Part 2 - Background Information
The Scottish Government considers the welfare of animals at the time of slaughter as important and takes it very seriously. There are very strict statutory welfare requirements contained in EU and domestic Scottish legislation.
EC Council Regulation 1099/2009 'on the protection of animals at the time of killing' came into force in the UK and all other member states of the European Union from 1 January 2013, increasing welfare protection for animals at the time of slaughter. In Scotland, the Welfare of Animals at the Time of Killing (Scotland) Regulations 2012 ("the 2012 Regulations") provides the powers to fully enforce the EU regulations and retains our longstanding stricter national rules which give greater protection than the EU regulations.
The legislation is aimed specifically at preventing cruelty and poor practice in slaughterhouses and other places where animals are slaughtered or may have to be killed. Regulations set down specific requirements which must be complied with at all stages of the slaughter or killing process; and it is an offence to cause any animal avoidable excitement, pain or suffering at any time between its arrival at a slaughterhouse and when it is killed.
Food Business Operators are primarily responsible for the welfare of animals on their premises. Official Veterinarians from Food Standards Scotland ( FSS) monitor and enforce the welfare regulations in all approved Scottish slaughterhouses to ensure that animals are spared avoidable pain, stress or suffering during the slaughter process. FSS approves Scottish slaughterhouses in line with EU Regulations EC/852/2004 'on the hygiene of foodstuffs' and EC/853/2004 'laying down specific hygiene rules for food of animal origin'.
Issue Being Addressed
CCTV has been identified as offering real benefits as an important complement to physical observation and verification of slaughterhouse practices ( FAWC report 2015).
In 2012, the Scottish Government consulted on introducing compulsory CCTV in slaughterhouses as part of its consultation on 'the implementation of EU regulation 1009/2009' and, on the basis of responses, decided to continue to encourage a voluntary approach for the time being.
It is acknowledged that there is the potential for animal welfare to be compromised wherever live animals are kept in slaughterhouses, and CCTV provision is not currently universal across all areas of slaughterhouses. Voluntary introduction of CCTV has been shown to be beneficial to animal welfare; and FSS data from 2017 shows that 68% of all slaughterhouses in Scotland already have CCTV in various configurations with 61% having coverage in the lairage, 61% in the unloading area, 46% in the restraint and stunning area, and 54% in the killing area. Slaughterhouses on the Scottish mainland are served with greater levels of CCTV: 86% of all slaughterhouses in Scotland already have CCTV in various configurations with 86% having coverage in the lairage, 77% in the unloading area, 59% in the restraint and stunning area, and 68% in the killing area. In excess of 99% of the animals slaughtered in Scotland in 2016-17 were monitored by some configuration of CCTV coverage.
Independent Assessment of Benefits of CCTV in Slaughterhouses
The Farm Animal Welfare Committee ( FAWC) was commissioned by GB Governments to produce an independent assessment of the benefits of CCTV in slaughterhouses. The report was published in February 2015: https://www.gov.uk/government/publications/fawc-opinion-on-cctv-in-slaughterhouses
CCTV was identified as offering real benefits in slaughterhouses as an important complement to official physical observation and verification of slaughterhouse practices and effectively recording animal welfare abuses. FAWC recommended that all approved slaughterhouse operators should install CCTV in all areas where live animals are kept and where animals are stunned and killed. FAWC also recommended that CCTV cameras should be installed so as to permit a clear and uninterrupted view of the processes being recorded at all times; that CCTV footage should be accessible to and viewed on a regular basis by Food Business Operator staff, Animal Welfare Officers and Official Veterinarians to ensure business compliance, particularly in those areas and for those processes where the risk of non-compliance is higher; and that CCTV footage should be retained by the slaughterhouse for a period of three months and be available to authorised officers.
FAWC stated that CCTV should not replace, reduce or be considered a substitute for current controls of slaughterhouse practice undertaken by Official Veterinarians, Animal Welfare Officers, slaughter operators and others.
However, FAWC recognised the additive value of CCTV towards protecting animal welfare and benefiting the plant operator's business, including:
- providing evidence of due diligence and compliance with legislative and commercial standards and responsiveness to consumer concerns increasing public trust;
- contributing to Food Business Operator reviews of effectiveness of operations (including improving handling and reducing stress in animals) and enable the Food Business Operator to make improvements to processes and operating instructions;
- providing a valuable training tool for slaughterhouse staff;
- encouraging collective responsibility in slaughterhouse staff;
- providing evidence for disciplinary action; and
- enabling disputes to be resolved including relating to spurious allegations.
Official Veterinarians have legal powers under regulation 20 of the 2012 Regulations to seize CCTV footage if they have a reasonable suspicion that a breach of the regulations has occurred. Failure to provide information (including CCTV footage) which is requested and reasonably required by FSS may constitute an offence. FSS has not experienced any such refusals. Unrestricted access for authorised officers, e.g. Official Veterinarians from FSS and staff from organisations approved by the Scottish Ministers, could provide better proactive and reactive opportunities to assess compliance with the regulations.
It is not possible for Official Veterinarians to be present at all parts of the slaughter process at all times; and offences might be committed where there is no ongoing oversight. In such circumstances, CCTV might be used to enable official observation and verification of animal welfare incidents, and can contribute towards the auditing of animal welfare and the verification of slaughterhouse compliance with legislation. CCTV offers authenticity and transparency and can be retained for future review or for evidential purposes. CCTV can also offer the Food Business Operator or Official Veterinarian access to monitor activity in hard to see areas such as the killing area or within gas stunning systems.