Honest Food 

the Countryside Alliance Campaign for Independent Food


PO Box 16141 London SE11 4ZH

Telephone: 020 8740 7194

E-mail: honest-food@countryside-alliance.org




Comments on:


1.    Outline of an Animal Health and Welfare Strategy for Great Britain

2.    Animal health and Welfare Strategy for Great Britain: a Partial Regulatory Impact Assessment

3.    Positive Animal Health: a Draft Action Plan for a Partnership Approach in England and Wales




General Comments:


The Countryside Alliance and its Campaign for Honest Food has welcomed unreservedly the idea of a long-term strategy for animal health and welfare in the United Kingdom. We have taken part and intend to take part in the future in all discussions on the subject and are ready to contribute in those discussions, with comments and in the ensuing dialogue. We have long argued that individual and often panicky legislation and regulation was not the answer to the many problems that have beset the UK livestock industry in the last few years. A thorough and completely open discussion of all the problems was needed and an overall strategy had to be put into place that would take involve all the many groups and organizations as well as individuals that are concerned with the many aspects of the subject.


It is in the Countryside Alliance’s opinion important to take a positive attitude and view the livestock industry as potentially one of the country’s most successful ones in economic and social terms. In order to do so a complete re-thinking about the livestock industry may be necessary and all of us who have taken part in the many discussions and debates need to think carefully about what kind of industry would we like to see in the UK and what kind of industry would be best for the country and for those who, in one way or another, depend on it. We appreciate that the final draft of the Animal Health and Welfare Strategy, at present due to be published in spring 2004, will deal with other animal keeping as well as farming and the livestock industry and welcome the idea that these various aspects should be linked. However, the present documents deal largely with farmed livestock and these comments do the same.

While welcoming the various documents, we do find it a little disturbing that there has to be quite so many of them and that they have to be quite as long as they are. In our view, part of the problem all agriculture, food production and, in particular, the livestock industry in this country has had to face, has been the prevalence of bureaucratic regulation and proliferation of paperwork. Reading through the three documents one is struck by the inevitable conclusion that there is a great deal of unhelpful generalization, repetition and what can only be described as wishful thinking. It is difficult to produce a document that would please everyone and, we appreciate that the purpose of this consultation is hear what the various stakeholders have to say. But we should like to put forward the idea that documents should be produced in as concise and purposeful way as possible. Prolix and unnecessary documents do not make the lives of stakeholders, animal keepers or the various professionals who have to deal with the subject any easier as well as creating the impression that an unnecessarily bureaucratic framework is being created.




Outline of an animal health and welfare strategy for Great Britain


The Countryside Alliance welcomes this outline and looks forward to the final document. The idea of a ten-year overall strategy is one we greatly favour. We also feel that this opportunity should be taken to discuss even more widely the future of the livestock industry and the various problems and possibilities it faces. We do not feel that, as yet, such a discussion has taken place or has been planned and regret that fact. The Alliance fears that it may be put off until another outbreak or epidemic and that is regrettable.


The Countryside Alliance welcomes the emphasis placed on scientific research and underpinning for the strategy and, therefore, one assumes for any future legislation and regulation. This is not, however, spelled out. We also welcome the fact that best practice will be investigated and possibly adopted from outside this country as well as inside. However, we feel that there is insufficient emphasis on the need to take scientific research and its results from outside the UK and, even the EU. We feel that the past insistence on using largely research done within DEFRA and organziations directly connected with it has to be modified. More attention must be paid to work done by laboratories – in the UK and outside it – financed by non-governmental organizations. Private enterprise in scientific research ought not to be treated disdainfully. Naturally, the studies we have in mind are those that have been carried out under well-defined conditions and have had their results peer-reviewed (a necessary detail, not mentioned in the Outline).


The Countryside Alliance feels very strongly that, as much has been made of the need for transparency in discussions about the animal health and welfare strategy, it is imperative that the source of the legislation be made absolutely clear. The documents do not do so. It has not been specified that all EU legislation and regulation has to be transposed into British legislation as a matter of legal requirement. This may seem obvious to DEFRA but is not always obvious to all stakeholders. It must be made so, in order to have a sensible and open discussion.


We have also found it somewhat disconcerting that while the necessarily lengthy discussions about the long-term strategy were conducted, a number of highly contentious pieces of legislation, such as the Animal Health Act and Statutory Instrument 843 (dealing with TSE) have been passed. This indicates a certain lack of strategic thinking. Further on the same subject, it is clear that detailed EU legislation is due in the near future that will deal with many of the subjects covered by the Strategy. We should like to see some indication of how all these various pieces will fit together and should like a more open and general discussion about all these aspects.


We also hope that assurances that EU legislation and regulation will not be gold-plated in the UK will, finally, be put into practice. There have been many promises of this kind in the past and, so far, little has changed.


The Countryside Alliance welcomes the emphasis on research into preventative medicine and vaccination (though, again, we would welcome a clearer explanation of the fact that veterinary medication and research are largely EU competences) and look forward to a more detailed break-down of resources devoted to necessary research rather than the continuing “firefighting” and slaughter that requires compensation for farmers and, if the FMD epidemic of 2001 is anything to go by, causes grave economic dislocation in rural areas.


We look forward to a more detailed analysis of what emergency and surveillance structures have been put into place and what plans there are for the future. We hope that assurances about best practice and scientific research outside the UK being used will apply equally to questions of veterinary and epidemiological surveillance. It is imperative that we should leave what might be termed “the not invented here attitude” be abandoned at all levels.


Finally, while the Countryside Alliance welcomes unreservedly the notion of all participants working together to promote the animal health and welfare strategy, and the emphasis laid on the profitability for the livestock industry attached to it, we find a little disturbing that any of it should be under dispute. If, as this document implies, this is a new idea, we have to question what exactly its authors think has been the underlying principle of livestock –keeping and farming in this country. If the profitability of high levels of animal health and welfare are questionable and ill-understood concepts, then the need for a general and far-reaching discussion about the future of the livestock industry is very great, indeed.


Helen Szamuely (Dr)

Director, Campaign for Honest Food