FSA 22-09-18 - Annual Animal Welfare Main report 2021/22

1. Summary

1.1    This paper provides an update on FSA activities delivered through the ‘Deter, Prevent, Detect, Enforce’ Animal Welfare Action Plan and its objective of making ongoing improvements in slaughterhouses in England and Wales. This extends to additional reactive work not included in the overarching action plan. 

1.2    The Board is asked to:

• Consider the progress made in delivering the ‘Deter, Prevent, Detect, Enforce’ welfare agenda
• Endorse the approach being adopted as the FSA seeks to improve animal welfare implementation and assurance in slaughterhouses in England and Wales on behalf of the animal welfare policy owning departments 
• Note the achievements against the action plan as well as positive reactive work and potential policy changes that will impact future delivery of animal welfare policy within slaughterhouses

2. Introduction

2.1    This paper provides the annual report to the Board on the FSA’s delivery of animal welfare activity on behalf of Defra/Welsh Government as policy holders in England and Wales. The key actions are outlined in our ‘Deter, Prevent, Detect, Enforce’ Animal Welfare Action Plan. 

2.2    The paper covers: 

• Background and context
• Significant in-year activities
• Consumer and stakeholder interest in animal welfare
• Highlights of the key deliverables from the Animal Welfare Action Plan 
• Cost and funding details
• Summary of data on compliance levels in slaughterhouses with reference to transport/farm
• Summary of the impact of Covid-19 in context of animal welfare controls and enforcement and subsequent return to BAU
• Forward look to potential policy changes that will impact future FSA animal welfare delivery activity

3. Background and context 

3.1    Defra and Welsh Government are the policy holders for animal welfare controls within approved slaughterhouses. Application of the controls including enforcement of animal welfare breaches are carried out by the FSA in England and Wales. Animal welfare is monitored by Official Veterinarians (OVs) based in approved slaughterhouses. Where checks at the slaughterhouse identify animal welfare breaches that have occurred on farm or during transportation, they are referred to the Animal and Plant Health Agency (APHA) and the Local Authority (LA), who are responsible for subsequent investigation and enforcement. In Northern Ireland, the Department for Agriculture, Environment and Rural Affairs (DAERA) has the policy and delivery responsibility for animal welfare.

3.2    Full responsibility for animal welfare and food safety in slaughterhouses rests with Food Business Operators (FBO) who must meet legislative requirements in terms of slaughterhouse design, layout, equipment, and operation. Their staff, responsible for slaughter activities, must be competent, appropriately trained and hold a Certificate of Competence (CoC) to slaughter all species presented to them. The FBO is responsible for ensuring all animal needs are met and for the welfare of animals in their care and authorised individuals are responsible for handling and processing animals. 

3.3    The animal welfare action plan and related work seeks to build on a developed risk-based regime to uphold the responsibility of FBOs in producing safe food and ensuring the welfare of animals at slaughter. The programme actively aligns to continuous improvement projects including the FSA Operational Transformation Programme to explore and implement new opportunities to improve consumer confidence and trust in the industry. 

4. Significant in-year activities

4.1    The supply of CO2 to the food and hospitality industry came under scrutiny in July 2021 as possible disruptions to domestic supply were forecast due to reduced processing from the main manufacturer. The FSA Animal Welfare team were integral to cross industry and Government contingency planning. After several weeks the manufacturer and industry customers secured a commercial arrangement to maintain continued supply. The FSA Animal Welfare team have rehearsed contingency planning arrangements with Defra and industry to prioritise supply for animal welfare at slaughter to mitigate against future supply issues. This has included exploring alternative stunning methods, alternative food packaging options and alternative methods of manufacture. 

4.2    A “Slaughter Sector Survey” was designed and completed during 2021/22 on behalf of Defra and Welsh Government. This is an exercise previously completed in 2011, 2013 and 2018 in all slaughterhouses in England and Wales. The survey ran for one week from 7-13 March 2022. This latest survey was digitised to improve user experience and streamline the data collection and analysis processes. A report was produced for Defra and Welsh Government which was published on 8th August 2022.

Farm animals: slaughter sector survey 2022 - GOV.UK (www.gov.uk)

    Key findings were:

• There was a reduction in the number of red meat and poultry slaughterhouses in England and Wales from 248 in 2018 to 211 in 2022. 
• Farms continue to be the source of most animal species transported to slaughter, particularly poultry. Numbers of animals sourced from livestock markets have fallen. 
• The levels of slaughter without stunning are similar to 2018 but with a small decrease from 25% to 23% for sheep (from 61,120 sheep to 49,450 sheep) and an increase from 7.5% to 25% for goats (based on a small sample size; this is an increase from 30 goats to 92 goats in the week surveyed). 2% of meat chickens (423,701) were slaughtered by non-stun methods, down from 3% (611,469) in 2018; and meat chickens stunned with lower electric frequency to meet religious slaughter specifications fell from 6% (1,082,586) in 2018 to 3% (568,933) in 2022. These are positive results in that there is a decrease of non-stun animals at slaughter. 
• 88% of pigs were stunned with CO2, an increase of 2% on 2018. This is against alternative methods of captive bolt or electrical stun. 
• Approximately 80% of meat chickens were gas stunned compared with 65% in 2018 which is another welfare positive statistical increase. This is against the alternative method of electrical stun. 

4.3    From June to August 2021 the FSA Veterinary Audit Team carried out an animal welfare themed audit at slaughterhouses. 43 slaughterhouses (18%) were audited. The audit concluded that overall FBO systems are compliant and provided a good level of assurance that legislative requirements are implemented. The audit did find, in some cases, that FBO Standard Operating procedures (SOPs) documentation could be improved. It also found that, in some cases, FSA checks on the quality of SOPs could also be improved. All recommendations have been addressed through an action plan and communicated to industry. 

4.4    Two unrelated incidents of undercover filming within slaughterhouses by activist groups required attention in April and July 2021. In the former, welfare non-compliances of varying degrees of severity were identified through the available footage (from both the activist group and the FBO). A range of enforcement action was taken that required the FBO to make changes to processes and management controls. Several Certificates of Competence were suspended until operative retraining had taken place. In the second incident a story was aired by BBC Panorama using covert footage from an activist group filmed a year and a half earlier. This meant that the FBOs own footage was no longer available. Though the programme focussed on practices within the horse racing industry it did highlight one practice at slaughter, relating to feral ponies, which was stopped as it was not in strict adherence to animal welfare regulations.
 
4.5    The FSA animal welfare team were integral in utilising research from New Zealand focussed on the use of electrical stunning for halal slaughter. Recommendations for adopting the practice were accepted by an All-Party Parliamentary Group for Animal Welfare and the Demonstration of Life (DoL) protocol was subsequently introduced as a voluntary scheme. This protocol has offered an alternative option to stun small ruminant animals (sheep and goats) prior to slaughter with an approved religious body certifying that the stun method is halal compliant. The Slaughter Method Survey 2022 shows a small decrease for sheep from 25% to 23% without prior stunning. This halts a previous increase seen in small ruminants, from 10% in 2011 to 25% in 2018. However, there has been limited uptake of the DoL protocol to date, and not considered entirely sufficient to account for the small decrease. 

4.6    Following engagement with industry the animal welfare team have introduced a referral for investigation triage process which is overseen by a panel of experts who make early assessments of animal welfare cases that could be prosecutable. This ensures proportionality and consistency of FSAs approach to these cases. In 2021/22 there were 18 cases reviewed by the panel, 16 of which were accepted for progression to the criminal investigator. 2 cases were deemed to have insufficient evidence to proceed to investigation. 

5. Consumer and stakeholder interest

5.1    Insights from the Food and You 2 Survey, (Wave 4 Latest data) conducted by FSA showed how consumers are concerned with animal welfare in the food production process. 35% of consumers reported that they were highly concerned and 41% were somewhat concerned. Further FSA and FSS research on the UK public’s interests, needs and concerns around food (conducted November – January 2022) asked consumers about their future food concerns over the next 3 years; 60% said that they were extremely or quite concerned about treatment of animals in the food chain and this was ranked 7th out of 14 issues. When asked what FSA / FSS should do in collaboration with partners with regards to the environment, ethics and welfare, the most common action (selected by 57% of respondents) was ‘Ensure high standards of animal welfare, including for imported foods’.

In terms of purchasing decisions, Food and You 2 data showed that the vast majority (91%) of consumers felt it was important to buy meat, eggs and dairy products produced with high standards of animal welfare. Two thirds (64%) reported that they actually bought meat, eggs and dairy which had information on animal welfare always or most of the time and 40% reported that they checked for information on animal welfare when shopping always or most of the time. 

Only a third (33%) of consumers felt that meat, eggs and dairy products showed enough information about animal welfare. Similarly, the FSA / FSS research revealed that 64% of respondents agreed that the treatment of animals in the food chain was something they cared deeply about. However, a smaller proportion of consumers (46%) were prepared to pay more for food products that are environmentally friendly or have high welfare standards.

5.2    From April 2021 to March 2022, 15 Freedom of Information requests (FOIs) related to animal welfare matters were received and dealt with by the FSA animal welfare team, which is more than double the number received in the previous reporting year. This represents 11% of all FOIs received by the FSA. During the same period there were no Parliamentary Questions received by the animal welfare team. The 2021/22 FOI levels are commensurate with pre-Covid levels (from 2018-2020) as shown in the table below:

Year	Animal Welfare FOIs	% of FSA FOIs
2021 - 2022	15	11
2020 - 2021	7	5
2019 - 2020	14	10
2018 - 2019	14	8

6.  Highlights and progress on the Animal Welfare Action Plan (Annex 1)

6.1    The ‘Deter, Prevent, Detect, Enforce’ approach is delivered through the Animal Welfare Action Plan. The action plan is monitored by a steering group comprising representatives from FSA and other government departments, who review outstanding actions and approve new activities. In 2021/22 we have:

Strengthened verification and compliance by:

• Supporting industry during Covid-19 by developing guidance that permitted extensions to temporary Certificates of Competence
• Introducing Demonstration of Life protocol for small ruminant animals 
• Running our fourth Animal Welfare themed audit
• Enhancing FSA animal welfare documentation 
• Triaging potential prosecution cases

Improved accountability and collaboration through:

• Building closer working relationships with meat and farming industries representative bodies 
• Agreeing with Defra and Welsh Government what activities will be funded to deliver animal welfare controls in 2021/22

Improved education and awareness by:

• Enhancing guidance about Certificates of Competence, evidence gathering, and decision making
• Producing industry communications and best practice guidance across a range of animal welfare themes 

Improved quality of our analysis and reporting through:

• Strengthening of monitoring and reporting on animal welfare standards
• Making continued enhancements to the FSA animal welfare non-compliance database and associated published open data
• Publishing animal welfare non-compliance statistics

The plan for the coming year will seek to drive forward improvement activities in all areas.

• We will support APHA in their aim of providing best practice guidance to OVs about referring farm and transport non-compliances
• We will facilitate improved data transfer between FSA, APHA and Local Authorities using secure digital evidence repositories
• We will enhance data reporting to APHA and Local Authorities relating to farm and transport non-compliances, and we will make this a mandatory discussion item at a cross agency working group

6.2    There has been improved collaboration with industry in recent years relating to animal welfare and we will look to continue and strengthen those relationships. 

7. Cost and funding details

7.1    Funding for welfare activities by Defra and the Welsh Government for work carried out on their behalf in 2021/22 is reflective of the duties performed and demonstrates the work done in recent years on quantifying the activities being undertaken on behalf of the policy holders.

7.2    The Service Level Agreement for 2021/22 totalled £491k and contributions were Defra 85% and Welsh Government 15%.

7.3    Animal welfare related activities and controls in Northern Ireland are delivered within the wider scope of all operational controls under a service level agreement with DAERA. 

8. Summary of trend data on compliance levels (Annexes 2 and 3)

8.1    In 2021/22 there were over 1 billion animals (1,036,098,739) processed in slaughterhouses. Over 99.9% (1,035,943,907) met animal welfare compliance standards and regulations. Of the 154,832 animals (0.0149%) processed not in compliance with animal welfare regulations, 51,132 animals (0.0049%) experienced some impact on their welfare.

8.2    In 2021/22 there has been a reduction in major and critical non-compliances overall. There has been an increase in major and critical non-compliances in the slaughterhouse and during transport. There was a reduction in major and critical farm non-compliances. The data can be summarised as follows:

• Slaughterhouse; 372 non-compliances. This is a 10.1% increase from 2020/21 (338).  Likely factors attributed to this increase are the reintroduction of Welfare Assurance Team inspections leading to detection of insufficient FBO SOPs, and enhanced guidance about live and retrospective CCTV viewing which has led to an increase in detection of other non-compliances during FBO processing.
• Farm; 835 non-compliances. This is a 48.8% reduction from 2020/21 (1631).
• Transport; 3105 non-compliances. 19% increase from 2020/21 (2609).  The re-categorisation of offence location of some non-compliances has impacted the balance between farm and transport.
• Total of 4312 non-compliances, which equates to a 5.8% reduction from 2020/21 (4578).  This demonstrates that FSA presence, guidance and where necessary enforcement is having a positive impact on industry compliance. 

Factor	2020/21	2021/22	% Change
Slaughterhouse	338	372	10.1%
Farm	1631	835	-48.8%
Transport	2609	3105	19.0%
Total	4578	4312	-5.8%

8.3    Enforcement data indicates that 19% of slaughterhouse non-compliances are identified either by live or retrospective CCTV viewing. CCTV is routinely used as evidence to support enforcement action.

8.4    CCTV continues to play an active role in identifying training needs, and in suspension and revocation of Certificates of Competence (CoC). There were 6 CoCs revoked and 58 COCs suspended 2021/22, of the 64, 50 were supported by CCTV footage. This equates to 78% of all suspensions and revocations.  For context, there are approximately 8700 CoCs issued but there is no data on how many are active at any point in time. The suspensions and revocations in 2021/22 equate to 0.74% of all CoCs. 

9. Summary of the impact on animal welfare in slaughterhouses during Covid-19 pandemic

9.1    During the Covid-19 pandemic the meat industry faced a range of significant challenges throughout the supply chain with particular pressure on resourcing. Animal welfare standards and controls remained a high priority throughout this period for both the industry and regulators with significant collaboration to overcome issues in changing production demand, working patterns and social distancing requirements.

9.2    FSA Field Operations overcame challenges in resource availability throughout the period with the potential to impact on slaughter operations. This was a concern for pig and poultry processing due to the nature of the supply chain and animal welfare challenges materialising on farms through backlogs.

9.3    Robust contingency planning and co-operation with back up support from across the FSA and APHA enabled operations to continue virtually unaffected. This resulted in no notable animal welfare or food supply issues materialising as a result of FSA delivery challenges. 

9.4    The FSA ceased all non-urgent assurance functions during the pandemic and restricted slaughterhouse attendance to core function teams (OV/MHIs). This resulted in the suspension of inspections from the Welfare Assurance Team. From June 2021 these inspections gradually resumed and have steadily increased so that 56% of slaughterhouses have had a welfare inspection by March 2022. All slaughterhouses will have had a welfare inspection by October 2022.

9.5    Routine welfare monitoring remained in place with an emphasis on the use of CCTV in slaughterhouses where social distancing would have created difficulties.

9.6    Covid-19 did impact on FSA monitoring and supervision in slaughterhouses, but it is difficult to definitively isolate actual impact on compliance. The reduced and altered processing activity as well as improvements to compliance previously achieved along with improved industry standards will have had impacts. 

10. Forward look to 2022 and beyond

10.1    The extreme hot weather experienced in July and August 2022 had an impact on animal welfare reported incidents of heat stress and dead on arrival (DOA) at slaughterhouses. Increased monitoring and daily reporting of actual incident numbers and animals affected was undertaken and the data reported to Defra for inclusion in COBRA contingency planning meetings. The experience is to be reviewed as a “lessons learned” exercise with Defra and APHA in order to formalise activity and reporting requirements for future extreme weather events.

10.2    Following an internal review of our processes for verifying and achieving compliance, we will be updating our operational instructions to reflect how we deliver enforcement in accordance with retained Regulation 2017/625 which is part of the OCR package. This is part of our wider review of changes in existing controls following the implementation of OCR. We are discussing any impacts on welfare legislation with Defra and Welsh Government.

10.3    Defra conducted a statutory Post Implementation Review of the Welfare of Animals at the Time of Killing (England) Regulations 2015 (WATOK). There are several observations and recommendations that Defra need to consider, which may impact on the meat industry and the delivery of animal welfare controls. The FSA animal welfare team will work closely with Defra, Welsh Government, and Industry to understand the delivery requirements of any new measures to ensure minimal impact whilst continuing to safeguard animal welfare.

10.4    In December 2020 Defra consulted on improvements to animal welfare in transport which aligns to the UK government manifesto commitment to end excessively long journeys for slaughter and fattening. The Government has announced it will ban live exports of livestock (but not poultry) for slaughter or fattening and proposes to make other changes to improve animal welfare in transport. The FSA animal welfare team will work closely with Defra, Welsh Government and APHA to support the introduction of any measures.

10.5    Welsh Government have included mandating CCTV in slaughterhouses in the recently published Welsh Programme for Government and are planning to consult on a proposal during 2022/2023. It is reasonable to expect that the proposal will, in part, reflect the regulations in England and Scotland. The FSA animal welfare team continue to work closely with Welsh Government.

11. Conclusions

11.1    This paper sets out an update on activities in England and Wales under our ongoing approach to ‘Deter, Prevent, Detect, Enforce’ animal welfare breaches on behalf of Defra and Welsh Government.

11.2    The Board is asked to:

Consider the progress made in delivering the ‘Deter, Prevent, Detect, Enforce’ welfare agenda

Endorse the approach being adopted as the FSA seeks to improve animal welfare implementation and assurance in slaughterhouses in England and Wales on behalf of policy owning departments. 

Note the achievements against the action plan as well as positive reactive work and potential policy changes that will impact future delivery of animal welfare policy within slaughterhouses.