Search | Site Info | Site Map

MENU

HOMEPAGE

Animal Health/
Welfare/Zoonoses

Environment

Land Reform

Social/
Economic/
Political

Food

Science

Fishing

Tourism

Education

Cultybraggan
Farm

Trade

Book Reviews

Light Relief

Links

Glossary

Correspondence

Vacancies

Contact Us

Get Acrobat Reader

 

 

Back to ANIMAL HEALTH - GENERAL Homepage

Draft Animal Health and Welfare (Scotland) Bill

Response to SEERAD consultation document

Dr James Irvine

Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire

Filed 04 Jul 05
©www.land-care.org.uk

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 farm’s 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 critical level.

Figure 1:

Cultybraggan cattle chewing the cud in the sun
To enlarge Click Here
©Kimpton Graphics

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 it.

Biosecurity

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 nation’s 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 and Excise.

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 emergency programme.

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 people.

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.

Bovine Tuberculosis

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 Government’s 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 prevalent.

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 government’s 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 Government’s 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 contamination.

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 farm’s livestock breeding programme, with major economic consequences and adverse effects on animal health and welfare.

Again, the draft Bill is more of an animal rights charter than being primarily directed towards improving animal health and welfare.

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 government’s policy regarding the reform of the CAP (12).

Unless it is the deliberate intention of Government to bring about the demise of Scotland’s 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 Scotland’s 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 vet’s 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 farm.

Corporate Responsibility

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 Government’s action in heightening the public’s expectations as to what might constitute an offence, and facilitating the public’s 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 livestock farming.

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 Act

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 Johne’s 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 Johne’s disease, was not taken. Consequently the government authorities have no real idea just how prevalent it is in UK cattle. However, as Johne’s 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 or health

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 herd’s closed status would be lost and the risk of importing infection thereby increased.

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 Scotland’s 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 their care.

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 that.

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 animal’s 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 government’s 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 27:

“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.

Stakeholders

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 (20):

"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 Scotland’s 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 technology”

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 Scotland’s farmed livestock. Introducing further bureaucratic regulation, backed by greater legal powers is not necessarily the best way forward and could be counter-productive.

©www.land-care.org.uk

References

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
www.scotland.gov.uk

2. SEERAD (2005). Draft Animal Health and Welfare (Scotland) Bill Consultation: Draft Bill.
ISBN 0-7559-2555-6

3. Cunningham, Ian (2002). Royal Society of Edinburgh Inquiry into Foot and Mouth Disease in Scotland.
http://www.royalsoced.ac.uk

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 Here

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 Click Here to View

8. DEFRA (2005). Provisional TB statistics for Great Britain. 02 June 2005
www.defra.gov.uk/animalh/tb/index.htm

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.
http:/www.royalsoc.ac uk

12. Irvine, James (2005). Peter Cook discusses the economic realities facing suckler herd farmers in Scotland.
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 03 Jun 05, www.land-care.org.uk Click 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, www.land-care.org.uk Click Here to View

14. DEFRA (2005). New animal health and welfare advisory group appointed.
http://www.defra.gov.uk/news/2005/050606a.htm

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, www.land-care.org.uk Click 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 Click 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 Click Here to View

18. Editorial (2005). SEERAD reneges on terms of environmental scheme.
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 31 May 05, www.land-care.org.uk Click 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, www.land-care.org.uk Click 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 Click Here to View

Finis