MLHR response to DAFM 2021 to 2025​ NEW Animal Welfare Strategy

"The Department of Agriculture, Food and the Marine have released their new Animal Welfare Strategy. We are very disappointed at the continued lack of understanding as to the true situation of animal welfare in this country especially in the area of equine welfare. Until the government admits that our animal welfare record is nothing to stand over and that it needs major reforming then the necessary changes will not take place. Please take time to read our response to this strategy and share the link. Animal welfare matters"

MLHR Response to the Department of Agriculture's new Animal Welfare Strategy

Any opportunity to discuss and highlight the state of animal welfare in this country and to work towards a greater understanding of the animals we share this island with, their needs and our responsibilities towards them, is a positive thing and we welcome all initiatives which are aimed at improving present standards.
It is reassuring to read of the Minister’s ‘clear commitment to animal welfare’ and his belief that ‘together we can ensure that as a society, we afford our companion, farmed and wild animals, the respect, care and high welfare standards they deserve.’

​​​However, we do believe that the full extent of the present animal welfare situation is not truly understood and appreciated by the government and authorities.  We are concerned that without a clear understanding of the failings of our present system we cannot make the changes necessary to move forward towards achieving the vision of this strategy which is for Ireland to become ‘increasingly recognised as a country that actively promotes and safeguards the welfare of all animals,’ Knowledge and evidence based information are stated as two of the five key strategic principles of this strategy and it is essential that the many groups who have been working on the ground in the area of animal welfare are consulted throughout this process. No matter how small the groups may be they have invaluable insight and understanding of the present situation.

The idea of a ‘One Health, One Welfare’ approach is certainly one that is being understood and appreciated more and more across the world. It focuses on how animals, nature and humans are all interconnected and how government policies must reflect this connection or threaten the very survival of our own species. We cannot continue to view nature and animals only for what we can extract from them because our own welfare, both mental and physical, is so dependent on them. This attitude which has prevailed for far too long must change and it is only right that it be government led and supported.
 
So if we start, as the strategy does, from the premise that all animals are sentient beings and that ‘their welfare will be at the core of all animal-related activities and industries’, then our present situation in Ireland is one severely in need of reform. The world around us is changing rapidly. In the coming years we will face the stark reality of huge climatic changes, loss of biodiversity and the struggle to feed our ever growing population all while allowing nature to heal from the damage we’ve already caused her as we strive to stop inflicting further damage. The future of agriculture and the animals we use in this industry is inextricably linked to all of these concerns and now is the time in which to act. We need to feed an ever growing world population but we cannot do it at the expense of our fellow creatures and their right to ‘a life worth living.’
When we use the phrase sentient beings we must truly understand what that means. We cannot say we agree with the idea that animals are sentient beings, therefore having a consciousness and being able to feel pain and suffering and then allow them to be treated the way they are in this country, both legally and illegally.

Pig and Poultry Farming

​No matter what the marketing power of the image of pasture based Irish livestock, the reality of Irish pig and poultry farming is an intensive, indoor based system. Almost 99% of Ireland’s pigs are now bred and reared indoors, living on non-straw bedded, solid or slatted floors, often in units of over 1,000.
This clear movement towards larger farms with over 40% of our pig population now living in pig units of over 10,000 has been supported over the years by the Department of Agriculture. So where in this lifestyle is the protection of the five freedoms which are mentioned in the new strategy as being of ‘critical importance in setting out basic requirements in underpinning public policy and legislation?’ There simply are no good animal welfare outcomes in intensive farming and no measuring of animal based indicators or enhanced monitoring processes is going to change that. The evidence is there, if not from our own country then from all the countries who have adopted intensive farming years ahead of ourselves.
Pigs are intelligent, social creatures and the short miserable lives they spend in this sterile environment, devoid of all basic enrichment causes them untold stress which routinely resorts to them biting and attacking each other and indeed biting onto the metal bars of their cages until they draw blood as a means of release.
The out-dated and brutal practice of docking pigs' tails, usually without anaesthesia, to stop them biting onto another pig’s tail has been illegal since 2008 across the EU. Nevertheless its widespread use continues unabated here in Ireland and the strategy simply makes reference to attempting to reduce the practice. Yet this practice is illegal, it's contrary to any concept of compassionate animal welfare and it has been shown to often not even work, so it simply should be stopped outright.
We sincerely hope that My Lovely Pig Rescue, which has already been instrumental in providing a training day for department vets last year on the care, handling and socialisation of pigs in their own natural environments, will be involved in the ‘stakeholder consultation to explore the development of high-welfare outdoor-reared pig and poultry sectors.’
 
In 2012 the EU banned conventional battery cages for laying hens. They were now to live in ‘enriched cages’ giving them access to greater space, a nest, a perch and a dust bath. But the reality is quite different and they live their entire lives in a space no bigger than an A4 sheet of paper, unable to fly, stretch their wings, run, forage or have access to fresh air and natural light. 70 million chickens are produced here annually, 4 million turkeys and eggs from 2 million hens. When you see the state of many rescued ex-battery hens in their balding and bedraggled state it's clear that the system is not working to uphold animal welfare guidelines.
Do these creatures in any way have lives worth living?

​Live Animal Exports

​The continuing live exports of cattle, sheep, goats and pigs is another disgrace especially when further employment could be created here by increasing the amount of meat processing plants. There's really no way to ensure that animals travelling for long distances are properly looked after, that they do not experience high stress levels from the journey and most importantly that they go on to receive humane treatment at the other end. In recent years there has been widespread footage of horrific treatment of animals who are exported abroad and we cannot be naive enough to believe that all of our Irish animals somehow escape any of this. There is also the huge issue which is never openly discussed by the dairy industry of the hundreds of thousands of male calves born each year who are deemed surplus to requirements but are a necessary part of milk production. Exporting these calves when they should still be with their mothers is unconscionable in a society which supposedly prides itself on its high animal welfare standards. Allowing them to die of disease or neglect which also happens is beyond cruel and though we do not support the cull of these calves we certainly believe that having the decency to call out a vet to administer a lethal injection can be the only proper and humane end to these animals short lives. There needs to be a clear strategy to deal with these calves and ensure that their lives are not treated as worthless.
 
The strategy clearly states that ‘as our knowledge and understanding increases so too does our responsibility to ensure that we care for animals in ways that ensure their best possible welfare and quality of life.’
How can this statement be reconciled with the current practices in pig and poultry farming and live exportation?
In the Minister’s introduction to the strategy he speaks about the importance of animal welfare being ‘reflected in the choices we make as consumers when buying animal based products.’ So we must ask where is the choice for consumers when our supermarket shelves are flooded with intensively farmed pig in all its guises and when free-range chicken is not competitive in price and so most consumers will not opt for it. When animal welfare is connected to profit margins, either at the start of the food chain with falling pork prices affecting farmers ability to keep up with best practice welfare standards or at the end with the consumer opting for the cheaper product with the lower animal welfare levels, then the animals will always lose.

​Fur Farming

We welcome the proposed legislation to prohibit fur farming but this has been talked about for years now and we would like to see the quick and effective introduction of such legislation and an end to this desperately cruel industry which in no way supports the Minister’s statement of his department’s ‘proud history of supporting the welfare of animals.’

The Greyhound Industry

The strategy mentions the introduction of a ‘new system to improve greyhound traceability led by Rasaicht Con Eireann’ formerly Bord na gCon and we hope that this and other provisions in the Greyhound Racing Act 2019 will bring about complete reform within an industry which has been heavily financed by the taxpayers over the years amounting to ‘subsidised cruelty’ as one government minister commented.
Serious and disturbing animal welfare concerns within the greyhound industry were exposed last year by the RTE investigates documentary ‘Running for their lives.’
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We would like to see clear evidence by the end of 2021 to show that reforms have been made in this industry, that the killing of greyhounds who are not fast enough has been completely halted, that an effective rehoming programme has been initiated and that the extra funding of 2.4 million euros which was granted to the greyhound industry in 2020, funding which really should have gone to the amazing charities all over the country who are struggling to rescue and rehabilitate greyhounds, has been used appropriately to ensure the future welfare of all Irish greyhounds.

Companion Animals

We welcome the establishment of a new Advisory Council on Companion Animal Welfare.
The over breeding of dogs in this country has earned us the title of puppy farming capital of Europe with upto 100,000 puppies coming from this illegal trade every year. Much greater resources need to be directed towards halting this terrible industry. We would also like a complete review of the legal puppy farms in this country as we do not believe that those with large amounts of breeding bitches can possibly provide the care and attention needed to give either the mother dogs or the puppies correct socialisation or love. There should be a cap on the amount of breeding bitches and we would like to see it as low as 10 whereas at the moment some farms have hundreds which we find absolutely ridiculous.
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We would also like to see extensive funding directed towards charities who provide TNR schemes for feral cats. No one knows the exact numbers of ferals out there, some estimates put it as high as one million but the numbers are certainly in the hundreds of thousands. It is an immense problem every year and as we head into cat breeding season this month we commend all the amazing small charities, who are mainly volunteer run and public funded and who work tirelessly to help as many feral colonies as they can. The area of cat welfare has too long been neglected and ignored in this country by the government.

Foxes and Hares

We are very disappointed that there is no mention of the treatment of foxes and hares in this country. Hunting itself is simply mentioned under the phrase ‘hunting and pest control activities’ which is part of a long list meant to blanket cover a wide variety of disparate groups and just simply stating that all these groups have ‘a responsibility to ensure that they meet ethical and legislative obligations regarding the welfare of animals in the context within which they operate.’
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There is still seemingly no appetite in government for finally putting an end to the out-dated and cruel practices of fox hunting and hare coursing. There are simply no provisions or welfare standards which could ever be put in place that would justify the continuation of either of these forms of ‘sport’ or ‘entertainment’ or truly safeguard the welfare of either animal. It is time that Ireland stepped into the 21st century and banned both of these pursuits. They have no place in modern Irish life.

Animal experimentation

​The numbers of animals being used each year in this country for scientific research is still alarmingly high. The animals experimented on include horses, dogs, cats, rats, guinea pigs, and ferrets. The numbers used were as high as over 240,000 in 2017 but have dropped to just over 138,000 in 2019. So much of this testing on animals is no longer necessary and we would appeal to the Minister to include animals used in the research industry as part of his new welfare strategy and give the area due attention with the aim to eventually banning it.

Equines

For a country which prides itself on its international image of world-renowned horse trainers and jockeys it is nothing short of a national disgrace that every year we have hundreds, even thousands of horses being dumped on public and private land, in woods and forests where they often die before anyone comes across them, wandering our major cities endangering themselves and drivers, drowning in canals, rivers and bogs, being jockeyed at 1 or 2 years of age and raced illegally on our national roads. Un-chipped, no passports, indiscriminately bred from and then dumped once no longer of value, these majestic creatures which have done so much for Ireland through the ages are so under-valued in this country.

It is the lack of proper and consistent enforcement of our present control of horse laws and animal welfare legislation which has allowed this situation to continue. Equine ID laws and horse licensing laws are not being enforced so we need to look at that lack of enforcement and the present model in use in conjunction with updating legislation. One change which is imperative is a change in the present situation governing registration of ownership of equines. At present the onus is only on the buyer to change ownership details. This leads to countless horses with incorrect owners on the system and no way to trace the present owner who is responsible for the neglect, cruelty or abandonment of the animal as the owner on the system can simply say that he sold the horse months or years ago. The onus needs to be on both buyer and seller. We need owners to take responsibility for their equines. We need to make it easier to have successful prosecutions for equine neglect and cruelty.

We very much welcome the idea of a ‘cohesive national approach to the control of horses’ and we hope as stakeholders to be included in the consultation process which the Department of Agriculture, Food and the Marine is to start with local authorities and other stakeholders.

Education in equine welfare for all owners is of the utmost importance if we are to change the current culture and be able to once more take full pride in our shared equine heritage.

We would also like to see an end to the slaughter in this country of horses for meat production. Is this really the end that we want for those horses no longer of use or getting on in age? Do they not deserve to live out their retirement having worked so hard for their owners all their lives?
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We would also like to see changes to the selling of horses online. All advertisements should have passport information provided in photographs and an easily accessible website where purchasers can check microchip information to ensure description of the animal is as per the advertisement.

Ex-gratia Funding

We welcome the proposal to increase the ex-gratia funding to animal charities. We hope this will mean that smaller charities, who have a lot of work done by volunteers who give all their spare time to the cause will be better funded than at present to allow them to employ staff and to expand their operations. The work of these volunteers who are out at all hours of the day and night and over the weekend and holiday periods when larger organisations are not available must be recognised and must be properly financially supported.

Conclusion

​‘The ‘One Health’ concept recognises that human health and animal health are interdependent and bound to the ecosystems in which they exist.’
 
To be leaders in animal welfare we must be willing to change our present ways, to adopt new strategies for food production and for the welfare of our farmed, companion and wild animals. Intensive animal farming cannot be the future. It does not give happy, healthy animals, it does not provide nutritious, antibiotic free food and it is not aligned with any modern appreciation and understanding of animal sentience or animal needs and welfare considerations. Farming needs to protect our animals and restore our planet to health as much as it needs to feed us.
 
To be leaders in animal welfare we must embrace all animals equally and ensure that whether they sit on our sofa or sit in a stable that they are equally valued.
 
To be leaders in animal welfare we must see the lives of all our animals through their eyes and adopt policies that will ensure them a happy, enriched and fulfilling life according to their own needs and behaviours.
 
When we have achieved this we will also have created a much better world for ourselves and our children, one where our own health and welfare will be immeasurably improved and where our relationship with all the other creatures of our world will be one of compassion and kindness.
 
We look forward to being part of this change.

Dept of Agriculture Animal Welfare Strategy
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