Following the story run by Meat Management last week former Agriculture Minister, George Eustice, requested the right of response to views expressed by AIMS (Association of Independent Meat Suppliers) on stunning immediately after the cut in religious slaughter.

AIMS, the UK trade association which represents the majority of abattoirs, had previously responded to remarks, made by George Eustice in a Westminster Hall debate saying it: “Was amazed to hear that the previous Agriculture Minister, George Eustice, now believed that stunning immediately after the cut in religious slaughter should be encouraged to mitigate the adverse effects of slaughter without stunning.” AIMS maintained that a number of large Halal slaughterers have been wanting to adopt this practice for many years but were actively prevented from doing so by Defra while Eustice was in office. It said Defra had, under Eustice, insisted that the ‘20 second rule’ must be applied to a completely unconscious sheep after stunning, preventing further movement along the line. If the 20 second rule is still applied, there is no benefit to the slaughterer, no advantage over simply not stunning at all, which is why no abattoir currently does it for sheep.

Full statements available:

George Eustice

Former Minister, George Eustice MP has clashed with AIMS in the past.

In his response, written by the MP to Meat Management, Eustice said: “Last week the industry group, AIMS, suggested that my comments on religious slaughter meant I supported their agenda. My views on non-stun slaughter have been consistent for over five years. There has been no U turn and, not for the first time, I disagree with AIMS on this matter. I want us to toughen our regulations in this area and significantly curtail the practice of non-stun slaughter, but AIMS have traditionally been apologists for the practice and generally strive to weaken the law.”

Meat Management put that point to AIMS, which, as part of its detailed reply said: “It seems that not for the first time AIMS is unwittingly at cross-purposes with former Agriculture Minister George Eustice MP. It is essential that this misunderstanding stops now. He has our sympathy for it is now quite clear that he has been badly served by the advice given to him by a minority of his civil servants and advisers.

“We would contend that much of the response prepared by officials is not merely untrue but simply nonsense and in trying to clarify a murky situation AIMS would like to make absolutely clear its wish to help Mr Eustice achieve his genuine objective of improving the welfare of sheep at slaughter. It is an objective we in AIMS share with committed enthusiasm.

“In order to clear up some of the apparent misunderstanding between AIMS and Mr Eustice we would make the point that if Government is unwilling to ban slaughter without prior stunning, a total ban which almost all UK veterinary surgeons would strongly support, stunning immediately after the cut is the single best measure to reduce suffering and should be strongly encouraged. Sadly, DEFRA effectively eliminated the practice completely by removing any operational benefit to the slaughterer. To apply the 20 second rule, prohibiting movement along the line for 20 seconds, to an unconscious sheep was an act of unmitigated folly by DEFRA. Such interpretation of the legislation cannot be defended. To correct matters all that is required is for DEFRA to deem the 20 second rule applicable only up to the point of stunning, which will guarantee that stunning is performed absolutely as soon as possible after the cut, minimising any suffering. This would immeasurably improve the welfare of sheep over the alternative of bleeding out while conscious.”

Eustice continued: “In 1875 we were the first country in the world to require the stunning of animals prior to slaughter. Rendering an animal immediately unconscious prior to slaughter makes them insensible to pain and reduces the stress and fear associated with the slaughter process. Scientific studies including the Dialrel Study have demonstrated that animals that are slaughtered without stunning suffer significantly increased levels of pain and stress.

“In 1904 a limited derogation from this requirement was created but only to accommodate the limited requirements of religious communities. Our laws were refined in 1933 and have had several iterations since then. The regulations have not changed substantively since 1995 and are based predominantly around the concept of ‘stand still times’ to reduce movement of the conscious animal during slaughter. However, the latest figures from the FSA show that last year 25 percent of all sheep and close to 20 percent of chickens were not stunned prior to slaughter. This derogation has grown out of control and the spirit of the law is no longer being adhered to.

“I want the meat processing industry to play its part and take its responsibilities in this area far more seriously. The role of the slaughterman in any abattoir is a highly skilled and responsible one and I cannot believe that the majority of them feel comfortable with what they are sometimes asked to do.”

The issue around religious slaughter, as both AIMS and Eustice agree, can be contentious.

In their responses Eustice calls for the subject to become a free vote in parliament whereas AIMS says it has a “Strong wish to join with Eustice in a campaign to improve welfare at slaughter. We are willing to provide him with the hands-on practical and veterinary knowledge and experience which Defra veterinary officials have unfortunately demonstrated they lack.”

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George Eustice Full Response to Meat Management

"Last week the industry group, AIMS, suggested that my comments on religious slaughter meant I supported their agenda. My views on non-stun slaughter have been consistent for over five years. There has been no U turn and, not for the first time, I disagree with AIMS on this matter. I want us to toughen our regulations in this area and significantly curtail the practice of non-stun slaughter, but AIMS have traditionally been apologists for the practice and generally strive to weaken the law.

In 1875 we were the first country in the world to require the stunning of animals prior to slaughter. Rendering an animal immediately unconscious prior to slaughter makes them insensible to pain and reduces the stress and fear associated with the slaughter process. Scientific studies including the Dialrel Study have demonstrated that animals that are slaughtered without stunning suffer significantly increased levels of pain and stress.

In 1904 a limited derogation from this requirement was created but only to accommodate the limited requirements of religious communities. Our laws were refined in 1933 and have had several iterations since then. The regulations have not changed substantively since 1995 and are based predominantly around the concept of “stand still times” to reduce movement of the conscious animal during slaughter. However, the latest figures from the FSA show that last year 25 percent of all sheep and close to 20 percent of chickens were not stunned prior to slaughter. This derogation has grown out of control and the spirit of the law is no longer being adhered to.

I want the meat processing industry to play its part and take its responsibilities in this area far more seriously. The role of the slaughterman in any abattoir is a highly skilled and responsible one and I cannot believe that the majority of them feel comfortable with what they are sometimes asked to do.

While the number of cattle slaughtered without stunning is small, it poses the greatest challenge for the individual animal. Bovine animals have a third artery to the back of the head that means they remain conscious for a long time during the slaughter process. It takes about 45 seconds to the point of collapse but somewhere between 1 Minute 20 and 2 minutes for animals to lose consciousness. In contrast, non-stunned sheep and chickens will tend to lose consciousness much faster in around fifteen seconds. I have argued for consideration of a post cut stun specifically on cattle because of the long time to loss of consciousness and the fact that a captive bolt is typically used. However, when it comes to sheep, the right approach would be to increase minimum stand still times or require a strict quota to curtail the number of sheep slaughtered without stunning in the first place.

The drift towards the “mainstreaming” of non-stun slaughter requires a government response in my view. We could introduce a German style quota to place a strict cap on the number of animals killed under the derogation. Our own law states that the derogation is only for meat produced for Jews or Muslims but this is not enforceable in practice.

AIMS argued that we should allow the routine retention of a sample of stunned sheep to prove that they recover after the stun. This would violate the laws we have on scientific experimentation on animals and is unnecessary. Granted, some Muslim communities are sceptical that water bath stunning of chickens always leads to a so called "recoverable stun." However, the question does not arise on sheep. It is incontrovertible that head only stunning in sheep constitutes a recoverable stun so there is no justification to cause unnecessary suffering in order to routinely demonstrate this to buyers. Even on chickens, the scientific evidence already exists.

When it comes to the law around the individual restraint of sheep during non-stun slaughter, AIMS attempted to challenge these rules through the courts, but were unsuccessful. Sheep cannot perform their natural instinct to "follow" while their legs are held in a V-restrainer and therefore individual restraint remains the right approach to mitigate stress in a difficult situation where there is a longer and more protracted death, than would be the case under modern methods of slaughter.

Religious slaughter is a highly contentious issue. It is a matter of personal conscience. For some, it is an issue of religious conviction while for others it is a profound issue of ethics regarding the way we treat sentient animals. In my view, religious slaughter should become a free vote issue in parliament."

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AIMS Full Response to Meat Management

It seems to us that not for the first time AIMS is unwittingly at cross-purposes with former Agriculture Minister George Eustice MP. It is essential that this misunderstanding stops now. He has our sympathy for it is now quite clear that he has been badly served by the advice given to him by a minority of his civil servants and advisers.

We would contend that much of the response prepared by officials is not merely untrue but simply nonsense and in trying to clarify a murky situation AIMS would like to make absolutely clear its wish to help Mr Eustice achieve his genuine objective of improving the welfare of sheep at slaughter. It is an objective we in AIMS share with committed enthusiasm.

In order to clear up some of the apparent misunderstanding between AIMS and Mr Eustice we would make the point that if Government is unwilling to ban slaughter without prior stunning, a total ban which almost all UK veterinary surgeons would strongly support, stunning immediately after the cut is the single best measure to reduce suffering and should be strongly encouraged. Sadly, Defra effectively eliminated the practice completely by removing any operational benefit to the slaughterer. To apply the 20 second rule, prohibiting movement along the line for 20 seconds, to an unconscious sheep was an act of unmitigated folly by Defra. Such interpretation of the legislation cannot be defended. To correct matters all that is required is for Defra to deem the 20 second rule applicable only up to the point of stunning, which will guarantee that stunning is performed absolutely as soon as possible after the cut, minimising any suffering. This would immeasurably improve the welfare of sheep over the alternative of bleeding out while conscious.

AIMS is not, and never has been an apologist for slaughter without stunning. AIMS takes the view that whether it is lawful or not is a matter for the UK Parliaments, another matter with which we are in complete agreement with Mr Eustice. However, AIMS believes that, if stunning is not to be compulsory, post-cut stunning should be encouraged, whereas Defra by its perverse actions as described in the previous paragraph, effectively eliminated it. There are abattoirs which do not stun currently which would post-cut stun tomorrow if the 20 second rule ceased to apply once unconsciousness supervened. This would be a massive welfare gain with no downside.

So that there should be no misunderstanding and absolute clarity AIMS has always supported the 20 second rule because it is underpinned by scientific evidence.

The same Defra officials, who apparently cannot perform the simplest of calculations, mislead the Minister into believing the pernicious myth that the number of animals not stunned exceeds the demand from Muslim consumers. The ridiculous statement that 20% of chickens slaughtered are not stunned is simply untrue, a monstrous over-estimate. One wonders whether the explanation for this error is wilful ignorance, incompetence or mischief. It is agreed that around 5% or more of the UK population is Muslim and Muslims eat little beef and no pork, Muslims do however consume more than 25% of the sheep kill. There is thus no significant surplus of sheep meat not stunned over Muslim demand.

However, we acknowledge the concern of Mr Eustice that the Halal market has moved substantially away from stunning. The key cause of this is a belief by Muslims that they cannot be entirely sure that stunned carcases are Halal. Mr Eustice’s letter says that this is beyond dispute. Again, this assertion in his letter is simply not true. Recovery unharmed has never been demonstrated in peer reviewed scientific research in the UK for either sheep or poultry. Muslims would be foolish to believe assurances given by Government, especially without any direct evidence. Many poultry and sheep plants operate electrical “stunning” systems which kill the animal and Muslims would need it to be demonstrated that this was not the case for any plant which claimed to supply Halal meat. AIMS questions whether the civil servants explained this to Mr Eustice or perhaps it is a matter of which they are ignorant? Moreover, sheep would not recover uninjured from electrical stunning of the extended duration demanded by many FSA Official Veterinarians who do not properly understand the process. Muslims are entitled to be certain that sheep certified as Halal have been neither injured nor killed by the stun.

AIMS did not advocate “regular” demonstration of recovery, as anyone who actually read our original press release will have noticed. Very occasional demonstrations will suffice. If demonstration of recovery is “unnecessary”, why has New Zealand found such demonstrations essential to sell stunned Halal meat into the biggest and most observant Halal markets in the world?

No change in the law is required, only logical and humane interpretation to achieve the over riding objective of reducing animal suffering by promoting stun Halal.

If Parliament were to legislate to make stunning of cattle immediately after the cut compulsory, AIMS would respect it in its entirety as it is underpinned by science and because AIMS supports the Law without fail. It is indisputable that cattle remain conscious for a considerable time after the cut, which must involve suffering, and yet Government still sees fit to permit slaughter of cattle without any form of stunning. This emphasises that this is a political and libertarian decision for Government, not genuinely influenced by animal welfare. It is plain that the author of the letter in response has a limited grasp of the facts because sheep typically do not remain conscious for as long as 14 seconds. Most lose consciousness in a fraction of this time, emphasising the greater problems with cattle because of the different anatomy.

The remarks attributed to Mr Eustice in an attempt to justify the cruelty of Defra’s policy of forcing un-stunned sheep to be loaded and slaughtered alone are simply nonsense. The evidence given to the Court was unsubstantiated by the facts and ignored independent scientific evidence. A publicly funded study by AHDB with involvement from scientists at Bristol University conducted by the foremost veterinary experts, demonstrated a major reduction in stress if sheep were allowed to enter the restrainer together, following each other naturally and voluntarily. Independent research also demonstrated that a sheep isolated individually suffers “intense emotional distress”, something self evident to anybody who works with sheep but obviously not to Defra advisers. No other country in the EC separates sheep and forces them in to a restrainer alone and Defra policy is contrary to EC veterinary advice on this issue. We believe that advice to Mr Eustice as Minister was so poor on this topic that he believed that individual restraint would slow down the process of non-stun slaughter. Technical adaptations and sufficient man-power mean that throughputs have been maintained but the sheep suffer fear, panic and distress which is completely needless. Defra is therefore guilty of causing unnecessary suffering.

AIMS is in full agreement that religious slaughter can be contentious, we also believe that the application of experience, good sense and a practical approach can ameliorate much of the associated negativity. We also make it as clear as we can that AIMS has a strong wish to join with Mr Eustice in a campaign to improve welfare at slaughter. We are willing to provide him with the hands-on practical and veterinary knowledge and experience which Defra veterinary officials have unfortunately demonstrated they lack. With goodwill and a clear vision for a better future we can join forces to improve the welfare of animals at the time of slaughter."

This story was originally published on a previous version of the Meat Management website and so there may be some missing images and formatting issues.

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