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news release

Choosing to lower welfare standards to new EU Directive level

Uncaged has discovered that the Government intends to adopt new EU rules that would allow newborn puppies, kittens, ferrets and fox cubs to be killed by a blow to the head. The statement is buried in a lengthy Home Office Consultation Document setting out how it intends to implement a new EU law on animal testing [1].

The plans can be found on page 4 of an Appendix discussing proposed 'Methods of Killing' [2]. It supports the introduction of 'Concussion/percussive blow to the head' as a method of killing 'neonate' dogs, cats, ferrets and foxes - newborn animals up to a few weeks old.

In some countries, this method is occasionally used to euthanase farm animals. However, one veterinary handbook [3] states:

"Percussive blow to the head may not always result in death in small piglets and lambs. Restraint of the animal is necessary and may be stressful. Operator fatigue may lead to inefficient application and result in poor welfare to the animal. The method is physically exhausting for personnel."

Another veterinary textbook [4] describes this method of killing as "Manual Blunt Force Trauma", observing:

"Common acceptable tools used for manual blunt force include ball peen hammers, steel rods, wooden clubs and pipes... Consistency of delivery is a challenge, therefore manual blunt force trauma is questionable in terms of reliability and effectiveness... One of the big problems with blunt force trauma is that caring stockpeople who are good at taking care of infant animals often do not want to use this method."

Despite these warnings, Home Office officials comment that this method is: 'Likely to be humane'. This suggests a disturbing lack of regard for animal welfare on the part of the Government.

Many animal handlers in laboratories refuse to kill animals because they fear it will desensitise them [5]. If the traditional methods of killing, such as injection or gassing, are that disturbing, then this raises fears about the kind of callous mentality that will be fostered in people who destroy young animals in such violent fashion.

By proposing to allow this killing method, the Government is demonstrating that it is willing to ditch existing higher welfare standards in the UK.

Dr Dan Lyons, Uncaged Campaigns Director, comments:

"The barbaric methods of the Canadian seal hunt are poised to arrive in British labs and breeding establishments. The only thing the Government appears to care about is any 'poor public perception', with no real concern whatsoever for the animals themselves."

General lack of regard for animal welfare and democracy

The UK Government consultation exercise on how it will 'transpose' the new EU Directive on animal experiments [6] into UK national laws closed on 5 September 2011 - the Government is now considering submissions. The UK must transpose the provisions of the new Directive into UK legislation by November 2012.

This process is a critical juncture in the history of animal experimentation. The outcome of this process will set the scene for animal experiments for a generation. Currently, approximately 3.5 million animals are used in experiments that may cause them 'pain, suffering, distress or lasting harm' in the UK every year. If the Government implements its current preferred options, then regulations will be explicitly weakened for the first time in over 135 years. This will have adverse effects on animal welfare, the quality of science and public health.

However, there is no reference to reducing animal experiments or reducing suffering as Home Office 'Transposition Objectives' in the consultation document (Paragraph 26). Also, there is no reference to respecting 'the ethical concerns of the public' as stipulated by the new Directive (Recital 12). Similarly, the Home Office has not considered the impact on animal welfare in its Impact Assessment [7]. Therefore, disregard for animal welfare is built into the very foundations of the Home Office strategy.

The Home Office intends to use the European Communities Act to impose new legislation area without proper parliamentary scrutiny. Uncaged believes that because this is an issue with enormous animal welfare, scientific and public interest implications, any new laws should be introduced as primary legislation to ensure full democratic accountability.

Many of the provisions in the EU law are weaker than existing UK measures, under pressure and the Government appears to be caving into industry demands to lower many UK standards to the EU level. The Home Office Consultation document contains a vague reference to retaining some stronger UK measures, but analysis of the document reveals that these are relatively scarce.

These are some of the worst threats to animal welfare from the preferred options as outlined in the Home Office Consultation Document ('HOCD'):

  • loopholes permitting severe and prolonged pain (Article 15, Article 55(3), HOCD p23/Q31, HOCD p40/Q56)
  • loophole permitting experiments on great apes (Article 8(3), Article 55(2), HOCD p14/Q10, HOCD p40/Q56)
  • loopholes permitting use of stray/feral animals, potentially leading to stolen pets being used in experiments (Article 11, HOCD p16/Q15)
  • less restrictions on painful experiments on cats, dogs and horses (HOCD p11/Q5)
  • permitting painful killing methods not currently allowed, such as decapitation of adult birds or smashing the heads of newborn puppies’ and kittens (Article 6 & Annex IV, HOCD p20/Q24)
  • ensuring that no current animal experiments are prevented under the new laws (general, e.g. see severe pain limit refs above)
  • lowering competence standards of researchers (Article 23(1), HOCD p29/Q41)
  • removing requirement for researchers to inform Inspectors if they break regulations (Article 24(2)(b), HOCD p30/Q43)
  • weakening independent assessment of experimental proposals (Articles 36(1), 38(3), 42 HOCD p31-32/Q45; also HOCD p34/Q49)
  • rubber-stamping of toxicity tests on animals and the breeding of GM animals (Article 40, HOCD p33/Q47)
  • retention of excessive secrecy (HOCD p43/Q59)
  • weakening UK restrictions on the repeat use of an animal in experiments, which could lead to more prolonged, distressing ordeals for animals (Article 16, HOCD p18/Q21)
  • permitting smaller cages for some animals (Article 33 & Annex III, HOCD p27/Q40)
  • decimation of the Inspectorate with some labs only visited every five years (Article 54, HOCD p38/Q54)
  • weakening the powers of ethical review bodies and national advisory committee (Animal Welfare Bodies Articles 26-27, HOCD p36/Q52; Animal Procedures Committee Article 49, HOCD p37/Q53)

The Consultation Exercise closed on 5 September. The Home Office is now considering submissions. It is vital that you alert your MP, family, friends and local community to this terrible threat to animals.

What you can do

  1. Please send a copy of this briefing to your MP as well to alert them to this looming danger - get their contact details from www.vote4animals.org.uk

  2. Please write to your local paper – you can download suggested text from here.

  3. Please send an urgent donation to support this crucial campaign.

  4. Please contact dan@uncaged.co.uk for a full copy of Uncaged’s response to the Consultation Exercise.

  5. For further information, including links to the text of the new Directive, visit the Home Office Consultation webpage


Related Links:


  1. http://www.homeoffice.gov.uk/...
  2. http://www.homeoffice.gov.uk/...
  3. http://www.efsa.europa.eu/en/scdocs/doc/45ax1.pdf , p194.
  4. http://books.google.co.uk/...
  5. http://www.apgaw.org/... (p5)
  6. http://eur-lex.europa.eu/...
  7. http://www.homeoffice.gov.uk/publications/...

Uncaged Campaigns 03.09.11, updated 20.09.11.



Uncaged 1993-2012: This is the archived website of Uncaged. All information correct at the time of archiving - November 2012.