Animal Aid


Posted 1 November 2001

RCVS complaint

Animal Aid lodged a formal complaint with the Royal College of Veterinary Surgeons over its failure to speak out against the extreme suffering of animals during the foot and mouth mass slaughter. Our complaint has been rejected. But Animal Aid's battle to end the cruel practices continues. Read the correspondence here.

Mr. A Tyler
Director, Animal Aid
The Old Chapel
Bradford Street
Kent TN9 1AW

Ref: 06/01/55C
Direct line:020-7202 0789

4 October 2001

Dear Mr Tyler

Your complaint dated 11 June against Mr Roger Eddy has now been given full consideration.

Your complaint is based on Mr. Eddy's:-

a) Statement that he had "enthanased many animals by intracardiac injection (pentobarbitrone) including dogs, cats, lambs and piglets and on one or two occasions, calves" and "the use of intracardiac injection using pentobarbitone is a very quick and humane way of euthanasia providing a sharp needle is used. It is not a painful experience"
b) Endorsement of intracardiac injection as a means of culling young animals during the foot and mouth outbreak.
c) Comments on the killing of animals in the sight of other animals during the foot and mouth outbreak.

You consider that Mr. Eddy is guilty of professional misconduct and in support of your complaint you have referred to a report from the American Veterinary Medical Association panel on euthanasia, which states that intracardiac injection must only be used if the animal is heavily sedated, unconscious or anaesthetised. The preface to the report states that the recommendations in the report are intended to serve as guidelines for veterinarians who must then use professional judgement in applying them to the various settings where animals are to be euthanased.

Your complaint essentially turns on the proposition that intracardiac injection without additional sadation or anaesthetic, and culling within sight of other animals of the same species during the foot and mouth outbreak, are so abhorrent that neither the College nor any practising veterinary surgeon should countenance them.

I have sought the views of the Royal Society for the Prevention of Cruelty to Animals (RSPCA) and the Humane Slaughter Association and I enclose copies of my letters to Mr Kirkwood, Chief Executive and Scientific Director of the Humane Slaughter Association and Mr. Laurence, Chief Veterinary Officer of the RSPCA and their replies.

Although the responses from the RSPCA and Humane Slaughter Association answer your complaint, I have also obtained the opinions of a number of experts in veterinary anaesthesia and veterinary cardiology. All were asked to comment with reference to the following questions:

(1) What is the innervation of the standard route if injection?
(2) Which parts of the route are likely to cause pain?
(3) What are the consequences of missing the lumen of the heart?
(4) How difficult is the technique?
(5) Are there any species or age of animals when this would not be an appropriate technique?
(6) In field conditions, would you consider intracardiac administration of anaesthetic an acceptable method of euthanasia in small lambs and piglets?

The answers received are set out below. The names of the experts are not disclosed.

Expert 1 in veterinary anaesthesia:

"My overall feeling in this is probably the most appropriate route for young animals - and is humane when it is performed efficiently. Unfortunately, there is ample evidence that this has not always been the case. However, poor marksmen taking pot shots at ewes and lambs make it comparatively humane by comparison.

1. Innervation

Skin - cutaneous nerves and branches of intercostal nerves ) spinal
Intercostal muscle - intracostal nerves.

2. Pain

Intercostal muscles

3. Consequences of missing

a) The animal may or may not die later. May be rendered only temporarily unconscious - or not unconscious at all. There are a large number of reports of 'recovered lambs', calves etc. from all the centres - some found on disposal sites hours, even days, later.

Other complications - pneumothorax.

4. Difficulty

In 4th and 5th intercostal space LHS ventrally therefore small target area
d) and there is variation in size and shape between breeds of sheep
e) pig heart is small in relation to body size etc
So, under the conditions which are likely to pertain this may not always be an easy technique.

5. Age and species

No information available to my knowledge - but not an appropriate technique since the animal is older therefore hypothetically - up to 4 weeks maximum? Then hypothetically - up to 4 weeks maximum? Then jugular i/v route for up to 6 months, then captive bolt …

6. Field conditions

Not ideal - but what of the alternatives? (shooting, slitting throats etc have been mentioned by some of those in the field)

Expert 2 in veterinary anaethesia:

"I strongly believe that the intracardiac route of injection of a Pentobarbitone solution is as kind a way of euthanasia of small lambs and piglets as is possible in the field. It is considerably less stressful for an animal than looking for a vein. When carried out by someone who is experienced at the job (and in the current FMD crisis, people become experienced very quickly) then the only pain should be the needle. I have never personally used this method except in anaesthetised animals (when it is very easy) but many of the students I teach have been working for MAFF, and they assure me they have become proficient very quickly indeed.

(2) If the needle misses the heart and the drug is deposited in the pleural cavity, there may be momentary pain before the drug is absorbed. However pentobarbitone (as Sagatal) is not very irritant, - for many years it was used as an anasthetic by intraperitoneal administration, and the animals did not show any signs of pain other than as a result of a needle. Intraperitoneal pentobarbitone based solutions have also been used for euthanasia of rodents with the animals showing no signs of pain from the irritant effects of the injection. I have once seen pentobarbitone injected into the pleural cavity of a dog - it showed signs of pain for about 1 minute (whimpering), then seemed fine, before becoming anaestetised about 5 minutes later.

(3) I would be very concerned about thee intra-cardiac injection of euthanasia solutions which include drugs designed to stop the heart (Potassium; local anaesthetic, etc). The intracardiac injection of these solutions could result in cardiac arrest before the barbiturate drugs have time to reach the brain; the animal then dies from a 'heart attack' whilst fully conscious; human survivors of heart attacks say that it is very painful!

(Incidentally this goes for the use of these drugs by IV injection - give them too fast and that is what can happen. I am very concerned that we are happy to use these agents under circumstances where they are not necessary, just because it looks better by reducing the chance of a 'last gasp').

In summary, I consider that for lambs and small piglets, intracardiac injections of barbiturate is the best method of euthanasia which is practicable in the field under the present circumstances. Unnacceptable levels of stress are far more likely to occur as a result of poor handling procedures in general (crushing through too many animals in a pen; separation of ewe and lamb, etc) than from the actual procedure of intracardiac injection."

Expert 3 in veterinary anaesthesia:

"The thoracic wall is mainly innervated by the intercostals (nerves) and, if one keeps the needle in front of the rib, it will not touch the nerve. The innervation of cardiac muscle and percardium is not really known. However, I would suggest that you contact a card-carrying anatomist such as .......

If one misses the lumen of the heart, the solution will invariably end up in the thorax and will be absorbed. Provided that it is a non irritant solution (ie pentobarbitone) it should produce death fairly quickly. It is not so long ago that people were anaesthetising cats and dogs by the intra-thoracic route. There is a remote possibility that the material will end up in the pericardial sac or in the lung parenchyma and would probably get absorbed from there.

The technique should be relatively easy, provided due consideration is given to the anatomy and the apex beat is palpated.

As far as contraindication on age and species is concerned, the limiting factor will be on size and availability of veins. If veins are easily accessible then they should be used.

Under the field conditions, an overdose of anaesthetic agent is acceptable but I would aim to use "Euthatal' [pentobarbitone] or its equivalent. If there are any problems, then intramuscular injection of ketamine would be acceptable followed by intra-cardiac, -peritoneal or -thorascic JAVMA Vol. 218 p671."

Expert 4 in veterinary anaesthesia:

"To inject solutions reliably into the cavities of the heart in cattle sheep and pigs is not easy and learning the technique requires practice under the direct supervision of an expert. Except perhaps for small rodents and other small laboratory animals this route of administration is not commonly taught in our veterinary schools to undergraduates.

Entering the heart cavities entails penetration of the skin, the intercostals muscles, the parietal pleura, the pericardium, myocardium and endocardium. The nociceptive nerves of the skin are sensitive to needle penetration. It is difficult to ascertain whether the intercostal muscles contain noicieptors but needle injury to the intercostals nerves running on the cauda surface of the ribs is painful. The parietal pleura is known to be sensitive, but the sensitivity of the pericardium, myocardium and endocardium to needle penetration has not (as far as I am aware) been determined.

Injections into the pleural cavity of small volumes of pentobarbital solutions do not appear to cause distress once the injection is complete.

Injection into the heart muscle itself seems likely to produce the effects of myocardial infarction. The result can be ventricular fibrillation which is followed some 10-20 seconds later by unconsciousness. The intervening seconds can be very painful although it is not known what causes this pain. Normal cardiac muscle does not exhibit pain sensation but it is believed that ischaemia (such as results from compression of blood vessels due to the space occupying injectate) causes the muscle to release acidic substances such as lactic acid or other pain promoting substances such as histamine, kinins or cellular proteolytic enzymes that are not rapidly removed from the damaged heart muscle.

As with many other methods some method of physical handling of the animal is needed. The amount of control and kind of restraint needed will be determined by the animal species, breed, size, state of domestication, and degree of excitement. Proper handling is essential to minimise pain and distress.

The species of animal is important. There can never be any excuse for intracardiac injection in cattle. Even small calves have obvious and easily accessible jugular veins that should offer no difficulty for venepuncture right from the time of birth. Minimal restraint, experience and practice are required for sucessful jugular venepuncture and injection in cattle of all ages.

In sheep and goats, the situation is more complicated due to wool or hair obscuring the course of veins. However, injection into the cephalic vein is not difficult to teach or perform. The course of the vein can be made more obvious by thorough wetting of the overlying hair or wool and only minimal restraint is needed. Older, larger animals can be sat up for injection. The ear veins are easily observed, especially in goats and these animals have relatively long, thin necks, so that jugular venepuncture can be carried out in the standing animal. (For more details, see 'Veterinary Anaestesia' 10th edition, Hall, Clarke and Trim, W.B. Saunders 2001, pages 347 to 350). Inexperience or lack of training of personnel may necessitate the use of intraperitoneal injections in lambs up to 3 weeks of age but this should be avoided whenever possible.

Venepuncture in large boars and sows is usually easy to carry out when the animal is hanging back from a snare around the upper jaw. The ear veins are easily recognised and may be distended by applying a rubber band around the base of the ear. In smaller pigs intravenous injections may easily be made into the anterior vena cava when the animal is restrained supine with the fore-legs held back and the head hanging down. The technique is rapid, not difficult to learn and causes minimal disturbance due to injection (For more details, see 'Veterinary Anaestesia' 10th edition, Hall, Clarke and Trim, W.B. Saunders 2001 pages 372-373. Where this cannot be managed in very small piglets - e.g. up to 3 weeks of age - intraperitoneal injection causes less pain and disturbance than any other route. The intracardiac injection of any substance is likely to cause extensive tissue damage, especially in a struggling animal and cannot be recommended in pigs of any age.


The intracardiac route of injection is NOT an acceptable method of euthanasia in small lambs and piglets even under field conditions (where other, less objectionable methods can always be used by trained personnel). Intraperitoneal injection, even if slower in producing death, is less traumatic or distressing for the animal.

Expert in veterinary cardiology

'The route of injection would involve the passage of the needle through the following structures:
a) The skin of the thoracic wall
b) The intercostals mscles
c) The pleura
d) The pericardium
e) The myocardium
The sensory innervation of the thoracic wall at this point is provided by the thoracic spinal nerves. These innervate the skin, the intercostals muscles and the pleura. The skin and pleura are similar in their sensitivity to pain. Pain sensation from the mediastinal pleura and pericardium is mediated by the phrenic nerve. Cardiac nociceptors project through the sympathetic cardiac nerves via the spinal nerves of segments T1-T5.

All structures through which a needle would pass into the heart are capable of pain sensation. The skin and pleura are probably the most sensitive.

Assuming the needle for injection has penetrated the thoracic cavity the consequences of missing the lumen of the heart are that euthanasia solution would be injected into the pleural cavity, the pericardial cavity or the myocardium. From the two former sites the solution would be absorbed gradually and provided the dose of the drug used for euthanasia was sufficient the animal would become aneasthetised and die, albeit gradually but without significant pain. If the injection was given directly into the heart muscle the animal may experience discomfort or cardiac rhythm disturbances. The agent would be gradually absorbed and again ultimately the animal would become anaesthetised and then die.

The technique is not difficult provided that there is a good knowledge of the anatomy of the thorax and the operator is sufficiently experienced in the technique.

The technique would become more difficult in larger animals and therefore with advancing age and increasing size the technique becomes less practicable and other techniques become more appropriate in adult animals.

I think that intracardiac injection is an acceptable method of euthanasia of piglets and lambs. The route of injection is not significantly more painful than any injection which involves penetration of the skin. Provided the animal is adequately restrained and the operator adequately experienced the injection can be administered fairly accurately. Even if the injection is administered outside the lumen of the heart the animal will absorb the administered agent and ultimately the result will be the same provided sufficient agent is administered. Alternative methods of humane destruction such as a captive bolt or free bullet are less appropriate in smaller species and immature animals. Intravenous injection, although more appealing from an aesthetic point of view is more difficult than intracardiac injection, also necessitates penetration of the skin and probably requires greater skill on the part of the operator.

The RSPCA and Humane Slaughter Association do not support your views regarding intracardiac injection and culling within sight of others of the herd and on this basis it appears clear that there is no issue of professional conduct for the college to investigate. The chairman of the Preliminary Investigation Committee has confirmed this.

Whilst there is some difference of opinion on this matter within the profession as evident from the experts views - and this is to be expeced - it is clear that the majority view of those consulted is that the practices are acceptable.

I recognise that Animal Aid does not agree with the views expressed by Mr Eddy and thus with the majority of those consulted by the RCVS.

You should also be aware that although no doubt Mr Eddy would provide details if requested, normally an admission without any supporting evidence, would be insufficient for the College to embark upon the investigation of a complaint.

Furthermore, intracardiac injection is a recognised practice in this country and even if in the future the RCVS were to advise that in all cases killing by intracardiac injection was inappropriate (which there is no intention to do), the fact that a veterinary surgeon had used that method prior to any such notification would be taken into account in considering any complaint.

Finally as your complaint is lodged against an officer of the College, the chairman of the Preliminary Investigation Committee has decided that the relevant papers should be placed before the full committee at it's next meeting on 10th October 2001 for the committee to consider and if appropriate confirm the decision in this case. Mr Eddy, a member of the committee will not, of course be present for any part of the Committee's discussion or decision. Any comments or observations you may wish to make on this response should be sent to the RCVS by 9th October 2001.

Yours sincerely

Gordon Hockey
Head of Professional Conduct/Assistant Registrar


October 8, 2001

Dear Mr Hockey

I received on Friday October 5 your response to Animal Aid's complaint against Mr Roger Eddy. You tell me I have until October 9 to answer - given that the matter comes before the full RCVS committee on October 10. In other words, I have had less than two full working days.

Given that my complaint was registered in early June and that your two named witnesses responded in the same month, the timing of your reply strikes me as thoroughly cynical and discourteous.

I have seen Mr Ivan Walton's response to what you sent him and I would urge that his full document be put before the October 10 hearing, along with this email document from me.

My preliminary observations are these:

I note that you failed to invite UFAW - which does not support the use of i/c injection - to join the RSPCA and HSA in offering their view on the matter. Why the omission? Were you concerned that their response would undermine your support for Mr Eddy?

I note also that one of the four anonymous experts you consulted (number 4) also opposes i/c injection - and that the other three were all unhappy at some aspect of the procedure. Expert number one thought it inappropriate for use in animals over four weeks. Mr Eddy admitted in an email to me that he used i/c injection on conscious cats and dogs (i.e. on adult animals).

In other words, the self-selecting case you make for the use of i/c injection is hardly overwhelming.

On the question of killing animals in the sight of their fellows, the RCVS first informed me that the slaughterhouse prohibition arose merely out of 'anthropomorphic perceptions'. In your new reply , you state (in letters to Mr Kirkwood and Mr Laurence) that no such prohibition exists, except with respect to horses. This is utterly wrong, and I am surprised that the RCVS's head of professional conduct should be making and propagating such a fundamental error. Let me refer you to Schedule 6, par. 2.3. of the 1995 Welfare of Animals at Slaughter Regulations.

(3) In England and Wales no person shall bleed any bull, cow, heifer, steer, calf, sheep, goat or pig in a slaughterhouse, knacker's yard or lairage within sight of any other such animal.

Despite this welfare-based statutory prohibition you continue to defend the killing of animals in the sight of others, and - as evidence for your case - are happy to draw my attention to a paper unnervingly titled 'Can animals have a preference not to be killed?'

Let me reiterate what I wrote in a letter to Ms Butler on May 21:

'Is the RCVS line really that sheep and cattle observing the bloody deaths of their family and social group members are untroubled? When those who are yet to be killed huddle and seek to hide in a corner of a field, away from the gore and twitching death throes of their mates, are you really saying they are untroubled?

Let us put the issue more starkly: Would the RCVS say a cat would be untroubled while watching another cat, confined in the same room, being kicked to death? Or that a foal could, with equanimity, watch his mother being mutilated by a thug with a broken bottle?

Does the RCVS recognise that, for instance, a dog can go through emotional turmoil (not eating, becoming lethargic) when his lifelong companion dies? And is the RCVS not aware of the anguish that a dairy cow experiences when - for commercial reasons - her calf is stolen from her within 24/48 hours of birth. Farmers themselves are aware of this phenomenon. They often speak of the days of pining and bellowing. The cow/calf situation demonstrates what is often denied by those who exploit animals - that species other than our own have memories and feelings of anticipation. This can also be seen in the way, for instance, a dog will cower and shake when approached by an individual who habitually beats him.

As I say, I would appreciate the full text of this email message being put before the October 10 full committee meeting of the RCVS.

Yours sincerely

Andrew Tyler
Animal Aid

PS Kindly acknowledge receipt of this email in advance of the October 10 committee meeting.

Gordon Hockey
Head of Professional Conduct
Royal College of Veterinary Surgeons

November 9, 2001

Dear Mr Hockey

I write in response to your October 12 letter, in which you informed me of the findings of the Preliminary Investigation Committee with respect to Mr Roger Eddy.

As I have commented once before in another context, I am dismayed but not surprised by this outcome.

In your second paragraph, you say that the committee 'decided that there were no issues of professional conduct identified' from my complaint. This is despite the fact that Roger Eddy admitted in correspondence with me using i/c injection to kill adult cats and dogs - a procedure that the first of your four anonymous experts opposed where grown animals were concerned. Why is this brushed aside?

In your fourth paragraph, you fail to acknowledge the factual error in your October 4 correspondence - namely, your assertion that the 1995 Welfare of Animals (Slaughter or Killing) Regulations permit the killing of animals within a slaughterhouse in the sight of their fellows. This is incorrect, as I previously pointed out. Killing in the sight of others is expressly forbidden. I never claimed that this prohibition applied to killing in fields and barns for disease control, as you seek to imply. My point was that such a prohibition should apply in disease control circumstances, given that the 1995 Regulations recognised that stress is reduced when animals don't see their fellows being slaughtered in front of them.

I had hoped that the RCVS would endorse this point of view rather than unquestioningly defend the conduct of the cull. Surely you have seen reports of animals cowering in sheds or in corners of fields, as they wait the approach of the killing gangs.

Presumably, you would be happy with this situation because your position is that a group of animals remains indifferent to the sight of members of their own social and family circle being killed in front of them; nor do they have any fear of the men who bloodily took the lives of their fellows. This is an extraordinary posture for the RCVS to maintain, not least in the light of scientific evidence published just this week which reinforces the obvious - that sheep recognise each other and also recognise human faces.

What astounds me is that the College is so adamant in defending painful and traumatic practices, such as i/c injection and killing in the sight of others. Your role, I feel I must remind you, is to protect animals and serve as their advocates, not to excuse the inexcusable.

I can see that your impulse is to close ranks around a high-ranking colleague. But this matter is more than about the reputation of one individual. It relates to fundamental questions of policy and practice.I hope that, even at this late stage, the appropriate committee will make a judgement in the interests of animal welfare rather than be motivated by narrow personal loyalties.

Animal Aid's central objective in this affair is to encourage the RCVS to order a ban on the use of i/c injection in all circumstances other than where an animal is heavily sedated, unconscious or anaesthetised - as required by the Amercian Veterinary Medical Association.

We also wish to encourage the RCVS to demand an end to killing animals in the sight of their fellows. Animals targeted as part of a cull deserve and require this small consideration.

Yours sincerely

Andrew Tyler
Animal Aid

Send this page to a friend

Read about how we treat your data: privacy policy.

© Copyright Animal Aid 2014