1. Skip to content

National Secular Society

Challenging Religious Privilege

Farm Animal Welfare Council: Welfare Information About Livestock Products

30th August 2004

Dear Dr Clark

Welfare Information About Livestock Products

We appreciate being given the opportunity to respond to the above consultation. Our response is confined to the welfare and labelling considerations associated with ritual/religious slaughter.

We consider it indefensible that the Government disregarded the advice given by FAWC Report on the Welfare of Farmed Animals at Slaughter or Killing in recommendation 61 that slaughter without prior stunning be ban banned, as it is in many other major meat producing countries. The pretext the Government gave for justifying its actions was so weak, illogical and unconvincing it was clearly a subterfuge to hide the real reason: that it is much more concerned about upsetting religious groups than in preventing unnecessary pain to defenceless sentient animals. The full text of our response to their refusal follows in Appendix 1, which we stand by and wish to be regarded as an integral part of this submission.

Our answers to selected numbered questions are as follows:

1a. What are your views on the desirability of labelling according to welfare provenance? and

1g. What do you think might be the consequences for animal welfare of welfare labelling?

3c What aspects of welfare should labelling address? - At Slaughter? e.g. Slaughter with or without pre-stunning?

We do not accept the Government’s arguments, for which we do not believe there is any evidence, that "Banning this form of slaughter in the UK would result in people importing meat from countries where this practice is permitted, thus providing no improvement in animal welfare."

Until there is a ban on slaughter without prior stunning, labelling to alert consumers to this aspect is the best alternative to reduce the amount of food slaughtered in this way, and therefore the gratuitous suffering it entails.

1d. If you agree with welfare labelling, should such labelling be voluntary or mandatory and why? and

1f. Should labelling be applied to imported food as well as UK produced food?

These points are covered in Paras 11 and 12 of our response to DEFRA given in Appendix 1 and we repeat them here with an amplification shown in square brackets.

Labelling

"11. The Government has suggested a voluntary labelling system, to be agreed between consumer groups and industry, as a way of providing clear information to the public. We consider a labelling system to be absolutely essential, as we believe all consumers (not just religious ones) should have the right to choose what kind of meat they are purchasing and how it was killed. We call on the Government to require all products (not solely food for human consumption) containing meat that has been slaughtered without prior stunning to be so labelled whenever sold. This should extend to food menus in restaurants.

[This clearly includes imported meat and meat products. Unless these are included, much of the slaughtering of meat and meat products eaten in this country would simply be imported and it is not inconceivable that some of the slaughter methods could be even less humane than they are here. It might even cause a significant increase in the export of livestock from the UK, and such long range transportation of animals is notorious for the suffering caused. Moreover, a pernicious consequence of excluding imported meat from labelling regulations would be to give imported meat an unfair advantage over home produced meat.]

"12. Neither producers nor merchants are likely to be enthusiastic about setting up voluntary labelling schemes, as labelling food as kosher or halal might deter more consumers than it attracts. If they do so, however, it will generally be for cosmetic or PR reasons and it is difficult to see how they could persuade producers to label their products. Voluntary schemes have no effective sanction against those refusing to label, or those labelling falsely. A voluntary scheme will not only be toothless and ineffective, but is likely to disadvantage the scrupulous relative to those who unscrupulously mislabel. The proposal could therefore result in a worse situation than pertains now with no labelling.

4. What other relevant issues do you feel the Group should consider? We hope the FAWC will not only press the case for labelling as shown above but also continue to work for the ban on slaughter without pre-stunning that other countries have been able to introduce. We are happy to assist the FAWC in any way we can to achieve this, including providing additional copies of our detailed submissions covering this area. We have reproduced a recent article from the New Statesman castigating the Government for its refusal to accept FAWC’s recommendation on slaughter without prior stunning. A valid question posed by the article is why there is so little support from Animal Welfare organisations for a ban. Perhaps FAWC could work towards seeking their support, but we fear -- that for them -- as with the Government -- religious sensitivities trump all other considerations.

Yours sincerely,

Keith Porteous Wood
Executive Director

APPENDIX 1

LETTER FROM NSS TO DEFRA

Department for the Environment, Food and Rural Affairs Area 605,
1A Page Street
London SW1P 4PQ

24 June 2004

FAO Mr Tony Hughes

Dear Mr Hughes

Consultation on Government's Draft Response to the Farm Animal Welfare Council (FAWC) report on the Welfare of Farmed Animals at Slaughter or Killing

Introduction

1. This response is made in accordance with the public invitation issued by Defra on 1 April 2004.

2. The National Secular Society is pleased to see that Defra, on behalf of the Government, has accepted a large number of the recommendations proposed by the Farm Animal Welfare Council on 10 June 2003. We remain concerned however about the Government’s refusal to accept one of the most crucial recommendations, Recommendation 61 (Slaughter with Pre-stunning). Recommendation 61 (Slaughter with Pre-stunning)

3. We note that the Government acknowledges that animals slaughtered without pre-stunning experience "very significant pain and distress" and yet is still willing to permit religious groups to carry out this cruel practice on two grounds. We repeat these below in italics, followed with our own comments:

a) Banning this form of slaughter in the UK would result in people importing meat from countries where this practice is permitted, thus providing no improvement in animal welfare.

5. We do not consider this argument to be either cogent or sustainable from the standpoint of ethical principles. It could be used just as easily as a pretext to "justify" not imposing warranted restrictions relating to almost any product that is also obtainable from abroad. The argument could for example be applied with equal logic to "justify" not banning child pornography in the UK.

It is not even as if the FAWC or the Society are seeking for the UK to be the first country to set a moral example over pre-stunning. Other countries, to their credit, have already done this -- apparently without any ill effect - and the UK adding its weight might well encourage others to do so.

6. We acknowledge that there may well be some increase in imports of meat not pre-stunned if Recommendation 61 were introduced and enforced. It is significant, however, that the Government has given no indication that it has even considered (far less taken steps to find out) the scale of these increased imports relative to the reduction in not pre-stunned slaughter in the UK if the Recommendation were to be adopted. We do not think that the proportion would be high, especially given that such meat would be more expensive because of carriage costs. It is therefore likely that the implementation of Recommendation 61 would materially reduce the proportion of UK consumption of meat that is not pre-stunned, rather than not doing so as the Government is spuriously claiming.

7. We have been unable to find any underlying logic for the Government’s argument so are finding difficulty in convincing ourselves otherwise than that it is simply a cynical ruse, motivated by a disinclination to take on religious interests, which also lays bare an apparent complete indifference for the gratuitous suffering of animals that will directly result if the Government’s argument carries the day.

8. We call on the Government to have an independent study into the points raised in the paragraphs 5 and 6 and publish these and notify us before announcing their response to this consultation.

9. The argument is clearly an unprincipled position and we restate our view that this Government has a moral duty to uphold the principles of animal welfare, and implement changes to the current legislation to reduce animal cruelty, consistent with the findings of the FAWC research and without regard to individual religious viewpoints.

b) A ban on religious slaughter would not be consistent with the provision of the Human Rights Act 1998.

9. As the Government is aware, Article 9 of the European Convention allows people to manifest their religion in practice and observance but it also provides limitations to that freedom. We are not aware whether this matter has been tested in the Courts. We call on the Government to publish in detail any clear advice it has received as to whether the ban would be consistent with the HRA, or state publicly that it does not have specific legal advice on this point.

10. Were urge the Government to adopt Recommendation 61 in full. If it does not do so, however, we call for Recommendation 62 to be adopted in full, for both sheep and cattle. It is not clear from the Government’s response that it will accept this Recommendation even for cattle, merely that it sees merit in the argument. It is essential that both groups of animals are stunned immediately after being cut to reduce the length of time these sentient beings suffer.

Labelling

11. The Government has suggested a voluntary labelling system, to be agreed between consumer groups and industry, as a way of providing clear information to the public. We consider a labelling system to be absolutely essential, as we believe all consumers (not just religious ones) should have the right to choose what kind of meat they are purchasing and how it was killed. We call on the Government to require all products (not solely food for human consumption) containing meat that has been slaughtered without prior stunning to be so labelled whenever sold. This should extend to food menus in restaurants.

12. Neither producers nor merchants are likely to be enthusiastic about setting up voluntary labelling schemes, as the labelling food as kosher or halal might deter more consumers than it attracts. If they do so, however, it will generally be for cosmetic or PR reasons and it is difficult to see how they could persuade producers to label their products. Voluntary schemes have no effective sanction against those refusing to label, or those labelling falsely. A voluntary scheme will not only be toothless and ineffective, but is likely to disadvantage the scrupulous relative to those who unscrupulously mislabel. The proposal could therefore result in a worse situation than pertains now with no labelling.

Training

13. We also ask the Government to clarify its response to the series of recommendations on training for slaughterhouse staff (Recommendations 80-89) and urge that these recommendations be made more specific and prescriptive. It is important that staff are properly trained and assessed and we urge that the proposed guidance (Recommendation 80) be produced as soon as possible, and that qualification and assessments systems be reviewed without delay.

Conclusion

14. Overall, we believe the Government’s reluctance to act on this matter, despite clear evidence of cruelty to animals, is largely driven by a desire not to upset religious interests despite them representing a very small proportion of the population. Unacceptably, the victims are the rest of the meat-eating public (well over 90%) unaware of the method of slaughter that has been employed for the unlabelled food products, joints and cuts sold in supermarkets, local shops and communal dining facilities such as restaurants student canteens.

15. We urge the Government to take into account the growing interest in animal welfare. Customers are entitled to have the information to make informed choices, but by refusing to make labelling compulsory the Government is not assisting and may even be hindering them to exercise such choices in an informed way. The need for customers to be given information on which to make these choices is becoming increasingly pressing because of the escalating trend in catering establishments such as university and school canteens to provide only ritually slaughtered meat, even where not all of their patrons observe religions calling for such meat. Indeed, the refusal to enforce labelling removes any incentive to minimise slaughter without pre-stunning, and some slaughters kill more animals than is needed to fulfil the demand for ritually slaughtered meat.

16. We urge the Government to follow the example of New Zealand, Australia, Switzerland and Sweden, all of whom have made pre-stunning mandatory, and for whom we cannot find evidence of adverse consequences. If it chooses not to do so it must explain why the above countries can introduce a ban but the UK cannot. Even Saudi Arabia now accepts the practice, provided it does not kill the animal. Not all religious groups who require their animals to be bled to death are against pre-stunning and we think there is a cogent argument, based on animal welfare and current scientific evidence rather than centuries-old tradition, which makes adoption of pre-stunning an unarguable ethical imperative in a humane modern society.

17. This Government is keen for policy making to be based on evidence. We commend the steps already made to adopt the sensible Recommendations of the FAWC and ask that the Government takes a principled and necessary step further to end forthwith the proven cruel and inhumane practice of cutting an animal’s throat without pre-stunning.

18. In sum, therefore, our response is:

a) Government to adopt Recommendation 61 in full immediately.

b) Government to introduce a mandatory labelling system so all consumers can be aware of the practices used in producing the meat, whether raw or processed.

c) Government to adopt Recommendation 62, in any event, to reduce suffering.

d) Government to adopt Recommendations 80-89 to tighten up training and assessment requirements for slaughterhouse staff.

e) A further Recommendation (see our response of 7 April 2003, Recommendation A) to set up a Commission of Enquiry into the extent of animal cruelty caused by ritual slaughter and to establish a practical plan for the removal of pre-stunning exemptions.

f) A further Recommendation (see our response of 7 April 2003, Recommendation B) to exercise much greater supervision over ritual slaughter, with increased powers to prevent abuse. If any clarification is sought of the above or questions arise on any related issues, I am happy to respond by email, telephone or in person.

Yours sincerely,

Keith Porteous Wood
Executive Director

APPENDIX 2

Link to article here.

God's own chosen meat
Nick Cohen
New Statesman Monday 5th July 2004

In failing to ban ritual slaughter, ministers aren't respecting Jewish and Muslim wishes, but comforting the reactionaries in their communities. By Nick Cohen

If you work on the assumption that you can judge a society by how it treats its animals, that perennially inquisitive visitor from Mars would quickly realise that Britain is a country obsessed with class hatreds but wary of the power of religion. All he would need to do is compare and contrast the outrage provoked by the hunting of foxes and the ritual slaughter of cattle.

As despairing hunters point out, the proposed ban on fox- hunting makes little sense. Indeed, if the true aim is to promote animal welfare, it makes no sense, as it is only hunting with dogs which would be prohibited. Farmers would remain free to shoot foxes that are threatening their lambs or chickens. No one from the anti-hunting movement has been able to explain why it is better to wing a fox with a bullet and leave it to bleed or starve to death than allow dogs to finish it off. Or as the Burns inquiry into hunting put it, in insurpassable bureaucratese: "We are satisfied that this experience [of being hunted with dogs] seriously compromises the welfare of the fox. We are satisfied that digging out and shooting a fox involves a serious compromise of its welfare."

Just so. But Labour backbenchers have ignored the heavy hints from their leaders that the politically wise course is to forget about hunting, and have pushed for a ban in every parliamentary session. It is their last shot in a class war they have all but lost. They don't believe in nationalisation. They don't believe in restraining the rich. But, damn it, they still believe that the gentry shouldn't dress up in silly costumes and charge across the fields.

None of the ambiguities that surround hunting haunt the production of (Muslim) halal and (Jewish) shechita meat. If the animal isn't stunned before its throat is cut, death is crueller than it need be. Yet at the beginning of June, the Department for Environment, Food and Rural Affairs overruled its own advisers and decided that religious slaughter should not stop, and scarcely anyone outside the National Secular Society noticed. Even animal charities I contacted did not know what Whitehall had done. Like the government, they did not want a fight with the religious.

The Farm Animal Welfare Council, which is charged with telling ministers how to promote humane treatment, had said that slaughtering without first stunning an animal was "unacceptable", and that the current legal immunity from prosecution enjoyed by religious slaughtermen should be repealed. The council was merely repeating a scientific consensus that has known for two decades that calves, in particular, take much longer than other species to die after throat-cutting. A 1995 study found that their brains could still be active for 104 seconds. Other experiments raised that figure to 126 seconds.

Possible reasons for the suffering are laid out in various research papers that Compassion in World Farming has collected. After the throat is cut, large clots can form at the severed ends of the carotid arteries, leading to occlusion of the wound (or "ballooning" as it is known in the slaughtering trade). Occlusions slow blood loss from the carotids and delay the decline in blood pressure that prevents the suffering brain from blacking out. In one group of calves, 62.5 per cent suffered from ballooning. Even if the slaughterman is a master of his craft and the cut to the neck is clean, blood is carried to the brain by vertebral arteries and it keeps cattle conscious of their pain.

The language of the studies is suitably dry, but every now and again emotion breaks through. John Webster, professor of animal husbandry at the University of Bristol's school of veterinary science, summed up the case against religious slaughter when he snapped that fear afflicted the animal as much as pain. "What is totally unacceptable is the distressing fact, for the cow, that she is conscious of choking to death in her own blood."

The government accepted that "animals (especially cattle) slaughtered without pre-stunning are likely to experience very significant pain and distress", but refused to end the benefit of the clergy enjoyed by anyone who could claim religious sanction for refusing to stun. The government claimed that a ban on cutting the throats of conscious animals may contravene the Human Rights Act's guarantees of religious freedom - highly unlikely, as Sweden bans religious slaughter and has not been had up before the European Court of Human Rights. It added that if the production of halal and shechita meat stopped in Britain, the devout would import it from abroad - true, but you could say the same about child pornography. The truth was that ministers could not see the political mileage in antagonising religious conservatives.

Outsiders should always be wary of dismissing other people's taboos as primitive. A sophisticated English atheist will condemn religious superstition but turn pale if a plate of horsemeat is put in front of him. None the less, it is hard to find a justification for religious slaughter. The taboo it enforces is against eating meat from an injured animal. Stunning a cow is held to be a way of inflicting injury, so the animal must be slaughtered while conscious.

Historians seeking to rationalise the irrational have speculated that Bronze Age dieticians thought that meat from an injured animal was unhygienic, but, in truth, if the prohibition had a reasonable basis, it has long been forgotten. The Jewish tradition, inherited by Islam, is that God told Moses how to kill animals. The advice was transmitted orally for many generations before being codified in the Talmud. To the faithful, religious slaughter is God's will, and that's the end of the matter.

Or so it seems. In reality, Islam and Judaism are no different from other religions: people can read what they want into them. Thus Orthodox Jews insist on shechita meat, Reform Jews do not, while the Board of Deputies of British Jews said that the overall attitude of Judaism is best summarised in the 12th chapter of the Book of Proverbs: "A righteous man regardeth the life of his beast."

Meanwhile, much of the meat that is sold as halal comes from cattle, sheep or poultry which are stunned before they are killed - and most Muslims don't mind. (New Zealand law requires that sheep be stunned before death, but that country nevertheless exports vast quantities of lamb to the Muslim world.) The late Al-Hafiz Masri, who in the 1960s became the first Sunni imam of Woking mosque, founded British Islam's first animal rights movement and argued that there was no Koranic prohibition on stunning animals. He pointed out that the Prophet had said to a man who was sharpening his knife in the presence of an animal: "Do you intend inflicting death on the animal twice - once by sharpening the knife within its sight, and once by cutting its throat?"

In other words, by refusing to follow the advice of the Farm Animal Welfare Council, the government is not deferring to the wishes of monolithic Jewish and Muslim "communities", but comforting the most reactionary elements within them.

And in that appeasement, it is showing the limits of multiculturalism. As many critics of postmodernism have pointed out, a truly relativist multiculturalist is equally unable to condemn religious slaughter and Holocaust denial, or the burning of heretics, or the oppression of women. They are all valid cultural narratives and it is coercive to challenge them.

But challenged, I think, religious slaughter is going to be. There is obviously a big smash-up looming on the liberal left about Islamic fundamentalism. Concern for poor minorities and respect for "the other" can't coexist with liberal principles indefinitely. I had always assumed that the argument would be about the status of women, but why not about the treatment of animals?

This is Britain, after all, a country where respectable members of the middle class can be turned into street militants by the export of veal calves, where pets are loved and children are resented, where the hunting of foxes matters more to Labour MPs than the redistribution of wealth, and where the public gives more each year to the Donkey Sanctuary for "the provision of care, protection and/or permanent security anywhere in the world for donkeys (and mules)" than it gives to Age Concern or Mencap.

Doubtless the government thinks it has successfully defused an issue that might lose it a few votes in a few Labour seats. But they shouldn't be complacent. It is dangerous to underestimate Britons' attachment to animals.