Consultation Response

Transcription

1 Consultation Response FROM THE RSPCA IN WALES Draft Code of Practice for the Welfare of Livestock: Meat Chickens and Breeding Chickens February 018 GENERAL COMMENTS: Absent Legislation The RSPCA recommends that reference is made in the Code to two key legislative clauses, as they are both legislatively relevant and of principal importance to those who care for meat chickens and meat breeding chickens. These are: 1. Article 1 of Title II from the Lisbon Treaty (009) which recognises animals as sentient (e.g. capable of feeling): In formulating and implementing the Union's agriculture, fisheries, transport, internal market, research and technological development and space policies, the Union and the Member States shall, since animals are sentient beings, pay full regard to the welfare requirements of animals, while respecting the legislative or administrative provisions and customs of the Member States relating in particular to religious rites, cultural traditions and regional heritage. - We therefore recommend the Code acknowledges that chickens are sentient beings - capable of feeling - and that the our interactions with them should pay full regard to this recognition. This overarching acknowledgement would sit well alongside, and strengthen, the existing referenced framework of the Five Freedoms on page.. Paragraph 9 of Schedule 1 of The Welfare of Farmed Animals (Wales) Regulations (007), states: 'Animals may only be kept for farming purposes if it can reasonably be expected, on the basis of their genotype or phenotype, that they can be kept without any detrimental effect on their health or welfare'. - Reference to this legislation should be included prior to clause 9 on page 8 (with regard to meat chickens) and also prior to paragraph 8 on page (with regard to meat breeding chickens). - An increasing number of higher welfare breeds have reached the market since the legislation has been introduced. The direction of the industry is moving, and campaigns by animal 1 protection organisations will only seek to create further change to call for higher welfare breeds. The Codes should acknowledge this change and endeavour to reflect future developments in this area, via the inclusion of an additional paragraph, which references breeds with demonstrably higher welfare outcomes, e.g. Hubbard JA7, JA87 and Aviagen Ranger Gold, Ranger Classic and Rambler Ranger PAGE 1 externalaffairscymru@rspca.org.uk

2 Scope The Code outlines expected practices with regard to those who farm conventionally reared meat chickens as defined by the legislation outlined throughout, but this good advice does not apply to those who farm commercially reared birds defined as extensive indoor (barn reared), free range, traditional free range, free range - total freedom and organic. There is an exception for this cohort granted on the provision that birds farmed in these systems are covered under other regulations. However, these other legal requirements do not cover many important areas concerning bird welfare that are covered in the Code, but at present are aimed at conventionally reared chickens, only. Therefore, explicit reference should be made on page 6 that these recommendations are best practice for all production systems. Whilst the RSPCA understands the Code s main purpose is to provide guidance on how to comply with the legislation, it believes the Code is such an important reference document for farmers that it should seek to provide best practice recommendations for all systems of production, many of which would benefit from the additional rigor applied to conventionally reared meat chickens. Whilst the RSPCA acknowledges that legislatively, the monitoring health and welfare of the birds at the slaughterhouse on page 19 only applies to conventionally reared meat birds, the welfare of birds from all production systems could benefit from post slaughter welfare monitoring. Consideration should be given on clause to include a suggestion that keepers of non-conventionally reared meat chickens may want to collect ante and post-mortem assessment information on their flocks if it is available so that they can monitor the level of conditions which affect the welfare of their flocks too. Welfare Outcome Assessment As welfare outcome assessment is swiftly becoming the industry norm, reference should be made in the Health section (p.1) to such accepted on-farm assessment protocols as Assurewel being incorporated into on farm welfare monitoring. Whilst the broiler industry has been receptive in adopting welfare outcome based measures in law (EU Broiler Directive), monitoring welfare should be a proactive process of continual welfare improvement (Main, et al., 01 ), rather than a reactive method of tackling the poorest performers. Projects like AssureWel have demonstrated that when multiple stakeholders promote the monitoring of animal based on farm, welfare outcomes improve significantly (Mullan, et al., 016 ). The Codes should aspire to improve welfare for broilers by actively encouraging welfare outcome assessment on farm. SPECIFIC FEEDBACK: Code number RSPCA Feedback 'For meat chickens, feed should not be withheld for more than 1 hours before the birds are slaughtered or delivered to a new farm. This period of 1 hours must be an inclusive period to include the catching, loading, transport lairaging and unloading time prior to slaughter' - Previously, this included the following sentence that 'Prior to transport water should be provided up to the start of the loading procedure'. It would be beneficial to retain this somewhere in this section. 6 Suggested amends to the clause which starts ' Lameness and leg disorders can be a key cause of poor welfare in meat chickens.' [It would be beneficial to retain the original wording 'are a major cause of poor welfare.' Whilst poor welfare could have any number of causes, where leg problems and lameness issues arise they do result in poor welfare.] In the standard commercial broiler reared up to 6 weeks of age this has been associated with selection for rapid growth and Poultry meat Marketing Standards

3 can be less of a problem in the slower grower strains. [It would be more objective to retain original wording data is available that demonstrates slower growing strains have fewer leg problems.] 6 This issue (restricted feed) would sit more appropriately in the breeding meat chicken section as it is more of an issue in breeding flocks. 69 'All meat chickens should be housed at light levels which allow them to see clearly and which stimulate activity,' should also include 'this can be achieved by lighting systems using natural or artificial lighting or a combination of both' Consideration should be given for recommending, as best practice the provision of natural light via windows in the house, as a guide, the light openings should correspond to at least % of the total floor area of the house. However, 6% should be a target. Natural light provides greater illumination and there is a growing body of evidence that chickens exhibit a qualitative preference for natural daylight over artificially lit environments. Supporting scientific evidence Illumination Vision is chickens dominant sense. The poultry eye is similar to that of the human eye. Chickens have well-developed colour vision and their eyes are designed for bright light conditions requiring a high level of illuminance to work to their full potential (Prescott, et al., 00). The SCAHAW report (000) concluded that brighter lighting (e.g. more than 100 lux) is important to stimulate activity In addition, the SCAHAW report states that welfare problems arise at light intensities below 0 lux. Increased activity can help reduce the incidence of leg disorders and contact dermatitis, such as hock and foot pad burn. It has also been reported that chickens have a greater preference for higher light levels of 00 lux and are less fearful at higher light intensities. Natural Light Natural light is itself is also likely to enrich the birds environment, as it provides a range of light levels in different areas within the house, which will change throughout the day, and provides a range of light levels for the performance of different behaviours. Further, stock-keepers have reported that they prefer working in a naturally lit environment as they can manage and inspect the more clearly and, in particular, it has been reported that it helps with the cleaning out process - enabling the operator to better inspect whether the house has been effectively cleaned and disinfected. Research conducted by Lewis & O Connell (011) demonstrated that chickens provided with natural light (average intensity of 8. lux) had increased activity levels, i.e. spent less time lying and more time standing. They found that the provision of natural light also led to an increase in the average frequency of locomotion, improved leg health, and did not affect the performance of aggressive behaviour (compared to chickens provided with artificial light: average light intensity of 11. lux). In addition, they reported the provision of natural light improved litter quality (lower moisture levels). Studies by researchers at Queen's University Belfast involving 16 paired broiler flocks also showed that birds in naturally lit sheds were significantly more active and had reduced gait scores, which indicated improved walking ability (Bailie & Weeks, 01). Further, they also reported a benefit of the increased activity and ground pecking/scratching resulting in significantly better litter quality. Bailie, Ball & O Connell (01) revealed that the provision of natural light reduced litter moisture, as well as the proportion of time broilers spent lying, i.e. birds were more active. Consequently, broilers had better leg health, i.e. lower gait scores and a higher latency to lie.

4 They further demonstrated that providing natural light did not affect the levels of preening, resting and aggressive behaviour in broilers. - Bailie, C.L., Ball, M.E.E., & O Connell. 01. Influence of the provision of natural light and straw bales on activity levels and leg health in commercial broiler chickens. Animal, 7:, pp Prescott, N., Kristensen, H.H. and Wathes, C.M. 00. Light. In: Weeks, C. and Butterworth, A. (eds). Measuring and Auditing Broiler Welfare. CABI Publishing, UK, Scientific Committee on Animal Health and Animal Welfare (SCAHAW), 000, The Welfare of Chickens Kept for Meat Production (Broilers) Report - Lewis, C.L. and O Connell, N.E The influence of natural light and straw bales on the behaviour and leg health of broiler chickens. Poster presentation at UFAW Conference, Portsmouth 9-0 July. 71 Re: dawn and dusk light provisions, include 'Buildings that expose birds to natural daylight can effectively provide this transition and the natural wavelength light spectrum may have additional beneficial effects on bird behaviour, such as increased activity levels and improved leg health in addition to improved litter quality.' 76 Whilst the legislation permits a stocking density of up to 9kg/m, the Codes do not provide firm guidance informed by scientific evidence that when stocking density exceeds 0kg/m there is a steep rise in the frequency of serious welfare problems, regardless of the quality of management or the housing specification. The Codes have a role to provide farmers not only with the tool for how to comply with the legislation, but also how to understand the complex interactions that inform the legislation, so that they in turn are suitably informed in order to make better management decisions for welfare. The impact of stocking density on welfare is so overarching that it behoves the Codes to make a clear judgement on best practice (a maximum stocking density of 0kg/m), regardless of legally permitted upper limits. Supporting scientific evidence Behavioural Impacts Providing limited space allowance, e.g. stocking above 0kg/m, primarily impacts on bird behaviour and hinders the chickens ability to freely perform a range of behaviours, such as walking, running, lying stretched out, stretching their wings and preening, which will not be improved with better environmental control systems. Further, it denies them the opportunity to lie and rest without being disturbed by other birds (SCAHAW, 000; Defra, 00). Broilers will jump across a high barrier to get away from a crowded area to one where there s fewer chickens (Buijs et al., 011), indicating they want to be in an area that s less crowded. This is noteworthy as they are normally reluctant to jump a high barrier to get at food unless they ve been food deprived for a considerable period, such as six hours. Health Impacts Less space also limits the opportunity to exercise, and less active birds are more prone to lameness (Defra, 00). The incidence of hock and foot pad burn are positively correlated with stocking density (Haslam, 00) - increasing significantly between 0kg/m and 8kg/m (RSPCA, 006). Marian Dawkin's work on stocking density (00) also supports a maximum stocking density of 0kg/m for improved health outcomes. Increasing stocking densities have also been shown to be significantly associated with higher gait scores (Knowles et al., 008). The SCAHAW (000) Report concluded, 'It is clear from the behaviour and leg disorder studies that stocking density must be kg/m or lower for major welfare problems to be largely avoided and that above 0kg/m, even with very good environmental control systems, there is a steep rise in the frequency of serious problems The greatest threat to broiler welfare due to behavioural restriction would appear to be likely constraints on locomotor and litter directed

5 activities caused by high stocking densities, and consequences for leg weakness, poor litter quality and contact dermatitis'. - Buijs, S., Keeling, L.J., & Tuyttens, F.A.M., (011) Using motivation to feed as a way to assess the importance of space for broiler chickens. Animal Behaviour, 81, Dawkins, M.S., Donnelly, C.A. and Jones, T.A. (00) Chicken welfare is influenced more by housing conditions than by stocking density. Nature 7: - - Defra (00) Stocking density and welfare in broilers. UK: Defra (AW019). - Haslam, S. (011) Management and welfare of farm animals (th ed). UFAW, London. - Knowles, T.G., Kestin, S.C., Haslam, S.M., Brown, S.N., Green, L.E., et al (008) Leg disorders in broiler chickens: prevalence, risk factors and prevention. PLoS ONE, (): e1. doi:10.171/journal.pone RSPCA, (006) Everyone s a winner. How rearing chickens to higher welfare standards can benefit the chicken, producer, retailer and consumer. UK: RSPCA. - Scientific Committee on Animal Health and Animal Welfare (SCAHAW), 000, The Welfare of Chickens Kept for Meat Production (Broilers) Report 78 The RSPCA would welcome the retention of previous suggested wording to accompany this paragraph: 'Thinning is stressful for the birds and should be avoided.' And the previous paragraph: 'Deliberately placing a high number of chicks and routinely 'thinning' or depleting should be avoided as this causes unnecessary distress to the birds and may result in stocking densities that are too high. In addition this practice is more likely to be associated with poor litter management, associated conditions such as pododermatitis and with increased levels of lameness. p.0 Heading: 'Additional recommendations for extensive indoor systems' - this title seems out of place given that there is no suggested content. p.1 Heading: 'Additional recommendations for breeding and grandparent chickens' - additional recommendations for meat breeding and grandparent chickens on page should clearly state that slower growing breeds should be considered as a best practice method of managing welfare, rather than the comprehensive list of recommendations which address chronic welfare issues in breeder flocks, which manage rather than address the root cause of the welfare issue (e.g. breeds with fast growth rates) 9. Replace the word controlled with restricted p. Heading: 'Aggression, injurious pecking and environmental enrichment' - The Code outlines expected practices with regard to breeding and grandparent chickens, but this good advice should also apply to those who farm any system of conventional meat chicken, including those under 'extensive indoor (barn reared), free range, traditional free range, free range - total freedom and organic.' The exception for the latter cohort is granted on the provision that birds farmed in these systems are covered under other regulations. However, these other legal 6 requirements (Poultry meat Marketing Standards ) do not cover many important areas concerning bird welfare that are covered in the Code, but at present are aimed at conventionally reared chickens, only. 6