MOF, Alm.del - 2017-18 - Endeligt svar på spørgsmål 343: Spm. om oversendelse af Kommissionens rapport fra besøget den 9.-13. oktober 2017, hvor Kommissionen evaluerede Danmarks praksis vedrørende halekupering, til miljø- og fødevareministeren

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

Ref. Ares(2017)5757256 - 24/11/2017

EUROPEAN COMMISSION

DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Health and food audits and analysis

DG(SANTE) 2017-6123

DRAFT 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

MOF, Alm.del - 2017-18 - Endeligt svar på spørgsmål 343: Spm. om oversendelse af Kommissionens rapport fra besøget den 9.-13. oktober 2017, hvor Kommissionen evaluerede Danmarks praksis vedrørende halekupering, til miljø- og fødevareministeren

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.

The report concludes that the Danish action plan for better pig welfare is a long term project but it

has not yet resulted in better compliance with the provisions of the directive with regard to the

avoidance of routine tail-docking in pigs. This project has however led to the development of certain

measures which are promoting successful 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 fattening farms.

The large number of pigs exported to other Member States that will only buy docked piglets presents

a challenge for the competent authority to change tail-docking practices on the farms supplying this

trade. However, this cannot be an explanation for continuing tail-docking for pigs which go to

fattening farms in Denmark which supply pigs to Danish slaughterhouses. These fattening farms

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 both

born and fattened 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 enrichment material. As almost

half of the Danish piglets 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.

Table of Contents

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

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

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

Background ....................................................................................................................................2

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

5.1

5.2

5.3

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

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

Official Controls ......................................................................................................................9

Overall Conclusions .....................................................................................................................12

Closing Meeting ...........................................................................................................................13

Recommendations ........................................................................................................................13

BBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation

DVA

DVFA

NGOs

SEGES

The

Recommendation

Explanation

Competent Authority

Danish Veterinary Association

Danish Veterinary and Food Administration

European Union

Non-Governmental Organisations

Member State

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

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

;

Regulation (EC) No 882/2004 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)

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)

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 Farm 1: 1300 breeding sows, 6000 weaners.

Farm 2: 1500 fattening 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.

ACKGROUND

Denmark is the 4

largest producer of pigs in the EU with approximately 3300 pig farms.

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.

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).

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 fattener's farms 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

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 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 behavioral 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.

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. 1462 of

December 2015 “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 the animal welfare Act no. 50 of 11

January 2017.

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

enforcement notices (Indskaerpelse) and reporting to the Police; see country profile:

http://ec.europa.eu/food/audits-analysis/country_profiles/details.cfm?co_id=DK.

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

6. The national strategy to reduce the routine tail-docking of pigs is part of the action

plan for better pig welfare that runs from June 2014 until January 2020. Reducing the

number of tail-docked piglets 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 farms with weaners and rearing 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 SEGES to

engage these major stakeholders and improve compliance. Overall non-compliances

were found in 13.5% of inspected farms, 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 the organisation for cooperation between animal welfare groups,

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

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

products using this label have been on the market since May 2017 and the lowest (one

heart) level has already achieved a share of 25% of the national market.

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.

10. According to SEGES 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 30kgs

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 harmonise the implementation 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 on their farms and draw up action plans together with their

veterinarians.



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 SEGES as

additional risk factors. The list also has an "other" category to allow for

miscellaneous issues which may arise on individual farms. The guidelines

refer to the SEGES 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 and SEGES before referring to them

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

inform farmers 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 (SEGES)

that is 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 SEGES 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. SEGES 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 SEGES provides extensive guidance including a manual for the

prevention of tail-biting. The SEGES 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. SEGES 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 government animal

welfare label.

Universities and research

19. Research carried out by SEGES research institute 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 SEGES research institute and Aarhus University concluded

that the daily provision of 150 grams of straw in combination with a lower stocking

density (1.2 m

/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.

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 SEGES, i.e. it is very difficult to avoid tail-docking

in existing Danish production systems.

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

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

farmers wants 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 on each farm 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 farms

have included actions on tail-biting in their action plans under this contract. Farm

visits are followed up by reporting via a database (VETREC).

26. On the fattening farm 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 SEGES. The advisory service has experts ready to assist farmers who want to stop

tail-docking or who have tail-biting issues on their farms.

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

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, could form the basis for making changes to environmental conditions

and management systems to potentially avoid routine tail-docking.

31. The findings that only eight percent of farms 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 fattening farm 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 farm 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 piglets 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 farms 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

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

“knowledge to secure pigs’ tails.” 50% of funding is from the EU Rural Development

Programme.

Other economic factors

34. SEGES 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. The CA is making use of EU funding to promote better pig welfare and contributes to

the knowledge of how to keep pigs with entire tails.

36. The industry's own economic analysis indicates that avoiding routine tail-docking

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

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.

Findings

Planning and procedures for farm inspections

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

farms 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 begins the CA holds a meeting with SEGES 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 no. 3, 5,

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 farms). 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

region/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 farms inspected, and was largely due

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

deficiency, occurring on 17% of farms inspected, was for insufficient "manipulable

materials".

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

43. Enforcement notices were served on the following numbers of pig farmers 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.

45. During the visit to a pig farm 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 does not provide clear

criteria on which to base the assessment of these other requirements; however, the

inspectors indicated that the SEGES 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 fattening farms (33%) and

farms specialised in rearing weaners (38%) than in breeding farms (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 the health of the 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 to the farm 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, which

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

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

enforce the provisions of the Directive concerning whether effective changes to

management or environmental systems had been made on farms prior to routine 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 underestimates the real

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

units.

VERALL

ONCLUSIONS

The Danish action plan for better pig welfare is a long term project but it has not yet resulted

in better compliance with the provisions of the directive with regard to the avoidance of

routine tail- docking in pigs. This project has however led to the development of certain

measures which are promoting successful 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 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, 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 fattening farms.

The large number of pigs exported to other Member States that will only buy docked piglets

presents a challenge for the CA to change tail-docking practices on the farms supplying this

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

to fattening farms in Denmark which supply pigs to Danish slaughterhouses. These fattening

farms 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 both born and fattened 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

enrichment material. As almost half of the Danish piglets 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 new working groups.

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

No.

Recommendation

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

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

fattening herds compared to breeding herds and

post-mortem

data on tail damage

at slaughter to further target fattening farms 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 farm 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.

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

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 to a 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 4, 9)

In addition to the measures

normally taken to prevent tail

biting and other vices, and in

order for the pig's behavioral

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 323, 12-2)

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, 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, 9)

Pens for weaners above 20 kg,

breeding stock and finishers

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

at 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 is lowered

sufficiently. No guidance on the

assessment of climate parameters.

must have a sprinkling system

or similar devices for regulating

the animals' body temperature

(Act 104, 4)

For gilts, dry sows and pregnant

sows kept in groups a misting

system shall be installed, by

which their body temperature

can be regulated (Act 56, 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 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)

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

According to inspectors gas

concentrations are assessed on a

sensory basis and by looking at

the pigs. The CA does not avail of

a device to 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.

Inspectors use a table to assist in

calculation of available space.

Sizes of troughs and other objects

are usually estimated and then

deducted.

5. The guideline on inspections

provides guidance on preventive

measures. Assessment is mainly

based on animal based indicators

6. The guideline on inspections

does not provide guidance on

feeding space or ratio pigs /

feeding space in ad libitum

systems.

7. The guideline on 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 inspectors

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

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

Diet

11. “animals are fed a

wholesome diet appropriate

to their age and species and

which is fed to them in

sufficient

quantity

maintain them in good

health and satisfy their

nutritional

needs.”

(Directive 98/58/EC Annex,

14)

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

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)

in all out"

11. The guideline for inspection

provides no guidance on what

constitutes a wholesome diet and

sufficient quantity.