The Scottish government have joined England and Wales in hosting a consultation regarding live animal exports. Animal Aid would like to see a complete ban on the needless live export of animals, however this brings an opportunity to improve conditions for some of the victims of the animal farming industry.
Please join us in responding to the Scottish consultation. We have provided some example responses to the consultation questions below to help you, although greater consideration may be given to responses in your own words, rather than exact duplicates.
The deadline for responses is 26th February 2021.
More details about the consultation are available here
The consultation is in response to this Farm Animal Welfare Council (FAWC) report
Respond by completing the online form on the Scottish government website here
Find out how to respond to the England and Wales consultation here
Guidance in responding to the consultation questions
You may like to incorporate into you response a general statement of your thoughts about live exports. The questions themselves don’t adequately prompt for this. Here is a suggestion:
I would like to see an end to the consumption of animals and animal products for food, and as such argue for a transition from animal-based to 100% plant-based agriculture. I would, therefore, like to see an end to all live transportation of farmed animals. However, I welcome moves which reduce journey times, eliminate the worst suffering, exclude as many animals as possible from live transportation and improve transit conditions for those that sadly do continue to be needlessly transported.
Presently the UK exports live farmed animals in their thousands every year, often in stressful, crowded, filthy and downright hazardous conditions. The live export of farmed animals causes stress, injury, dehydration, stress-linked disease due to impaired immune function, such as salmonellosis in sheep and respiratory disease in cattle, for example. The live export of high numbers of sick or diseased animals is a particular concern, both for the welfare of the animals concerned and the spreading of disease.
Q1 no, Q2 no Q3 yes Q4 yes Q5 no Q6 no Q7 no Q8 no Q9 no Q10 no Q11 no Q12 yes Q13 no Q14 yes Q15 broadly speaking yes Q16 yes Q17 N/A
Q1. Do you agree with the FAWC recommendations for future research and the Scottish Government’s position and proposed course of action? Please provide any further relevant information.
New scientific findings should be used to inform areas of concern and that this should ideally be species-specific and subgroup-specific.
In terms of funding for research, we are concerned that industry-led and industry-funded research will be driven by industry interests and priorities, rather than the wellbeing of animals. Research must be commissioned and undertaken by institutions prioritising the interests of animals.
Q2. Do you agree that prior permission should be obtained from the relevant UK authority for some journeys exporting live animals and permission should only be granted if the reasons for not undertaking a shorter alternative journey are justified? Please provide any further relevant information.
I strongly urge that a full live export ban be considered. A ban on all live exports being the most effective way to protect farmed animals from the suffering, stress and hardship of long-distance live transportation. I am extremely disappointed that the Scottish Government is not at the very least following the course laid out by the Governments of England and Wales in proposing a live export ban for the live export of animals for slaughter and fattening.
Q3. Do you agree with the Scottish Government’s position on determining fitness for transport and proposed course of action? Please provide any further relevant information.
Transporting animals who are unfit for travel is by far the most common form of non-compliance. For poultry species, this accounts for nearly all violations. Transporting animals that are unfit for transport is unacceptable, and I agree with FAWC that this needs urgent attention.
The definition of fitness for transport needs to be more precise and include species-specific requirements, covering all relevant aspects of the journey, the vehicle and the travelling conditions. Requirements for assessing fitness during journeys must also be stipulated.
Provision of training must be improved and be mandatory. Crucially, there must be a clear understanding where responsibility lies in determining fitness for transport. There needs to be robust enforcement and significant penalties for violations.
Q4. Do you agree that there should be no distinction between registered and unregistered horses in future legislation on welfare during transport? Please provide any further relevant information.
Yes, I agree that there should be no distinction between registered and unregistered horses for the purposes of protection during transportation. Under EU regulations, UK registered horses have been exempted from the regulations governing live export and transportation.
I am extremely concerned that for some time registered horses have not been protected by the current live transportation regulations. Retired registered horses are particularly vulnerable and in need of protection afforded by such legislation.
Q5. Do you agree with the Scottish Government’s position on the means of transport and proposed course of action? Please provide any further relevant information.
The Scottish Government’s response to the FAWC recommendations on means of transport is not sufficient and disappointing. I agree with FAWC’s recommendation that all vehicles transporting farmed animals should be inspected by Vehicle Approval Bodies, irrespective of journey length.
I am also disappointed with the Scottish Government’s response to the FAWC call for a requirement that all vehicles should be fitted or retrofitted with accelerometers. There is significant evidence that sudden accelerating, breaking or turning and other inappropriate driving causes physical harm and stress to animals being transported.
Satellite navigation should be required for all vehicles, regardless of journey length.
Mandatory training for all those involved in transportation is also vital. It is wholly inappropriate for certification of competency to apply indefinitely. Competency should be reassessed and renewed at least every two years, ideally annually.
Q6. Do you agree with the Scottish Government’s position on the maximum time an animal may spend at market and proposed course of action? Please provide any further relevant information.
I oppose the trading of animals and the use of livestock markets full stop from an ethical standpoint. From a welfare point of view they are to the detriment of animals and have a huge potential to cause animal suffering, neglect and harm.
As it is, urgent attention must be paid to strengthen regulation and licensing. A maximum time should be set for how long animals can spend at a market.
Q7. Do you agree with the Scottish Government’s position on space allowances for animals in transport and proposed course of action? Please provide any further relevant information.
Species-specific minimum headroom heights should be specified in law and be a legal requirement for all journeys.
Headroom should allow for an animal to hold their head in a comfortable position and be measured from the highest point of the head, including horns. This needs to be included in legislation and guidance.
Headroom is important for both the maintenance of normal posture and to ensure sufficient ventilation. Headroom should also provide sufficient clearance to allow evaporating heat to escape.
Crucially, maximum stocking densities must apply to all journeys and should be a legal requirement. The Scottish Government needs to clearly state this as policy.
To guard against breaches and ensure compliance, an improved and more robust inspection regime is needed. I would like to draw your attention to these shocking Freedom Of Information findings from Onekind: https://theferret.scot/suffering-scotlands-farm-animals-live-transport/
Q8. Do you agree with the Scottish Government’s position on transport practices and proposed course of action? Please provide any further relevant information.
Legislative protection should be extended beyond commercial transportation to also cover non-commercial live animal transportation.
Protection also needs to apply to the transportation of animals used for scientific purposes including in laboratories.
We disagree with the Scottish Government position that protection of non-commercial animals may be non-statutory. Non-commercially transported animals have the same capacities for suffering and experience as those animals transported commercially and legislation must ensure they have the same level of protection.
Q9. Do you agree with the Scottish Government’s position on thermal conditions and ventilation for animals in transport and proposed course of action? Please provide any further relevant information.
Unweaned animals are especially vulnerable, I therefore do not believe that unweaned animals should ever be subjected to cruel live transportation.
Young calves should not be transported as they are not well adapted to cope with transport, which results in high rates of morbidity and mortality, both during, and in the few weeks immediately following transport. Their immune systems are not yet fully developed, and they are not able to control their bodily temperature well, so therefore are susceptible to heat and cold stress. Their health is therefore hugely compromised by transportation.
I am concerned about heavily fleeced sheep being transported in the summer and closely shorn sheep being transported in the winter.
As well as temperature, humidity is an important factor affecting the welfare of animals during transportation, particularly in relation to heat stress
Poultry are particularly vulnerable to temperature fluctuations, and poorly feathered birds are especially at risk from the cold.
Q10. Do you agree with the Scottish Government’s position on maximum journey length and proposed course of action? Please provide any further relevant information.
I would like to see an end to the cruel live transportation of all farmed animals and horses.
However, we do not believe that most of the recommended maximum journey times proposed by FAWC (FAWC, 2019. Table 7) are short enough to protect animals sufficiently.
In terms of maximum journey length, it has been widely accepted that an 8 hour journey time should be the maximum permitted.
Unweaned animals are incapable of independent intake of solid feed and water and are particularly vulnerable. They are fundamentally unsuited to live transportation. The Eurogroup for Animals 2021 white paper recommends that any farmed animals that are unweaned or under the age of 8 weeks should be designated as unfit for transport.
The proposed minimum space allocations for pigs do not specify a requirement that they must be able to lie down during transit, even though the EU good practice guide for transporting pigs states this.
I am very concerned about scenarios where animals continue to be subjected to lengthy journeys as a result of journeys being broken, animals rested, and then the same animals continuing to third destinations under new paperwork.
Q11. Do you agree with the Scottish Government’s position on mid-journey breaks and proposed course of action? Please provide any further relevant information.
It is important that the system of maximum journey times doesn’t enable a repeat cycle of travel-rest-travel, where, in practice, animals would be subject to long overall journeys, including onward trips to far destinations such as the Middle East or Africa.
The use of mid-journey breaks cannot substitute for what is needed: an enforced maximum journey time of 8 hours or less for all live transportation.
Q12. Do you agree with the recommendation that anyone who transports livestock, poultry or horses should require transporter authorisation and a Certificate of Competence, including if they only transport animals on short journeys? Please provide any further relevant information.
We agree with the FAWC recommendation that short journeys of 65km or less transporting livestock, poultry and horses should become subject to the requirement for transporter authorisation and a Certificate of Competence.
Q13. Do you agree with the Scottish Government’s position on transportation of animals by sea and proposed course of action? Please provide any further relevant information.
I want to see an end to the systematic live transportation of animals, particularly over significant distances. I have particular concerns about the negative effects on animals of sea transportation.
I agree with the FAWC recommendation that time spent on a sea crossing should be counted as journey time and not as ‘neutral time’. The Scottish Government should legislate for this.
Q14. Do you agree the Scottish Government should consider the proposed review on research into transportation by rail or air alongside other research priorities? Please provide any further relevant information.
We agree with the FAWC recommendation that more research is needed into the welfare issues associated with transporting animals by rail or air.
According to FAWC “Ever increasing numbers of chicks are transported by air over long distances and may be subject to delays and periods of holding in less than optimal conditions constituting significant welfare concerns.” (FAWC, 2019. p254). Chicks, and especially day-old chicks, are particularly vulnerable and their wellbeing during transportation is a major concern.
Q15. Do you agree with the Scottish Government’s position on the collection and use of feedback to identify welfare risks in transport and proposed course of action? Please provide any further relevant information.
As FAWC points out, enforcement of the current regulations governing the health and welfare of animals in transit, is the responsibility of local authorities, who have to undertake this duty with very limited resources. We are concerned that insufficient resources and support make it impossible for local authorities to discharge this duty effectively. FAWC has highlighted a lack of enforcement in the UK as a major concern. This needs urgent attention.
Q16. Do you agree with the Scottish Government’s position on the enforcement of welfare of animals in transport and proposed course of action? Please provide any further relevant information.
In assessing culpability for non-compliance, ignorance cannot be a defence. I agree with the FAWC recommendation that more education and training, including use of agreed guidance, is applied to all those involved with the transport process. It is essential that training and information is provided to all those undertaking live transportation of animals. It is important, as stated elsewhere, that this information and all guidance is clear and accessible and sets out where responsibilities lie.
To strengthen enforcement, greater investment is needed for inspections, which must be more thorough and frequent. The Scottish Government needs to commit resources and publish a detailed plan for strengthening the enforcement and inspection regime.
Respond by completing the online form on the Scottish government website here