Part 3 - Proposals for Consultation
The Scottish Government's objective is for animal welfare standards in slaughterhouses to be maintained at least at current EU standards and improved where necessary. A related objective is to provide FSS supervisory staff with a slaughterhouse environment which enables them to operate efficiently and effectively by providing them with the information needed to carry out their tasks of ensuring animal welfare at time of slaughter.
Legal Status of CCTV in Slaughterhouses
There is currently no domestic or European legislation that requires CCTV for monitoring or verification of animal welfare in slaughterhouses.
Compulsory CCTV recording in all slaughterhouses as an enforcement measure could be required by introducing secondary legislation. Section 26(1) of the Animal Health and Welfare (Scotland) Act 2006 provides powers to make regulations for the purpose of securing animal welfare. Any such amendment would be subject to the scrutiny and approval of the Scottish Parliament before it could take effect.
FSS monitors and enforces animal welfare regulations in slaughterhouses under the 2012 Regulations in line with a hierarchy of sanctions, ranging from verbal and written advice through to reporting offences for prosecution. Penalties under any secondary legislation introducing compulsory CCTV in slaughterhouses would be proportionately applied by FSS and limited by the requirements of the Animal Health and Welfare (Scotland) Act 2006.
Enhanced Animal Welfare Provision
The Scottish Government is committed to providing the best possible welfare standards of animal welfare at slaughter. The benefits of CCTV in slaughterhouses are considered to be achievable through the current voluntary route. However, the introduction of compulsory CCTV can ensure full coverage and protection of all areas in the slaughterhouse where live animals are present.
One of the primary benefits of CCTV is considered to be improved compliance with animal welfare at slaughter requirements, resulting from the deterrent effect of CCTV combined with increased information to aid enforcement by FSS staff.
While there is limited evidence available on the specific deterrent effect of CCTV in slaughterhouses there is evidence of the effectiveness of such equipment from other contexts ( e.g. the use of speed cameras have been demonstrated to reduce speeding and CCTV use has reduced theft of and from parked vehicles).
Animal welfare benefits can come from the use of CCTV to observe and record real-time slaughter processes, record individual events and contribute information to the auditing of animal welfare. Detection of animal welfare breaches can result in a) consequences that act as a deterrent to future poor practice; and/or b) feedback and continuous improvement to slaughterhouse practices. Recordings can also aid the verification of slaughterhouse compliance with legislative requirements.
CCTV footage can have authenticity and transparency as evidence and can be retained for long periods. It can also enable Official Veterinarians to observe animals in high welfare risk areas as well as those that are dangerous or inaccessible to people; and identify animal behaviours that might be hidden from human observers.
Enhanced Animal Welfare Enforcement
Arguably, compulsory CCTV should improve the efficiency and monitoring and enforcement activity, by providing Official Veterinarians with the information they need more readily and conveniently. It is considered that, resulting from an enhanced supervisory role and any behavioural change within slaughterhouses, compulsory CCTV will lead to improved welfare compliance within the sector.
Enhanced enforcement would require CCTV cameras to be installed and recording in all approved slaughterhouses in areas where live animals are unloaded, kept, handled, stunned and killed. In line with the FAWC recommendation, the Scottish Government would like to require that any recorded images are kept for a 90 day minimum period. Where necessary, if being used as part of an ongoing investigation or prosecution, they could be kept for longer periods.
To enable enforcement, authorised officers, e.g. Official Veterinarians from FSS and staff from organisations approved by the Scottish Ministers, could be given power of unrestricted access to live or recorded footage for the purpose of monitoring and verifying animal welfare standards in the slaughterhouse.
Cost of Compulsory CCTV to Businesses
The Scottish Government does not hold information on the cost to Food Business Operators of the installation and ongoing maintenance of CCTV systems. However, data from 2017 supporting consultation by the Department for Environment, Food and Rural Affairs estimated an average one-off cost of £2,500 for a new CCTV system or around £500 for each area without current coverage. That assessment also suggested average annual costs for maintenance and data storage in the region of £350 per slaughterhouse.
Alternative figures of £6-25,000 for a new system and annual maintenance costs in the region of £600 were reported to the Scottish Parliament's Cross Party Working Group on Animal Welfare in January 2012.
Given the disparity in cost estimates, this consultation asks specific questions of those involved in the livestock and meat industries to inform a Business and Regulatory Impact Assessment to accompany any possible future regulations on the introduction of compulsory CCTV.
FSS data for March 2016 to March 2017 notes that 46.7 million animals were slaughtered and that 46.5 million (99.6%) of these were slaughtered in a slaughterhouse monitored by some configuration of CCTV coverage. Additionally, 98.34% of cattle, 97.81% of sheep/goats; 97.06% of pigs; and 99.78% of poultry were slaughtered in a slaughterhouse monitored by some configuration of CCTV coverage.
The Scottish Government is aware that slaughterhouses vary in terms of size and throughput; and that the costs of introducing compulsory CCTV in all areas will place a disproportionate financial burden on the smaller facilities. However, those smaller premises should be able to meet any legal requirements with the use of a less extensive CCTV system than larger slaughterhouses. The Scottish Government considers that exempting smaller businesses from any compulsory CCTV recording would undermine the overall effectiveness of a requirement for compulsory recording.