Consultation outcome

Summary of responses and government response: draft code of practice for the welfare of pigs

Updated 9 September 2019

1. Introduction

1) This document summarises the responses we received to our consultation on a new statutory Code of Practice for the Welfare of Pigs, for England, and sets out the actions we will now take. The consultation started on 29 January 2018 and closed on 9 March 2018.

2) The statutory code provides owners and keepers of pigs with guidance on how to comply with relevant welfare legislation. The purpose of the consultation was to seek views on whether and how well the new statutory code achieved its aims of providing owners and keepers with up-to-date and enhanced guidance on how to comply with the current legislation, and whether it reflected the latest scientific and veterinary knowledge.

3) The consultation related solely to a new statutory Code of Practice for the Welfare of Pigs, for England, as animal welfare policy is devolved. The Northern Irish, Scottish and Welsh governments issue their own farm animal welfare codes.

2. Overview of responses

4) A total of 30 responses were received to the consultation. The largest number of responses (8) came from animal welfare organisations. Other responses were received from:

• the veterinary profession (7)
• members of the public (6)
• the livestock sector (5)
• academia/universities (1)
• charities (1)
• retailers (1)
• local authorities (1).

3. Summary of responses to consultation questions

Q1. Do you agree that the new statutory code (provided in draft as part of this consultation) provides improved and up-to-date guidance to owners and keepers on how to comply with the relevant farm animal welfare legislation? If you wish to comment on specific sections of the code, please provide the relevant paragraph number and cite references to any relevant evidence.

5) In total there were 29 responses to this question. Of these, 15 agreed the updated code did provide improved guidance, subject to some specific amendments to the content of the draft code, whilst 8 respondents did not agree that the updated code provided improved and up-to-date guidance. A number of comments from the veterinary profession centred on the content and the prescriptive nature of the advice in the code, questioning whether parts of it were based on scientific or veterinary knowledge.

6) The vast majority of respondents also chose to provide detailed comments on different sections of the draft code, along with a large number of supporting research papers. Many of the comments received offered contradictory viewpoints across and within the differing category of respondents. Areas which attracted the most comments were the sections on disease control and biosecurity (9 respondents); handling (14 respondents); on-farm killing (12 respondents); teeth clipping, tail docking/tail biting and enrichment materials (18 respondents); and the section on farrowing sows and piglets (13 respondents). Respondents from the veterinary profession and from the livestock industry provided the majority of these comments.

7) The length of the code was raised by respondents, either positively as they felt the welfare information and guidance that producers needed now was considerably more than when the existing pig welfare code was first published in 2003, or as a concern to some, who thought the code too lengthy, repetitive and would benefit from further refinement to aid clarity.

Q2. Do you agree that the new statutory code (provided in draft as part of this consultation) reflects the latest scientific and veterinary knowledge? If you wish to comment on specific sections of the code, please provide the relevant paragraph number and cite references to any relevant evidence.

8) In total there were 28 responses to this question, with 16 specifically addressing the question asked. Of these, 4 agreed (3 from animal welfare organisations and 1 member of the public) that the updated code reflects the latest scientific and veterinary knowledge, subject to some specific comments on its content. There were 3 respondents who disagreed (all members of the public) with one commenting that they felt most of the guidance went against veterinary advice.

9) There were 9 respondents which felt the code only partially reflected the latest scientific and veterinary knowledge and provided comments and links to research for further consideration. These respondents were from across different sectors: 3 from the veterinary profession; 4 from the livestock sector; 1 from academia and 1 member of the public.

10) There were specific comments on the content of the code, some of which were repeated from those provided against Q1 and focussed on disease control and biosecurity; mutilations, specifically tail docking; on-farm killing; enrichment; and on the section on farrowing sows and piglets. One respondent from the veterinary profession commented that the subject is large, complex and constantly evolving and in some areas the evidence used does not appear to be a balanced reflection of the debate and therefore the draft should not attempt to, or be presented as, a full and thorough review of all aspects of research.

Q3. In what ways do you think the new statutory code will reduce industry’s ongoing costs in complying with legislation? Can you quantify this?

11) There were 13 responses to this question. Of these, 8 respondents (3 members of the public, 3 from the veterinary profession, and 2 from the livestock sector) believed that costs would not be reduced and burdens to the industry would increase.

12) There were 2 respondents (1 from the veterinary profession and 1 from an animal welfare organisation) which felt costs would reduce and lead to savings in terms of treatment for disease and on-farm mortality.

13) One response from the veterinary profession felt the new code would be no more useful than the existing code in helping pig producers comply with legislation. One response from academia opted to submit comments on the cost of the code and one response from an enforcement body felt that there would be severe consequences for business in terms of non-compliance with statutory requirements.

14) Seventeen respondents either did not answer this question or had no information to offer.

Q4. Do you agree with the estimate of three hours for owners and keepers of pigs to become acquainted with the content of the new statutory code? If not, provide details of your reasoning.

15) Of the 22 responses to this question, 13 disagreed with the estimate that it would take three hours for owners and keepers of pigs to become acquainted with the content of the new statutory code. These responses were from across different sectors: 4 from the veterinary profession; 3 from livestock sector; 5 members of the public and 1 from an animal welfare organisation. Two responses from the veterinary profession commented that becoming acquainted with the code would require time and therefore cost to businesses. Comments from these respondents also included a suggestion for the changes between the old 2003 code and the updated code to be highlighted and for a support system to be put in place so that queries could be raised. Two respondents from the livestock sector noted concern that the length of the document and the way it was written could detract from the important messages/information within, and hinder or deter people from reading and fully understanding the code, particularly where English was not a first language.

16) There were 9 respondents (3 from animal welfare organisations; 3 from the veterinary profession; 1 from a charity; 1 from an enforcement body; and 1 from academia) which agreed that three hours should be sufficient for producers to familiarise themselves with the code. However, comments noted that additional time would be needed to fully consider the information at the back of the code and in the Annexes to really understand any impacts. Additional time would also incur cost to business. An animal welfare organisation commented that as the code should be retained on the farm site at all times as a reference document, and as long as subjects that are required are easy to find, then the amount of time it takes to read should not be a significant factor. Furthermore owners and keepers will be able to re-read and refer to specific sections if and when welfare issues occur.

17) Additional comments received across all sectors included suggestions for training sessions, workshops, or an online training package to be made available on specific issues to help farmers.

Q5. What do you think is the most effective way for government to make owners and keepers of pigs aware of the new statutory code?

18) There were 24 responses from across all sectors to this question which suggested a range of ways in which the government could make owners and keepers of pigs aware of the new statutory code. The vast majority of respondents suggested that key sector groups and industry bodies were well placed to communicate changes and disseminate the new code to the pig farming community. These suggested groups included farmer associations as well as pig practitioners and advisors such as the National Pig Association; the British Pig Association; specialist local pig veterinarians: the Pig Veterinary Society; the British Veterinary Association; Red Tractor and RSPCA Assured.

19) Other suggestions included the proposal that local government inspectors could assist in publicising the new code, or that social media could be used or the trade and farming press, including smallholder publications. Communication channels used by breed clubs and societies could also be used to target non-commercial pig keepers. Another proposal was that in addition to copies of the code being made available to all existing registered pig keepers, it should be made available to all new pig keepers when they register their holdings and request a herd mark from the Animal and Plant Health Agency (APHA).

20) Six respondents did not answer this question.

4. Government response

21) Following the public consultation, the government has carefully considered the comments received and has worked with key stakeholders to refine, amend and remove duplication from the code. Amendments have been made, for example, to the sections on animal based measures, enrichment and tail docking and the section on pigs kept in outdoor husbandry systems has been enhanced.

22) The independent Farm Animal Welfare Committee has scrutinised the post consultation draft and has confirmed that the updated Code of Practice for the Welfare of Pigs incorporates the latest scientific, veterinary and husbandry advice and provides clear guidance to owners and keepers to help ensure and enhance the welfare of their animals.

23) The new Code of Practice for the Welfare of Pigs will be laid before Parliament for a period of 40 days before it can come into force.

24) Defra will work closely with key stakeholders, including the National Pig Association, AHDB Pork, the Pig Veterinary Society, Red Tractor and the RSPCA, to ensure owners and keepers of farmed pigs, are fully aware of the updated statutory code. Defra will work with its enforcement body, the Animal and Plant Health Agency, to ensure that, in future, its inspectors will make an assessment on whether the provisions of the legislation and the updated code are being met. Defra will also work with local authorities in order to ensure that they are fully aware of the updated code.

25) Defra will keep the updated code under review.

Annex 1: List of respondents

Agriculture and Horticulture Development Board

British Veterinary Association and Veterinary Public Health Association

British Quality Pigs/Dalehead

Catholic Action for Animals

Compassion in World Farming

Conservative Animal Welfare Foundation

Garth Pig Practice Ltd

Humane Society International

National Animal Health and Welfare Panel / Trading Standards South West Animal Health and Welfare Panel

National Pig Association

Pig Health and Welfare Council

Pig Veterinary Society

Red Tractor

RSPCA

Sainsbury’s Supermarkets Ltd

Soil Association

Universities Federation for Animal Welfare

University of Bristol, Animal Welfare Research Network and Animal Welfare and Behaviour Group

Viva!

World Animal Protection

Individual members of the public

Individuals from the veterinary profession