(Warmwell has used blue highlighting to make initial scanning easier. The response document may be read without highlighting by clicking here.)
The Consultation document referred to may be found here http://www.defra.gov.uk/corporate/consult/ahws/index.htm
the Countryside Alliance Campaign for Independent Food
PO Box 16141 London SE11 4ZH
Telephone: 020 8740 7194
Response by the Countryside Alliance to the first consultation document on the preparation of an animal health and welfare strategy for Great Britain 2003
The Countryside Alliance and Honest Food welcome the decision taken by the UK Government, the Scottish Executive and the National Assembly of Wales to launch a consultation exercise with the aim of preparing a complete animal health and welfare strategy for the next ten to twenty years. The Countryside Alliance has long advocated such a course of action. We have taken part in the preliminary discussions that have resulted in the document published in January 2003 and intend to continue to participate fully in the preparations for the strategy. The Director of Honest Food has attended meetings of stakeholders in London and the Political Officer of the Countryside Alliance in Wales did so in Cardiff. The response will, therefore, be based on discussions in those meetings as well as the document itself. A separate response will be submitted to the National Assembly for Wales.
1. We appreciate that this document is a first, necessarily sketchy draft, whose ideas may well appear to be, at this stage, somewhat superficial. We look forward to seeing more detailed proposals and responding to them in turn.
2. We also appreciate that any animal health and welfare strategy has to be devised within a network of international agreements. In particular, we are aware and would wish that future documents in the development of this strategy would make it crystal clear, that the United Kingdom has a legal obligation to introduce EU legislation for internal purposes. This is a qualitatively different link from the one created by such an organization as the OIE, whose agreements deal with international trade and exchange and are largely advisory. The Countryside Alliance hopes that future documents will draw the necessary distinction, as it is vital that all those involved in putting the strategy into practice must know clearly the legislative and regulatory structure behind it.
3. The Countryside Alliance welcomes the general ideas laid down in Section 4.1 and elaborated in Section 10 for the proposed Strategy’s aims. As mentioned above, we are aware that these are preliminary, general proposals. We are, however, somewhat disturbed by the fact that while leisurely negotiations continue about the Strategy, whose timetable seems a little unclear, a great deal of detailed and often contentious legislation is being put into place. We refer especially to the Animal Health Act 2002, SI843, which laid down rules for dealing with infectious diseases but had to be amended within weeks of passing (a fact that would indicate unnecessary haste in the promulgation), the currently discussed FMD Contingency plan as well as the Draft EU Directive on FMD and the proposed Animal Welfare Bill. Should an overall Strategy not be laid down first, perhaps decided on a little faster, with specific legislation to follow? How will the strategy relate to the specific legislation? Will the latter have to be amended or will the strategy have to work round it? What will happen if the European Union finds the strategy after it had been decided on in some way faulty or inadequate? We feel that these questions need to be considered.
4. The Countryside Alliance has long advocated the need for firm proven scientific base for regulation and we are, therefore, very pleased to see that the proposed Strategy intends to be “evidence based (including sound science, economic, social and legal aspects)”. It is important that any regulatory regime should not be based on the precautionary principle, which is too often simply prejudice turned into regulation. We welcome the importance placed on “the principles of sustainable development”; the acknowledgement of the need for “sufficient flexibility to deal with local or regional issues”.
5. We are pleased that the concept of profitability is mentioned, as a strong healthy livestock industry and rural economy cannot exist without that. We should like to see that concept given greater importance. We do not want to see a situation where animal keeping for whatever reason becomes a purely charitable or indefinitely subsidized endeavour. We are, of course, aware of the need to balance profitability with good husbandry and good animal health and welfare practices but we do not think the potential conflict between the two concepts need be all that great. Recent animal epidemics and food scared have reduced drastically the profitability of most of the livestock industry, which has had to survive on a combination of subsidies and compensation. A clearly thought out policy of animal health and welfare rules that has the informed consent and co-operation of all those involved as listed in Section 6.1 will also increase the profitability of most of the enterprises involved.
6. While we welcome the ongoing consultation with stakeholder organizations we should like to draw attention to the fact that these may or may not be representative and, understandably, have an agenda. We should like to see a greater involvement on the local level, that is, we believe very firmly that the best strategy is one that is implemented at the lowest possible level by farmers, producers, local veterinarians, local officials, zoo keepers etc etc. In the past there has been too much emphasis placed on centralized decision-making and implementation, which caused conflict and dissatisfaction as well as inadequate standards.
7. Given the level of regulation already in existence around the livestock industry and the keeping of animals in general, as well as the proposed additions to it, there is a vital need for understanding between those who set up and administer the regulatory structure and those on whom it impacts. We must, as a country, move beyond the perceived situation in which the regulators are seen as the enemy of enterprise of any kind. There must be a clear perception that the two “sides” are not really that but groups wit different tasks but the same aim.
8. The Strategy at this early stage necessarily does not give details of the scientific backing for the regulatory regime. However, the Countryside Alliance is concerned that there should be maximum flexibility in the sourcing of scientific data. By this we do not mean that it should be anything but of the highest standard but we urge DEFRA, nor for the first time, to ensure that they pay full attention to research and validation of scientific tests and experiments in other countries not only the United Kingdom and members of the European Union. In the same way we hope that there will be greater co-operation between veterinarians and scientists who work directly for DEFRA and private laboratories both in this country and others. Greater attention needs to be paid to surveillance systems.
9. Other questions we should like to see tackled at an early stage with ideas defined clearly would be the question of who would be paying for regulations imposed in the name of public health and welfare and, especially, the usually high cost of inspection. Again, we should like to see a high level of co-operation between inspectors and those inspected.
10. Finally, the Countryside Alliance would recommend a closer look at the existing regulations and subsidies that may well be contributing to the problems in animal health and welfare. There is reasonable evidence, for example, that the calamitous spread of FMD in 2001 was made worse by two factors: the disappearance of the small and medium-sized slaughterhouses that meant longer travel for animals and the ewe subsidy, which contributed to overstocking and, again, greater movement of animals. We appreciate that most of the relevant regulation and subsidy is in the EU’s competence, nevertheless, we feel that this subject should be addressed more seriously.
We hope these points are of use and look forward to taking part in future consultations.
Helen Szamuely (Dr)
Director, Honest Food (a Countryside Alliance campaign)