Alan Beat of http://www.smallholders.org writes,
Researching on the DEFRA website, we came across an intriguing opening paragraph on the page http://www.defra.gov.uk/animalh/welfare/default.htm
"Welcome to the Animal Welfare section of the DEFRA website. Like many of you looking at this site, we recognise that animals are sentient beings - not merely commodities. It follows that the standards of animal welfare we apply are very important."
Just thought you'd like to know that!
DEFRA have just released a Disease Control (Slaughter) Protocol document for "consultation". This is intended to clarify and regulate the way in which slaughter will be applied during the next FMD epidemic using the draconian powers now being sought in parliament under the Animal Death Bill. We will spare you the whole document but include here the most relevant extracts and our own response:
4. There are three sets of circumstances when animals may be required to be slaughtered. These are:
7 Animals affected or suspected of being affected.
7 Animals which are believed to have been exposed to infection.
7 To prevent the spread of disease, e.g. a ‘firebreak’ cull. (This requires passage of the Animal Health Bill.)
The last point confirms that firebreak culling as applied during 2001 was illegal!
5. Animals which are affected must be slaughtered and an Infected Premises (IP) declared. EU Directive 85/511 requires the slaughter of all susceptible animals on IPs.
This is not so; the Directive stipulates slaughter of infected animals only and provides for different treatment of discrete groups within the IP. Maybe they should try actually reading it? There is a clear case under EU law for rapid testing on an IP to slaughter only those animals actually infected.
6. Animals may be slaughtered if they are believed to have been exposed to infection. In these cases, animals which are thought to have been exposed will be subject to a veterinary inquiry to determine if, in the opinion of the Veterinary Inspector, they have been exposed.
Has nothing been learned from the mistaken diagnoses of the 2001 epidemic? Only on-farm or full laboratory testing can provide a fair and reliable basis for the decision to slaughter. Clinical signs are only acceptable in unambiguous circumstances involving cattle and pigs - but certainly not sheep or other species in which clinical signs are notoriously unreliable indicators of disease.
7. The third group is when the Secretary of State has announced the need for a cull to prevent the spread of disease, e.g. a ‘firebreak’. Such a decision by the Secretary of State would describe the species, geographical area and, if appropriate, type of farming of the cull. As with all other disease control measures speed would be of the essence, but before the slaughter notice is signed the Veterinary Inspector must be satisfied that animals fulfil the criteria for inclusion. If the owner of the stock can provide evidence based on the criteria that they should be exempted then the Veterinary Inspector will take that into account before reaching a decision on slaughter.
It is impossible to conceive of a situation in which vaccinate-to-live within a "firebreak" zone would not be far better than slaughter on moral, ethical, scientific and economic grounds - so why even include this category within a slaughter policy?
Animals affected or suspected of being affected
9. The decision to slaughter these will be on either the results of laboratory tests carried out on samples arising from animals suspected of being affected with disease, or clinical evidence of disease.
10. In an area considered to be free of disease, normally disease will be confirmed on laboratory grounds. However, once disease has become established in an area it is likely that cases will be diagnosed on clinical grounds alone.
Again the same points apply as in para. 6 above - rapid testing is the only realistic method permissible.
Animals exposed to infection
11. These are animals that are believed to have been exposed to infection. These are also known as Dangerous Contacts (and can include animals on contiguous premises). As virus can be excreted by such animals prior to the development of obvious and identifiable clinical signs, it is important that they are culled as soon as possible to stop virus production and hence spread of disease.
Then test them - fast - and stop guessing.
The range of possible routes for spread of infection contained in the further paragraphs to no. 24 are rendered academic by fast and accurate diagnostics. Simply test, then slaughter only when necessary.
To prevent the spread of disease
25. The Government is committed to using the new slaughter powers in the Animal Health Bill only where this is justified by the circumstances and on the basis of sound veterinary, epidemiological and scientific advice. That means in particular that a risk assessment will be made of the possibility of disease spreading. It will include those animals that are judged to be at lesser risk of infection but which, should they become affected, would present a very significant risk to the farming and livestock community more generally. It is in such circumstances that effective preventative action may be necessary to safeguard the wider public interest. It could apply in particular to protect areas of dense livestock population. Any decision to use the wider powers of slaughter provided in the Animal Health Bill would be taken in the light of an overall assessment of the risks, costs and benefits in a given situation. This could include not only risks of transmission but also social and economic risks that would arise if effective and timely action were not taken. The Government would justify its decision to use the slaughter powers, explaining the veterinary, epidemiological and other relevant factors that had been taken into account.
Test, then if clear, vaccinate-to-live. It's simple; no risks taken, no unnecessary slaughter.
An explanation of the process by which a decision to use such powers would be reached
26. Because specific details of the nature of a cull cannot be known until such a cull is required during an outbreak this section indicates the steps that would be undertaken before the decision is reached.
a) Identify a group of animals that could contribute to spread of disease. This would be based on
7 epidemiological modelling
7 consideration of local factors
7 determination of which species are involved
7 determine geographical area involved.
b) Consider if any exemptions could be allowed based on husbandry or other criteria, e.g. genetic value.
c) Determine the rules for inclusion of animals at the boundaries of that area.
d) Analysis of risks, cost and benefits.
e) Publish an outline of the reasons why such a cull is needed.
No mention is made here of the number of livestock present on a holding - shown to be a significant factor in the 2001 epidemic. Large flocks/herds were implicated far more than smallholdings with few animals, and this should be reflected in any future policy.
Who is going to weigh up such a range of variables to reach a fair decision? Who indeed is qualified to do so? If such decisions are to be honestly made, they need to be reached by a consensus among people qualified to do so AND who are seen to be genuinely independent from any political or other constraints.
AN OUTLINE OF THE PROCEDURE BY WHICH ANIMALS ON A PREMISES WILL BE DEEMED TO BE INCLUDED IN A SLAUGHTER.
27. The premises to be visited would be determined. This could be as a result of:
7 Report of suspect disease.
7 Link to an Infected Premises.
7 Believed to contain animals to be slaughtered to prevent the spread of disease.
28. Once premises are determined, the following action would be taken:
a) Veterinary Inspector visits and ascertains if animals are to be slaughtered because they meet the criteria in paragraph 27. This could range from a detailed clinical examination to establishing if animals of a certain species kept under specified husbandry conditions are present.
b) The Veterinary Inspector would be required to explain the reasons to the owner and give them an opportunity to provide evidence if they believe the animals can be exempted.
c) To ensure the reason for slaughter is clear to the owner a slaughter notice is then issued.
Refer back to para. 6 again - positive results from rapid testing must be required for all but unambiguous cases.
Use of slaughter notices
29 These will allow the owner of the stock to be provided with:
7 the justification for slaughter (i.e. under which powers the slaughter is required) ;
7 the reasons why their stock are included, e.g. clinical signs, vehicle contact from IP, meet the criteria for slaughter to prevent the spread of disease.
30. Both as part of the slaughter notice and during explanations the owner must be made aware that they can ask the DVM to review this decision and be advised how and by when this can be done.
Slaughter notices should state either
a) positive test results, or
b) unambiguous clinical signs