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Draft Animal Health and Welfare (Scotland) Bill
Response to SEERAD consultation document
Dr James Irvine
Teviot Scientific, Cultybraggan Farm, Comrie,
Filed 04 Jul 05
The Scottish Environment and Rural Affairs Department
(SEERAD) published the Draft Animal Health and Welfare (Scotland)
Bill Consultation: Consultation Paper and Draft Regulatory Impact
Assessment (1) and the draft Bill (2)
in May 2005.
The closing date for responses to the consultation
was 4th July 2005.
Background to this response
The following comments are made from the perspective
of my situation as a livestock farmer in Perthshire. The farm occupies
some 520 acres of less favoured ground plus substantial
additional summer grazing, allowing the livestock density to come
within the highest grade of extensification as defined by SEERAD.
The farm has run a herd of some 120 suckler cows
(together with their calves) and a number of in-calf heifers either
for sale or as replacements. Approximately 25% of the herd is pedigree
Aberdeen Angus, 25% pedigree Limousin and the remaining 50% are
commercial crosses between the two breeds. An appropriate number
of Aberdeen Angus and Limousin bulls are kept to prevent inbreeding
in this closed herd.
Currently the size of the herd is being downsized
as the farms response to the economic situation precipitated
by the reform of the Common Agricultural Policy (CAP). With the
introduction of the Single Farm Payment (SFP), characterised by
decoupling from production and declining subsidy payments year on
year, livestock farming in the context of this farm has become even
more difficult in terms of economics. As the economics of farming
in Scotland have become increasingly more precarious, the availability
of a skilled workforce has also declined such as to now reach a
Cultybraggan cattle chewing the cud
in the sun
To enlarge Click Here
The herd at Cultybraggan has been built up over
the past 17 years. For the past 5 years its has been closed,
meaning that no cattle have been introduced into the herd from other
farms or from auction markets. This is one of the most important
measures that can be taken towards achieving a high standard of
animal health through minimising the risk of importing disease.
I played a role in initiating the Royal Society of Edinburgh Inquiry
into Foot and Mouth Disease in Scotland and served on the committee
that produced the report (3)
From this background of concern and care over
the important matter of farm livestock health and welfare, I make
the following points with regard to the draft Animal Health and
Welfare (Scotland) Bill and the Consultation Document that accompanies
Foot and Mouth disease (FMD)
In the context of the draft Bill the government
authorities intend to impose punitive legislation on livestock farmers
without they themselves taking satisfactory measures to ensure the
protection of the nations livestock from exposure to highly
infectious agents, such as the virus of Foot and Mouth Disease (FMD).
Furthermore it is unacceptable that the government authorities seek
exemption for themselves and their officials from any legislative
action with regard to animal health and welfare issues.
Central to the draft Bill is the power it proposes
to give to government officials to adopt a slaughter policy
to ring-fence disease beyond a disease infected area if, in
their view, it was thought necessary. It is clearly stated that
this could be over a very wide area, with the potential of reproducing
the horrific scenes of the UK FMD epidemic of 2001 and the alleged
numerous instances of associated cruelty to livestock.
The management of the FMD UK2001 epidemic involved
the slaughter of some 10 million cattle and sheep, only a tiny proportion
of which were ever tested for FMD virus, and of these only very
few were shown to be positive. Massive distress was caused to farmers,
to the rural community and to the general public. It created horror
in the minds of people throughout the world. The inappropriateness
of the contiguous cull in FMD UK 2001 has been well described and
its inappropriateness substantiated by peer reviewed papers (4).
The proposed new legislation on animal health
and welfare would only be acceptable if the government authorities
had in the past 4 years effectively:
1. put in place measures to greatly reduce the risk of the FMD
virus (or indeed any other highly contagious virus) from entering
the UK, and
2. had adopted modern technology to rapidly detect and identify
the virus responsible, so that the nature of the spread of the
disease could be accurately followed and emergency vaccination
started without delay if deemed appropriate.
So far the government authorities have only paid
lip-service to these important issues, with for example the deployment
of a minimal number of sniffer dogs to detect the continued importation
of large quantities of illegal meat products into the UK (5).
In item 14 of the Consultation Document, reference
is made to Biosecurity Codes that SEERAD wish to impose on livestock
farmers, but seriously fails to effectively apply such a code to
government operations - albeit through another department, Customs
It is irresponsible of government to attempt to
obtain a statutory right to slaughter livestock in order to ring-fence
disease over an indefinite area without applying modern, available
technology that is capable of accurately and rapidly identifying
where the virus is and its exact character and pattern of spread.
As things stand at the moment in the UK, it will
take 5 days from the time a sample is received in the specialist
laboratory before the strain and the type of FMD virus can be identified
by the old gold standard technique of tissue culture.
According to Roger Breeze (6), previously
of the US Department of Agriculture, within the entire USA it would
be possible to get mobile real-time PCR technology to a suspected
case of FMD within 4 hours, and to confirm or exclude the diagnosis
of FMD within a few hours thereafter. Samples could be flown to
the central specialised laboratory and within 6 hours of their arrival,
the full genotpye of the virus could be established, indicating
which vaccine would be required for an emergency vaccination-to
-live programme to control further spread. Using internet and global
positioning technology and repeated sampling, much more precise
information as to the spread of the infection would be available,
particularly in view of the fact that real-time PCR technology will
detect FMD viral infection in the preclinical phase. The test can
be carried out on farm with advice from the central specialised
laboratory using broadband internet technology.
Technology is also available that will distinguish
infected from vaccinated livestock, further facilitating a vaccinate-to-live
Using such technology the number of livestock
that would need to be slaughtered would be greatly reduced to the
benefit of animal health and welfare, and also to the benefit of
The Consultation Document contains what should
now be regarded as outdated information concerning modern diagnostic
technology, talking about where the infection is 'masked'
by vaccination. In reality a virus would have great difficulty
in spreading through a vaccinated population provided the vaccination
rate was higher than 80%.
It is difficult to explain why the UK authorities
are so reluctant to adopt modern technology, apparently being restrained
by the desire for inappropriate validation and trying
to reinvent technology that is already established in other parts
of the world. It is unclear whether this is due to ignorance, professional
jealousy amongst its chosen advisers, through unwillingness to commit
funds for the purpose, or whether it is due to obfuscation within
the EC for political or other reasons.
It is relevant that no mock exercise, either north
or south of the border, to test the effectiveness of FMD Contingency
Plans has to date ever taken vaccination as an emergency procedure
into consideration, hiding behind the untruth that there would be
too many possible scenarios to do this. As Robert Breeze pointed
out in his excellent article referred to above, the USA would have
a catastrophic disaster on its hands if the authorities there followed
the UK example. Time, with the immediate use of modern technology,
is of the essence.
While concentrating in detail on how to prosecute
and sentence livestock farmers (so as to ensure that they are put
out of business never to return) should they be found to have transgressed
the terms of the Bill at whatever level, the Government proposes
that their own officials be exempt from all criminal procedures
. During the FMD UK2001 epidemic there were numerous alleged acts
of cruelty committed by government officials, many of whom were
unskilled in livestock management. Also conspicuous was the absence
of the RSPCA (England & Wales) and of the SPCA (Scotland) during
the FMD UK2001. It is not acceptable that there be one rule for
farmers and another for government officials - at least not in a
democracy which the UK claims to have.
What is particularly concerning is the apparent
intention to pursue charges against farmers and then to leave it
to the courts - with all the delays, stress and expense involved
on the part of the livestock farmer - to sort matters out. And apparently
this can be done by police without any veterinary input.
The control of bovine tuberculosis (bTB) - or
rather the lack of it - is another striking example of how the government
authorities impose legislative control over farmers with the slaughter
of their livestock in the absence of the government themselves taking
effective steps to control the spread of the disease. I refer to
the UK Governments discredited 10 year Strategy for the control
of bTB, while the incidence of the disease in parts of England escalates
alarmingly. It must be only a matter of time before the number of
cases of bTB in Scotland rises and the wildlife is infected.
There is more than sufficient evidence since 1984
that badgers are contributing to the spread of the disease in cattle
(7). However, badgers are classified as
a 'protected species' and this apparently takes precedence over
all else. The Government, not wishing to face up to the powerful
animal rights organisations that have done so much damage to the
UK pharmacological industry and who have allegedly given large funds
to support the Labour party, takes the easier but only partially
effective course of tightening the restrictions on farmers. But
even when a farmer has run a closed herd for years, the herd can
become infected with bTB from infected badgers in the area, as shown
by events in the south west of England where bTB is particularly
Figures released by the Department of Environment
Food and Rural Affairs (DEFRA) on June 2nd of this year indicate
that, by April 30, there had been 1581 suspected new herd TB incidents
recorded in Great Britain this year. Of these, 867 had been confirmed
and 274 were still awaiting the results of culture testing. This
compared to 1437 suspected new herd incidents in 2004, of which
754 were confirmed. Also, 19,279 herds had been tested by April
30 (20,497 in 2004), amounting to 2,092,526 cattle (compared with
2,107,946 in the same period last year). More herds were under restrictions
as a result of TB in the period April 1 to April 30 - 3,634 this
year compared with 3,353 last year (8).
It is clear that the bias in the mindset of the
government authorities not to effectively tackle the problem of
TB in badgers and its transmission to cattle is illogical. It is
causing great damage to animal health and welfare, as well as great
stress to farmers who care for livestock and the economics of their
businesses, made worse by the intention of the government to reduce
the levels of compensation payments for cattle slaughtered under
the governments instruction.
According to the Veterinary Record, 419 vets have
written to Mrs Beckett, UK Secretary of State for Environment, Food
and Rural Affairs (DEFRA), expressing a vote of no confidence
in the Governments policy on bTB. They say that TB in cattle
is spreading out of control and that if the government continues
with its present policy the situation will get worse and that infection
and disease will spread in an unfettered manner in the badger population
until it is so widespread that it also becomes uncontrollable (9).
The badger vaccination study that DEFRA has recently
announced (10) to extend over a period of 3 years
is highly unlikely to be successful, given the anticipated vaccination
success rate to be only 70% or even less.
With this imbalance of approach to the problem
of controlling bTB, it is not appropriate that the proposed legislation
is so one sided. There does not appear to be any clause concerning
the compulsory slaughtering of TB infected wildlife, such as badgers.
Fallen Stock Scheme
The government introduced the fallen stock scheme
prohibiting the burying on farm of stock that die on the farm. The
logic for this is obscure. The reason given was on account of the
risk of the BSE infectious agent getting into the water supply.
However, the incidence of BSE is now so low in the UK (especially
in Scottish suckler herds) that the Over Thirty Months Scheme (OTMS)
is about to be lifted, enabling older cattle to enter the food chain.
The appropriate siting of an onfarm burial area would prevent such
But the consequence of the Fallen Stock Scheme
is that dead stock are collected by transport that goes from farm
to farm. At least some of such dead stock will have died of disease
that may be contagious. There is a significant risk of serious breaches
in biosecurity about which the farmer can do very little, but if
he does not comply with the scheme he is liable to be severely penalised.
Clearly the Scottish Executive chooses to apply
the "precautionary principle" so beloved of the Green
Movement according to political expediency.
Animal Health and Welfare can be compromised by the actions of
the public without adequate remedy
With the establishment of the Land Reform (Scotland)
Act there is now extensive access by the public to most farmland
by legal right. This includes fields with livestock, with the proviso
that the public should behave responsibly as they themselves assess
what is or what is not responsible within certain broad guidelines.
But most of the public have little idea how farms work and even
less about livestock. The "education, education, education"
about rural affairs so disingenuously promised by the Scottish Executive
agency Scottish Natural Heritage (SNH) never materialised - and
probably never will.
Leaving farm gates as the public found them, and
taking litter home, are admirable recommendations, but should it
not be a criminal offence to so interfere with farm gates or leave
such litter (including remnants of food, plastic bags or glass bottles
etc) that the biosecurity of the farm is compromised? Leaving gates
other than in the condition in which they were found can lead to
serious disruption of the farms livestock breeding programme,
with major economic consequences and adverse effects on animal health
Again, the draft Bill is more of an animal rights
charter than being primarily directed towards improving animal health
High standards of animal health and welfare on farms are dependent
on a profitable livestock industry
Sir Brian Follet in the Royal Society Report of
its inquiry into infectious diseases of livestock (11)
emphasised that high standards of animal health and welfare on farms
can only be achieved in the presence of a profitable livestock industry.
The fact is that the livestock industry in the UK (including Scotland)
is far from profitable, and the economic situation is forecast to
be dire during the next 4- 5 years as a consequence of the governments
policy regarding the reform of the CAP (12).
Unless it is the deliberate intention of Government
to bring about the demise of Scotlands livestock industry,
it is inappropriate to lay on more gold-plating of existing animal
health and welfare legislation. Scotland in particular has a world
renowned reputation for the quality of its livestock. That can only
be achieved by the continued care over health and welfare issues
that has been characteristic of the Scottish industry for generations.
Yet the economics of farming in the UK is one of the worst in Europe.
Higher standards of animal health and welfare will be achieved by
letting the industry prosper rather than introducing ever more bureaucratic
control from Government, who sees land use in a context other than
farming, but rather as a pleasure ground for the urban elite (13).
Gold-plating the standards for animal health and
welfare, increasing the number of onfarm inspections by government
officials, increasing the threat of prosecution of all concerned
(including corporate members) that could lead to them being banned
from handling livestock in the future (as well as destroying their
careers as investors in the livestock industry and the management
of Scotlands land) is not the way forward.
Animal Welfare and Health should both be part
of a co-operative exercise carried out by the farmer and the farm
vet, not imposed by Codes of Practice initiated by Scottish Ministers
and enforced by government inspectors with a range of powers
in respect to arrest, powers of entry and to apply for a warrant.
The Government allegedly wants vets to have an increased role in
farm livestock care - the way to do this is to put greater trust
in the vets ability to advise on prophylaxis and to treat
where necessary. Putting the responsibility onto government inspectors
(who apparently do not need to take into consideration the opinion
of the farm vet) is not acceptable. This is particularly so if the
government officer with the power to raise legal charges against
farmers has no recognised chartered veterinary qualification. Trying
to impose severe legislative measures on an industry that the government
through its own actions is failing to adequately support will simply
destroy the industry.
The draft Bill is an Animal Rights Charter -
not a Charter of Animal Health and Welfare for livestock on farms.
The draft Bill is a prosecution based Bill, not
one based on an active collaboration between veterinarian and the
As mentioned above the draft Bill seeks to include
corporate responsibility for any breach of Animal Health and Welfare
legislation. Such a clause would appear to be generated by a desire
to be vindictive rather than through applying common sense.
Due to the precarious nature of the economics
of farming in Scotland - especially livestock farming - many farms
are supported financially by other types of business, both in relation
to employment of staff and the capital assets involved. The directors
of a company that has farming within its range of business activities
may well employ staff or contractors who present evidence of being
competent in caring for livestock, and provided them with the facilities
that may be required for doing so . In the event of an employee
of the company or a contractor being prosecuted for breach of the
proposed Animal Health and Welfare Bill (at whatever level) the
directors of the company would also be convicted and prevented from
being responsible (however indirectly) for any future enterprise
that involved the care of livestock. Thus, if the terms of the draft
Bill were applied the farm would be ruined and the investment that
the farm needs for survival would be withdrawn.
The problem is made worse by the Governments
action in heightening the publics expectations as to what
might constitute an offence, and facilitating the publics
ability to take action on a basis of poor education on matters concerning
livestock husbandry. It is not possible to have a viable industry
with a background of draconian litigation against those who have
done their best to support livestock farming and through no fault
of their own find themselves with a criminal record and unable to
continue as directors of a company that includes the support of
This is another reason why the draft Bill is
really a Bill for animal rights organisations, who generally have
no significant investments in the farming industry. To that extent
the draft Bill fails in its stated aim: to improve animal health
and welfare in Scotland as far as farmed livestock is concerned.
Concern as to how the Bill may be implemented if it becomes an
While Scotland will have its own Bill, there are
ominous signs as to how such a Bill may be interpreted both north
and south of the border. This is particularly so in relation to
the strong influence the Soil Association apparently has in relation
to the thinking of both DEFRA and SEERAD. It is to be remembered
that health and welfare issues in the organic movement are based
on the principle of homeopathy, and not on the full application
of modern veterinary medical science.
South of the border (England) UK Minister, Ben
Bradshaw, appointed Helen Browning as chairman of the Animal Health
and Welfare Advisory Group (14). She is
a director of the Soil Association. At a recent conference she gave
a paper that revealed her bias against conventional farming methods,
which are based on science and which have served Scotland well over
many generations (15).
North of the border (Scotland) a similar bias
on the part of the Scottish Executive was evident at the same conference
referred to above that was jointly presented by the Soil Association,
the Scottish Agricultural College and Scottish Natural Heritage
(15). Concerns about the standards of animal health
and welfare within the organic movement have been expressed by Dr
Ruth Watkins (16) and Caithness vet Frank Stephen
(17) among others.
So far, the appointment to the chair of the Scottish
Animal Health and Welfare Advisory Group has not been announced.
No doubt the appointment will be made by a Scottish Executive Minister.
But the consistent bias on the part of the Scottish Executive towards
organic farming is likely to mean that the word "independent"
as applied to such an appointment will be just as much a misnomer
as south of the border.
Power to perform multiple tests on samples without the knowledge
of the farmer
This is a matter of concern in view of the lack
of trust that now exists between farmers and the Scottish Executive.
This lack of trust has been greatly increased by the manner in which
the Scottish Executive sold decoupling from production
to farmers, promising a great reduction in bureaucracy whereas the
reverse has been the case. Far from promoting a prosperous
sustainable agricultural industry in Scotland the economics
of farming in Scotland have been greatly compromised in favour of
biodiversity and conservation as advocated
by such lobby groups as Environment LINK, who carry little or no
personal financial responsibility for land management. Lack of trust
was further increased when SEERAD reneged on the financial terms
of a five year environmental contract, indicating that they were
willing and capable of altering the terms of a contract at will
(18). Tony Blair seems all too ready to
sell UK farming down-the- line as little more than a pawn in his
tiff with France's President Jacques Chirac, who accuses UK Prime
Minister Blair of somehow engineering the "non" vote in
France and the "ney" vote in Holland in relation to the
proposed European Constitution.
It could be that the government officials would
like to test cattle for Johnes disease in samples taken under
statute for brucellosis testing. However, in the absence over the
past many decades of a cost effective and practical programme for
controlling this important disease, it could be that the government
officials will resort to draconian measures with the slaughter of
many livestock as their preferred option - possibly enforced under
the terms of the draft Bill that is under discussion.
Although large numbers of cattle in the OTMS have
been examined for evidence of BSE, apparently the opportunity to
assess the prevalence of Johnes disease, was not taken. Consequently
the government authorities have no real idea just how prevalent
it is in UK cattle. However, as Johnes is now thought to be
so prevalent among UK cattle such that it may be getting out of
control, there is a possibility that the government authorities,
using the clause in the proposed Bill that would permit testing
without the owner's knowledge, will adopt a draconian slaughter
policy in the attempt to make good their own lack of positive co-operation
with farmers to achieve adequate surveillance.
While it sounds logical enough to test samples
for a range of diseases, the concern must be what government officials
may do with the information.
Power to seize animals considered to be at risk in terms of welfare
In terms of farm livestock, this is another worrying
feature of the draft Bill. Apparently this can be done by a policeman
or by a member of the SPCA who may not have any chartered veterinarian
qualification. In addition to that, there is the question as to
where, if seized by the officials, the animal is kept. Also , if
an animal is seized there will be associated biosecurity problems
as a consequence. Even worse, if the animal is returned to a closed
herd, nothing of significance having been found, then the herds
closed status would be lost and the risk of importing infection
Definition of an animal and exclusions
While fish are currently excluded from the affects
of the Bill, it would be very easy at a future review for this exclusion
to be dropped, destroying Scotlands renowned river and loch
fishing at a stroke - much in the same way as the Scottish Parliament
has banned hunting to the detriment of the environment, livestock
health and welfare and even that of the fox that it was supposed
to protect from alleged cruelty.
Again it would appear that the Bill is drawn up
more as an animal rights charter rather than as a practical and
realistic way of improving animal health and welfare of farmed livestock.
What is the real agenda behind the draft Bill?
SEERAD (together with its agency SNH) and the
supposedly independent Food Standards Agency (Scotland)
were represented in force at the conference already referred to.
Presented jointly by the Soil Association, the Scottish Agricultural
College and Scottish Natural Heritage, this conference was held
in May 2005 and was entitled "Farming, food and Health: an
indivisible chain (15). But government officials failed to
show up in any form or shape at the Scottish Countryside Alliance
conference Getting the balance right: rural Scotland 2005
where a wide range of highly relevant topics were discussed the
previous month (19).
The Soil Association is not known for its application
of good science. Indeed, there is no good scientific basis to support
a claim that organic farming improves either human or animal health
or welfare when compared to conventional farming on Scotland's less
favoured land where extensification criteria (in terms of low numbers
of cattle per acre) are easily met. Indeed, by supporting the practice
of homeopathy in the care of animals, the organic movement is charged
with denying aspects of modern veterinary medicine to animals in
As mentioned above, UK Minister Ben Bradshaw has
appointed Helen Browning as chairman of the advisory Animal Health
& Welfare Advisory Group in England. Helen Browning is a Director
of the Soil Association and has displayed more marketing skills
than scientific understanding (15).
The consultation document relating to the draft
Bill states on Para 88, point 3, page 54:
Using scientific knowledge - the Bill encourages the use
of scientific knowledge to develop policy
Regrettably SEERAD's keenness on promoting organic
farming contradicts that high sounding aim. As described by Dr Watkins
in relation to her experience with organic farming, the organic
movement is "anti-science (16).
With this background of prejudice against conventional
farming in Scotland it is difficult to know just what the real agenda
is behind the draft Animal Health and Welfare Bill. A degree of
healthy scepticism is appropriate.
Potential for the misuse of the Bill by the public
The draft Bill opens the door to abuse by the
public, through their lack of knowledge of livestock husbandry or
through malicious intent. A member of the public may not like the
local farmer because he uses pesticides on his crops or pastures,
albeit perfectly legitimately and according to good farming practice.
But the Soil Association may have so incited the idea that trace
elements of pesticides are harmful that the member of the public
wants to take action to promote the organic cause. Again,
a member of the public may not like the farmer because the farmer
may insist on the public behaving responsibly when they take access
to his farm. These scenarios, both of which have been facilitated
by the actions of Government, may well lead to malicious actions
by members of the public against the farmer. As presently written
the new darft Bill gives them an excellent opportunity to do just
Livestock, like people, can get ill or have accidents
that do not necessarily reflect on the care of those looking after
them. Furthermore, persons not knowledgeable about livestock seem
unaware of the differences in physiology between people and livestock:
nor of the features of the natural habitat of livestock, their living
requirements or indeed of their bodily functions. One essential
difference is that people have anal sphincters while cattle do not.
Cattle have powerful internal heating mechanisms and their 'feet'
are very different from those of humans. The skin and hair of certain
breeds of cattle are much more appropriate for outwintering than
that of any human being. Physiologically, rather than necessarily
pathologically, the weight and condition of cattle may vary according
to the time of year and whether or not they are in-calf or are suckling
single calves or twins. Cattle may opt to stand in mud while humans
rarely willingly do so.
The draft Bill extends the power of government
officials to seize animals if it is considered that an animals
state of welfare or health is not satisfactory. Members of the public
may thereby be encouraged to report any concerns they may have to
the authorities more readily than at present. Livestock farmers
could find this form of harassment difficult to contend with.
While the consultation document refers to a possible
increase in the work of government officials, it makes no reference
to the increased work load and anxiety imposed upon the livestock
farmer with visits from SPCA, police or other officials based on
false alarms but where the potential exists to destroy his livelihood.
As already emphasised, the present time is not the time to impose
such an additional burden on livestock farmers - or their will be
even fewer livestock farmers.
Compensation payments would be reduced
The consultation document infers that implementation
of the Bill should enable compensation payments to be reduced. It
is not at all clear how. Indeed the governments continued
efforts to reduce the schedule of compensation payments to farmers
in relation to a range of diseases - such as bTB, BSE or scrapie
- is a strong disincentive for farmers to co-operate, particularly
if they have valuable livestock.
The effect of the Bill on farm economics
The Consultation Document states on Page 40: Item
On the other hand, it was important that animal welfare
legislation was not so costly that it would place the Scottish
livestock industry at a commercial disadvantage, leading to the
importation of more animal products from countries with lower
animal welfare standards
In reality the Bill as drafted would do just that.
The Consultation Document provides the list of
organisations consulted by SEERAD over the draft document. Some
1000 organisations are listed in 11 double column pages. The majority
of these organisations have little relevance to farming, and even
fewer have any economic responsibilities in relation to farming.
The result is a draft Bill that imposes far more restrictions and
obligations on livestock farmers than is either appropriate or reasonable.
Tim Greet, President of the British Veterinary
Association (BVA), when addressing the BVA congress in 2004, said
"The current Government fashion for stakeholders meetings
provides single interest groups with an ideal platform to influence
Government thinking: we must be aware of the potential of this
lobby to distort the facts"
Licences for livestock shows, marts etc
What do the conditions for awarding such licences
involve? Such a clause provides the opportunity for SEERAD to impose
conditions that are unrealistic and likely to lead to the further
demise of Scotlands livestock industry. There is now such
a lack of trust between SEERAD and farmers that it would be unwise
to encourage further opportunities for increased bureaucratic control.
Lack of investment in technology
Animal welfare does not involve rapidly changing modern
This statement within the consultation document
reveals the lamentable mindset within SEERAD. There has been a dearth
of investment in the technology of animal welfare and health within
the UK, or even in the application of the technology developed abroad.
This is particularly so in relation to FMD. It is also evident in
just how long it has taken the UK to get up to speed in detecting
BSE in relation to cattle over thirty months of age entering the
food chain, although comparable arrangements have been in place
on the continent of Europe for many years.
Although improved laboratory facilities have been
provided in Scotland, it is not clear that there has been a commensurate
development in terms of research relevant to improving the health
and welfare of Scotlands farmed livestock. Introducing further
bureaucratic regulation, backed by greater legal powers is not necessarily
the best way forward and could be counter-productive.
To facilitate access a number of the references
listed below are to other papers on this website. These papers
may give a wider reading list.
1. SEERAD (2005). Draft
Animal Health and Welfare (Scotland) Bill Consultation: Consultation
Paper and Draft Regulatory Impact Assessment.
ISBN 0 7559-2554-8
2. SEERAD (2005). Draft Animal
Health and Welfare (Scotland) Bill Consultation: Draft Bill.
3. Cunningham, Ian (2002). Royal
Society of Edinburgh Inquiry into Foot and Mouth Disease in Scotland.
4. Mitchell, A.R.(2005). FMD and
the contiguous cull.
Veterinary Record 156: pp 847-848.
5. Irvine, James (2005). Comments
on: "Stopping illegal imports of animal products into into
Great Britain. UK National Audit Office Report."
See FMD Homepage, filed 25 Mar 05, www.land-care.org.uk Click
Here to View
6. Breeze, Roger (2004). Agroterrorism:
betting far more than the farm.
Biosecurity and bioterrorism: biodefense strategy, practice and
science: Vol 2: pp251-264
To view this article in pdf format Click
7. Irvine, James (2003). TB in
cattle and badgers: Zuckerman Report (1980) revisited.
See TUBERCULOSIS Homepage, filed 10 Mar 03, www.land-care.org.uk
Here to View
8. DEFRA (2005). Provisional TB
statistics for Great Britain. 02 June 2005
9. Leader (2005). Bovine TB: recommendations
for premovement testing. Latest figures.
Veterinary Record, vol 156, p754 (11th June).
10. Leader (2005). Bovine TB:
badger vaccination study announced.
Veterinary Record, vol 156: p790. (18th June).
11. Follet, Brian (2002). Royal
Society Inquiry into infectious diseases of livestock.
12. Irvine, James (2005). Peter
Cook discusses the economic realities facing suckler herd farmers
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 03 Jun 05,
Here to View
13. Irvine, James (2005). Director
of National Institute of Economic and Social Research says that
"the UK would be better off without farming" and that
"farmers get paid for nothing".
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 17 Jun 05,
Here to View
14. DEFRA (2005). New animal
health and welfare advisory group appointed.
15. Irvine, James (2005). The
unhealthy relationships between the Scottish Executive, the Soil
Association, the Scottish Agricultural College, the lobby group
Environment LINK and the media needs to be addressed. Review of
conference presented by Soil Association, Scottish Agricultural
College and Scottish Natural Heritage "Farming, food and health:
an indivisible chain" Battleby, Perth 25 May 2005
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 21 Jun 05,
Here to View
16. Watkins, Ruth (2005). Proposal
for a new organic status for hill farmers and conservation farmers:
organic B introduction and problems with the organic rules.
See ANIMAL HEALTH - GENERAL Homepage, filed 19 Jan 05, www.land-care.org.uk
Here to View
17. Irvine, James (2003). Concern
over organic livestock animal health.
See ANIMAL WELFARE Homepage, filed 09 Jun 03, www.land-care.org.uk
Here to View
18. Editorial (2005). SEERAD
reneges on terms of environmental scheme.
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 31 May 05,
Here to View
19. Irvine, James (2005). Comment
on the Roger Wheater/Alex Hogg session "Enhancing out environment:
holistic management or single species priorities". Scottish
Countryside Alliance Conference, "Getting the balance right:
rural Scotland 2005" 12th April, Royal Society of Edinburgh.
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 12 Apr 05,
Here to View
20. Editorial (2004). BVA
congress 2004: address by the President, Tim Greet.
See ANIMAL HEALTH - GENERAL Homepage, filed 14 Oct 04, www.land-care.org.uk
Here to View