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Time to outlaw non-stun slaughter

Write to your Minister responsible for food policy and food labelling. You can find a sample letter and the appropriate contact details on our action page.

Cow in close up

Council Regulation 1099/2009 on the protection of animals at the time of killing was passed three years ago and was due to be implemented in European member states by the beginning of 2013.

With the UK administrations at different stages of implementing the Regulation 1099/2009,  OneKind is urging government to take the opportunity to end the cruel slaughter of animals without pre-stunning in UK slaughterhouses.

OneKind believes that the slaughter of animals without pre-stunning should be banned outright. 

At present, European law prohibits non-stun slaughter but allows member states to derogate and provide exemptions for the Jewish (Shechita) and Muslim (Halal) methods of slaughter.  The UK took up this derogation and provided for it in the Welfare of Animals (Slaughter or Killing) Regulations 1995 (WASK), which have been amended but still apply.   Schedule 12 of WASK lays down provisions for slaughter by a religious method, while making it clear that these relate only to slaughter by members of the Muslim and Jewish faiths, and to provide meat for consumption only by people of those faiths.

Proponents of non-stun slaughter suggest that the operation can be humane, providing it is properly carried out.  But according to the independent UK Farm Animal Welfare Council (FAWC):

“When a very large transverse incision is made across the neck a number of vital tissues are transected including: skin, muscle, trachea, oesophagus, carotid arteries, jugular veins, major nerve trunks (e.g. vagus and phrenic nerves) plus numerous minor nerves. Such a drastic cut will inevitably trigger a barrage of sensory information to the brain in a sensible (conscious) animal... such a massive injury would result in very significant pain and distress in the period before insensibility supervenes.”
FAWC concluded:

“Council considers that slaughter without pre-stunning is unacceptable and that the Government should repeal the current exemption.”
The Scientific Panel on Animal Health and Welfare (AHAW) of the European Food Safety Authority stated:

“Cuts which are used in order that rapid bleeding occurs involve substantial tissue damage in areas well-supplied with pain receptors. The rapid decrease in blood pressure which follows the blood loss is readily detected by the conscious animal and elicits fear and panic. Poor welfare also results when conscious animals inhale blood because of bleeding into the trachea. Without stunning, the time between cutting through the major blood vessels and insensibility, as deduced from behavioural and brain response, is up to 20 seconds in sheep, up to 25 seconds in pigs, up to 2 minutes in cattle, up to 2½ or more minutes in poultry, and sometimes 15 minutes or more in fish”.

The AHAW Panel concluded:

“Due to the serious animal welfare concerns associated with slaughter without stunning, pre-cut stunning should always be performed.”

The Federation of Veterinarians of Europe is also strongly opposed to slaughter without pre-stunning. FVE stated:

“FVE is of the opinion that the practice of slaughtering animals without prior stunning is unacceptable under any circumstances”.

New UK slaughter legislation

Every year in the UK approximately 3 million cattle, 13 million pigs, 19 million sheep and lambs, 70 million fish and 800 million birds are slaughtered for human consumption4.
The Regulation sets out a number of overarching welfare requirements intended to protect these animals, but gives relatively little detail on how these should be achieved. At the same time, it allows member states to maintain pre-existing national rules that provide greater protection and, in specific areas only, to bring in additional controls or to provide derogations.

A number of the domestic standards relate to animals subjected to slaughter without pre-stunning.  For example, the use of rotating boxes to invert cattle prior to religious slaughter is currently prohibited and OneKind has urged the retention of this provision. Turning conscious individuals upside down prior to cutting their throats causes unnecessary pain, distress and suffering to animals in their last moments of life.

The new Regulation applies directly in all EU member states, but the four UK administrations have taken different approaches to implementing it.
DEFRA proposes to make new legislation for England – the Welfare of Animals at the Time of Killing (England) Regulations 2013.  Until this appears,  the government has advised stakeholders of the changes necessary to comply with the EU Regulation.

Northern Ireland has produced guidance for businesses and individuals and advised that they should continue to meet the requirements of the Welfare of Animals (Slaughter or Killing) Regulations (Northern Ireland) 1996.

The WASK remains in force in Wales, too, until the new domestic legislation - the Welfare of Animals at the Time of Killing (Wales) (WATOK) - is introduced later in 2013. 

Scotland has produced and implemented new Welfare of Animals at Time of Killing (Scotland) Regulations (WATOK) to amend the existing domestic WASK Regulations.  All existing national rules that go beyond the requirements of Regulation 1099/2009 are currently retained while further consideration is given to last year’s consultation responses.

Regrettably none of the administrations has proposed to ban non-stun slaughter, although DEFRA and the Scottish Government have consulted on the issue.  Failing a ban, a number of new provisions have been proposed:

  • Slaughter without a pre-cut stun must only take place in a slaughterhouse using approved equipment
  • An immediate post-cut stun must be administered for all bovine animals
  • Before the neck cut the slaughterman must ensure the knife is surgically sharp, the blade is undamaged and the blade is at least twice the size of the neck
  • CCTV should be made mandatory in premises undertaking non stun slaughter for religious purposes
  • A clearer definition is needed for mechanical restraint
  • Manipulation of wounds should be specifically prohibited until the animal is dead
  • Non stun slaughter must only be carried out in the presence of a vet
  • Standard Operating Procedures for non stun slaughter must be presented to competent authorities for approval.

Half measures perhaps, but in the absence of a full ban on non-stun slaughter, the reality is that they are all essential. 

The consultation process highlighted the growing calls for CCTV to be made mandatory in abattoirs, following reports by Animal Aid of appalling cruelty to animals in unseen areas of slaughterhouses in England. Many slaughterhouses already have CCTV but it does not cover all the key areas and monitoring is not consistent across the industry.  OneKind would support legislation to make CCTV compulsory but unfortunately there is no enthusiasm for this in any administration.  It might however be possible to achieve improved coverage and protection for animals by means of guidance codes supported by government, and OneKind urges government to take a lead in this area without further delay.

Would the public support a ban on non-stun slaughter?

We believe so, and progressive examples from overseas strengthen the call for reform in the UK.

Slaughter without prior stunning has been successfully banned in Poland, Norway, Iceland, Switzerland and Sweden, while Finland, Denmark and Austria require stunning immediately after the incision if the animal has not been stunned before. 

A ban on Kosher slaughter was introduced in New Zealand last year and then overturned following judicial review, but pre-stunning remains a legal requirement for Halal slaughter, with the consent of the Muslim population.  A proposed ban in the Netherlands was narrowly overturned earlier this year, again due to opposition from the Jewish, rather than the Muslim, community.

In the UK, Food Standards Agency figures for 2012 show that more than 80% of animals were stunned before slaughter for Halal meat in the UK.  The Halal Food Authority accepts recoverable stunning prior to bleeding although other Islamic authorities do not.

Shechita slaughter, required by orthodox Jews, always requires that the animal is not pre-stunned. However, surplus meat enters the market from this source and we believe it should be labelled as coming from animals slaughtered without pre-stunning.  It is likely that many consumers would not buy it, calling into question the economics of Kosher meat.

The need for clear labelling

At present, lack of information is one of the obstacles to modernising the supply of meat and meat products.

The exemption for religious slaughter in WASK) makes clear that it relates to a method of slaughter for people of that religion, not for everybody. However, poorly applied and enforced legislation allows consumers to be misled into buying meat without knowing whether animals have been slaughtered without pre-stunning. 

National and local authorities have allowed non-target supply to persist, despite the clearly expressed concerns of consumers and animal welfare groups.

OneKind has no wish to see discrimination against any Scottish, UK or European citizens on religious grounds.  However, to disregard the wishes of consumers who, for valid ethical reasons, wish NOT to purchase meant from non-stunned animals is also discriminatory.  Consumers who are not made aware of the origin of the product are misled and denied the opportunity to choose according to their own beliefs. 

The restrictions within WASK are unequivocal and must be enforced. As long as meat from animals slaughtered without pre-stunning is available in the UK, whether slaughtered locally or imported, it must be clearly and accurately labelled as such.

What can you do to help?

Whether you live in England, Northern Ireland, Scotland or Wales, you can write to your Minister responsible for food policy and food labelling. You can find a sample letter and the appropriate contact details here – simply key in your postcode and the rest is simple.

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