Letter to Animal Health and Welfare Strategy Team Defra
7th April 2003
WELFARE STRATEGY FOR GREAT BRITAIN: CONSULTATION RESPONSE
Mr Simon Howson
Animal Health and Welfare Strategy Team
1A Page Street
London SW1P 4PQ (also sent to: firstname.lastname@example.org)
Dear Mr Howson
Welfare Strategy for Great Britain: Consultation response
The National Secular Society holds the view that the gratuitous animal cruelty which is caused by the practice of religious slaughter without pre-stunning is to be condemned. The privilege granted to religious bodies alone to inflict this cruelty should not be tolerated in a humane society. We note with approval that the Farm Animal Welfare Council (FAWC) is reportedly about to issue recommendations to withdraw the exemption from the requirement to pre-stun animals immediately before slaughter. We urge the Government to encourage and accept such proposals and implement them as soon as possible.
It is now thought that the purpose of religious laws on animal slaughter was to improve hygiene in primitive conditions, at a time when there was much less awareness about cruelty than there is today. We suspect that, even as concern over animal welfare grew, ritual slaughter was ignored because it was not thought to be widely practised. This is no longer the case; it is now a multi-million pound industry. Our members have attributed the official sidestepping of the animal welfare aspect up until now to stem from a concern over multi-culturalism; there seemed to be in practice no limit to what the UK State will permit defenceless animals to be subjected to in the name of religion. This is not worthy of a country that claims to be one of animal lovers.
According to the Prof. Geoffrey Alderman, political director for the Campaign for the Protection of Shechita [Jewish ritual slaughter], the 'justification' for Jewish religious slaughter seems to be solely an interpretation of religious texts written thousands of years ago in a society without modern facilities such as refrigeration. He seems content that these texts be interpreted without any consideration of scientific knowledge gleaned in the intervening millennia, for example the ability to make precise neurological measurements of the suffering of animals.
We are convinced that more humane regulations would have been introduced decades ago, were it not for fear of upsetting religious interests and their growing influence over our parliamentary system. We are encouraged by the first signs that the FAWC is taking active steps to address the practice of slaughter without pre-stunning, and hope that it will not be diverted from its compassionate path by religious resistance.
Scale of problem, now and in the future
This privilege to slaughter without pre-stunning affects over 3 million birds per annum in the UK. This consists of the slaughter of over 750,000 birds p.a. by the Muslim method and 2.3 million birds p.a. by the Jewish method (here ). This is represents an unacceptable level of cruelty. We are also aware of a third type of religious slaughter which is not normally preceded by stunning: "hatka (decapitation) which is used by Sikhs", but have not been able to establish whether it is practised in the UK.
As to the scale of future ritual slaughter, there were about 620,000 practising Muslims in this country in 2000, rising to an estimated 750,000 by 2005, and about 800,000 Muslims by 2013. By 2039 there are expected to be around the same number of active Muslims as Christians .
It has been brought to our attention that notices in the canteens of a number of universities (including SOAS and Leeds) advertising that all meat served there is Halal. Whether this has resulted from a disproportionate emphasis being placed on minority cultural/ethnic/religious sensibilities with insufficient attention being given to the majority sensibilities, or whether it is as a result of pressure from minority communities, it is not known. Were canteen facilities to adopt such policies widely, and given the rise substantial rises forecast in the number of Muslims, the volume of meat killed under the Halal method would grow exponentially.
Religious privilege, and religious objections
It is clear that it is for animal welfare reasons that UK regulations require that animals kept for the production of meat must either be stunned to cause immediate loss of consciousness until death is caused by bleeding, or killed outright using specific methods set out in the legislation. For similar reasons, the welfare of birds is safeguarded in slaughterhouses by measures designed to prevent birds from being caused 'avoidable excitement, pain or suffering'.
Despite these regulations, religious or ritual slaughter which disregards these welfare measures is licensed in the UK, and we note, accepted in the EU by permitting animals slaughter without prior stunning on religious grounds. Details of this are described and criticised by the Humane Slaughter Association (here).
Jewish law demands that animals must be alive, healthy and have no injury at the time of Shechita (Jewish method of slaughter) and be killed without pre-stunning.
Islamic law demands that animals are alive at the time of slaughter. Various Muslim authorities hold different views on pre-slaughter stunning; some accept that stunning does not kill and is therefore not contravening their laws, others refuse the meat from animals that have been stunned.
We also reproduce below a transcript of a recent BBC Radio 4 programme on this subject, in which the animal welfare arguments are explained and the 'justifications' for shechita are given , together with a commentary added by ourselves.
As far as Jewish objections are concerned, the March 1999 report The Welfare Of Animals Which Are Subject To Religious Slaughter (section entitled The Jewish and Muslim Communities on pp 4-7) gives a number of theological justifications for their adopting a humane method and adds "We recognise that when stunning is not performed correctly, it can cause suffering to animals. Nonetheless, the bulk of the scientific evidence (including that from the eminent scientist Dr Judy MacArthur Clarke, chair of the FAWC, quoted below) suggests that animals which are properly stunned experience less pain and fear than animals which are conscious at the time of throat-cutting and during the time taken to lose brain responsiveness." Having considered the evidence, the Report recommends (page 6) "Bearing in mind the emphasis of Jewish teaching on preventing cruelty to animals, we would urge that the laws of Shechita be allowed to evolve to permit the use of what has become the most humane form of slaughter."
Religious objections to stunning were first made before the very substantial improvements in stunning technology of recent years. It can now be almost guaranteed that stunning an animal neither kills nor injures it, the main objections raised by religious bodies.
The Humane Slaughter Association also points out that 'there is emphasis in Jewish and Islamic teaching of the need for kindness and humane treatment of animals, and both faiths recognise that taking the life of an animal carries great responsibility.' They expressed this in their evidence to the FAWC whose report as far back as 1985 stated: 'Ministers should require both the Jewish and Muslim communities to review their methods of slaughter so as to develop alternatives which permit effective stunning'.
We should follow other countries and withdraw the pre-stunning exemption
If the UK were to do as we recommend, it would not be the first European country to do so; it would be in the company of two highly respected European neighbours. Sweden has now banned ritual slaughter and Switzerland's 1893 law prohibiting such practices is still in force. A recent attempt to repeal the Swiss law failed because of concerns over the welfare of animals.
A further reason why the move we propose is more feasible than might be thought initially is that that some Muslims now accept pre-stunning. According to Commons Research Paper 98/12: "In both Denmark and New Zealand pre-stunning is a legal requirement for Halal slaughter, with the consent of the Muslim population." According to the evidence we cite from Compassion in World Farming reports (below), even "the Saudi Arabian Standards Organisation has accepted electrical stunning, provided that it does not kill the animal".
Australia no longer permits ritual slaughter without pre-stunning. The Australian Quarantine and Inspection Service and states on its website that: "Although some countries willingly perform ritual slaughter, Australia does not accept this approach in its traditional form based on animal welfare concerns. Instead, Australia has adopted an approach that is believed to minimize the stress on animals during the ritual slaughter process while facilitating religious beliefs."
In New Zealand, all cattle is now pre-stunned and the New Zealand Jewish community appears to accept meat prepared in this way as being Kosher.
Our Principal Recommendation
We urge the UK government as soon as possible to completely withdraw the exemption from the requirement to pre-stun animals immediately before slaughter, an exemption which applies solely to ritual slaughter.
The rationale for our recommendation is, as stated above, a humanitarian one to prevent avoidable cruelty to animals. If the statutory regulations are justified, they should be applied to all situations, except perhaps emergencies. If they are not justified, they should be repealed. In this case, we are convinced that the regulations to reduce cruelty during slaughter are justified, and they should be applied to all non-emergency situations. We advocate a Commission to deal with the practicalities of making the changes we recommend.
It would be better if the relevant religious authorities were persuaded to change their own regulations in the light of the improved technology of pre-stunning and much greater public compassion concerning defenceless animals. We urge the Government to explore all possible avenues to request and encourage them to do this. If, however, religious authorities refuse to accept any changes in the face of these representations, we still urge the Government to repeal the religious exemptions to the requirement to stun animals before slaughter. We emphasise that we have no objection to ritual slaughter provided every practical step is taken to avoid animal cruelty.
Supplementary Recommendations pending the enforcement of a complete ban on ritual slaughter without prior stunning
The attachments to this Submission contain powerful evidence of additional unnecessary cruelty in ritual slaughter both in this country and (admittedly outside your jurisdiction) abroad. It is absolutely unacceptable - as the Freethinker article (attached) reports - for Jewish abattoirs to kill more animals than are 'needed' to satisfy the demand for Kosher meat. We also note that some parts of animals slaughtered in Kosher abattoirs are sold for non-Kosher use, without being labelled as such. The matter was raised in the Commons (Hansard 30 Jun 1998: Column: 152) but not at that stage satisfactorily resolved.
Recommendation A. A Commission of Enquiry to be established into the extent of needless animal cruelty inflicted in ritual slaughter. The remit should include extensive practical investigation of such slaughter both in official slaughter-houses, and where it occurs elsewhere in the UK. The investigation should include neurological tests to show the extent to which animals (especially those not pre-stunned) are sentient when being killed. References are made below work already conducted in this field and other studies in the course of completion.
The Commission should be charged with drawing up a practical plan for the removal of pre-stunning exemptions for ritual slaughter and proposing changes to regulations and/or statutes to implement this. Pending removal of the exemption, the Commission should make detailed recommendations as to how the changes recommended below should be implemented.
Recommendation B. Much greater supervision to be exercised by secular authorities over ritual animal slaughter, with greatly increased powers to prevent abuse.
Only those passing a strict slaughter competency examination conducted by an independent secular authority should be licensed to carry out such slaughter, which may only be carried out in licensed slaughter houses. The slaughtering of animals other than by licensed slaughterers in licensed slaughter houses should be subject to criminal sanctions which should include heavy fines.
Regulations to be (if necessary, introduced and) enforced that slaughter can only be carried out: with the sharpest of knives; employing the most humane methods of restraint; and animals (especially cattle) must be prevented from seeing and - as much as possible - hearing and smelling others of their species being slaughtered. Those breaking these proposed regulations should be heavily fined, and if offending persistently, have their licence revoked.
Recommendation C. Animals killed by ritual slaughter without prior stunning to be indelibly marked as such immediately after slaughter, and all meat sold from such animals to be labelled at the point of sale*. This should include butchers, supermarkets, restaurants, cafés or takeaway vendors such as kebab establishments. Where such meat forms part of a prepared product such as beefburgers or ready made meals, the slaughter details should be clearly stated on the list of ingredients. We suggest that the labels or list of ingredients should state that the animal has been killed by religious slaughter and consequently was not stunned in advance.
Recommendation D. A ban to be imposed on the export of live animals for ritual slaughter to places where it is believed to be carried out in a barbaric way*. (Widespread concern has been expressed about some ritual slaughter in France, for example.)
Recommendation E. A ban to be imposed on the import of ritually slaughtered meat where it is believed to be carried out in a barbaric way*.
* to the extent permitted by EU law and world trade regulations. Where these preclude action, the UK Government should seek to persuade EU and other trading partners to introduce a blanket ban on slaughter without pre-stunning and the implementation of recommendations similar to those listed above. The ritual slaughter carried out in France away from slaughter houses is a matter of great concern, from a public health standpoint as well as the cruelty aspects.
We attach as evidence:
1. Two papers from Compassion in World Farming prepared by their Political and Legal Director Peter Stevenson who has specifically given his consent for their inclusion as evidence toDEFRA:
(1a) The Welfare Of Animals Which Are Subject To Religious Slaughter March 1999 and
(1b) Animal Welfare Problems In UK Slaughter-Houses: A Report By Compassion In World Farming Trust, July 2001.
(2) an extract from an article concerned with ritual slaughter from the April 2002 edition of the Freethinker, a monthly secular humanist magazine published by an associated organisation. The article is written by its editor Barry Duke who was not aware of the consultation process, but has given his consent for the article to form part of our Submission.
Please let me know if I can clarify any points in our submission, or be of assistance in any other way.
Keith Porteous Wood
TRANSCRIPT OF SUNDAY PROGRAMME BROADCAST ON RADIO 4 30 MARCH 2003
Roger Boulton (RB): The British government is revising its existing animal welfare and slaughter legislation and code of practice which requires all animals to be stunned before being killed, except for religious slaughter. It's asked for the farming and animal welfare council to report on the issue. This week the council met with the Jewish delegation and told them it would recommend the exemption is removed. The Jewish delegation walked out. For religious Jews the only permitted method of animal slaughter is shechita, the slitting of an animals throat so that it bleeds to death; stunning is not allowed. Earlier today I talked to the chairman of the FAWC, Dr. Judy MacArthur Clarke (JMcAC) and asked her why the council wanted to change the law.
JMcAC: "Having investigated this at great length, we have come to the conclusion which the council came to back in 1986 when the Council made its previous report on slaughter, that there is suffering to these animals; there is significant suffering and therefore in our view on welfare grounds our recommendation to government is that the exemption should be repealed."
RB: "But the Jewish community argues that the rapid blood loss of blood achieved when religious slaughter is carried out means that the animal looses consciousness in less than five seconds and therefore this is not cruel."
JMcAC: "Well it depends what species of animal you are talking about. Sheep and goats certainly tend to become insensible within periods of time like you are saying, about five seconds, but the evidence on cattle is that they take between twenty two and forty seconds to loose consciousness and calves up to a hundred and twenty seconds. So those are very significantly long periods of time."
RB: "And they know exactly what is happening to them?"
JMcAC: "It is difficult to know whether they know exactly what is happening, but it is also difficult to mount a case that says that they are conscious and yet unaware of what is happening."#
RB: "So you have no doubt that Jewish religious slaughter is cruel?"
JMcAC: "I think that's clearly evident from the evidence that we've received and in many ways I think I would put the onus on the other foot in the sense of saying that if one considers what happens to those animals and the knowledge that for example from scientific data we know that cattle are going to be conscious for periods of up to forty seconds and calves up to one hundred and twenty seconds it is difficult to believe it is not a cruel exercise."
RB: "To respond to some of the issues raised by Dr. Clarke there I'm now joined by Prof. Geoffrey Alderman, political director for the Campaign for the Protection of Shechita, which is what religious slaughter is called. Could I ask you first Professor. Alderman (GA), "Why is religious slaughter so important to Jews?"
GA: "Shechita is prescribed in the Talmud and Torah. It is the only method prescribed for the slaughter of food animals and it is a basic precept of Jewish orthodoxy world wide."
RB: "Can we then turn to the question of cruelty? Dr. Clarke made the point there that with some instances with cattle it could take up to forty seconds; in some instances, with calves, it could take up to one hundred and twenty seconds, tow minutes for them to die after their throat is cut. Do you accept that?"
GA: "No, I don't accept that. What I do accept is that there are wide variations in scientific evidence and views of this matter. I also accept the view of a team from Bristol university, of the National Blood service in 1999, published in the Veterinary Record, that the method of slaughter which Dr. McArthur-Clarke would prefer is actually harmful to the human food chain."
RB: "That would involve stunning the animal?"
GA: "Yes, the reason for this, Roger, is that the use captive bolt pistol can lead to toxins from the brain entering the animal's blood stream. Its interesting isn't it that there has never been a case of BSE in kosher slaughtered animals."
RB: "But let's assume for the moment that it is shown that cattle and other animals do suffer because of the method that you use, you would still have to say as a Jew, 'well that's too bad, we have no option'"
GA: "When my son was eight days old, I offered him for circumcision, now he may have suffered at the time, but this is a price we pay for the practice of our religion. Having said that, I do not believe that there is any definitive scientific evidence that shechita is any more cruel than any other method and I would say that since shechita encompasses stunning and slaughtering in one act, not in two, it is less cruel."
RB: "Let's look forward. If the government decides to remover the exception and says to all those who use this particular method of religious slaughter that that's no longer allowable will you obey the British law or the Jewish law?"
GA: "There's absolutely no question that Jews are law abiding citizens. Shechita at the moment is part of the law of the land, but if the law were changed, we clearly would not disobey the law; we'd simply have to find other ways of probably importing kosher meat and poultry."
RB: "But there is no question that Jews, even if such a law was passed, that Jews would eat meat killed by stunning beforehand. It has to be done through the religious method."
GA: "That's correct." (END OF INTERVIEW)
National Secular Society's comments on Professor Geoffrey Alderman's contribution:
That such slaughter is prescribed in religious books revered by Jews written thousands of years ago in a much less compassionate society and quite different circumstances does not, in our opinion, justify unquestioned adherence to their precepts today.
If the method of pre-stunning used is harmful to the food chain, then it should be revised to find alternative methods; this is a long way from suggesting that the only alternative is shechita. We understand that a major (and perhaps the only) cause of contamination of meat with BSE was the failure to remove completely the spinal cord, something that is unconnected with stunning.
"A common misunderstanding is that the bolt has to enter the brain in order to produce unconsciousness. This is not the case, otherwise the percussion bolt gun would be totally ineffective. The percussion bolt has a blunt end which looks like a mushroom, It is designed to concuss without penetrating the brain and it is used mainly for stunning cattle before halal slaughter and (for worker health reasons) for stunning cattle that are thought to have bovine spongiform encephalopathy."
To conclude that shechita is less cruel because it involves one process rather than the two in conventional slaughter (with the first of the two processes rendering unconsciousness) seems to reveal a degree of desperation in Professor Alderman's argument, and a revealing contempt for the intelligence of listeners.
That the Professor is prepared to submit his son to circumcision in the name of his religion and the one he has imposed on his child is no justification for inflicting needless suffering on animals that have no religious affiliations.
As far as the importing of meat that is not pre-stunned is concerned, we urge DEFRA to work towards banning such slaughter methods throughout the world, starting with the EU.
Extract from New Zealand's MAF website taken in April 2003 (link here.)
"Currently shechita of cattle and lambs is carried out in one slaughter premises in New Zealand, 2 - 3 times a year. ...Although stunning is not currently required by law, the Jewish authorities have reluctantly agreed to stun cattle within 10 seconds of the throat being cut. This was in response to concerns about the length of time that cattle remain responsive to pain during bleeding. No stun is used for sheep as they generally become insensible within 10 seconds. While it is thought that chickens retain brain function for periods of time similar to cattle, a post-cut stun has not been considered.
"The arrangements relating to cattle were put in place to reflect changing societal views on animal welfare. They represent a compromise from an animal welfare perspective because there is an unreasonable risk of pain for a period of up to 10 seconds. They are also viewed by some devout Jews as a religious compromise as it is perceived that the post stun may affect the bleed-out of the animals.
"Cattle are restrained in an ASPCA pen operated in accordance with MAF-approved operating procedures. These ensure the minimum stress to the animals. Sheep are restrained by hand and poultry in a bleeding cone. ...No kosher meat is exported from New Zealand but some is imported from Australia.
7.2 Halal: New Zealand has been exporting halal slaughtered meat to the Middle East since 1979. It is now the largest exporter of halal slaughtered sheepmeat in the world and a significant exporter of halal slaughtered beef.
When the export market to the Middle East developed in the late 1970s, slaughter without stunning was not considered acceptable to the New Zealand meat export industry. It was considered that such export would have an adverse effect on trade to markets, which are dependent on New Zealand maintaining high animal welfare standards. A significant research effort was thus directed in the early 1980s toward developing techniques that met both Muslim needs and animal welfare concerns. The result was the development of an electrical head-only stunning method that renders the animals only temporarily unconscious. If not slaughtered, the animals make a full recovery. Muslim authorities have agreed this meets the requirement that the animals be alive prior to slaughter, but there may be some individual Muslims who do not agree."