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)1712011 - 28/03/2018

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

In the whole report (English version) please change Accepted

SEGES to Pig Research Centre (PRC) as this is the

correct English name.

Not accepted

The first part of the comment (“The

DVFA

suggests (....) number of tail-docked pigs”)

can be accepted as it is correct that the

objective of the action plan on better pig

welfare is to reduce the number of tail-docked

pigs and not to improve compliance with the

tail-docking provision of the Directive.

However the second part of the comment

(Furthermore

it is the opinion of the DVFA

(…) sanctions will be given)

cannot be

accepted as:

In the view of the audit team the presented

instructions and guidance were not sufficient

for inspectors to be able to properly assess if

evidence of tail lesions justified the need for

tail-docking.

Furthermore the audit team has seen no

written evidence / documentation of the

recording and evaluation of tail injuries on

partly

Text

amended

Footnote

(no.)

Whole

report

Executive summary

paragraph,

The DVFA suggests that "better compliance with the

line

provisions of the directive with regard to the avoidance

of routine tail-docking in pigs" is replaced by "a

reduction in the number of tail-docked pigs”. The

justification for this amendment is that the objective of

the action plan on better pig welfare is to reduce the

number of tail-docked pigs.

Furthermore, it is the opinion of the DVFA that in

general routine tail-docking is not carried out. The

provision in Directive 2008/120/EC has from a legal

point of view so to say two "legs". The first states that

tail-docking can be carried out only where there is

evidence that injuries to pig's tails have occurred.

When

the

farmer

can

give

this

evidence/documentation, tail-docking can be carried

out, and this can't be regarded as routine tail-docking.

This is typically the case in a control situation, also

when the issue of export of weaner pigs is taken into

account.

the

farmer

can't

give

evidence/documentation that injuries to tails have

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

occurred, a sanction will be given, and this was the

case for one herd in 2017. The second "leg" requires

that measures have been taken to prevent tail-biting. If

it during a welfare control in a pig herd is assessed that

the measures taken by the farmer are not sufficient, e.g.

insufficient access to suitable enrichment material,

sanctions will be given.

farms or in inspection reports.

In addition 98,5% of pigs born in Denmark

continue to be tail-docked and this is in

contradiction with the fact that only one

sanction has been given in 2017 because of

non-compliance with the tail-docking

provision in more than 453 inspected herds (

453 herds had been inspected up to 24

September 2017).

Therefore it can be concluded that tail-

docking was carried out routinely in Denmark.

With regard to the measures that need to be

taken to improve inadequate environmental

conditions and management systems before

resorting to tail-docking, the Danish CA stated

that these were addressed by inspectors in an

oral discussion with the farmer.

However, no clear procedures for this were

presented during the audit and it was not clear

how improvement measures were assessed to

be adequate and sufficient as instructions and

guidance were not found to be sufficiently

clear to do this.

The DVFA suggests that "fattening farms" is replaced Accepted

Text

amended

Footnote

(no.)

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

Text

amended

Footnote

(no.)

paragraph, by "herds with slaughter pigs" to be in accordance with

last line current Danish terminology, according to which

“fattening pigs” are now called “slaughter pigs”.

Furthermore, “herds” instead of “farms”, cf. the

comment to the first paragraph in chapter 4

Background. This comment applies

every time

”fattening farm(s)” occur in the document.

The DVFA suggests that "piglets" is replaced by Accepted: “piglets” has been replaced by

paragraph, "weaner pigs", as it is weaner pigs that are exported.

“weaner pigs” or “30 kg weaner pigs” where

first line

appropriate.

Last

In accordance with the comment to the second Not accepted. See comment to the 2

paragraph, paragraph above the DVFA suggests that the word paragraph above.

first line “routine” is deleted.

Last

The DVFA suggests that the following "or another type Accepted

paragraph, of" is inserted after "more". It may not only be a

line

question of quantity of enrichment material, but also of

the type of enrichment material. The same comment

applies to the

third line of the last paragraph in

chapter 6 Overall Conclusions.

Last

The DVFA suggests that "piglets" is replaced by Accepted: “piglets” has been replaced by

paragraph, "weaner pigs", cf. the comment above.

“weaners pigs” or “30 kg weaner pigs” where

line

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

appropriate.

Accepted. “farms” has been changed in

“herds” with some exceptions as sometimes

the term “on farm” cannot be satisfactory

paragraph, The number (3300) of farms (in Danish “bedrifter”)

translated by “in the herd”.

line

mentioned here, is the number given by Statistics

Denmark. This reflects an economic entity /business,

and may include a number of herds (in Danish

“besætninger”) on different locations. As it is herds

that are selected for animal welfare controls, the

number (8675) given in finding no. 41 is larger. To be

consistent with this the DVFA therefore suggests that

"farm(s)" is replaced by "herd(s)" and that “on farm”

is replaced by “in the herd”

in the rest of the

document, including the recommendations and the

annex. The DVFA also suggests that this is explained

in a footnote.

last

paragraph,

last line

5.1 (2)

No footnote 5 has been inserted.

Footnote 4 gives the legal references to the

Commission Recommendation and the Staff

Working Document already

4 Background

First paragraph, first line:

(5)

Text

amended

Footnote

(no.)

The DVFA suggests that "Order no. 1462 of 7

Accepted

December 2015" is replaced by "Order no. 1324 of 29

line

November 2017, as the order has been amended. The

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

amendment doesn't affect the part about tail-docking.

5.1 (4)

Last line

The DVFA suggests that "the animal welfare Act no. Accepted

50 of 11

January 2017" is replaced by "Order no. 20

of 11

January 2018, which codifies the animal welfare

Act”. The animal welfare Act has been amended to

include a legal basis for the minister to issue legislation

on education.

According the Country Profile (page 28) enforcement

notices include both injunctions (indskaerpelse) and

prohibitions (paabud/forbud). The most common

sanctions are injunctions, but also a few prohibitions

are given. Therefore the DVFA suggests that

"enforcement notices (indskaerpelse)" is replaced by

"enforcement notices (injunctions (indskaerpelse) or

prohibitions (paabud/forbud))".

Accepted

Text

amended

Footnote

(no.)

5.1 (5)

line

5.1 (6)

First line

The DVFA suggests that "routine tail-docking" is Accepted

replaced by "number of tail-docked" as the national

strategy is a part of the action plan for better pig

welfare, cf. the comment to the second paragraph in the

Executive Summary.

The DVFA suggests that "the organsiation ...... groups" Accepted

is replaced by “DOSO (the organisation … groups”, as

5.1(8)

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

DOSO is the most commonly used in Denmark.

Text

amended

Footnote

(no.)

line

5.1 (8)

The DVFA suggests that “Meat products” is replaced Accepted

by “Meat”, as meat products could first be labeled by

5th+6

line

December 2017.

5.1 (8)

Last line

The DVFA suggests that "the lowest (one heart) level Accepted

has already achieved a share of 25 % of the national

marked" is replaced by "labelled meat has already

achieved a share of 25 % of the national marked, with

the largest increase in meat from the lowest (one heart)

level", as this will better reflect the actual situation.

The DVFA suggests that "harmonise the Accepted

implementation" is replaced by "exchange experience

and as far as possible harmonise enforcement" as this

would better describe the objectives of the group.

5.1 (11)

line

The DVFA suggests that the words "or other Accepted

consultant" is inserted after “veterinarians”, as there

may be a need to consult others, e.g. in case of

paragraph,

ventilation problems. The same comment applies to

last line

conclusion no. 30.

5.1 (13)

The Association of Danish Pig Producers has joined Accepted

5.1 (12)

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

the group; the DVFA therefore suggests that this

association is mentioned.

The DVFA suggests that practicing veterinarians are Accepted

mentioned together with farmers, as it is the intention

that the information campaign should also target them.

The DVFA suggests that “the one heart level of” is Accepted

inserted after “in”, as this would reflect the current

situation.

The DVFA suggests that "SEGES research institute Accepted

and" is deleted, as the Pig Research Centre did not

participate in this study.

The DVFA suggests that “(VETREC)” is substituted Accepted

with “VetReg”, as this is the correct name.

Text

amended

Footnote

(no.)

line

5.1 (13)

Last line

5.1 (18)

line

5.1 (20)

line

5.1 (25)

Last

sentence

5.1 (30)

Last line

5.1 (32)

The DVFA suggests that "routine" is deleted; cf. the Not accepted. See response to comments on

comment to the second paragraph of the Executive the 2

paragraph of executive summary.

Summary.

The DVFA suggests that "piglets" should be replaced Accepted

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

by "weaner pigs".

The DAA suggest to delete ”50% of funding is from Accepted

the EU Rural Development Programme.” as the Green

Development programme is a purely nationally funded

programme and is not part of the Danish Rural

Development Programme.

Please note that neither the Danish Agricultural Accepted

Agency nor the Danish Environmental Agency,

provide EU funding to promote pig welfare within the

scope of the audit.

The conclusion should be modified accordantly.

5.2 (36)

First line

The DVFA suggests that "routine" is deleted; cf. the Accepted. “avoiding routine tail-docking” was

comment to the second paragraph of the Executive replaced by “rearing pigs with intact tails” as

Summary.

this correctly reflects what causes the extra

costs.

It is the opinion of the DVFA that the guideline on Accepted

animal welfare controls in pig herds gives sufficient

guidance on mixing of pigs in chapter 5.3.10.

Examples are given on possible measures to prevent

fighting, including on how pigs should be given a

possibility to escape and hide from other pigs. The

Text

amended

Footnote

(no.)

First line

5.2 (33)

5.2 (35)

5.3 (39)

line

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

DVFA therefore suggests that no. 5 is deleted.

The DVFA suggests that for clarity of the text "number Accepted

of inspections carried out by " is inserted in front of

last line

"the Region/unit", which should be replaced by

“Veterinary Inspection Unit”.

5.3 (46)

Last line

The DVFA suggests that "breeding farms" is replaced Accepted

by "Sow herds" both to avoid confusion with the "real"

breeding herds (zootechincal), and cf. the comment to

the first paragraph of chapter 4 Background. The same

comment applies to

the third line of recommendation

no. 3.

The DVFA suggests that "health" is deleted, it is a Accepted

superfluous word.

5.3 (41)

Text

amended

Footnote

(no.)

5.3 (47)

line

5.3 (48)

In order to specify who send the data, the DVFA Accepted

suggests that "by the business operator" is inserted in

line

front of "sent".

5.3 (51)

The DVFA suggests that "routine” is deleted, cf. the Accepted as the word “routine” is superfluous

comment to the second paragraph of the Executive in this context.

Summary.

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

Text

amended

Footnote

(no.)

The DVFA suggests that "better compliance with the

provisions of the directive with regard to the avoidance

of routine tail-docking in pigs" is replaced by "a

paragraph,

reduction in the number of tail-docked pigs.”, cf. the

line

comment to the second paragraph of the Executive

Summary.

Partly accepted. It is true that the objective of

the Danish action plan is the reduction of the

number of docked pigs and this is now

reflected more correctly in the text. However

the conclusion that measures taken by the

Danish authorities so far have not yet resulted

in better compliance with the provisions of the

Directive is correct and must be maintained.

Accepted

paragraph,

line

The DVFA suggests that "piglets" is replaced by

"weaner pigs".

In the

first line

the DVFA suggests that "routine" is

deleted, cf. the comment to the second paragraph of the

Last

Executive Summary. In the

second line

that “fattened"

paragraph,

is replaced by "reared" to be in accordance with current

line

terminology, and in the

fourth line

that “piglets” is

replaced by “weaner pigs”.

Last line

Deleting routine – not accepted (see comment

to 2

paragraph of executive summary)

Replacing fattened by reared and piglets by

weaner pigs – accepted.

The DVFA suggests that "new working groups" is Accepted

replaced by "a new working group", as only the group

mentioned in finding no. 13 is new.

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

Text

amended

Footnote

(no.)

2, 3

line

5, 8

line

The DVFA suggests that “routine” is deleted. This

suggestion is made both with a reference to the

comment to the second paragraph of the Executive

Summary, and as one of the objectives of the action

plan for better pig welfare is to reduce the number of

tail-docked pigs as such.

Not accepted. In addition to the comment to

the 2

paragraph of executive summary, it

should be stated here that the recommendation

refers to improving compliance with the tail

docking provision of the Directive and not to

the Danish action plan for better pig welfare.

Annex 2

Danish

national

legislation

No. 1

No. 2

The DVFA suggests that “Act 4, 9) is replaced by Accepted

“(Act 49,9) to give the correct reference.

The DVFA suggests that "323, 12-2)" is deleted, as this Accepted

order has been repealed, and that “(Act 56, 1)” is

replaced by “(Act 56, 3,1)” to give the correct

reference.

The DVFA suggests that “(Act 104,4)” is replaced by Accepted

“(Act 56, 4)” to give the correct reference, that

“”misting” is replaced by “sprinkling” as the same

word should be used for the same device, and that

“(Act 56, 8)” should be replaced by “(Act 49, 8)” to

give the correct reference.

No. 3

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

Text

amended

Footnote

(no.)

No. 6

The DVFA suggests that “risk” is inserted after Accepted

“possible”.

ANNEX 2, in the column on compliance criteria

Re. no. 3:

It is a misunderstanding that the Veterinary

Inspection Units do not avail of a device to measure

ammonia. This may be caused by the fact that

inspectors does not use this as a routine during

inspections, but assess the air quality on a sensory basis

and by looking at the pigs. A measurement can,

however, be used to support a sanction in case of

inadequate air quality. The DVFA therefore suggest

that “The CA does not avail of a device to measure

ammonia levels” is replaced by “The CA does not as a

routine measure ammonia levels”.

No. 4

The DVFA suggests that the sentence “Inspectors use a Accepted

table to assist in calculation of available space” is

deleted. The DVFA is not aware of any table, maybe

there is some confusion with the table used in

connection with transport.

All linguistic comments will be passed to the

translation service of the Commission for

All comments to the English version of the draft should

assessment/ incorporation in the Danish

be reflected in the Danish version.

version of the report.

Furthermore the DVFA has the following linguistic

DVFA comments to the translated report:

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

Commission services' response to the competent authority's comments on draft report DG (SANTE)/2017-6123–Denmark– evaluate Member State activities to

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

12 February 2018

Reference in draft

report

Page

Section

(Short description) Competent

authority's comments

Commission services' comments

Action in response to competent

authority's comments

Accepted

Not

accepted

comments.

Text

amended

Footnote

(no.)