Please show your support for slaughterhouse CCTV – the deadline is 21 September!

Question 1. Name Question 2. Address Question 3. Organisation (if you are part of one/ or simply answer N/A or ‘individual’ if you are an individual responding).

Question 4. Should there be mandatory CCTV recording in all approved slaughterhouses in areas where live animals are present? Please give reasons for your response.

Yes.

The voluntary system of installation of CCTV in slaughterhouses is not working and by the government’s own admission, between 2011-13 there was a voluntary increase in uptake and from 2013 onwards this has since plateaued.

• Cameras are often not installed throughout the premises and may not be adequately maintained or positioned. A law should set out detailed requirements and state how the footage would be monitored.
• A report released in May revealed that 93% of slaughterhouses investigated by Animal Aid and Hillside Animal Sanctuary were breaking welfare laws.
• Routine abuse has been revealed time and again in Animal Aid’s numerous investigations spanning 2009 to 2017. Secret filming revealed that workers punched and kicked animals in the head; burned pigs with cigarettes; beat animals; smashed sheep headfirst into solid structures; attacked pigs with shackle hooks; and misused stunning equipment to deliberately give animals powerful electric shocks through their ears, tails abdomens and open mouths.
• Other nations have moved on this before the UK, namely Israel and France, with Italy, the Netherlands and Belgium’s Flemish region expected to follow suit.
• In addition to this it is worth mentioning the matter of monitoring by an independent body that has animal welfare as its priority rather than profit. This is key for effectively deterring and detecting problems.

Question 5. Is it reasonable to require Food Business Operators to retain CCTV footage for 90 days? Please give reasons for your response.

 Yes

• It is imperative that footage is retained for 90 days, and it costs the ‘Food Business Operator’ (i.e. the slaughterhouse owner) very little to do so.
• It is essential that vets and others are able to look back over a period of time to determine whether a questionable action brought to their attention was a one-off or part of a systemic and ongoing problem. 

Question 6. If you believe the 90-day retention period to be unreasonable what is a reasonable retention period for CCTV footage? Please give reasons for your response.

N/A

Question 7. Should there be unfettered access to CCTV footage, both real time and stored, for authorised officers, e.g. Official Veterinarians of the Food Standards Agency? Please give reasons for your response.

Yes

• Investigations by animal protection groups have revealed that abuse has occurred at slaughterhouses even when a vet was theoretically supposed to be present to oversee animal welfare.
• Ensuring officials are able to watch in real time means problems could be picked up as soon as they occur.
• The CCTV footage can be used for future training and correctional purposes.
• Stored footage can be used to investigate tip offs and determine whether a situation was a one off event or part of a duration of poor practice and whether the situation is widespread.
• Stored footage provides evidence, should it be required, for criminal prosecutions.

Additional information that you may care to include under this heading:

• An external, independent body overseeing the monitoring of footage would help safeguard animal welfare in cases where vets were implicated in not acting when they should. For example, ABP Sturminster continued to slaughter cows using a stun pen that was not set up legally.
• A truly independent body that operated outside of the often-charged slaughterhouse atmosphere would be able to spot-check footage, and act without fear of reprisals on the ground.

Question 8. What are your views on the possible costs and benefits of these proposed reforms, as set out in the internal Impact Assessment? Please provide evidence to support your response.

• The cost of installing cameras is, as George Eustice has said, relatively modest, and the benefit of ending gratuitous abuse far outweighs this cost.
• A significant sector of the industry has been shown to be non-compliant with welfare laws, despite the presence of a vet and an appointed Animal Welfare Officer, and despite training and certification. Of 15 slaughterhouses, 14 were found to be breaking animal welfare laws, as detailed in the shocking recent report, ‘Britain’s Failing Slaughterhouses’
• The granting of Certificates of Competence suggests that workers know how to comply with the law, and cameras – if independently monitored – will ensure they continue to do so even when no regulator is physically present. 
• A significant percentage of slaughterhouse vets and hygiene inspectors report being bullied by slaughterhouse staff. CCTV would protect them, and allow them to undertake their duties without being intimidated.

Question 9. Are there other potential economic benefits or costs not set out in the Impact Assessment? Please provide evidence to support your response.

N/A

Question 10. Should CCTV be installed in all approved slaughterhouses, regardless of size? Please provide justification for your response.

Yes.

• Animal Aid’s evidence shows that workers at slaughterhouses of all sizes, across the whole country, break welfare laws when they think they are not being watched.
• In order to ensure the entire industry is better regulated and that illegal acts are deterred and detected right across the board, CCTV should be made mandatory for all slaughterhouses. The cost would be proportional to the size of the operation.

Question 11. What do you think Government could do to help small businesses comply? Please provide justification for your response.

• It might offer a longer period for compliance for the very smallest slaughterhouses.

Question 12. Have we identified the main potential animal welfare gains from CCTV in slaughterhouses?

Yes, but there are other gains, too, including:

• CCTV deters acts that could lead to injuries and deaths, while footage could be used to determine how accidents occurred and prevent them occurring again. Such incidents include: the accidental shooting of a worker at Sandyford in 2011 and the death of a man crushed at the same slaughterhouse, in the same year.
• CCTV could protect the public. There have been a number of firearms thefts from slaughterhouses, and a number of suicides and murders using captive bolt guns taken from abattoirs.