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National Pig Association THE VOICE OF THE UK PIG INDUSTRY NPA is active on members' behalf in Brussels & White-hall, and with pro-cessors, supermarkets & caterers – fighting for the growth and pros-perity of the UK pig industry.

"New welfare measures may create a better image, but they add considerably to costs," she says. "Undermining the industry's viability creates a competitive disadvantage for EU pig producers in the current global market, and a trading advantage for imported product from differing welfare systems. Is this really in the interests of the welfare lobby?"

Her remarks follow the recent publication of a pig welfare report from an influential European standing committee which proposes (among many other things):

• Straw (or equivalent) for all pigs, including for sows to nest in.
• No totally-slatted accommodation.
• Enhanced space allowances for growing pigs and finishers.
• Natural light in new buildings.

As these recommendations provide a baseline for future legislative proposals, it is crucial that the welfare benefits are examined carefully, with full awareness of their justification, possible costs and impact on the EU pig industry, says Ann Petersson in a consultation response to Defra.

"For example, initial capital estimates to include putting solid areas on a totally slatted system, will need 15-20% more pens.

"Taking a 3000 finisher system, this would average at a cost of 3150, totaling 390,000. Additional running costs will be required for heating (less pigs in a pen), creating climate change levy cost implications."

The real question, she says, is whether the additional requirements would create better welfare conditions for pigs.

"To date, our general impression is that there is unconvincing welfare evidence to warrant the proposed changes.

"It is vital that Defra takes a hard look at the impact of the proposed recommendations to be discussed and agreed at the Council of Europe, as foremost we share the goal of improving the welfare of the pig and ensuring high welfare product goes to UK consumers."

NPA has urged Defra to pay particular attention to the following points from the report:

• Certificate of competence

NPA response: Our present code of practice requires practical competence, which is monitored by vets through regular farm assurance visits. A certificate is unnecessary with this system, and adds another layer of bureaucracy.

• Visual barriers

NPA response: We opposes the draft recommendation that there should be "visual barriers within group pens" Practical evidence has proven that visual barriers have the potential to create a negative welfare impact, not positive. Other pigs in a group can equally act as an effective physical barrier from aggressors, and will also prevent any escapee getting trapped behind an artificial barrier, or a bottleneck arising.

Furthermore, there is the possibility of a disruption of ventilation flow if rigid visual barriers are constructed in an old building. Visual barriers will also make it more difficult for stockmen to inspect the pigs.

The NPA is concerned that the provision of visual barriers could impair welfare, in certain circumstances. The wording therefore should not be prescriptive, allowing straw bales, for example, if the circumstances so warrant

• Solid floors in the lying area

NPA response: We are concerned at the continuing drive to compulsorily introduce solid floors in the lying area. This proposal goes against practical evidence, which indicates that pigs on slats or perforated floors of suitable materials are drier and significantly more comfortable.

Trying to adapt old buildings to create solid floors in the lying area could have adverse implications for welfare, as very careful adjustment of ventilation would be required.

The key criteria are the quality of flooring, its state of repair, and suitability for the purpose intended. The current Stotfold work is addressing the implications of varying systems on welfare needs.

• Manipulable materials

NPA response: All pigs to have access at all times to adequate amounts of materials for investigation and manipulation, including rooting. Materials listed include straw, hay, maize chaff, grass, peat, earth, wood and bark.

We are surprised that peat is still included in this list, in view of its link to potential health and environmental problems. The crucial words in the text relating to pig health and welfare are not included in the brief extract in the summary letter from Defra.

This prescriptive wording will cause intense welfare problems from blocked up slatted accommodation. As about 80% of the new environment friendly buildings built in this country over the last 10 years have slatted flooring, agreement to this recommendation would render this these buildings illegal for pig production. As this is clearly not in the industry's interests, the NPA strongly recommends that the words "unless it is not technically feasible for the slurry system used" should be included in this section on manipulable materials to prevent such problems. To emphasise the importance of the pig's well being, and without prejudice, the wording on environmental enrichment regarding the use of objects (para 81) in our latest code of recommendations could be a useful inclusion in this context.

We note that Article 13 applies to all pigs, including sows and gilts, if the latter are in new accommodation only. It does not apply to existing accommodations until 1 January 2013. Yet legislation implementing the EC Welfare Directive requires manipulative materials to apply to all pigs from 1 January 2003. Is this a legal inconsistency, or did the drafting of the EC Welfare Directive only intend the application to new and replaced accommodation for sow and gilts. Not to all existing buildings?

• Water sprays

NPA response: This recommendation for water sprays needs to be kept optional and left to the stockman's judgement. It may be beneficial and a useful tool in southern climes but will not be in the cooler, wetter climes of the northern member states. A compulsory requirement would therefore be impractical, unnecessary and uneconomic, with implications for ventilation.

• Natural light in newly built or rebuilt facilities

NPA response: Where is the scientific evidence for this recommendation? We ask Defra to challenge Article 20.1 on the grounds that perception, rather than practical evidence, has influenced this recommendation. In other words, public image, rather than welfare interests, has been the main determinant.

If this recommendation were to be agreed, then thermal insulation, efficiency and costs would be affected, significantly in certain instances for no apparent scientific justification.

The key issue is the adequacy of the light for the pigs and their inspection, and its safe location.

• Teeth clipping prohibited (although grinding permitted in very limited circumstances)

NPA response: NPA maintains that both clipping and grinding should be retained for use in appropriate circumstances, and question the justification for moving away from the text in the recently agreed EC welfare directive.

We are concerned that the Council of Europe may not have an adequate understanding of the extent of welfare problems from tail biting, as there appears to be a concerted drive to ban tail-docking. Producers do not want to tail-dock. It is another task on-farm, which producers would prefer not to undertake. However, in the current state of knowledge and experience of the possible contributory factors to the problems of tail-biting, tail tipping or docking has been found to be an effective deterrent.

We note that the castration of pigs less than 7 days is allowed "without tearing of tissue". We would welcome a technical explanation on how castration can be achieved, without the tearing of tissue.

• Dry sows

NPA response: Surely the welfare arguments justifying group housing should apply to all holdings, irrespective of size, with no 4-week exemptions. We ask Defra to ask for the extension of the group housing provisions to ensure that they are compatible with UK legislation. This will not only ease enforcement, but also ensure a more level playing field throughout the EU of the group housing provision.

As mentioned earlier in our response, visual barriers are not necessarily in the best welfare interests of the pig. Practical evidence suggests that dominant sows could claim these areas as their own. Visual barriers are difficult to construct in existing buildings, and increase the risk of injury to both pigs and stockmen. Furthermore, visual barriers disrupt the ventilation flow and can make it more difficult for stockmen to inspect the pigs.

• Pigs from ten weeks to slaughter or service

NPA response: What is the scientific evidence for nearly doubling the current space allowances? Considerable capital and running costs will be necessitated. These changes may improve the image of pig keeping, but not enhance the pig's welfare. The delicate balance required to achieve appropriate room temperature and airflow in unheated buildings is significantly affected by stocking density, and the suggested changes could adversely affect pig welfare.

Ann Petersson says: "We are very concerned by the possible outcome of these negotiations and ask Defra to question the Council of Europe on the real welfare benefits of these recommendations. There appears to be inadequate scientific evidence available to justify these changes, which will have a substantial cost impact on EU pig production with no real enhancement to pig welfare."

She says producers are very concerned that there is discussion of further changes to pig welfare regulations, so soon after Defra have brought out their new pig welfare code. "Although they appreciate the background to the Council of Europe as a forum, producers are worried that these recommendations could set a 10-year agenda for future Commission proposals. Pig producers are very worried at the prospect of further regulatory burdens, which they feel have played a major part in the huge decline in pig numbers in England and Wales."

See the NPA response in full.

See the EU welfare report.

Source: National Pig Association - 11th May 2003