Proceedings of the Second NAHWOA Workshop

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Discussion report
 Discussion of the EU livestock regulation (1804/99) at the 2nd NAHWOA workshop in Cordoba, Spain 9-11/01/2000

Susanne Padelš and Ray Keatinge˛

šInstitute of Rural Studies, University of Wales, Llanbadarn Campus, Aberystwyth, SY23 2AL, UK
˛ADAS Redesdale, Rochester, Otterburn, Newcastle upon Tyne, NE 9 1SB, UK

 

1.0 The Network for Animal Health and Welfare in Organic Agriculture

The Network for Animal Health and Welfare in Organic Agriculture (NAHWOA) is a concerted action project funded by the European Union under the FAIR programmes (CT98 4405) with the main objectives of:

2.0 NAHWOA debate on EU Regulation 1804/99

NAHWOA provides a forum for ongoing discussion on animal production and welfare, within organic agriculture, which can contribute to the development of the organic livestock regulation. In this context, the network held a session at its 2nd workshop in Cordoba to discuss EU regulation (1804/99) which amends regulation 2092/91 to include livestock production in EU law on the labelling of organic produce.

The following document is intended to assist the members of the network and other interested parties in developing the implementation of the regulation in the member states. Prior to the meeting, members of the network aimed to get an overview of the ongoing discussions regarding the implementation of the regulation into national standards, apart from the section on bees. In addition, some documentary material was considered from Denmark, Switzerland, the United Kingdom, Germany and Austria.

However, it is important to note that the discussion was based on the opinion of individual representatives from the partner countries of the NAHWOA group and not on any official documentation or a broad national consultation process.

 

3.0    NAHWOA general response to EU Regulation 1804/99 and main recommendations

Members of the NAHWOA group welcomed the Regulation as a common legal framework for organic livestock production in Europe. The regulation provides a positive basis for the further development of organic livestock production in the EU. The group recognised that consumer protection was the main guiding principle behind the regulation, and in this context it is important that consumer confidence and the integrity of the organic production system are maintained.

Network representatives from several countries suggested that on some points, at least, their national standards are likely to stay more restrictive than the EU regulation. It was noted that the current regulation did not cover fish, and other more exotic species.

A significant number of issues require further interpretation and clarification, before they can be applied at national or individual farm level; this paper is seen as a contribution to this process. Some aspects of the regulation could pose specific problems depending on the production system, and on the region of the EU concerned.

In order to promote good animal welfare and minimise the need for veterinary intervention, NAHWOA would welcome the opportunity to assist in the development of more specific guidelines that would enable clearer implementation of the regulation at an applied level.

In addition, NAHWOA aims to continue developing the interpretation of the regulation for each species on the basis of current and new ethological knowledge.

Further research and development is required to:

 

4.0    Results of the discussion on specific points of the regulation

 

  1. General


    2. The Group supports the principle that organic livestock production is a land-based activity (1.4). NAHWOA would like to underline that under certain circumstances the collaboration of farms in a particular region is a good mechanism to meet the requirements for feed and manure usage within this section.

    As the main aim of the regulation is the labelling of organic produce for the benefit of the consumer, the Group is of the view that a holding has to fulfil all aspects of the regulation when livestock produce is marketed as organic (see conversion below).

    Definition of a holding (definition 22 and paragraphs 1.5-1.8)

    There is some degree of confusion (particularly in the UK) as to the definition of a unit or holding. The general interpretation of a holding, similar to the practice already used for crop production, is a clearly identifiable unit of land, buildings, livestock, management and financial record. However, the degree to which this can form part of an overall holding or business is unclear. Depending on the definition of holding, this aspect of the regulation could compromise organic research and production at research institutions that have not converted the entire holding. Given recognised research needs in organic livestock production, it would be very undesirable if this resulted in a loss of research capacity.

     

  2. Conversion (discussion also refers to sections 1.5 and 1.6)


    3. A holding will need to undergo a conversion period during which necessary changes are implemented, and conversion of land and livestock takes place, but no produce is marketed as organic.

    It is expected that livestock may be marketed as organic provided the land has completed conversion, and retrospectively from that date, provided that the stock have undergone minimum conversion periods as set out in Section 2.2.1. This will require careful planning of the timing of conversion of the livestock enterprises.

    The regulation should be interpreted to allow stock present at the start of conversion and not fulfilling the criteria in Section 3 to be finished and sold conventionally, although an enterprise with the same species might already have entered the necessary conversion period specified in paragraph 2.2.1.

    There appears to be an interpretation by some that the regulation could mean that all stock on an organic holding must be organic. However, the existence of point 1.6 (non-organic livestock may be present) and the specific regulation in point 2.3 (simultaneous conversion of all land and stock) seem to contradict this.

    Section 2.1.2 provides a derogation to reduce the conversion period to 6 months for outdoor runs, but does not lay down clear criteria as to what documentation is required. In the UK, the sector body group will recommend that conversion periods for non-herbivore outdoor runs can be reduced only to 12 months.

     

  3. Origin of stock

The Group welcomed the intention of the regulation that stock on organic farms should be purchased from organic holdings. From the point of view of disease prevention and positive health management, closed flocks/herds have clear advantages.

The Group notes the significant lack of information on suitable breeds for organic systems, particularly in pig and poultry production.

It is likely that some countries will maintain tighter rules with regard to the necessary conversion periods. In the UK, it is very likely that there will be no conversion of stock for meat production except with poultry: i.e. animals to be sold for meat will need to be born as organic. Denmark also considers that animals which live for less than a year before slaughter cannot be converted and must be born organic, which corresponds with the current IFOAM basic standards.

There are some concerns as to the interpretation of when suitable stock are unavailable; e.g. because of supply, price or quality. In some instances, organic stock may be available but at higher cost. In the opinion of the Group, the unavailability of suitable stock should be assessed on a similar basis as is currently used for the availability of seeds, either by the inspection or certifying body providing an overview of the market situation for that particular year or by the individual producer who would be obliged to supply some proof that enquiries have been made. Neither would it be desirable for organic livestock to be transported large distances within the EU, even if they are available in a distant member state.

 

4. Feed

Apart from the reliance on organic feedstuffs, the guiding principle of this section appears to be the preferred use of home-produced feeds. The proportion of home-produced feed required is not stipulated and leaves room for interpretation, i.e. does this mean more than 50% of feed should come from the farm? Not all regions of the EU can produce cereals for livestock feed locally, so that a continuing degree of derogation to this is required. The group supports the view that clearer guidelines should be elaborated as to when such derogations apply.

Concern was expressed that the rigid application of a positive feed list could limit further development in the feedstuffs available for organic systems. The network would welcome the development of criteria as to what feeds can be used on organic farms, in order to supplement the current list in Annex II C and assist certification bodies in producing positive lists adapted to national/regional conditions.

Because of the benefit to animal health, the group strongly supports the view that the feeding of young mammals should be based on natural milk (4.5), preferably from the same species. Where this is not available, organic milk powder would be the second preference. In the absence of any other sources, organically produced milk replacer, and, as an emergency measure, conventionally produced milk replacer (without antibiotic) could be used.

A suggestion was made from Switzerland to give a recommendation as to what should be done with milk withheld from sale following veterinary treatment.

The question was raised whether for monogastric, omnivorous species a limited range of feedstuffs from animal origin should be considered in future.

The minimum requirement of 60% roughage was discussed, and the group was concerned about the possibility of reducing this to 50% in the case of dairy cows during early lactation. Concerns were raised that a diet with 60% roughage could already cause a physiological disturbance for the dairy cow, resulting in higher rumen acidity and a lower milk fat content, so that further reductions should be avoided. In addition, it was not clear from what age the requirement for 60% forage in the diet applied to young calves whose rumen function was still developing. From the animal welfare point of view, NAHWOA welcomes that the regulation requires roughage, or fresh or dried fodder, to be offered to pigs and poultry, as there is clear indication of its beneficial effects. Clearer guidelines on suitable feeds and quantities to be offered should be developed for each species.

 

5. Animal health

Within the regulation, the Group recognised the need to balance aspirations for consumer confidence, environmental protection and animal welfare.

The Group underlined the positive role of management and husbandry in disease prevention, including the benefits of reduced stocking densities. However, it is recognised that in specific disease conditions there are gaps in current knowledge to enable effective control through management alone.

Although mentioned under Annex III, 2A in relation to general conversion planning, the Group wishes to reinforce the value of a specific animal health plan drawn up and agreed by the certifying authority at the start of conversion. This formal plan can be progressive, taking account of continuing improvements in technical understanding, and adapted to farm and local circumstances. A continuing comparison of planned versus actual recorded veterinary treatment could provide a good assessment of health status for a particular farm.

The role of bio-security, largely within a closed flock/herd, in maintaining a high health status is emphasised. Where stock is to be brought from outside the farm, the group recommends that animals be purchased from a source with equivalent or higher health status. Where this cannot be substantiated (through the existence of health plans, farm records etc.) it is recommended that additional diagnostic tests be undertaken to assure the health status of purchased stock.

The Group recommends that organic producers are encouraged to participate in voluntary health schemes as appropriate to their circumstances, in order to maintain and improve the overall health status of the farm.

The Group supports the view prohibiting the routine preventive use of chemically synthesised allopathic treatments (5.4 (c) and 5.8). However, NAHWOA is very concerned that this might be interpreted as prohibiting veterinary intervention until there is clinical evidence of disease. Strictly adhered to, this principle would be very counterproductive to the interests of animal welfare and consumer protection in organic farming.

In the opinion of the Group, preventive treatment should be considered as all treatment which is not based on the diagnosis of an individual animal (or group of animals) or, particularly in the case of vaccines, on an assessment of the risk to animal health and welfare according to local conditions and epidemiology of the particular disease concerned.

There is some confusion regarding the interpretation of allopathic, the degree of purification necessary to constitute chemical synthesis, and the status of vaccines within these definitions. Regarding the broad subject of veterinary intervention, there is an urgent need for clearer definitions and guidelines to be developed so that the regulation can be implemented effectively at an applied level. The Group upholds the view that at no time should appropriate treatment be withheld.

In several countries (e.g. Scandinavia and the UK), problems with restricting the number of allopathic treatments are anticipated, particularly as relatively few veterinary surgeons are trained in the use of alternative methods, notably homeopathy. In addition, lack of technical information on efficacy, safety, residue testing etc. is a limitation on greater use of alternative therapies by individual vets in the field, and on their acceptance within the regulatory framework for veterinary medicine use in food producing animals (e.g. Sweden). By December 2000, NAHWOA will make a fuller submission to the EU on the restriction on allopathic treatments, prior to a review of this aspect of the regulation.

There is general agreement in the group that a course of treatment (5.8) refers to all measures prescribed for a particular disease episode until an animal is fully restored to health. It is accepted that the maximum number of treatments annually is three for animals whose productive cycle is longer than a year. The 12-month period will begin from the date the group or individual animal is first treated.

The obligation to report all veterinary treatments to the certifying body before an animal is sold could create considerable logistic and administrative difficulties. The view of the Group is that this requirement is met by the maintenance of comprehensive up-to-date veterinary records on the farm, available for inspection at any time by the certifying body.

 

6. Husbandry management practises, transport and identification of livestock products

The group supports the ban on assisted artificial methods of controlling reproduction on organic farms, as they may cause unnecessary suffering to the animal. However, in some countries the ruling might be difficult to implement in relation to semen for artificial insemination, as it is very difficult to obtain reliable information about this from the semen providers.

The group was concerned regarding the number of possible derogations for mutilations. Clearer guidelines should be developed, particularly regarding age limits for castrations of pigs, and management systems where all mutilations become unnecessary should be encouraged. NAHWOA would welcome the elaboration of more detailed rules for transport.

Sections 6.1.4 to 6.1.6 are discussed in the context of housing.

 

7. Manure

The group did not feel it necessary to comment.

 

8. Housing

The network welcomes the principle that the area of range and housing has been included in the regulation, and aims to assist with the further interpretation of the regulation for each species on the basis of current and new ethological knowledge. Clearer regulations for housing conditions and husbandry requirements for all animal species need to be developed.

In some circumstances, the Group recognises the current lack of scientific information in relation to building design, group sizes and ethological needs.

Particularly, there appears to be no clear research to support the prescribed group sizes for poultry, taking into account the issue of the ability of the birds to access the required outdoor area. Questions were raised as to whether the outdoor area specified in Annex VIII relates to all the land used for poultry including the area that is rested to maintain vegetation cover, and how the outdoor space requirements are applied if the range area is used by several animal species.

Nordic climates, problems are expected in maintaining acceptable environmental conditions within poultry houses due to the size of pop holes required.

There is a general question as to what constitutes natural ventilation, and whether this excludes any mechanical systems.

There is no clear definition of ' regular exercise'.

The network welcomed the general principles laid down in section 6.1.4 that stock should not be tethered. However, this must also be taken in the context of 6.1.2 prohibiting systematic mutilations, including dehorning of cattle. It was noted that the prohibition of tethering will have economic implications for farms in some Alpine and Scandinavian regions, as well as localised areas of the UK. The group hopes that the derogation set out in 6.1.5 will stimulate the further development of suitable and cost effective housing solutions, particularly for horned animals and on small dairy farms. The necessary outside run area specified for the derogation might finally constitute a part of the loose housing system. However, it is likely that several countries will not accept a major derogation for tethering, other than for smallholdings.

Under 6.1.6, there is considerable confusion as to the definition of a smallholding. The regulation specifies that this should apply to farms where cattle cannot be kept in groups appropriate to their behavioural requirements.  Ethological research suggests that 3-5 cattle represent a stable group, but positive effects from keeping animals in groups are already seen with two animals. Given appropriate management, different age groups can be kept together, but above a certain age the sexes will need to be separated.

From a behavioural point of view, a smallholding would therefore appear to be a number of cows in a herd that leads to group sizes of less than 3 animals in each group of adult and non-adult cattle. However, the group recognizes that small farms with few dairy cows might face economic problems when they are forced to change the housing system, and wherever possible they should be encouraged to make use of the derogation under 6.1.5. 

The Group welcomes the restriction on the slatted floor area (8.3.5), but would like to recommend that a minimum solid area, that is, not of slatted or of grid construction, should be half of the minimal space area requirement as laid down in Annex VIII, so that producers who give their stock a larger indoor area than required in the regulation are not penalised.

The DK document raised the question of buildings under construction on the day when the regulation was passed and the group was of the opinion that these should be treated in the same way as buildings completed prior to the date, as they were planned in the absence of the regulation.

 

The Annex 1 C on organic bee production was not discussed.

 

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