significant pain and distress.
Again, however, pragmatism rules: the level of opposition to any form of
mandatory change will be strong (even if it actually stems from a very
small number of people or from groups who may not even be representative
of the communities on whose behalf they claim to speak and even though
71% of the UK public want a ban on slaughter without prestunning) so the
Government will take no action. Attempts to foster voluntary change will
fail because those who support slaughter without prestunning have made
it very apparent that they have no interest in or desire to change. The
measures announced by the Government amount to an abdication of responsibility.
In these respects, as in so many others, it is apparent that animal welfare
assumes a far lower priority in policy-making than commercial or indeed
political considerations. Welfare measures are welcome so long as they
incur no significant cost. As soon as they come into conflict with other
interests, the political will to implement them evaporates. Viva!’s
opinion on this issue is not determined by prejudice, cynicism or hostility
to the Government – simply by observing the Government’s behaviour
on a range of issues from hunting through to innumerable aspects of farmed
animal welfare. We regret that the Government’s draft response to
FAWC’s report has failed to tackle the most pressing and difficult
issues it raised. We implore the Government to reconsider their position
in all the areas we have highlighted but especially the use of aversive
gases, the effectiveness of stunning and slaughter without prestunning.
We remain hopeful that the Government will take this opportunity to deliver
truly significant improvements in animal welfare at slaughter.
Cook CJ et al (1995) The effect of electrical head-only stun duration
on electroencephalographic-measured seizure and brain amino acid neurotransmitter
release Meat Science 40 137-47
Anil MH & McIntyre JL (1993) Variations in electrical stunning tong
placements and relative consequences in slaughter pigs The Veterinary Journal
Gellatley J (2003) Going for the kill: Viva! report on religious slaughter
Meat Hygiene Service (2004) Animal Welfare Review 2003 Meat Hygiene Service
Shechita UK website (2004) http://www.shechitauk.org/downloads/download1.pdf
Smith R (2000) Sentenced to Death: a Viva! Report on the slaughter of
farmed animals in the UK Viva!
Wotton S (1996) Sticking techniques and exsanguinations in pigs, sheep
and calves Meat Focus International (July) 234-7