MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

Miljø- og Fødevareudvalget 2017-18
MOF Alm.del Bilag 411
Offentligt

Ref. Ares(2018)1710952 - 28/03/2018

EUROPEAN COMMISSION

DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Health and food audits and analysis

DG(SANTE) 2017-6123

FINAL REPORT OF AN AUDIT

CARRIED OUT IN

DENMARK

FROM 09 OCTOBER 2017 TO 13 OCTOBER 2017

IN ORDER TO

EVALUATE MEMBER STATE ACTIVITIES TO PREVENT TAIL-BITING AND AVOID

ROUTINE TAIL-DOCKING OF PIGS

In response to information provided by the competent authority, any factual error noted in

the draft report has been corrected; any clarification appears in the form of a footnote.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

Executive Summary

The report describes the outcome of an audit in Denmark from 9 to 13 October 2017. This audit is

part of a Commission project aimed at improving the implementation and enforcement of Directive

2008/120/EC which lays down minimum standards for the protection of pigs in the EU. The

objective of the audit was to evaluate the suitability and effectiveness of the measures in place to

prevent tail-biting and to avoid routine tail-docking of pigs.

This report concludes that actions taken by the Danish authorities have not yet resulted in better

compliance with the provisions of the Pig Directive with regard to the avoidance of routine tail-

docking in pigs. The action plan for better pig welfare is a long term project, which includes

reducing the number of tail-docked pigs among its objectives. It has led to the development of

certain measures which are promoting the rearing of pigs with intact tails. A new government

animal welfare label has led to a large increase in pigs with intact tails where their meat is destined

for the Danish market. However, due to the large percentage of exported meat and live animals, this

has not yet resulted in a significant reduction in the total percentage of tail-docked pigs in Denmark

Where the competent authority has provided clear compliance criteria together with focused

actions, this has brought about improvements in animal welfare such as with enrichment materials

and care of sick and injured pigs. However, compliance criteria for the enforcement of other legal

requirements related to tail-biting risk factors are less clear or lacking and therefore enforcement of

these requirements is less consistent.

The authorities are currently working on the implementation of new guidelines that will expect

farmers to assess risk factors for tail-biting. If these guidelines set clear criteria for inspectors to be

able to assess evidence of tail and ear lesions on farm and what constitutes sufficient measures by

farmers to change inadequate environmental conditions or management systems before resorting to

tail-docking of pigs, they could form the basis for a useful enforcement strategy to reduce the need

for tail-docking. In addition slaughterhouse data can be used by the competent authority for

measuring progress and carrying out targeted inspections in herds with slaughter pigs.

The large number of 30 kg weaner pigs exported to other Member States that will only buy docked

pigs presents a challenge for the competent authority to change tail-docking practices in sow herds

supplying this trade. However, this cannot be an explanation for continuing tail-docking for pigs

which go to herds with slaughter pigs in Denmark which supply pigs to Danish slaughterhouses.

These herds with slaughter pigs continue to have a high level of non-compliance indicating that the

competent authority has not taken sufficient action to ensure welfare standards for that part of pig

production which is completely under their control.

Progress with regard to the avoidance of routine tail-docking in pigs is possible where pigs are

born, grown and finished in Denmark as many Danish pig facilities would allow rearing of pigs

with intact tails, but with a higher cost as it means fewer pigs per pen and more or another type of

enrichment material. As almost half of the Danish weaner pigs are exported to other Member States,

there is a need to ensure receivers take actions in parallel otherwise this will continue to be a

reason for Denmark to not stop tail-docking. The report contains recommendations to the Danish

authorities to address the shortcomings identified.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

Table of Contents

Introduction ....................................................................................................................................1

Objectives and scope......................................................................................................................1

Legal Basis .....................................................................................................................................2

Background ....................................................................................................................................3

Findings and Conclusions ..............................................................................................................3

5.1

5.2

5.3

Implementing Measures ..........................................................................................................3

Economic Factors ....................................................................................................................9

Official Controls ....................................................................................................................10

Overall Conclusions .....................................................................................................................13

Closing Meeting ...........................................................................................................................14

Recommendations ........................................................................................................................14

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

BBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation

DVA

DVFA

NGOs

PRC

The

Recommendation

Explanation

Competent Authority

Danish Veterinary Association

Danish Veterinary and Food Administration

European Union

Non-Governmental Organisations

Member State

Pig Research Centre of Danish Agricultural and Food Council

Commission Recommendation (EU) 2016/336 of 8 March 2016 on the

application of Council Directive 2008/120/EC laying down minimum

standards for the protection of pigs.

Council Directive 2008/120/EC

Pig Directive

III

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

NTRODUCTION

This audit took place in Denmark from 9 to 13 October as part of the planned audit programme

of DG Health and Food Safety. An opening meeting was held with the Danish competent

authorities on 9 October 2017. At this meeting, the objectives of, and itinerary for, the audit were

confirmed by the audit team and additional information required for the satisfactory completion

of the audit was requested.

The audit team comprised two auditors from DG Health and Food Safety and a national expert

from a Member State (MS) and was accompanied throughout the audit by representatives from

the competent authority (CA) the Danish Veterinary and Food Administration (DVFA).

BJECTIVES AND SCOPE

The objective of the audit was to evaluate the suitability and effectiveness of the measures in

place to prevent tail-biting and to avoid routine tail-docking of pigs.

The scope of the audit included:



Primarily measures taken and documentation from the period March 2015 to March 2017

but actions taken by the competent authority and others prior to this date were also

included as findings in the audit report;

Activities of competent authorities;

Activities of farmers' associations, meat and feed industry, academia and Non-

Governmental Organisations (NGOs) to prevent tail-biting and avoid routine tail-docking

of pigs;

Voluntary (quality) schemes, financial incentives or any other factors that aim to

encourage and support farmers in avoiding tail-docking.



The main legal requirements are included in:



Council Directive 2008/120/EC

;

Regulation (EC) No 854/2004 of the European Parliament and of the Council

;

Council Directive 2008/120/EC of 18 December 2008 laying down minimum standards for the protection of pigs

(OJ L 47, 18.2.2009, p. 5)

Regulation (EC) No 854/2004 of the European Parliament and of the Council of 29 April 2004 laying down

specific rules for the organisation of official controls on products of animal origin intended for human

consumption (OJ L 139, 30.4.2004, p. 206)

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin



Regulation (EC) No 882/2004 of the European Parliament and of the Council

In assessing compliance with Council Directive 2008/120/EC the audit team will take into

account Commission Recommendation (EU) 2016/336 (hereafter: the Recommendation) and the

accompanying Staff Working Document

In pursuit of the objectives, the following meetings were held:

Meetings with competent

authorities

Comments

2 Initial and closing meetings, including meetings with

representatives of pig producer associations, NGO's

and private practitioners.

Competent

Central

authority

Veterinary Inspection 1 Meeting with DVFA Veterinary Inspection Unit

Unit North

North.

Farms

2 Herd 1: 1300 sows, 6000 weaner pigs.

Herd 2: 1500 slaughter pigs.

1 Slaughterhouse visit

Universities 1 Meeting with researchers of Copenhagen and Aarhus

Universities.

Slaughterhouse

Meeting

with

representatives

EGAL BASIS

The audit was carried out under the general provisions of EU legislation and, in particular Article

45 of Regulation (EC) No 882/2004 of the European Parliament and of the Council on official

controls performed to ensure the verification of compliance with feed and food law, animal

health and animal welfare rules and Article 10 of Council Directive 2008/120/EC (hereafter the

Pig Directive) laying down the minimum standards for the protection of pigs.

EU legal acts quoted in this report are provided in Annex 1 and refer, where applicable, to the

last amended version.

Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls

performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules

(OJ L 165, 30.4.2004, p. 1)

Commission Recommendation (EU) 2016/336 of 8 March 2016 (OJ L 62, 9.3.2016, p. 20) on the application of

Council Directive 2008/120/EC laying down minimum standards for the protection of pigs and Commission Staff

Working Document on best practices with a view to the prevention of routine tail-docking and the provision of

enrichment materials to pigs (C(2016)1345 final).

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

ACKGROUND

Denmark is the 4

largest producer of pigs in the EU with approximately 8675 pig herds

Danish sow farmers keep about 1 million sows and produce about 32 million 30 kg weaner pigs

annually, of which 14 million are exported to other MS and 18 million are fattened and

slaughtered in Denmark. About 90% of pig meat produced in Denmark is exported. The vast

majority of pigs are reared under intensive conditions. About 98.5 % (see paragraph 10) of

commercial pigs born in Denmark are tail-docked.

In 2014 a position paper was drawn up by representatives from Denmark, Germany and the

Netherlands and signed by ministers from these three countries plus Sweden. The paper is also

supported by the Belgian authorities. It calls for an urgent update of the Pig Directive, in

particular regarding the provision on tail-docking of pigs. These countries urged the Commission

to amend the legislation, with the aim to ensure that the conditions, which apply before tail-

docking can be carried out, must also apply for the

keeping

of tail-docked pigs to make herds

with slaughter pigs also responsible for bringing about a reduction in this practice.

This audit is part of a Commission project aimed at improving the implementation and

enforcement of the Pig Directive laying down minimum standards for the protection of pigs,

particularly reducing systematic tail-docking of pigs in the EU.

In 2014, the European Parliament published a study indicating extremely low implementation of

the Pig Directive in relation to tail-docking.

In 2016, the Commission published the Recommendation, which provides guidance on best

practices as regards measures to reduce the need for tail-docking and an accompanying Staff

Working Document on best practices with a view to the prevention of routine tail-docking and

the provision of enrichment materials to pigs.

The Directive leaves to MS the choice of appropriate form and methods of ensuring compliance

with these general conditions.

INDINGS AND CONCLUSIONS

5.1 I

MPLEMENTING MEASURES

Legal requirements

Paragraphs 4 and 8 of Annex I of Directive 2008/120/EC

Regulation (EC) No 882/2004

In their response to the draft report the Competent Authority noted that: "A farm (in Danish “bedrifter”)

reflects an economic entity that may include a number of herds (in Danish “besætninger”) on different

locations. As it is these herds that are selected for animal welfare controls all findings in this report relate to

herds”.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

Findings

1. The requirements of point 4 of Chapter I of Annex I of the Pig Directive on the provision

of enrichment material are transposed into Danish law by the following provisions:



Act no. 56 of 11

January 2017

”om indendørs hold af smågrise, avls- og

slagtesvin”,

§ 5 states that weaner pigs, breeding pigs and rearing pigs must have

permanent access to a sufficient amount of straw or other manipulative materials

that can meet their needs for manipulative- and rooting materials.

Act no. 49 of 11

January 2017

“om indendørs hold af gylte, goldsøer og

drægtige søer”,

§ 9 states that gilts, dry sows and pregnant sows must have

permanent access to a sufficient amount of straw or other manipulative materials

that can meet their needs for manipulative and rooting materials.

Order no. 17 of 7

January 2016”om

beskyttelse af svin”,

§ 23 states, that in

addition to the measures normally taken to prevent tail-biting and other vices, and

in order for the pig's behavioural needs to be met, all pigs shall have permanent

access to a sufficient amount of straw or other manipulative material that can

meet their need for manipulable and rooting materials.



2. The requirements of the second paragraph of point 8 of Chapter I of Annex I of the Pig

Directive on the provision of enrichment material and avoidance of routine tail-docking

are transposed into Danish law by the following provision: "Order no. 1324 of 29

November 2017 “om

halekupering og kastration af dyr”

§ 4. In addition to what is laid

down in the Pig Directive the national legislation states that (if tail-docking is carried out)

the tail must be cut as little as possible and no more than half of the tail may be docked.

Guidance is available on how to provide proof of this (measuring tail length in a sample

of docked piglets compared with piglets with intact tails). Tails should form an almost

complete circle.

3. National requirements with regard to care and accommodation for sick and injured

animals, flooring and cooling systems are more detailed than the provisions laid down in

Council Directives 2008/120/EC and 98/58/EC (see Annex 2)

4. Most of the requirements of Council Directive 98/58/EC are implemented by Order no.

707 of 18 July 2000 on Minimum Requirements for the Protection of Farm Animals and

Articles 3 and 4 of Directive 98/58/EC are regarded as being transposed by paragraphs 1

and 2 of Order no. 20 of 11

January 2018, which codifies the animal welfare Act.

5. Denmark has a well-established system of sanctions which includes warnings,

enforcement notices (injunctions (indskaerpelse) or prohibitions (paabud/forbud)) and

reporting to the Police; see country profile:

http://ec.europa.eu/food/audits-

analysis/country_profiles/details.cfm?co_id=DK.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

Strategy for prevention of tail-docking and avoidance of routine tail-docking

6. The Danish national strategy is laid down in the action plan for better pig welfare that

runs from June 2014 until January 2020. Reducing the number of tail-docked pigs is one

of nine points in this plan. It is agreed on by the Danish farming industry,

slaughterhouses, animal welfare organisations, consumer organisations, veterinarians and

retailers. The objective is to decrease the proportion of tail-docked pigs significantly. The

actions include:



A targeted welfare campaign carried out by the CA to verify compliance with

legislation on rooting and enrichment materials for pigs.

The Danish Government Animal Welfare Label that requires, amongst other criteria,

intact tails.

Cooperation with other MS (Belgium, Germany, Netherlands, Sweden) including a

position paper that was drawn up and signed by Germany, Denmark, Netherlands

and Sweden. The paper is also supported by Belgium.

Several research projects (see paragraphs 19 to 22).

6.4 million DKK funding for the development of a new technology to provide straw

in pig barns (see also paragraph10).



7. In 2014 the CA carried out a campaign on enrichment materials. Inspections were

carried out in 200 randomly selected herds with weaner and slaughter pigs across the

country. During a break between the first and second round of inspections a working

group was set up with the Danish Veterinary Association (DVA) and PRC to engage

these major stakeholders and improve compliance. Overall non-compliances were found

in 13.5% of inspected herds, there was a slight decrease in non-compliances between the

first and second round of inspections.

8. The CA together with the DVA, the Danish Agriculture & Food Council, abattoirs and

retailers and DOSO (the organisation for cooperation between animal welfare groups),

initiated an animal welfare label. There are three levels within this scheme and herds in

all levels must keep pigs with intact tails and provide more space and straw. Meat sold

under this label has been on the market since May 2017 and labelled meat has already

achieved a share of 25% of the national market, with the largest increase in meat from the

lowest (one heart) level.

9. The two large slaughterhouse companies that represent more than 80% of the slaughter

activities in Denmark and the organisation of medium and small slaughterhouses support

the goal in the action plan for better pig welfare to achieve a reduction in tail-docking.

These companies participate in the follow-up group for this action plan and in the

stakeholder group behind the governmental animal welfare label.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

10. According to PRC there are currently between 450,000 and 500,000 pigs with intact tails

slaughtered in Denmark, this number represents roughly 25% of the Danish internal fresh

meat market. However it represents only about 2.5% of total Danish pig meat production

(pigs slaughtered in Denmark) and about 1.5% of total Danish pig production (500,000

undocked pigs of the 32 million commercial 30 kg pigs produced in Denmark), therefore

around 98.5 % of pigs produced in Denmark are tail-docked.

11. Denmark participates in a working group on animal welfare in pigs together with

representatives from Lower Saxony, The Netherlands and North Rhine-Westphalia. One

of the objectives of this working group is to exchange experiences and as far as possible

harmonise enforcement of the Pig Directive in the different countries. The last two

meetings of the working group have focused on the implementation of the

Recommendation. However no specific agreements on harmonising enforcement policy

haven been made to date.

CA guidance on tail-biting assessment

12. The CA has recently updated their guidelines on how to use manipulable materials and

avoid tail-biting. The guidelines now include instructions for farmers and inspectors

regarding the assessment of improvement measures, in addition to the use of manipulable

materials, taken on farms that tail-dock. Farmers are expected to assess risk factors for

tail-biting as well as procedures for the management of tail-biting outbreaks in their herds

and draw up action plans together with their veterinarians or other consultants.



The updated guidelines on how to use manipulable materials and avoid tail-biting

cover the six parameters mentioned in the Recommendation as well as pen design

and stray electricity, as these have been identified by PRC as additional risk

factors. The list also has an "other" category to allow for miscellaneous issues

which may arise in individual herds. The guidelines refer to the PRC manual for

the prevention of tail-biting (see paragraph 17).

13. At the time of this audit, the new guidelines were not yet incorporated in the instructions

for official controls. The CA intends to discuss the guidelines with their inspectors and in

a working group with the DVA, the Association of Danish Pig Producers and PRC before

referring to them as part of official controls. In addition, an information campaign will be

launched to inform farmers and practising veterinarians about the need for this risk

assessment for tail-biting.

Pig sector associations

14. The Danish Agricultural and Food Council is one of the stakeholders involved in the

action plan for better pig welfare. They avail of their own research centre (PRC) that is

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

involved in several research projects on tail-biting and the rearing of pigs with intact tails.

There are regular meetings (at least twice every year) with the CA.

15. In the view of PRC, tail-docking is currently inevitable and there is not enough scientific

evidence regarding risk factors to advise farmers on how to sufficiently improve

management and environmental conditions to be able to stop tail-docking in current

systems.

16. PRC points out that around 14 million 30 kg pigs are exported to other MS on an annual

basis and that there is no demand for undocked pigs in these countries. This is a major

obstacle to getting greater efforts to avoid tail-docking.

17. On its website PRC provides extensive guidance including a manual for the prevention of

tail-biting. The PRC manual details equipment features and management practices to

reduce the risk of tail-biting. The information provided includes the main risk factors for

tail-biting as mentioned in the Recommendation.

18. PRC has also established a network for pig producers who have stopped tail-docking with

the objective to share experiences and best practices. Currently the network consists of

the eight farmers that participate in the one heart level of the government animal welfare

label.

Universities and research

19. Research carried out by PRC and Copenhagen University concludes that rearing pigs

with intact tails in existing conventional systems will increase the prevalence of tail

lesions and that

post-mortem

results from slaughterhouses severely underestimate the on-

farm prevalence of tail lesions.

20. Research carried out by Aarhus University concluded that the daily provision of 150

grams of straw in combination with a lower stocking density (1.2 m

/slaughter pig) have

the same preventive effect on tail-biting (in undocked pigs) as docking pigs kept at

standard stocking densities without straw.

21. Other ongoing research projects at Aarhus and Copenhagen University include a

comparison between Swedish and Danish systems, early detection of tail-biting outbreaks

and intervention measures to stop tail-biting outbreaks.

22. Researchers of Aarhus and Copenhagen University stated that the main risk factors for

tail-biting are known and there is extensive evidence of the effect of enrichment materials

and stocking density on tail-biting, and that it is possible to advise farmers how to adapt

their systems.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

Veterinary association

23. A representative of the DVA stated that it is not possible for veterinarians to give advice

on how to construct new premises because there is insufficient knowledge on risk factors

for tail-biting to guarantee farmers that tail-biting will not occur. The view of this

association was similar to PRC, i.e. it is very difficult to avoid tail-docking in existing

Danish production systems.

24. Pig practitioners visit pig herds under a Veterinary Advisory Service Contract, which is

mandatory for all herds with more than 300 sows and smaller farms where the farmers

want to treat pigs with antimicrobials themselves. This represents approximately 90% of

pig farms. The contracts focus on advice and prevention of illness rather than treatment,

to optimise the use of antimicrobials and to improve animal welfare. Private practitioners

do not certify that they consider tail-docking necessary, and the CA has always held that

it is the farmer's responsibility to justify tail-docking.

25. Veterinary Advisory Service Contracts expect veterinarians to select the most important

health and welfare issues in each herd and draw up action plans for improvement. Since

January 2017 pig farmers are obliged to focus on animal welfare on at least two

veterinary visits each year. Currently around eight percent of herds have included actions

on tail-biting in their action plans under this contract. Farm visits are followed up by

reporting via a database (VETReg).

26. In the herd with slaughter pigs visited, the farmer, together with his veterinarian, had not

drawn up an action plan. The CA inspectors however identified animal welfare problems

with insufficient manipulable material and insufficient arrangements for the care of sick

animals. The inspectors indicated that a private veterinarian should have already signalled

the need for better care of sick animals. A CA representative indicated that further

discussion with private veterinarians on better pig welfare is planned.

Agricultural Advisory Services

27. The Danish Agricultural Advisory Service is part of the Danish Agricultural and Food

Council and advises farms on the basis of guidance and scientific evidence provided by

PRC. The advisory service has experts ready to assist farmers who want to stop tail-

docking or who have tail-biting issues in their herds.

Conclusions on Implementing Measures

28. The action plan for better pig welfare is a long term project which has not yet been

effective in decreasing the percentage of docked pigs. The new government animal

welfare label is a success which has led to an increase in the consumption in

Denmark of meat from pigs with intact tails. However, due to the large percentage of

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

meat and live pigs which are exported this barely influences the total percentage of

pigs which are tail-docked.

29. Inspection campaigns focusing on rooting and enrichment materials and a number of

research projects have had a limited impact on improving pig welfare but these

actions have not changed the belief of many private practitioners or industry

representatives regarding the perceived problems with rearing pigs with intact tails.

30. The new CA guidelines which expect farmers to assess risk factors for tail-biting,

draw up action plans and take improvement measures together with their

veterinarians or other consultants, could form the basis for making changes to

environmental conditions and management systems to potentially avoid routine tail-

docking.

31. The finding that only eight percent of herds have included actions on tail-biting in

their action plans is in contrast with the need for tail-docking in 98,5% of Danish pig

farms. The herd with slaughter pigs visited did not avail of an action plan in spite of

animal welfare issues that should have been detected by the farm's veterinarian. This

indicates that herd action plans drawn up as a part of Veterinary Advisory Service

Contracts do not sufficiently address the tail-biting risk on Danish pig farms.

32. Due to the large number of Danish 30 kg weaner pigs exported to other MS, there is a

need to ensure that farmers receiving pigs in these MS take actions in parallel.

Otherwise this will continue to be a reason for a large number of herds in Denmark to

not stop tail-docking.

5.2 E

CONOMIC FACTORS

Legal requirements

Article 33 of Regulation (EU) No 1305/2013

Findings

European and National Funding Measures in the Pig Sector

33. In its Green Development programme the Danish Agrifish Agency is funding several

projects to develop tools and information for farmers to assist them in adopting

preventive measures instead of tail-docking. Projects include a "stable concept for the

Regulation (EU) No 1305/2013 of the European Parliament and of the Council of 17 December 2013 (OJL 347,

20.12.2013, p.487) on support for rural development by the European Agricultural Fund for Rural Development.

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

rearing of pigs with intact tails", “a unit for automatic feeding of straw to pigs” and

“knowledge to secure pigs’ tails.”

Other economic factors

34. PRC has calculated the additional costs for rearing pigs with intact tails from 7 to 110 kg

at 6.70 euro per pig. Factors that contribute to these extra costs are: 20% more space

(2.50) euro, more hospital pens (0.30 euro), straw dispensers (0.80 euro), extra

maintenance (0.50 euro), extra labour (2.30 euro), extra feed (0.10 euro), increased

mortality (0.20 euro).

Conclusions on economic factors

35. European financial measures are not used to promote the rearing of pigs with intact

tails. However, some nationally funded programmes contribute to the knowledge of

how to keep pigs with intact tails.

36. The industry's own economic analysis indicates that rearing pigs with intact tails

causes additional costs (€6.70 per pig), and this cost is a challenge to achieving

progress.

5.3 O

FFICIAL

ONTROLS

Legal requirements

Directive 2008/120/EC

Article 5 of Regulation (EC) No 854/2004 in connection with Section I, Chapter II, point B(1)

and point C. of its Annex I and the relevant provisions of Section II, Chapter I of that Annex.

Article 3 and Article 43 (1) (b) of Regulation (EC) No 882/2004

Findings

Planning and procedures for farm inspections

37. There are satisfactory procedures for the planning of inspections. Procedures to select

herds for inspections include zero point (baseline) controls and prioritised (risk-based)

controls. Control of requirements concerning tail-biting, tail-docking, and permanent

access to a sufficient quantity of enrichment material are an integrated part of all zero

point and prioritised controls.

38. In addition to zero point and prioritised controls the CA makes use of campaigns as an

enforcement initiative to specifically focus on certain areas. Recent campaigns have

focused on enrichment and rooting materials in 2014, housing of piglets up to the age of

seven days in 2015 and correct treatment of sick animals in 2016. Before a campaign

MOF, Alm.del - 2017-18 - Bilag 411: Kommissionens endelige rapport om at evaluere medlemsstatens foranstaltninger til at forhindre halebidning og undgå rutinemæssig halekupering af svin

begins the CA holds a meeting with PRC and also informs the DVA about the focus of

the campaign and interpretation of the relevant legislation by the CA.

39. Guidance for carrying out inspections was available and included detailed guidelines on

the assessment of enrichment material, cooling systems, hospital pens and care for sick

and injured animals. However, for other legal requirements, in particular nos. 3, 6, 7, and

8 in Annex 2 to this report, no clear criteria were set for inspectors to be able to assess

compliance on farm.

40. The guidelines from the Danish Veterinary and Food Administration on enrichment and

rooting materials that are currently used by inspectors incorporate in section 5 guidance

on measures that are to be taken in a tail-biting outbreak. This section indicates which

risk factors are to be checked and stresses the importance of novelty and sufficient

quantity of enrichment materials in cases of tail-biting outbreaks. The guidelines do not

offer guidance on the assessment of the need for tail-docking.

Official controls on pig farms

41. The CA report to the Commission on checks carried out in 2015 on the protection of

animals kept for farming purposes

states that 3.3% of production sites were inspected

(284 out of 8675 herds). However animal welfare inspections carried out in the context of

campaigns are not included in this report as these are not "inspections" as defined in

Commission Decision 2006/778/EC. When these were included in the number of

inspections carried out by the Veterinary Inspection Unit visited, approximately 6% of

pig herds were subject to an animal welfare check in 2015.

42. From the report to the Commission, the most common non-compliances were in the

category "inspection", which was about 30% of herds inspected, and was largely due to

inappropriate treatment of sick and injured animals. The second most common

deficiency, occurring in 17% of herds inspected, was for insufficient "manipulable

materials".

43. Enforcement notices were served on the following numbers of pig herds in recent years

for insufficient manipulable material: 40 in 2015, 21 in 2016 and 44 in 2017. These were

found to be compliant at follow-up visits.

44. The DVFA and inspectors stated that the need for tail-docking is assessed by discussing

the main risk factors and the situation on farm with the farmer during inspections.

Farmers are currently not expected to provide written evidence on tail and ear lesions and

improvement measures to justify the need for tail-docking.

The format for this report is given in Commission Decision 2006/778/EC.

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45. During the visit to a pig herd to demonstrate inspection procedures, the inspectors had a

strong focus on the requirements that had been included in the campaigns and on what

detailed guidance was available (enrichment materials and sick and injured pigs) and also

included the other legal requirements which are relevant as risk factors for tail-biting. The

CA guidance and procedures for inspection do not provide clear criteria on which to base

the assessment of these other requirements; however, the inspectors indicated that the

PRC manual (see paragraph 17) provided advice on issues such as feeding space and

ventilation.

46. Data from inspections carried out in the whole country indicate that levels of non-

compliance with animal welfare legislation are higher in herds with slaughter pigs (33%)

and herds specialised in rearing weaners (38%) than in sow herds (20%).

Slaughterhouse controls

47. As part of the routine meat inspection of all pigs, not just those under the welfare label,

CA inspectors register tail damage seen at

post-mortem

inspection. They use two

different codes: one for tail damage without infection and tail damage with infection

(pyaemia). According to the Danish guidelines, in cases where tail-biting affects animal

health or animal welfare (finding of abscess, joint inflammation, lameness, etc.), the

farmer may receive a sanction. The Veterinary Inspection Unit visited had followed-up

one case in 2016 and two cases in 2017, which had been referred from the Meat

Inspection section of the CA after they had detected severe tail-biting.

48. The

post-mortem

data for each consignment of pigs slaughtered is sent by the business

operator to the herd of origin. This includes data other than tail damage which is relevant

to the conditions on farm, such as pleurisy lesions. Farmers are also provided with

average scores from the slaughterhouse so they can compare their results.

49. The percentage of damaged tails detected at slaughter shows a downward trend over the

last three years: in 2014, 0.73% (0.07% with pyaemia), in 2015, 0.62% (0.06% with

pyaemia) and in 2016, 0.49% (0.04% with pyaemia).

Conclusions on official controls

50. Where clear compliance criteria were set and incorporated into inspections and

campaigns, this has brought about improvements in animal welfare, such as with

provision of enrichment materials and care of sick and injured pigs. However, as no

such criteria have been established for the other relevant legal requirements related to

tail-biting risk factors, the enforcement of these is less consistent.

51. The current instructions and guidance are not sufficient for inspectors to properly

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enforce the provisions of the Directive concerning whether effective changes to

management or environmental systems had been made in herds prior to tail-docking.

The new DVFA guidelines (see paragraphs 12, 13) provide a basis for better

enforcement, but do not provide sufficient criteria for inspectors to be able to assess

a) evidence of tail and ear lesions on farm and b) what constitutes sufficient measures

by farmers to change inadequate environmental conditions or management systems

before resorting to tail-docking of pigs.

52. Feedback from the slaughterhouse helps ensure that severe cases of tail-biting are

investigated and the routine

post mortem

data also makes farmers aware of some of

their tail-biting issues. Slaughterhouse data on tail damage underestimate the real

level of tail-biting on farm, but is still a useful indicator of conditions in fattening

units.

VERALL

ONCLUSIONS

Actions taken by the Danish authorities have not yet resulted in better compliance with the

provisions of the Pig Directive with regard to the avoidance of routine tail-docking in pigs. The

action plan for better pig welfare is a long term project which includes reducing the number of

tail-docked pigs among its objectives. It has led to the development of certain measures which

are promoting the rearing of pigs with intact tails.

A new government animal welfare label has led to a large increase in pigs with intact tails where

their meat is destined for the Danish market. However, due to the large percentage of exported

meat and live animals, this has not yet resulted in a significant reduction in the total percentage

of tail-docked pigs in Denmark.

Where the CA has provided clear compliance criteria together with focused actions this has

brought about improvements in animal welfare such as with enrichment materials and care of

sick and injured pigs. However, compliance criteria for the enforcement of other legal

requirements related to tail-biting risk factors are less clear or lacking and therefore enforcement

of these requirements is less consistent.

The authorities are currently working on the implementation of new guidelines that will expect

farmers to assess risk factors for tail-biting. If these guidelines set clear criteria for inspectors to

be able to assess evidence of tail and ear lesions on farm and what constitutes sufficient measures

by farmers to change inadequate environmental conditions or management systems before

resorting to tail-docking of pigs, they could form the basis for a useful enforcement strategy to

reduce the need for tail-docking. In addition slaughterhouse data can be used by the competent

authority for measuring progress and carrying out targeted inspections in herds with slaughter

pigs.

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The large number of 30 kg weaner pigs exported to other Member States that will only buy

docked pigs presents a challenge for the CA to change tail-docking practices in sow herds

supplying this trade. However, this cannot be an explanation for continuing tail-docking for pigs

which go to herds with slaughter pigs in Denmark which supply pigs to Danish slaughterhouses.

These herds with slaughter pigs continue to have a high level of non-compliance indicating that

the competent authority has not taken sufficient action to ensure welfare standards for that part of

pig production which is completely under their control.

Progress with regard to the avoidance of routine tail-docking in pigs is possible where pigs are

born, grown and finished in Denmark as many Danish pig facilities would allow rearing of pigs

with intact tails, but with a higher cost as it means fewer pigs per pen and more or another type

of enrichment material. As almost half of the Danish weaner pigs are exported to other Member

States, there is a need to ensure receivers take actions in parallel otherwise this will continue to

be a reason for Denmark for not stopping tail-docking.

LOSING

EETING

A closing meeting was held on 13 October 2017 with representatives of the competent

authorities, at which the main findings and preliminary conclusions of the audit were presented

by the audit team. The competent authorities agreed that the action plan initiatives have not yet

achieved a full significance but they clarified that it is a long term project and that they expect to

achieve an impact with the continuous involvement of the stakeholders and the creation of a new

working group.

ECOMMENDATIONS

The competent authorities are invited to provide, within 25 working days of receipt of the report,

an action plan containing details of the actions taken and planned, including deadlines for their

completion, aimed at addressing the recommendations set out below:

No.

Recommendation

The competent authority should provide inspectors with suitable compliance

criteria to enable them to effectively enforce legal requirements of Council

Directive 2008/120/EC and Council Directive 98/58/EC that are related to risk

factors for tail-biting.

Conclusion 50. Findings 39, 45.

The competent authority should provide inspectors with suitable instructions and

guidance to be enable them to enforce the provision on the prevention of tail-

biting and avoidance of routine tail-docking, as laid down in the second paragraph

of point 8 of Chapter I of Annex I of Council Directive 2008/120/EC, including

how they should assess evidence of tail and ear lesions on farm and what

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No.

Recommendation

constitutes sufficient measures by farmers to change inadequate environmental

conditions or management systems before resorting to tail-docking of pigs. This

entails the development of measurable criteria to enable inspectors to properly

assess progress with regard to the risk factors listed in the new DVFA guidelines

on enrichment materials and the avoidance of tail-docking.

Conclusion 51. Findings 39 and 44 to 46.

The competent authority should, as required by Article 3(a) of Regulation

882/2004, take account of identified risks such as the level of non-compliance in

herds with slaughter pigs compared to sow herds and

post-mortem

data on tail

damage at slaughter to further target herds with slaughter pigs and improve risk

factors for tail-biting on these premises.

Conclusion 51. Finding 46. Conclusion 52. Findings 47 to 49.

The competent authority should continue to work with private veterinarians to

maximise the impact of Veterinary Advisory Service Contracts and ensure that

priorities set in herd action plans support farmers in their assessment of risk

factors as well as other relevant data related to the need for tail-docking, as

required by point 8 of Chapter I of Annex I of Council Directive 2008/120/EC.

Conclusion 31. Findings 24 to 26.

The competent authority should consider liaising with other Government Agencies

responsible for funding new buildings where pigs are to be kept and renovating

existing ones with the assistance of European funding under Article 17 of

Regulation (EU) No 1305/2013 to ensure not only that payments related to such

facilities are suitable to commitments going beyond the relevant mandatory

standards where they are related to animal welfare but that in general all funded

facilities, as a minimum, comply with relevant mandatory requirements (of

Directives 2008/120/EC and 98/58/EC) including the avoidance of routine tail-

docking e.g. slurry systems that can handle optimal enrichment materials, different

temperature zones, suitable flooring, feeding, space allowances etc.

Conclusions 35, 36. Findings 33, 34.

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ANNEX 1 – LEGAL REFERENCES

Legal Reference

Reg. 882/2004 -

Article 45 (MS)

Official Journal

OJ L 165, 30.4.2004,

p. 1, Corrected and

re-published in OJ L

191, 28.5.2004, p. 1

Title

Regulation (EC) No 882/2004 of the

European Parliament and of the Council of

29 April 2004 on official controls performed

to ensure the verification of compliance with

feed and food law, animal health and animal

welfare rules

Regulation (EC) No 854/2004 of the

European Parliament and of the Council of

29 April 2004 laying down specific rules for

the organisation of official controls on

products of animal origin intended for human

consumption

Council Directive 2008/120/EC of 18

December 2008 laying down minimum

standards for the protection of pigs

Reg. 854/2004

OJ L 139, 30.4.2004,

p. 206, Corrected and

re-published in OJ L

226, 25.6.2004, p. 83

Dir. 2008/120/EC

OJ L 47, 18.2.2009,

p. 5-13

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ANNEX 2

Parameter

Commission

Recommendation

(EU) 2016/336

Enrichment

material

Legal requirements

Directive 2008/120/EC,

98/58/EC

1. “permanent access to a

sufficient

quantity

material to enable proper

investigation

and

manipulation

activities”

(Directive

2008/120/EC

Annex 1, Chapter 1, 4)

Legal requirements Danish

national legislation

1. Weaner pigs, breeding pigs

and rearing pigs must have

permanent

access

sufficient amount of straw or

other manipulative materials

that can meet their needs for

manipulative- and rooting

materials (Act 56, 5).

Gilts, dry sows and pregnant

sows must have permanent

access to a sufficient amount

of straw or other manipulative

materials that can meet their

needs for manipulative- and

rooting materials ( Act 49,9)

In addition to the measures

normally taken to prevent tail

biting and other vices, and in

order for the pig's behavioural

needs to be met, all pigs shall

have permanent access to a

sufficient amount of straw or

other manipulative material

that can meet their need for

manipulative and rooting

materials (Statutory order 17,

23)

2. All pigs must have access to

a lying area that is comfortable

in terms of physical conditions

and temperature; that is

sufficiently drained and clean

and where all the pigs are able

to lie down at the same time

(Statutory order 17, 14-2) In

pens for weaners, breeding and

slaughter pigs at least 1/3 of

the unobstructed available

floor area shall be solid or

drained or a combination

thereof ( Act 56, 3,1)

In pens only used for weaners

at least �½ of the unobstructed

floor area shall be solid or

drained or a combination

thereof (Act 56, 3,2)

Circulation

air,

concentration

dust,

temperature,

relative

air

humidity and concentration of

gases must be kept at levels

that are not harmful to the

animals (Statutory order 707,

Pens for weaners above 20 kg,

breeding stock and finishers

must have a sprinkling system

similar

devices

for

regulating the animals' body

Compliance criteria / guidance

/ instructions for inspections

1. National legislation goes

beyond the minimum standard of

the Directive in that it requires

that materials must be rootable.

Assessment is done on the basis

of the DFVA guidelines that

provide elaborate guidance on

suitable materials, distribution

and quantity. The guidelines

include a table of suitable

enrichment

and

rooting

materials, numbers of objects

(wooden logs, ropes) to be

provided to a certain number of

pigs and instructions on how

enrichment materials must be

distributed in the pen. Materials

must be natural, chains and

plastic toys are not considered to

be suitable enrichment materials.

Bedding is required for pregnant

sows and gilts in groups.

Cleanliness

2. “a lying area physically

and thermally comfortable

as well as adequately

drained and clean which

allows all the animals to

lay

the

same

time”(Directive

2008/120/EC, Annex 1,

Chapter 1, 3)

2. According to the guideline for

inspections reasons for dirty pigs

should be clarified. Animals

should not be forced to lie in

manure.

Inspectors state that single dirty

pens in a compartment may be

accepted, however when all pens

are dirty the farmers is required

to take measures to solve the

problem.

Drained floor = no more than 10

% openings

Thermal comfort

and air quality

3. “air circulation, dust

levels,

temperature,

relative air humidity and

gas concentrations must be

kept within limits which

are not harmful to the

animals”

(Directive

98/58/EC Annex 1, 10)

3. The guideline for inspections

offers elaborate guidance on the

assessment of cooling facilities.

Sprinkling

systems

are

mentioned specifically in the

legislation, but other cooling

systems may be accepted if

temperature

lowered

sufficiently. No guidance on the

assessment

climate

parameters.

According to inspectors gas

concentrations are assessed on a

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temperature ( Act 56, 4)

For gilts, dry sows and

pregnant sows kept in groups a

sprinkling system shall be

installed, by which their body

temperature can be regulated (

Act 49, 8)

Competition

for

food and space

4. “unobstructed floor

area”

(Directive

2008/120/EC, Article 3,

1a).

5. "measures taken to

prevent

fighting

(…)

adequate opportunities to

escape and hide from other

pigs"

(Directive

2008/120/EC, Annex 1,

Chapter 2, D 1, 2)

6. “feeding and watering

equipment

must

designed constructed and

placed so that (…) the

harmful

effects

competition between the

animals are minimised”

(Directive

98/58/EC,

Annex, 17)

7. "permanent access to a

sufficient quantity of fresh

water"

(Directive

2008/120/EC, Annex 1,

Chapter 1, 7)

8. "sufficient number of

staff who possesses the

appropriate

ability,

knowledge

and

professional competence

(Directive

98/58/EC,

Annex, 1)

9. “sick or injured animals

shall be accommodated in

suitable accommodation

with, where appropriate,

dry comfortable bedding.

(Directive

98/58/EC,

Annex, 4)

10. "specialised housings

(for piglets weaned less

than 28 days of age) which

are

separated

from

housings where sows are

kept"

(Directive

2008/120/EC, Annex 1,

Chapter 2, C3)

Space

requirements

according

Directive

(Statutory order 17, 4)

5. When mixing pigs, it must

be possible for the pigs to

escape from or to hide from

other pigs (Statutory order, 17,

36-2)

6. Equipment for feeding and

watering must be designed,

produced and installed in such

a way that it provides the

lowest possible risk of

contamination of feed or water

and of harmful effects,

resulting from internal rivalry

among the animals (Statutory

order 707, 15)

7. Pigs older than 2 weeks

must have permanent access to

sufficient amounts of fresh

water (Statutory order 17, 22)

sensory basis and by looking at

the pigs. The CA does not as a

routine measure ammonia levels

Temperature and ventilation

levels are assessed by checking

climate control computer of the

farm and by looking at the pigs

(panting, huddling).

4. The guideline for inspections

states that troughs, other objects

including the space under

suspended objects are to be

deducted from the available

space. Sizes of troughs and other

objects are usually estimated and

then deducted.

5. The guideline for inspections

provides guidance on preventive

measures. Assessment is mainly

based on animal based indicators

6. The guideline for inspections

does not provide guidance on

feeding space or ratio pigs /

feeding space in ad libitum

systems.

7. The guideline for inspections

does not provide guidance on

drinkers or ratio pigs / drinker

but does provide a table with

guidance on height of drinkers

for different categories of pigs.

8. The guideline for inspections

does not provide guidance to

assess if number and competence

of staff are sufficient.

9. The guideline for inspections

states that there must always be

at least one hospitable pen ready

to use (incl. litter, heating and

cooling facilities) on the farm.

Dry and comfortable bedding

should be provided in 2/3 of pen.

Stocking density in hospital pens

should be about half of normal

stocking density. It also provides

elaborate guidance on which pigs

are required to be in the hospital

pens. Sick and injured animals

must receive prompt and

adequate treatment and if not

recovering quickly, must be

killed immediately. Separate

guidelines exist for the handling

of pigs with hernias and shoulder

lesions in sows.

10. Some guidance on how to

assess weaning age. Housings

for early weaned piglets must be

"all in all out"

Health status

8. Farm animals must be

tended to by a sufficient

number of staff with the

relevant skills, qualifications

and

technical

know-how

required to be able to tend to

the animals in a responsible

manner in terms of animal

welfare (Statutory order 707,

3).

9. On all pig farms, a sufficient

number of hospital pens must

be available and you must as a

minimum always have one

hospital pen ready for use

(Statutory order 17, 13, 1). The

total number of hospital pen

places for sows shall be at

least 2.5 % of the total number

of places for indoor places for

pregnant sows in groups

(transitional period) (statutory

order 17, 13, 2.) The design of

the hospital pen must fulfil the

below criteria: 1. Soft bed in

2/3 of the minimum area. The

soft bed may be constituted by

a soft rubber mat or sufficient

amounts of straw to prevent

direct contact between the

animal and the floor (Statutory

order 17, 6). All hospital pens

must have a heat source and a

cooling facility (Statutory

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Diet

11. “animals are fed a

wholesome

diet

appropriate to their age

and species and which is

fed to them in sufficient

quantity to maintain them

in good health and satisfy

their nutritional needs.”

(Directive

98/58/EC

Annex, 14)

order) 17, 13, 5), 3. There

must be no draught in the pen

(Statutory order 17, 13, 5).

Space

requirements

for

hospital pens see Statutory

order 17, 13, 3-4).

10. Specialised housings (for

piglets weaned less than 28

days of age) which are

separated from housings where

sows are kept (Statutory order

17, 35,2)

11. The feed must match the

animals'

age,

weight,

behavioural and physiological

need (Statutory order 17, 20)

11. The guideline for inspections

provides no guidance on what

constitutes a wholesome diet and

sufficient quantity.