Submission on Animal Welfare Regulations by the Soil & Health Association
Ministry for Primary Industries
PO Box 2526
FROM: The Soil & Health Association
PO Box 340002
Submission on Animal Welfare Regulations by the Soil & Health Association
The Soil & Health Association of New Zealand Inc. (Soil & Health) was incorporated under the Incorporated Societies Act 1908 on 4 December 1942. Soil & Health’s objectives broadly include soil health and the promotion of organic gardening and farming. It has approximately 3000 members, chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Its age and membership make it the oldest and largest representative organic organisation in New Zealand.
Soil & Health recognises that New Zealand animal welfare standards need improving. Every year thousands of animals in New Zealand are farmed intensively, fed high doses of antibiotics, and grains with herbicide residues, kept in unhygienic and cramped conditions, with high levels of stress and injury, unable to express normal behaviours, which runs contrary to the stated principles in the Animal Welfare Act 1999.
As an organic organisation we advocate for the highest animal welfare standards. Organic livestock farming is based on the harmonious relationship between land, plants and livestock, respect for the physiological and behavioural needs of livestock and the feeding of good-quality organically grown feedstuffs. We support the Five Freedoms as set out under the Animal Welfare Act 1999. We believe that any farming methods that cause animals to suffer or prevent them from expressing normal patterns of behavior should be phased out. This is why we welcome the opportunity to comment on the Proposed Animal Welfare Regulations discussion document (the document), which contains the Government’s proposals to improve the enforceability, clarity and transparency of the animal welfare system in New Zealand.
The current animal welfare system does not deal properly with lower-level offending. Soil & Health supports the majority of the proposed regulations in the document in general as they enable the Ministry for Primary Industries to better enforce compliance with the Animal Welfare Act 1999. These include proposals for increasing penalties and infringement fees for offences. However Soil & Health has concerns with some of the proposed regulations and believe that a number of cruel practices outlined, such as colony cages and farrowing crates, should be phased out and prohibited altogether.
10. – Care and Conduct Regulatory Proposals
1. Electric prodders
Soil & Health supports the proposed regulation in part. Electric prodders are a cruel device. We oppose the exceptions of their use for cattle over 100kg, at a commercial slaughter premise, and for a circus. We believe that alternatives should be found for the intention of moving animals and that electric prodders should only be used when the safety of the handler is at risk. We believe that restrictions should be placed on the possession and sale of electric prodders, as these devices are freely available and sold online with no requirement for information or training to be provided to purchasers. We do however support the proposal being placed in regulation as it means it will be directly enforceable.
2. Use of goads
Soil & Health supports the proposed regulation to prohibit the use of goads to prod an animal in the udder, anus, vulva, scrotum or eyes. The use of goads to move animals causes the animals to become nervous and fearful. The use of electric goads and physical goads such as sticks will obviously cause pain. We support placing the prohibition in regulation as it means it will be directly enforceable.
3. Twisting an animal’s tail
Soil & Health strongly supports the proposed regulation to prohibit twisting the tail of an animal in a manner that causes the animal pain. Tail twisting is an unnecessary and cruel practice often used to restrain and move animals and can risk leading to tail breaking, which causes pain and distress. We support the regulation as it provides an enforceable deterrent to tail twisting.
13. Tethered goats
While Soil & Health does not support the tethering of goats generally, as they are naturally foraging herd animals and tethering them prevents them from expressing their natural instincts to roam and forage freely, we do support the minimum requirement of constant access to food, water and shelter if tethered. However we believe that the word ‘shelter’ needs to be further defined. Shelter must be defined as providing a space that is clean, dry and has adequate space. As stated in the document, goats are more susceptible to hypothermia than sheep therefore the definition of shelter must also include providing protection from the natural elements including wind and rain, and weather extremes such as snow and hail.
17. Opportunity to express normal behaviours in housing systems
Soil & Health supports the new requirements under 17(a) that hens must have the opportunity to express a range of natural behaviours, becoming part of regulation and thereby becoming directly enforceable.
18. Stocking densities
While Soil & Health supports the proposed stocking regulations becoming part of regulation, thereby making them directly enforceable, we are strongly opposed to the specific stocking densities set out under 18. We believe that stocking hens at this density will not allow them the opportunity to express the range of natural behaviours outlined under 17(a). We believe that for hens to express the range of natural behaviours outlined under 17(a) they must be stocked at 6 birds per m2, with a minimum of 18 cm perch space provided for each bird.
19. Housing and equipment design
While Soil & Health supports the housing and design regulations becoming part of regulation thereby making them directly enforceable, we are strongly opposed to the use of closed cages including colony cages for all poultry, not just laying hens. Closed cages do not allow the animals the opportunity to express the range of natural behaviours outlined under 17(a). Chickens are biologically omnivores and instinctively, when given the opportunity, actively forage for green growing plants, animal foods such as earthworms and insects, wild fruits and some seeds.We therefore believe that if we are going to allow hens the ability to express the range of natural behaviours outlined under 17(a) they must have unrestricted access to outside runs, with at least 50% of the outside run area covered with vegetation at all times, allowing the hens constant access to fresh grass or forage crop containing a diversity of species. We believe that all poultry sheds should have access to good pasture, and be situated to allow for rotation of grazing areas – for example mobile poultry sheds. We believe that adequate nesting space should be provided at a minimum of 7 birds per nest, and that perchesshould be available in all laying hen housing to a minimum of 18cm perch space per bird.
24. Dry sleeping area
Soil & Health supports the proposal that pigs must have access to a dry sleeping area. Failure to provide a dry sleeping area can cause distress and ill health, particularly when a sow is pregnant and is trying to create a nest for her piglets. Furthermore pigs have clean toilet habits and in nature would never defecate near where they sleep. However if left in a confined area then pigs may be left to lie in their own excrement. Providing a dry sleeping area means this would not happen.
25. Lying space for grower pigs
Soil & Health strongly oppose the proposed lying space for grower pigs. We do not believe the proposed spacing will allow for improvement of overstocking behaviour issues such as aggression, nor allow for the pigs to express normal behaviours. Keeping pigs at this density does not allow them to roam, play or dig as they would naturally outdoors. We believe that all pigs should have access to outdoor pasture.
26. Dry sow stalls
Soil & Health strongly supports the prohibition of dry sow stalls and placing the prohibition in regulation thereby making it directly enforceable. Dry sow stalls are an inhumane and cruel practice. Pigs are highly intelligent, social animals. Keeping sows in individual stalls deprives them of their most basic needs such as fresh air, sunlight, clean water and soft bedding, as well as their need to socialise. We support this proposal as it places prohibition in regulation, making it directly enforceable.
27. Size of farrowing crates
Soil & Health supports the proposal as it places prohibition in regulation, thereby making it directly enforceable, however we strongly oppose the use of farrowing crates in general and believe that they should be banned altogether. Farrowing crates only allow the sow to either stand up or lie down, thereby preventing her to properly mother her piglets. This causes frustration and depression and is therefore an inhumane and cruel practice that we do not support.
28. Provision of nesting material
Soil & Health supports the use of nesting material in the farrowing system. As stated sows have a strong behavioural instinct to build a nest prior to farrowing. With no material for bedding she would scrape her nose over the bare concrete in an attempt to build a nest for her piglets. Not providing materials that the sow can manipulate prevents her from expressing natural behaviours. We therefore support this proposal as it means that any offences of not providing nesting material for sows will be directly enforceable. We however propose that the wording be changed to state “natural material”, which should be further defined with a list of specific natural materials to be used such as straw, twigs and grasses. We further propose that the nesting material be a mandatory requirement all the way through farrowing until after the piglets have been raised and weaned.
31. Milk stimulation
Soil & Health were not aware of this practice still occurring however believe it is unnecessary and cruel. We support the proposal to prohibit stimulating milk let-down by inserting water or air into a cow’s vagina, and placing it in regulation thereby making it directly enforceable. We believe that it warrants regulation so that effective action can be taken if it occurs.
32. Cattle and sheep – vehicular traction in calving or lambing
Soil & Health supports this proposal to prohibit using a moving vehicle to provide tractions in calving or lambing, making it part of regulation thereby making it directly enforceable. We believe it is an unnecessary and unnatural technique that has a high risk of causing injury, pain and distress to both the young and the mother. We support animals birthing naturally without artificial stimulation and force. We believe that it warrants regulation so that effective action can be taken if it occurs.
11.0 Young calf management regulatory proposals
43. Loading and unloading facilities
Soil & Health supports the proposed regulation that facilities must be provided to enable young calves to walk onto and off transportation by their own action. However we believe that the regulation needs to specify acceptable methods of loading and unloading, for example stating that they must be ramps, or electronic lifts. We do not believe that the regulations should allow for flexibility for other methods that would enable calves to walk onto and off vehicles, as this may allow for breaches of welfare. We believe all acceptable methods should be specifically stated to provide for full clarity. Further we believe that the time period to allow farmers and other businesses to make arrangements necessary to put suitable loading and/or unloading facilities in place should not be more than 12 months.
44. Shelter on-farm, before and during transportation and at processing plants
Soil & Health supports the proposed regulation in part. We believe that the regulation on shelter should also cover the stocking density of animals in pens. Stocking density should be at a rate that provides enough room for all calves to lie down.
45. Fitness for transport – age
Soil & Health opposes the proposed regulation that young calves must not be transported for processing and slaughter until they are at least four days of age. We believe four days old is an unacceptable age, being too young for travel. As stated in the document the four-day minimum age is not a guarantee that individual calves will be in a suitable physical condition for transportation. While the intention is for the regulation to be read together with those regulations for the physical condition of young calves we do not believe this will happen in practice, and it will also make it more difficult to enforce. We propose that the age be lifted to match that of the European Union of 10 days old, rising to 14 days old for longer journeys over eight hours. Raising the age to 10-14 days means that there is a strongly likelihood that the young calf will be in a suitable physical condition for transportation.
46. Fitness for transport – physical characteristics
Soil & Health supports this proposed regulation. However as stated above we believe by raising the minimum age for transportation to 10-14 days old that this will help to ensure that the young calves are in suitable physical condition for transportation.
47. Maximum time off feed
Soil & Health supports this proposed regulation to reduce the amount of hours off feed from 30 to 24 however we believe that 24 hours is still too long to go without feed for young calves. Naturally a young calf would feed from their mother every 2 to 3 hours. Calves began to feel hunger soon after 3 hours from their last feed, when plasma glucose begins to decline. Hunger then increases gradually for the next 15 hours and then rapidly over the final 12 hours. Leaving young calves without feed for such a long duration is cruel, and also leaves them physically weak. We believe that 24 hours is an unreasonable maximum period to permit young calves to be off feed when being transported prior to slaughter. We propose that the time period be reduced below 24 hours.
48. Duration of transport
Soil & Health supports the proposed regulation to reduce the maximum amount of time a young calf spends in transportation from 12 hours to 8 hours.
49. Blunt force trauma
Soil & Health supports the proposed regulation to prohibit the use of blunt force trauma for killing calves.
50. Transport by sea across Cook Strait prohibited
Soil & Health supports the proposed regulation to prohibit the transportation by sea of young calves across the Cook Strait. We believe that the infringement fee of $500 rather than $300 is a suitable penalty.
12.0 Surgical and painful procedures regulatory proposal
66. Cattle – tail docking
Soil & Health supports the proposed regulation to prohibit tail docking of cattle. We believe it is a cruel and unnecessary procedure especially when there are other alternatives such as switch trimming. Tail docking can lead to significant health problems, including incontinence, hernias, phantom tail pain and increased sensitivity to pain. Further more tail docking does not improve cow hygiene. Tail docking on cattle is a purely anthropocentric procedure that improves comfort for milking personnel only. We support the proposed restrictions that tail docking only is performed for therapeutic purposes (i.e. in response to disease or injury), that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform it, and that pain relief must be used at the time of procedure.
67. Cattle and sheep – castration and shortening of the scrotum
Soil & Health supports this proposal in part. We propose that castration and shortening of the scrotum only be permitted at a young age of less than 6 months. Castration beyond 6 months of age should be banned. We support the proposed regulation that only conventional rubber rings must be used for this procedure as it helps to minimise the level of pain and distress an animal experiences. We also support the use of pain relief at the time of the procedure.
69. Cattle, sheep, & goats – dehorning
Soil & Health supports this proposal in part. We propose that dehorning only be permitted in the budding stage. Dehorning is a painful procedure. Studies have shown that dehorning stimulates both an acute pain response and a delayed inflammatory reaction. Young animals tend to recover quicker and have fewer complications than animals dehorned at an older age. It is generally accepted that the younger the animal, the less painful the procedure. We do however support the proposal to make pain relief mandatory at the time of the procedure.
70. Sheep – tail docking
Soil & Health supports this proposal in part. We propose that tail docking be banned on sheep i.e. over 12 months of age. We understand that tail docking of sheep has benefits such as reducing problems like fly strike. However tail docking is a painful procedure so restricting it to lambs will result in less pain and therefore reduce the impact of the procedure on the animal. We support the rest of the proposals for tail docking under 6 months of age and tail docking over 6 months of age and believe it provides a clear mandatory standard for the procedure. However we believe that the tail length should be further specified as the current wording “must not be cut flush” is unclear and confusing.
71. Sheep – mulesing
Soil & Health strongly supports the proposal to prohibit mulesing of sheep and placing this prohibition in regulation, thereby making it directly enforceable. This procedure is one of the most barbaric and cruel practices carried out in the farming industry. It is an extremely painful practice and lambs have been seen to demonstrate abnormal behaviour indicative of extreme pain for days afterwards. We believe that the most humane alternative to sheep mulesing is to breed sheep to have low wrinkles, fewer dags and less wool around their breech, and that this should be a stated objective. Other effective alternatives are tailing docking of lambs, timing of shearing and crutching, effective natural control of scouring (especially the control of intestinal worms), strategic application of natural treatments to prevent flystrike, and regular inspection of the flock especially daily during high risk periods.
72. Deer – develvetting
Soil & Health opposes this proposal, as we believe that the develvetting of deer should be prohibited. However if it is to go ahead we do not believe that farmers should undertake this procedure themselves, even if given veterinary approval. It should be made mandatory that only a vet or veterinary student under direct veterinarian supervision should undertake this procedure.
74. Horses – tail docking
Soil & Health supports the proposed regulation to prohibit tail docking of horses. We believe it is a cruel and unnecessary procedure. We support the proposed restrictions that tail docking only is performed for therapeutic purposes (i.e. in response to disease or injury), that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform it, and that pain relief must be used at the time of procedure.
80. Pigs – castration
Soil & Health supports this proposal in part. We propose that castration of pigs only be permitted at a young age of less than 6 months. Castration beyond 6 months of age should be banned. We support the proposed regulation that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform the procedure, and that pain relief must be used at the time of procedure.
81. Pigs – tail docking
Soil & Health opposes the regulation to allow for tail docking of pigs. We believe it is a cruel and unnecessary practice. The reason tail docking of pigs is performed is to reduce the incidence of tail biting. However tail biting is a result of keeping pigs in high-density stocking numbers and pigs become frustrated and distressed. Pigs are highly intelligent, inquisitive animals and need intellectual stimulation such as natural material to play with. Studies have shown that providing straw or other manipulable materials and keeping a lower density of pigs in a pen could largely prevent tail biting.
As set out above, Soil & Health supports the majority of the proposed regulations in in the document in general, however we oppose a number of the proposed regulations as they either prevent animals from expressing normal patterns of behaviour, or they are cruel mutilation practices that cause harm and distress, thereby running contrary to the Animal Welfare Act. We believe that animals should not be kept in closed cages. Instead all animals should have unrestricted daily access to pasture. We therefore strongly oppose the use of colony cages for poultry and farrowing crates for pigs and believe they should be prohibited. In summary, while we commend the government for their efforts to tighten animal welfare regulation and create better enforcement with the Animal Welfare Act, we believe there is still much room for improving New Zealand’s animal welfare standards to better meet the physiological and behavioural needs of animals.
Name: Mischa Davis
Position: Policy Advisor
The Soil & Health Association
PO Box 340002