To whom it may concern,
I am writing to respond to the consultation on the draft Animal Welfare (Sentencing and Recognition of Sentience) Bill.
Response to the consultation questions
Are you replying as an individual or an organisation?An individual
If you are responding on behalf of an organisation, please let us know which organisation.N/A
Do you consider that the term 'sentience' should be defined explicitly?Yes
If you answered ‘yes’, what definition should we use?I am happy with the given definition as long as it is understood to include feelings of pleasure and pain.
Do you consider that the term ‘animal’ should be defined explicitly?Yes
If you answered ‘yes’, what definition should we use?I am happy with the given definition.
Do you consider that the term ‘welfare needs of animals’ should be defined explicitly in the clause?Yes
If you answered ‘yes’, what definition should be used, and should the list of needs in the Animal Welfare Act 2016 be changed?As a humanist, I believe that society has a duty to reduce animal suffering arising from human behaviour. I am concerned that the current definition of ‘welfare needs of animals’ does not include a duty to prevent pain and suffering to animals during slaughter. At present, the law requires all animals to be pre-stunned before slaughter, so that they are insensible to pain and distress. However, there are exceptions to this law for Muslims and Jews who wish to slaughter animals using halal and kosher methods. These methods, which include cutting the animal’s throat with a knife and slowly bleeding it to death, are incompatible with the welfare standards applied more generally, take no account of the suffering and pain caused to the animal, and can only be described as cruel. I believe that these exceptions, to otherwise sensible welfare laws, should be ended. My view is shared by many animal welfare and veterinary organisations, including the Royal Society for the Prevention of Cruelty to Animals (RSPCA), the British Veterinary Association, the Humane Slaughter Association, and Humanists UK. The Government’s own Farm Animal Welfare Committee is also of this view.This could be achieved through expanding the fifth part of the definition of an animal’s welfare needs to include the need to pre-stun animals before slaughter. It should read ‘the need to be protected from pain, suffering, injury and disease whilst alive and during the the process of slaughter (including by the use of pre-stunning), euthanasia, and culling.’
Do you agree that the draft Bill should apply to all policy areas?Yes
If you answered ‘no’, why do you not agree with this?N/A
Do you agree that the draft Bill should adopt the term ‘should have regards’?No
If you answered ‘no’ how do you think the level of regards should be specified?I believe that this Bill should aim to retain the same level of protection for animals as they are currently afforded under European Union legislation. Therefore, it should read ‘pay full regard to the welfare requirements of animals.’
Do you have any views or comments on the consequences of this new duty?While I respect people’s right to hold religious beliefs, I do not agree that the right to manifest those beliefs should ever justify causing unnecessary pain and suffering to other human beings and indeed to animals, as is the case with non-stunned slaughter. It is my understanding that the Human Rights Act 1998 limits the right to manifest religious beliefs if those beliefs interfere with the health or morals of a democratic society. I would strongly suggest that slicing open an animal’s throat while that animal is still fully conscious and sensitive to pain and suffering very much interferes with the morals of our society. Therefore, in recognising animal sentience through this Bill, the Government should also recognise that protection from pain and suffering at the time of slaughter is an essential welfare need, which should not be relegated in favour of religious beliefs.The current law with regard to non-stunned halal and kosher slaughter is incoherent. It is well established both in our laws and in public opinion that part of the welfare needs of an animal is to be protected from unnecessary pain and suffering. This is recognised as applying at the time of slaughter and is why we have laws that require pre-stunning, and hopefully soon, compulsory CCTV in abattoirs. This means that the exceptions being made for halal and kosher slaughter cannot be justified. Nowhere else in our animal welfare legislation is such an exception made. For example, we (rightly) do not allow foxes to be hunted or cocks to be fought by people who can claim this is part of their cultural heritage. It is either cruel and unacceptable to subject an animal to this type of death or it is not. I do not see how for the animal who experiences such treatment, there is any difference. Adding a duty for stunning at slaughter as a welfare need will address this moral and logical inconsistency.
Do you have any views about whether a different formulation or approach might achieve the policy objectives? Views would also be welcome on how the approaches adopted in other countries might apply hereN/A
Do you agree with the new maximum sentence?Yes
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