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FAWC Response to the Consultation on Responsibility and Cost Sharing in Wales

5 June 2008

FAWC welcomes initiatives to foster greater partnership between the Welsh Assembly Government and industry stakeholders in developing and implementing future animal health and welfare strategy in Wales.  It is important that responsibility sharing along the entire food supply chain is included.

Approaches to responsibility sharing should minimise the development of new bodies with further tiers of administration which impose an additional financial burden on tax payers and the livestock sector.  It is important to ensure ‘joined up’ management within the area of animal health and welfare and with other policy areas impacting on the livestock sector, and Government may be best placed to ensure this.  Any approach to cost sharing through a levy must minimise administrative costs, ensure full representation of the levy payers in the management of collected funds and transparent accountability of expenditure.

Whilst it is reasonable to ask industry to bear the costs of measures which directly improve their business income, it is not realistic to ask them to accept those costs of animal welfare measures required by society, that will not improve the market attractiveness of their products or enterprise profitability, unless passed on through product price.  If increased product prices for higher welfare are not accepted by retailers or consumers, who have access to imported products which may be produced to lower welfare standards, the sustainability of the Welsh livestock industry will be called into question.  Increased consumer awareness and the use of welfare labelling (see FAWC report on labelling, 2006) should help in this regard.

The main limitation of the Consultation document – from FAWC’s viewpoint - is that it is largely focused on livestock disease control with little explicit mention of animal welfare, and it is not clear how animal welfare might be included within a responsibility and cost sharing arrangement.  For example, under Key Principles (Page 7, Paragraph 3.3) there is only mention of disease risk and no reference to animal welfare.  Indeed, it is apparent from this document (and from previous consultation documents on responsibility and cost sharing in both England and in Wales) that little thought has (as yet) been given to animal welfare considerations.

It is important that proper consideration be given to how animal welfare might be incorporated into any responsibility and cost sharing arrangements or indeed whether responsibility for welfare might be dealt with differently, with Government continuing to play a major role.  As noted above, producers and the livestock industries may have little incentive to improve animal welfare under current market arrangements.  There will remain aspects of animal health and protection of animal welfare that Government will need to take ultimate responsibility for on society’s behalf.

We hope you will find these comments helpful.

Yours faithfully,

Professor Richard Bennett
Farm Animal Welfare Council
Chairman, Ethics, Economics, Education and Regulation Standing Committee

Enclosure:  FAWC Report on Welfare Labelling