The Northern Ireland Assembly - Report on the Fur Farming (Prohibition) Bill

Rev Dr Ian Paisley (Chairperson)
Mr Savage (Deputy Chairperson)
Mr Armstrong
Mr Bradley
Mr Douglas
Mr Ford
Mr Kane
Mr McHugh
Mr Molloy

The Chairperson: Welcome Mr Given and Ms Hood from the Department of Agriculture and Rural Development. The Committee would like to deal with the proposals made last week, which you have replied to. We would also like to discuss the Committee’s proposal for additional penalties on conviction, such as the seizing of equipment, and why the Department has decided not to move forward on that.

Would you make a statement on that matter, and if the Committee is content with it we will move to the clause-by-clause consideration of the Bill.

Mr Given: Two issues were raised last week. The first concerned the forfeiture order and the proposal to include equipment. The second concerned the question of including some reference to when payments may be made under the scheme mentioned in clause 5.

The Department considers that clauses 2 and 3 are sufficient for the purpose of the Bill, which is to stop fur farming. We do not think it necessary to extend the forfeiture order to include equipment. It would be difficult to agree a definition of the word "equipment". For instance, would it include cages, or a barn? Our legal advice is that such an extension to the legislation would be an additional penalty on conviction and would require the Secretary of State’s approval. Our legal advisers tell us that he would be reluctant to give such approval because such a provision is not included in legislation applying to other parts of the United Kingdom.

Mr Ford: On a point of principal, I do not accept the view that the Secretary of State’s reluctance should be a reason for this legislature not to do what it thinks is best for Northern Ireland. I am not persuaded by that argument.

The Assembly Director of Legal Services has identified potential knock-on practical difficulties that probably go beyond the significance of this Bill, and I would be happy to accept the view that the Committee should not push for forfeiture of equipment at this stage. However, I am not deeply persuaded by the Department telling us that we should not do the best for Northern Ireland just because something is not happening in England, Wales or Scotland. The Committee should flag that as a point of principal in all its work.

The Chairperson: All Committee members would agree that this is a devolved Government. Whether the Secretary of State is so senseless that he does not see what we see as good sense is no reason for us not pressing ahead with our good sense and thus not leaving ourselves in the hands of his folly. This hidey-hole that you have found, Mr Given, is not a good hidey-hole — I am being jocular.

We do not think what you have said makes for good argument. We believe that if what we are saying is right then we should argue the point with the Secretary of State. If the argument is then lost; so be it. As my colleague, Mr Ford, said, the reason for not pursuing the matter is because of the information given by our legal adviser about the difficulties that would arise, not because we have any respect for the brains and talent of the Secretary of State or that he would not accept it because it is not done in the remainder of the United Kingdom.

Mr Ford: In fairness to Mr Given and Ms Hood; they flagged up some practical difficulties also.

The Chairperson: I think we have come to agree<->ment about the matter and we agree to proceed with only the amendment to clause 5.

Mr Given: I was absent for part of the week; however, Ms Hood had been working with the legal people to produce the amendment. If the Committee is satisfied with it, we will arrange for the Bill to be amended accordingly.

The Chairperson: Are you giving an undertaking that the Minister will move the clause as amended?

The Chairperson: The Committee would expect that this would be a matter for the Department and that the Minister would move the amendment.

Mr Given: I do not foresee any difficulties. I will persuade the Minister that it is a good idea.

The Chairperson: I do not think that this should come from the Committee. We are agreeing this amend<->ment on the undertaking that the Minister will move it.

Mr Ford: I am happy with the amendment; however, I would raise one point with Ms Hood about her email dated 27 June. It states that I suggested that rather than 10 April 2001, the date of the original letter, that the date of 13 May 2002 would be more appropriate. The transcript of last week’s meeting shows that I suggested that the date should be the one on which the Bill was introduced. It was only a minute or two later that Mr Given pointed out that the letter was sent out on 10 April 2001. I am not arguing for the date the Bill was introduced rather than the date that the notification was sent. When I made my suggestion, I was unaware that the letter had been sent on 10 April 2001. I do not believe that 13 May 2002 should be the cut off date.

Mr Ford: I want it on the record for when the Committee considers the regulations that you may make that I am not arguing for 13 May 2002 on the basis that you wrote to people on 10 April 2001.

Mr Given: The legal advice is that given the time that has elapsed, the date of introduction of the Bill might be a more appropriate date to use. The matter can be looked at if and when such a scheme is created.

Question proposed: That the Committee recommend to the Assembly that the clause be amended as follows: in page 3, line 36, insert

"(4) The scheme shall provide that payments shall not be made under the scheme in respect of a business which was first carried on after a date specified in the scheme." — [The Minister of Agriculture and Rural Development.]

Mr Ford: Would the Committee Clerk advise us if it is proper for us to be content with a clause if the Minister is to move an amendment suggested by officials? Failing that, the Committee would have to move the amendment.

The Chairperson: Yes. It would then be the responsibility of the Minister. The Committee has said that it would pursue the matter. I feel that having discussed the mater with the officials and agreed the wording of the amendment that it is now the Minister’s responsibility.

Mr Ford: The issue is whether the Committee Clerk can write a proper report on the Committee’s deliberations on this matter.

The Committee Clerk: Yes. The Chairperson will put the question in such a way that the Committee will be recommending to the Assembly that the clause, as amended, as directed by the Minister through the email from Ms Hood dated 27 June, be accepted. That recom<->mendation would stand whether or not the Minister tables it.

The Chairperson: That is the end of our consider<->ations. Thank you for your help. I understand that Mr Given is retiring. I would like to give you my good wishes. We are sorry that we will not be seeing your smiling face and your increasing halo. We trust that you will have a very happy retirement and that you will be re-tyred to run faster and smoother.

Paper provided by the Department of Agriculture and Rural Development (DARD) – 24 May 2002 ANNEX 1

Written submission by the Council for Nature Conservation & the Countryside – 5 June 2002 ANNEX 3

Written submission by Compassion in World Farming – Ireland – 24 May 2002 ANNEX 4

Cover letter to submission from the British Fur Trade Association – 30 May 2002 ANNEX 7

Letter from the Northern Ireland Assembly Director of Legal Services – 19 June 2002 ANNEX 11

COMMITTEE for AGRICULTURE AND RURAL DEVELOPMENT
FUR FARMING (PROHIBITION) BILL - COMMITTEE STAGE

1. The Department believes that a ban on fur farming should be introduced for the same reasons as prohibition is being taken forward elsewhere in the UK, namely that fur farming is not consistent with a proper value and respect for animal life.

2. In England and Wales the Fur Farming (Prohibition) Act 2000 received Royal assent on 23 November 2000. The ban will come into force on 1 January 2003 under the Fur Farming (Prohibition) Act 2000 (Commencement) Order 2001. From that date it will be illegal in England and Wales to keep animals solely or primarily for slaughter for the value of their fur. A Bill to ban fur farming in Scotland received Royal Assent on 11 April and will come into operation on 1 January 2003 by means of a commencement order.

3. The ban is being sought primarily on grounds of public morality rather than animal welfare although that too is a consideration.. Killing of animals is not right or wrong per se but animal life should not be destroyed in the absence of a sufficient justification in terms of public benefit. The Department believes that the rearing of animals solely or primarily for slaughter for their fur fails this test and that fur farming can not therefore be justified.

4. The position of fur farming is quite distinct from that of food production. Where the primary purpose of keeping an animal is the production of food, that purpose provides a sufficient public benefit to justify breeding the animals for slaughter. This is so even where the production of fur or hide is a secondary purpose of keeping an animal.

5. The ban on fur farming may be challenged by fur farmers on the grounds that it infringes the right to the peaceful enjoyment of property and possessions guaranteed under Article I of the First Protocol to the ECHR. Any interference with the use of property must achieve "a fair balance" between the general interest of the community and the individual’s right to the enjoyment of possessions. In GB the government was satisfied that a winding-down period of at least 2-3 years, together with the payment of compensation to existing fur farmers put out of business by the ban, would minimise the risk of a successful challenge. (In Northern Ireland although there are no known fur farms, provision to make a compensation scheme is included in the Bill in order to satisfy any ECHR considerations.)

6. There is also a risk that the Bill could be challenged under Article 28 of the Treaty of Rome which bans quantitative restrictions on imports and measures having equivalent effect to such restrictions, subject to the exceptions in Article 30. Article 30 permits exceptions to the prohibitions under Article 28 on a number of grounds, including those of public morality and the protection of animal life.

7. The proposed ban would arguably come within the scope of Article 28, as a ban on fur farming in the UK would have the indirect effect of hindering potential imports from other Member States of mink intended for fur farms in this country. It is considered that by virtue of Article 30 of the EC Treaty, the ban is lawful under EC law, being justified on the grounds of public morality.

8. The Bill will not repeal the Destructive Imported Animals Act (NI) 1933. It will therefore still be possible to issue licences to permit the keeping of fur bearing animals for the purposes of exhibition in a zoo etc or other exceptional purposes.

9. The Bill creates a primary offence of keeping animals solely or primarily for slaughter for the value of their fur or for breeding progeny for such slaughter. The offence can be committed by a company or by a person. It does not matter whether the slaughter will be carried out by the keeper of the animals or by another person.

11. The Bill makes it an offence knowingly to cause or permit the keeping of animals solely or primarily for the prohibited purpose.

(i) where a director of a company causes the company to keep animals for their fur;

(ii) where a family arrangement exists which amounts to an informal partnership by which profits of the business are channelled to a person other than the keeper; and

(iii) where a landlord grants a tenancy to enable the tenant to carry on a fur farming business.

12. It is anticipated that there would be relatively few cases where a person would be guilty of a secondary offence. However, in some cases the keeper may be abroad or have died. For example, in the case mentioned at 11(1), the company may be an overseas company, and the enforcement of fines against an overseas company may give rise to difficulties.

13. It may be argued that a landlord who does no more than turn a blind eye to his tenant’s business and fails to take any action to prevent it should not be caught but even then, the landlord will not be blameless. The decision to prosecute will be a matter for discretion.

14. Mink are native to North America but have been kept for fur in Great Britain since the late 1920s. Escapes from mink farms led to the current feral population, with mink recorded as breeding in the wild in the late 1950s. Mink are semi-aquatic carnivorous mammals, which in the wild are a pest and pose a threat to wildfowl, sea bird colonies and vulnerable mammals such as water voles. There used to be fur farms in Northern Ireland up until, it is believed about twenty years ago. It is not believed that there is any sort of fur farm in Northern Ireland now.

15. The keeping of mink for their fur is controlled by the Mink (Importation and keeping) Regulations (NI) 1976 which intended to ensure that mink are kept in secure conditions. The keeping of arctic fox is controlled under the Arctic Foxes Order (NI) 1988. Both sets of legislation were made under the Destructive Imported Animals Act (NI) 1933.

16. The Destructive Imported Animals Act (NI) 1933 is not concerned with animal welfare or moral issues. It is solely concerned with prevention non-native species from causing damage to the environment because of their destructive habits.

17. In addition to licences to keep mink or arctic foxes for commercial reasons, "special" licences to keep mink or other fur species for exhibition, or other exceptional purposes are permitted under the Destructive Imported Animals Act (NI) 1933. These will be unaffected by the proposed Bill to ban fur farming.

18. Even though there are no known fur farms operating in Northern Ireland, provision to make a compensation scheme has been included in the Bill in order to satisfy any ECHR issues which might arise.

19. A public consultation paper on the proposal to ban fur farming was issued in April 2001. 83 bodies and individuals received copies. It was also made available on the DARD web site and was publicly advertised in the main Northern Ireland papers. Only 8 responses were received, five of which contained substantive comments, which all supported the proposals.

20. There has been little if any public concern expressed about fur farms by the NI public. However there has been quite a concerted campaign by GB residents to ensure that Northern Ireland follows suit and introduces a ban in Northern Ireland so as to prevent GB businesses transferring to Northern Ireland. A lobby group based in London has constantly been in touch to ask what progress is being made on introducing a Bill in Northern Ireland.

COMMITTEE FOR AGRICULTURE AND RURAL DEVELOPMENT
FUR FARMING (PROHIBITION) BILL - COMMITTEE STAGE

Respect For Animals	British Fur Trade Association
Economic	Economic
Not raised.	The fur trade represents a turnover of over £500m per annum for the UK with BFTA members responsible for buying the majority of world trade at primary level (as pelts).
	Fur sales have grown in UK over past 5 years due to a re-channelling of fur through fashion outlets. Sales of fur in the UK, including fur trim, in 1999/2000 increased by well over 30%
	Copies of the IFTF/EFBA paper ‘The Socio Economic Impact of European Fur Farming’ have been provided.
Ethical	Ethical
Welcome Bill ‘wholeheartedly’ on grounds that ‘fur farming is morally indefensible as it involves inherent and unacceptable animal cruelty to produce a frivolous product for which there are many alternatives’.	No case (for public morality) made in the Bill or in the Explanatory & Financial Memorandum nor are the wider implications for other sectors explored.
	BFTA state that they believe that the real reason behind the GB Act as a £1m donation made to the Labour Party by the Political Animal Lobby.
	BFTA express surprise that the policy objective in the EFM (which states that it is necessary to prohibit fur farms in NI to bring the law into line with that in GB) suggests that the law in NI must follow English law.
Pre-publication copy of the Ethical Case Against Fur Farming has been provided	An opinion poll by Taylor Sofres plc in September 2001 found 8 out of 10 people questioned in the UK support fur farming provide there is good animal welfare. Only 3% strongly disagreed.
Environmental
Fur Farming is an unacceptable and unnecessary threat to the environment – mink are a ‘Houdini’ species and escapes are inevitable. Reference is made to comments made by Alex Fergusson, MLA in a debate by the Rural Affairs Committee of the Scottish Parliament (28.11.00).	In 1997, the Minister of Agriculture, Fisheries and Food, Elliot Morley stated ‘I have concluded that there is insufficient evidence to suggest that existing arrangements for keeping mink significantly contribute to the problems caused by feral mink’.
	Dr Nigel Dunstone wrote ‘ Early worries concerning the impact of mink. are largely without foundation. It can be seen that the relatively small size of mink .coupled with their low population density means they have little impact overall’.
	Fur farming uses 647k tonnes of waste from the fishing and meat industries each year.
Welfare
Welfare argument underpins ethical argument.	Fur Farming compares well to other farming sectors. Research Institutes, public bodies and the fur sector have funded studies into the welfare of farmed fur animals in excess of Euro7.5m. In 1999 European fur farmers encouraged the creation of the international and independent Fur Animal Welfare Research Committee who report to the Council of Europe’s Standing committee on farm animal welfare.
SCHAHAW Report (executive summary and conclusion provided) states that ‘current husbandry systems cause serious problems for all species of animals reared for fur’. Report refers to High level of stereotype behaviour as an indication of poor welfare; Mink kit mortality of up to 30%; Self-mutilation; and High level of infanticide amongst fox. Fur Breeders cannot provide better accommodation as the owners’ needs and convenience and not the animals basic requirements, ie Mink cages are never more than the length of a person’s arm and foxes’ cages as long as a grab. Killing methods are intended to reserve the animal pelt and include gassing (CO² or CO) using a ‘killing box’ attached to a petrol engine and electrocution of foxes.	The SCHAHAW Report does not have the support of the of the leading scientists in the field of animal welfare research who were part of the Report’s original working committee. A press release is included in the BFTA submission.
Fur Farming in Europe
Effectively banned in England, Wales, Scotland, Austria and Italy where intensive conditions are being phased out.	Fur Farming is well regulated (Regulation 827/86, Directives 98/58 and 93/119) and accepted under EU law. Three years ago, the EC adopted (with the support of the UK) its revised recommendations on fur animals.
	It is an unsubsidised activity, which is doing well in other European countries such as Denmark, Finland and Norway. It was worth Euro332m to Danish farmers in 1998; 4th largest agricultural export from Denmark; and In Finland, 50% of fur farmers rely exclusively on fur farming for their income.
Fox Farming is being phased out in Sweden and Netherlands. Both countries have given firm indications that mink farming is also to be banned.	European Farmers Organisations consider the ban in England and Wales to be disproportionate. In June 2000, the Commission recommended that the British Government should wait until EU common rules on fur farmed animals had been established.
Publications
The Welfare of Farmed Foxes/Mink Respect for Animals have provided two scientific papers on the welfare of farmed mink and foxes which were peered reviewed and appear in a recognised scientific journal. A summary of the conclusions of the two papers highlighting evidence of poor welfare such as killing or injuring of cubs/kits, pacing and self-mutilation. Copies of photos supporting these claims are available in the Committee Office.
Statement by the Farmed Animal Welfare Council (FAWC) A copy of a statement issued by FAWC in 1989 expressed disapproval of mink and fix farming. It said that ‘the systems employed in the farming of mink and fix do not satisfy some of the most basic criteria which it has identified for protecting the welfare of animals’. FAWC wrote to MAFF explaining that it had decided against drawing up a welfare code for mink and fox (which would have been normal practice) ‘to avoid giving it the stamp of approval which a Government backed welfare code would imply’.	The European Fur Breeders Association has its own Code of Practice, which incorporates all the Council of Europe’s recommendations together with its own ‘best practice advice’.
Advertising Standards Association In 1998, the Advertising Standards Association refused to uphold a complaint by the British Fur Trade Association regarding claims made in a leaflet produced by Respect for Animals.

COMMITTEE for AGRICULTURE AND RURAL DEVELOPMENT
FUR FARMING (PROHIBITION) BILL - COMMITTEE STAGE

Thank you for your letter of 21 May in connection with the above proposed legislation.

Council reiterates its earlier comments of 16 May 2001 and would further add that Mink already regarded as a significant factor in the decline of the common scoter may also be implicated in the decline of other ducks and breeding waders some of which are priority species under the Biodiversity action plan.

In our last communication, Council requested clarity in the term animal and notes that 2.1 states ‘in respect of animals of a particular description’. Is this clarified elsewhere in the Bill? Council is also concerned about the legal definition of fur and whether this would extend to the breeding of rabbits for meat and fur or to other domesticated animals such as sheep, cows, goats, pigs whose hides in some cases could be of greater economic value than the meat.

Council is concerned at farming of introduced species in that as escapees in the wild they could have an injurious environmental impact.

COMMITTEE for AGRICULTURE AND RURAL DEVELOPMENT
FUR FARMING (PROHIBITION) BILL - COMMITTEE STAGE

Compassion in World Farming – Ireland is pleased that the Northern Ireland Assembly is now considering the above Bill. On behalf of our many supporters in Northern Ireland who would welcome an end to the factory farming of animals for their fur, we urge the Assembly to pass the Fur Farming (Prohibition) Bill as soon as possible.

COMMITTEE for AGRICULTURE AND RURAL DEVELOPMENT
FUR FARMING (PROHIBITION) BILL - COMMITTEE STAGE

Thank you for your letter of 21 May. The National Trust remains supportive of the purpose of Bill. We have no comment to make upon the proposed text.

COMMITTEE for AGRICULTURE AND RURAL DEVELOPMENT
FUR FARMING (PROHIBITION) BILL - COMMITTEE STAGE

Many thanks for your letter of 21 May as well as for giving Respect for Animals the opportunity of submitting our views on the proposed fur farm ban.

We welcome the bill wholeheartedly on behalf of our members in Northern Ireland who have supported a call for an end to fur factory farming for many years.

Our strong view is that fur farming is morally indefensible as it involves inherent and unacceptable animal cruelty to produce a frivolous product for which there are many alternatives. The ethical case against fur farming is clear and I enclosed a pre-publication copy of a document we are soon to have printed on the subject.

The fact is that fur farming is both inherently cruel and presents an unacceptable and unnecessary threat to the environ<->ment. Mink have been described as a ‘houdini’ species and escapes from fur farms are almost inevitable even under the best of circumstances.

An interesting insight into the background to the unnatural and unwelcome presence of mink in the wild was given during a debate by the Rural Affairs Committee of the Scottish Parliament (28 November 2000). MSP Alex Fergusson said: ‘I come from an area in which there used to be a mink farm. When mink farming became unprofitable, the owner simply opened the doors of his cages and let the mink go.’

Whilst there are no fur farms currently operating in Northern Ireland at the moment there could not be a better time to ban them and to ensure that the threat they represent does not return.

The animal welfare arguments against fur farming underpin the ethical argument and are overwhelming and conclusive. The majority of the remainder of this submission is devoted to the welfare arguments, as there is now so much material available which backs our case.

Many of the concerns that Respect for Animals have been expressing for many years have recently been confirmed by the European Union’s prestigious Scientific Committee on Animal Health and Animal Welfare (SCHAHAW).

I have enclosed the Conclusions and Executive Summary of the SCHAHAW report which says, unambiguously, that ‘current husbandry systems cause serious problems for all species of animals reared for fur’. The report provides a damning indictment of fur factory farming referring to:

Mink and fox are inherently unsuited to intensive farm conditions. They are still essentially wild animals and keeping them in small barren wire cages is cruel.

The fur breeders have had ample opportunity to try to provide better accommodation but they have failed to do so. The fact is that they cannot. Their farms are constructed in accordance with the owners’ needs and convenience and ignore the animal’s most basic requirements.

Mink cages are never more than the length of a persons arm, for instance, and for fox they are as long as a grab – a particularly stressful way of handling such an animal.

The killing methods used to despatch animals on fur farms are unacceptable and have evolved, once more, to accommodate the needs of the operators.

The facts concerning the cruelty of fur farming have been accepted by a number of Governments which have already taken steps to ban it. All fur farming is now effectively banned in England and Wales, Scotland, Austria and Italy where the intensive conditions are now being phased out. Fox farming is already being phased out in Sweden and the Netherlands and both countries have given firm indications that mink farming is also to be banned.

Both papers have been peer reviewed and appear in a recognised scientific journal. The authors are members of the Cambridge University Animal Welfare Information Centre at the Department of Clinical Veterinary Medicine, University of Cambridge. D M Broom is Professor of animal welfare at that department.

‘Farmed foxes have a considerable degree of fear, both of humans and in general’. The barrenness of the cages in which they are kept is a ‘significant problem for the foxes’ and ‘farmed foxes can have substantial reproduction problems.’ (Conclusion ii, 2001, pp 241-242).

In fact Nimon and Broom say: ‘Killing and injury of cubs is a common problem on fur farms.’ (p239, 2001). This form of cannibalism is probably due to the inability of the foxes to live in the types of social groups found in the wild. A proportion of ‘low status’ vixens seems likely to kill and mutilate their young and the keepers cannot identify these individuals.

‘There is clear evidence that the welfare of farmed foxes in the typical bare, wire-mesh cages is very poor.’ (Conclusion ii, 2001, p242) In addition: ‘Increases in the size of the barren cage, without a consequent increase in the complexity of the environment, do not appear to benefit farmed foxes.’ (Conclusion v, 2001, p242).

‘The incidence of abnormal behaviours in farmed silver foxes is cause for serious concern. The killing and injury of cubs (tail removal, biting) by their mothers has been reported as a common problem on fox farms....’ (Conclusion xi, 2001, p242).

The Welfare of Farmed Foxes paper has as a final conclusion that ‘the desirable major improvements in welfare will be difficult to achieve.’ (Conclusion xii, 2001, p 243).

‘There is considerable evidence of poor welfare in mink kept in the most widely used cages under normal management procedures.’ (conclusion xii, 1999, p223).

This conclusion is based on the observed ‘high level and pervasiveness of stereotypes among farmed mink, and the incidence of fur chewing and even self-mutilation of tail tissue,..’ (conclusion iii, 1999, p 222). The distressing, repetitive forms of behaviour which include rapid pacing up and down placing feet in exactly the same position every time, head bending etc are known as stereotypes and are a clear indication of poor animal welfare. These forms of behaviour are found on all fur farms. ‘Fur chewing’ and ‘tail biting’ are also expressions of frustration and therefore of poor welfare and are conditions well known to fur breeders. References to them are to be found in all fur breeding textbooks.

Once again it is concluded that simply increasing the cage size on its own is not a solution. (Conclusion vi, 1999, p222). The fact is that these types of animals are highly inquisitive, active and semi-aquatic in their nature and their needs cannot be satisfied in intensive farm conditions.

The Farm Animal Welfare Council reached the same conclusions back in 1989 when it issued a statement in which it expressed its disapproval of mink and fox farming. Having thoroughly examined the evidence it said that ‘the systems employed in the farming of mink and fox do not satisfy some of the most basic criteria which it has identified for protecting the welfare of animals.’ (our emphasis). FAWC described animals kept in fur farms as ‘essentially wild’, reflecting the fact that, unlike animals such as pigs and cows which have been domesticated over a period of many thousands of years, mink and fox have been bred in captivity for less than 100.

FAWC sent a letter to the Parliamentary Secretary at MAFF with the statement which underlined how seriously it felt about the situation. It wanted to ‘give a clear warning’ that it did ‘not see fur farming as an acceptable alternative enterprise as currently practised.’ It went on to explain that it had decided against drawing up a ‘Welfare Code’ for mink and fox farming – as was its normal practice under these circumstances – ‘to avoid giving it the stamp of approval which a Government backed Welfare Code would imply’.

The FAWC documents are enclosed and provide a clear and conclusive criticism of fur farming from an independent and authoritative source.

During 1998 the assertions that fur farming caused welfare problems was challenged by the British Fur Trade Association which complained to the Advertising Standards Association (ASA) about a leaflet produced by Respect for Animals. One complaint concerned the statement in the leaflet that:

‘The fact is that these barren conditions (in fur factory farms) drive intelligent, inquisitive animals such as mink and fox to stereotyped behaviour, self mutilation and cannibalism.’

The ASA reviewed extensive and expert evidence from both sides and after prolonged consideration refused to uphold the complaint concluding that Respect for Animals had ‘adequately supported the claim that those types of behaviour could be caused by factory farming’.

The main methods used to kill animals on fur farms are gassing (for mink) using carbon monoxide (CO) and carbon dioxide (CO2) and electrocution (for fox). Others methods used include: lethal injection, neck breaking and clubbing.

Since the animals destined to be killed are all despatched as soon as possible after their winter’s moult, large numbers are slaughtered within a short period. Once more the owners’ convenience determines how the practice operates rather than the welfare of the animals.

Gassing of mink is mostly carried out in a ‘killing box’ in which many mink are placed at one time. The box will normally have been filled with either Carbon monoxide (CO) or Carbon dioxide (CO2) supplied from a cylinder or, in the case of CO, often from a petrol engine. I have enclosed a photograph that shows a killing box where the exhaust pipe of the engine propelling the contraption is connected to the box.

There are a number of problems associated with the common methods used to kill animals on fur farms.

Mink, being semi-aquatic, are adapted to hold their breath for long periods and it has been shown that they are also aware of high concentrations of carbon dioxide. It may be that they actually detect a lack of oxygen in the air and so gassing is a particularly inappropriate way of killing them. Experiments have shown that mink are indeed averse to CO2. Cooper and Mason<$FDetermination of the aversion of farmed mink (Mustela vison) to carbon dioxide. J Cooper, G. Mason, M Raj., The Veterinary Record. September 26, 1998.> reported that ‘mink detected and avoided high concentrations of carbon dioxide, and that if mink are to be killed humanely, less aversive techniques should be used.’ They found that mink sneezed and coughed in the presence of CO2 and made ‘rapid reflex withdrawals’ from the experimental tunnel.

Research on the use carbon monoxide provided by an engine (a method commonly used on fur farms) concluded that ‘Mink forced to inhale filtered exhaust gases showed excitation and considerable convulsions during a phase of decreased consciousness.’<$FEuthanasia of mink with carbon monoxide. E. Lambooy, J A Roelofs, N. van Voorst., The Veterinary Record. 13 April, 1985.> In fact the researchers noted that animals placed in a box with filtered exhaust gases ‘moved nervously, became extremely excited and showed convulsions for a period of 12 seconds’ (average).

Even worse, further research shows that mink exposed to 100% carbon monoxide took, on average, 64 seconds to lose consciousness.<$FEuthanasia of mink (Mustela vison) by means of carbon dioxide, carbon monoxide and nitrogen. Hansen, N. E., Creutzberg, A. & Simonsen, H.B. (1991), British Veterinary Journal 147, 140-146.>

No wonder the killing of animals on fur farms takes place well out of the public gaze and one can only guess at the suffering that takes place inside the ‘killing boxes’.

In fact the only time slaughter has been filmed in the UK, the evidence obtained led to the conviction for cruelty of the person carrying it out. Video taken by Respect for Animals during 1997 was used by MAFF to prosecute a person employed at the mink farm at Crow Hill in Hampshire. The charges arose from his actions during the slaughter. Mink were seen panicking and biting and struggling with the accused as a result of which he hit them and slammed them against the killing box and floor. In his defence he said that the frantic animals bit him because they ‘knew what was coming’.

Electrocution of fox is usually carried out using electrodes clamped to the animal’s mouth and inserted in the rectum. The animals are caught and held in a neck clamp. Its efficacy depends upon the state of charge of the battery that is the usual source of power.

Since foxes on fur farms generally live in a chronic state of fear, handling them causes acute stress. Being caught with tongs around their necks and then having their tails grabbed, to be suspended whilst electrocuted is a terrifying experience. This method cannot be described as humane, however quickly death comes to end the terror.

Fur is an unnecessary product yet its production involves unacceptable levels of animal suffering. The ethical case against fur farming is very strong and was not addressed by the SCAHAW report which confined itself to the animal welfare aspects of fur farming. The clear inference to be drawn from the SCAHAW report confirms Respect for Animals’ view that mink and fox are not suitable animals to be reared under farm conditions.

The enclosed document (The Ethical Case Against Fur Farming) argues the moral case authoritatively.

Thank you, once again for giving Respect for Animals the opportunity of commenting on the proposed ban. We would be very happy to provide further information should the Committee require (either in written on verbal form).

We urge the Northern Ireland Assembly to introduce a ban on fur farming as per the proposed bill as soon as possible.