Code of Practice for the welfare of poultry at slaughter
1st January 2005
Dear Mr Benneworth
Consultation on Code of Practice on the Welfare of Poultry at Slaughter
This is the formal response of the National Secular Society to the consultation on the above Code of Practice dated 18th October 2002.
The National Secular Society upholds the view that the gratuitous animal cruelty which is caused by the practice of religious slaughter is to be condemned. Our members feel strongly that the privilege granted to religious bodies to inflict this cruelty is unacceptable.
About the Society
The Society has been representing the non-religious for the last 130 years. An important part of our activities is combating religious privilege and speaking up for the 20 - 30 million of non-religious citizens whose collective voice is often ignored. We suspect that in the instance of religious slaughter we may also be speaking for millions of animal lovers from faiths that do not practise such slaughter, and indeed some within the faiths that do. There are also of course Jews and Muslims who for whatever reason,eat meat that is not ritually slaughtered.
Much of the Society's time is spent on education and constitutional matters such as the House of Lords, but whatever our activities in these areas, they are not generally concerned with physical harm. In the case of ritual slaughter, however, the scale of cruelty is huge. It would be hard to justify this level of cruelty even if it were necessary to provide human food, but given that this is not the case, then for such cruelty to continue to be sanctioned by law calls into question our right to be called a compassionate nation.
It may be that religious laws on animal slaughter were designed to improve hygiene in primitive conditions. Doubtless such practices started at a time when there was much less awareness about cruelty than there is today. Perhaps 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 feel strongly that this wilful evasion stems from a concern over multi-culturalism; there seems to be in practice little 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. We are convinced that a more humane law would have been introduced decades ago, were it not for fear of upsetting religious interests and their growing influence over our parliamentary system.
We note that under the provisions of the Welfare of Animals (Slaughter or Killing) Regulations 1995, 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.
We also note that under the Code of Practice on the Welfare of Poultry at Slaughter, the welfare of birds is safeguarded in slaughterhouses by a variety of management systems. These systems are to be used to prevent birds from being caused 'avoidable excitement, pain or suffering'. In large-scale slaughterhouses any deviation from these rules is only permitted when a bird is found to be injured or unfit for another reason. We understand that in these cases alone the bird must be killed immediately using an approved 'emergency method'.
Despite the above, religious or ritual slaughter which disregards these safeguards is licensed in the UK. It is only in the use of the religious method of slaughter that poultry may be killed in bulk without prior stunning. We note the position of the Humane Slaughter Association that no animal should be killed without prior stunning and we support this view. (http://www.hsa.org.uk/ here).
As you will be aware, Jewish law demands that animals must be alive, healthy and have no injury at the time of Shechita (Jewish method of slaughter) and are killed without pre-stunning.
You will also be aware that 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.
This privilege to slaughter without pre-stunning affects over 3 million birds per annum in the UK. This consists of the slaughter of 2.3 million birds p.a. by the Jewish method and 754,000 birds p.a. by the Muslim method. (http://www.viva.org.uk/Viva!%20Campaigns/Slaughter/goingforthekill3.htm here). This is big business and an unacceptable level of cruelty.
Our recommendation on the Code of Practice
Recommendation We urge the UK government to change the terms of the Code of Practice on the Welfare of Poultry at Slaughter to ban the ritual slaughter of poultry without pre-stunning.
We recognise that this recommendation will have the effect of making a substantive change to the interpretation of the WASK Regulations.
The rationale for our recommendation is, as stated above, a humanitarian one to prevent wanton and avoidable cruelty to animals.
Our recommendation is neither unrealistic nor idealistic. If the UK were to do as we propose, it would not be the first European country to do so, it would be in the company of two highly respected European neighbours. Both Norway and Sweden have banned ritual slaughter under such circumstances
A further reason why the move we propose is more feasible than might be thought initially is that the Humane Slaughter Association states that some Muslims now accept pre-stunning. With the use of a 'high frequency' waterbath the effect will be to stun and not to fibrillate. The bird remains alive but unconscious.
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'. This they expressed in their evidence to the Farm Animal Welfare Council 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'.
Religious objections to stunning were made before the very substantial improvements in stunning technology of recent years. It can now be guaranteed that stunning an animal neither kills nor injures it, the main objections raised by religious bodies.
It would be better if the relevant religious authorities were persuaded to change their own regulations in the light of modern standards of compassion to defenceless animals. We urge the Government to explore all possible avenues to request and encourage them to do this. If however, religious authorities remain intransigent in the face of these representations, however, we still urge the Government to repeal the ritual slaughter exemptions.
Please contact the Executive Director of the National Secular Society (details above) if you have any queries on this submission or if you feel we may be of further assistance.
Keith Porteous Wood