Welsh Assembly Government consultation on:
Response on behalf of:
Organic Centre Wales
Institute of Rural Sciences
University of Wales Aberystwyth
Ceredigion SY23 3AL
Prepared by Dr Phillipa Nicholas
27 June 2005
In general the Code provides good coverage of the welfare needs of sheep in Wales. Outlined below are a few specific comments that we feel need attention in the document:
Section FEED AND WATER, Point 13: Water should be available to livestock at all times, rather than as stated in the draft code “Ideally, water should be available at all times”. This ensures that at least part of the first of the FAWC Five Freedoms (Freedom from hunger and thirst) is fulfilled.
Section HEALTH, Point 21: Emphasise that health plans should be used as management tools to prevent ill health and disease, rather than just a diary of health management practices and medicine use. The risk of anthelmintic resistance developing on farms where incorrect drench administration practices are used should also be highlighted and references made to a good practice guide such as SCOPS (now translated into Welsh).
Section HEALTH, Point 26: Condition scoring requires some skill to do well and as a precaution farmers could be recommended to use weighing (at least on a sample of animals) as well as condition scoring until they have developed this skill fully.
Section HEALTH, Point 33: The need to use best practice (as outlined in SCOPS) when administering Anthelmintics must to be emphasised.
Section MANAGEMENT, Point 50: A number of issues are not addressed in this section. The first should be a ban on the use of electric prods to move animals; these are entirely unnecessary when moving sheep. The second is that there is no maximum journey time specified for sheep. Organic regulations (e.g. Soil Association) suggest the maximum journey time any animal should undergo before being rested is 8 hours. A third issue not addressed is waiting time before slaughter. Under organic regulations, if a wait at place of slaughter is anticipated to be longer than 6 hours, then bedding and a place for the animals to lie down must be provided. In addition, if the wait is long than 12 hours, feed and water must be provided also. Finally, no mention is made of keeping different social groups separated during transport. Mixing of social groups can cause quite high levels of stress and fighting amongst animals, especially when in a confined space such as a transporter. It would be relatively easy to put simple barriers in place to prevent groups of animals mixing and therefore reduce stress levels.
Section MANAGEMENT OF HILL EWES ON ROUGH GRAZINGS, Point 94: It should be emphasised that the farmer should be aware of all cross-compliance issues with respect to Agri-Environment and other schemes, not just the implications to the positioning of winter feed sites.
Section HOUSING, Point 118: State explicitly that animals should have access to clean, fresh water at all times when in housing.