Do you agree with the Scottish Government’s position on the collection and use of feedback to identify welfare risks in transport and proposed course of action? Please provide any further relevant information.
It is the view of the Scottish Government that feedback and constructive dialogue between transporters and APHA relating to issues arising on all long journeys is important. This enables issues to be identified including at an early stage, and informs the identification and development of mitigations, solutions and best practice. There are currently processes in place that address this recommendation for livestock and unregistered horses, and we agree that these should be extended to cover poultry and registered horses too.
We also agree with FAWC that feedback processes should help identify compliance issues and should help support effective enforcement activity, where this is needed.
We agree that the associated resourcing required for these feedback and other processes should be considered, alongside other resource priorities.
Of the 310 responses to this question, 66.8% were in favour of the Scottish Government’s position on the collection and use of feedback to identify welfare risks in transport and proposed course of action. 20.0% were not in favour and 13.2% did not express a view.
Of those who favoured the use of feedback, correspondents from all sectors mentioned the need for extra resources, for example that the “likely impediment to this is the lack of resources to APHA to follow up on the issues” (Scottish Animal Health & Welfare Panel)”
A number of respondents viewed the sharing of feedback as a “new process that needs to be developed and implemented” (unnamed organisation) and suggested that “resourcing should be in place to ensure that it happened in an efficient and smooth fashion” (British Poultry Council).
On the other hand, a small number of respondents supporting feedback mentioned that informal feedback arrangements were already in place. An unnamed transport organisation reported the holding of “regular meetings with our key agricultural stakeholders” and Orkney Islands Council noted that “informally we already work very closely with APHA”.
A number of correspondents mentioned that the use of feedback should be used, in addition to livestock transportation, for “all equids (including registered)” (unnamed organisation), for “all species including exotic and companion animals” (Scottish SPCA), and for “companion animals and exotic animal movements for commercial and rehoming purposes” (SRUC and SAWC). Another unnamed organisation expressed a desire for “poultry” and “aquatic farmed animals, such as fish” to be included in a review process.
Some respondents commented on the use of “enforcement” in the FAWC Opinion. Whilst they recognised and supported the need for such measures, greater support for “constructive dialogue across industry and government .... to understand the practical operational issues” was expressed by an unnamed organisation.
A number of respondents from the ‘farmers and representatives’ grouping in the Northern Isles were not in favour of the Scottish Government’s position on feedback. They doubted any gains from “creating a huge volume of work in requiring that all long journeys be reported to APHA” (Brian Moss and others) citing the withdrawal of APHA staff from the more remote areas as a reason the proposals might prove ineffective.
Animal Aid, and two other unnamed welfare organisations agreed with FAWC’s conclusion that lack of enforcement was a major concern that required “urgent attention” whilst supporting the use of feedback. However, 19 individual respondents supporting these organisations agreed these statements but did not favour the Scottish Government’s position on the use of feedback.
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