Support OneKind’s call for a ban on slaughter without stunning in Scotland, by responding to the consultation.
Council Regulation 1099/2009 on the protection of animals at the time of killing was passed three years ago and is due to be implemented in European member states by the beginning of next year.
The Scottish Government published its consultation document on 29 August, and consultations are expected shortly for England and Wales.
The current UK legislation, the Welfare (Animals) at Slaughter and Killing Order (WASK) 1995 will be partly revoked and replaced by new domestic legislation, the Welfare of Animals at the Time of Killing (Scotland) Regulations 2012 (WATOK), and the same process will also be undertaken for England and Wales, although consultations have not yet been published by these administrations.
The new Regulation sets out a number of overarching welfare requirements 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.
It would have been much better for animal welfare if the new Regulation had simply banned slaughter without pre-stunning, but it did not. Nonetheless this is one of the areas where member states have the power to impose stricter conditions, or even a ban, under new national rules. Given that no slaughter without pre-stunning currently occurs in Scottish slaughterhouses, OneKind urges the Scottish Government to take the opportunity to ensure that no animals in Scotland are ever exposed to such needless suffering.
The Scottish Government already proposes to retain the higher standards – 118 in all – that currently apply in Scotland.
A number of these relate to animals subjected to slaughter without pre-stunning. If this slaughter is allowed to continue in the UK, the maximum available protection must be retained. For example, the prohibition on the use of rotating boxes to invert animals prior to religious slaughter must stand. Turning conscious cattle upside down prior to cutting their throats causes unnecessary pain, distress and suffering to the animals in their last moments of life.
We also believe that the restriction on the use of religious slaughter to animals intended to supply food for persons of the relevant faith must be retained and enforced. It is not good enough to cite practical issues surrounding traceability as a reason for turning a blind eye to meat from non-stunned animals making its way onto the wider market. Consumers have valid ethical objections to buying meat produced by religious slaughter: these must be respected and the necessary enforcement provided.
The Scottish consultation points to a greater willingness among Scottish stakeholders “to go much further to legislate to improve animal welfare in Scotland than appears to be the case in some other parts of the UK at present.” Representatives of the slaughter and farming industries, religious communities and animal welfare organisations have all agreed that existing national rules should be retained in legislation, unless there are valid reasons for change. This position makes it all the more important for Scotland to retain or introduce the fullest range of protections available, and to provide an example to other parts of the UK.
Other aspects of the new legislation
Another change will involve a transition from registered slaughterman licences to Certificates of Competence. At present, under WASK, most commercial operations require a slaughter licence but from January 2013 these will be replaced by Certificates of Competence. Certificates of Competence will be required for slaughter as well as for functions such as handling animals prior to slaughter, restraint and stunning, and aspects of religious slaughter.
Other key requirements are that all slaughterhouses killing more than 1,000 animals a week must have a designated Animal Welfare Officer monitoring and enforcing welfare practices; and Guides to Good Practice must be developed and disseminated in consultation with the competent authority. Premises must be designed and maintained to avoid injury to animals, and standard operating procedures (SOPs) – written instructions on how the slaughter process should be carried out and monitored – will be required for anyone involved in killing for any purpose.
The Consultation also notes 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. At this point the Scottish Government is not consulting on the general use of CCTV, but it has asked for views on CCTV in premises undertaking non-stun slaughter for religious purposes. As already stated, there is no non-stun killing in Scottish slaughterhouses, but it would be valuable to establish the principle of full monitoring, and OneKind will be supporting that proposal.
In Scotland, 55 million poultry, 1.5 million sheep, 645,000 pigs, 616,000 farmed game, 426,000 cattle and 196 goats were killed in slaughterhouses, at knackers’ yards or on farms in 2010-11. The new regulations will affect all abattoirs in Scotland slaughtering these species, as well as slaughter outside a slaughterhouse.
What you can do
OneKind will be submitting a full response to the consultation, which is open until 26 October 2012. You can make your response too and add your name to the call for a ban on slaughter without stunning.