FEDERATION OF VETERINARIANS OF EUROPE

FVE/06/doc/033
FINAL
(25/10/2007)

Welfare of Animals at Slaughter and Killing

Members
A New Regulation
Austria
Belgium
Bosnia-Herzegovina
Executive Summary
Bulgaria
Croatia
Cyprus
The Federation of Veterinarians of Europe welcomes the opportunity to make an initial
Czech Republic contribution to the drafting of the new legislation on the welfare of animals at slaughter and
Denmark killing.
Estonia
Finland
France Veterinarians are commonly perceived by the public in their traditional role as caretakers of
FYROM companion animals and livestock. However, one very important and often underestimated
Germany
Greece part of their field of activity is the work in food hygiene and therefore public health. Every
Hungary establishment that slaughters animals for food has an Official Veterinarian present
Iceland
Ireland
throughout the slaughter process who ensures that the required standards of animal welfare,
Italy animal health and hygiene are maintained.
Latvia
Lithuania
Luxembourg The veterinarian, in addition to being particularly trained to protect animal health and public
Malta health, possesses the full range of knowledge and skills necessary to assess animal welfare,
Netherlands to identify the causes of poor welfare and to make recommendations for its correction. As
Norway
Poland such, veterinarians have a central role to play in the regulation of the slaughter and killing of
Portugal animals whether for human consumption or disease control.
Romania
Serbia/Montenegro
Slovak Republic FVE believes that the Regulation must ensure that stress during the slaughter process should
Slovenia be kept to a minimum and where possible distress and pain eliminated. To achieve this,
Spain
Sweden animals should be stunned effectively before slaughter with a method causing immediate
Switzerland unconsciousness, preferably death. If stunned, no further procedures may be performed on
Turkey the animals before they are subsequently die by exsanguination.
United Kingdom

Observer The following are some of the key points which should be included in the new Regulation:
President
Ukraine
*It is imperative that all operatives involved with stunning and slaughter must be properly
trained, their skills and knowledge examined and certified. Tjeerd Jorna
Sections
*Each abattoir should appoint an appropriate employee to be the Animal Welfare Operative Vice-Presidents
UEVP (AWO) responsible for overseeing the unloading, lairaging and slaughter process and to
Practitioners Seán O Laoide
ensure compliance with the standards and legislation. Gundega Micule
EASVO * All equipment or method used for stunning and killing should be approved on a European John Williams
State Officers level before use. Walter Winding

UEVH
* The Official Veterinarian has an important role to fulfil both in auditing and inspection.
Hygienists
FVE is of the opinion that from an animal welfare point of view, and out of respect of an
EVERI
Veterinarians in
animal as a sentient being, the practice of slaughtering animals without prior stunning in
Education, Research unacceptable under any circumstances.
and Industry
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Federation of Veterinarians of Europe AISBL

Rue Defacqz, 1
B – 1000 Brussels
Tel: +32.2.533.70.20 - Fax: +32.2.537.28.28
E-mail: info@fve.org - Internet: www.fve.org
Introduction
The comments attached are made following consideration of the current Council Directive
93/119 and lists our suggestions as to what amendments are required given the current state
of scientific knowledge. As well as taking into account the recent scientific reports on the
subject produced by the European Food Safety Authority and the Office Epizootic
International scientific, the comments provided are also based on the practical experience of
a number of our members who have first hand knowledge of the problems, difficulties and
opportunities encountered in the humane killing of animals of many species in
slaughterhouses, during the eradication of disease and in the laboratory.

FVE believes that the format and scope of the new Regulation should be similar and
complementary to the Regulation on the protection of animals during transport (1/2005) and
the Food Hygiene Package.

The veterinary profession in Europe, in addition to being particularly trained to protect

animal health and public health, possesses the full range of knowledge and skills necessary
to assess animal welfare, to identify the causes of poor welfare and to make
recommendations for its correction. In addition, as food hygiene Official Veterinarians they
also possess audit and inspection skill. Consequently, veterinarians have a central role to
play in the regulation of the slaughter and killing of animals whether for human
consumption or disease control.

The veterinarian, as the advocate for the animal, has a professional and ethical responsibility
to ensure that the welfare of the animal is given priority over commercial, financial or
production requirements, in other words that the animal is put first.

A key factor in establishing and maintaining optimal animal handling and stunning in
slaughterhouses is a clearly communicated management commitment to animal welfare
demonstrated through the appropriate training of all staff involved in animal handling and
ongoing monitoring, supervision and recording of animal handling and stunning practices.

As stated in the Treaty of Rome animals are sentient beings, not agricultural products.

Specific comments
Article 1
The scope of the current Directive is unclear. The first article of the new Regulation should
be carefully considered so to avoid ambiguity. See also comments on articles 5, 9 and 12.

Article 2
Definition 5: Stunning: immediate or rapid loss of consciousness which lasts until death
occurs through slaughter or destruction of the brain.

Definition 7: Slaughter: A process causing the death of an animal, including bleeding.

A definition of bleeding should be added. We Suggest:

Bleeding: Procedure where both carotids or the vessels from where they arise are cut in the
purpose to kill the animal or to empty the carcass of blood.

Article 5
FVE believes that the new regulation should be extended to cover all animals brought to a
slaughterhouse for slaughter (and not only solipeds, ruminants, pigs, rabbits and poultry). A

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slaughterhouse as defined by Regulation 853/2004 means any establishment used for
slaughtering and dressing animals, the meat of which is intended for human consumption.

Article 7
All operatives involved with stunning and slaughter must be properly trained, their skills
and knowledge examined, in particular in the field of welfare, and the person should be
certified as competent by the Official Veterinarian. (EFSA-Q-2003-093, page 6, 1.2.) FVE
will assist the EU in laying down training objectives.

Regulation 854/2005 of the hygiene package Art 5 point 7 says ‘Member states shall ensure
that official veterinarians and official auxiliaries are qualified and have undergone training
in accordance with Annex I, Section III, Chapter IV, e.g. point s) regarding animal welfare
at the level of production, transport and slaughter’.

The slaughterhouse operator should monitor and correct non-compliances with welfare
requirements. The role of the official Veterinarian should be to audit documentation of
checks carried out by the operator and verify compliance.

Each abattoir should appoint an appropriate employee to be the Animal Welfare Operative
(AWO) responsible for overseeing the unloading, lairaging and slaughter process and to
ensure compliance with the standards and legislation. (Article 7) FVE would wish to assist
the commission in laying down the knowledge, skills and competencies such a person needs
and to detail his/her tasks.

In order to have a global and uniform approach with regard to animal welfare at slaughter
for commercial food production and for disease control purposes, broad guidelines should
be drawn up at Community level. In addition, specific parameters should be defined for
those points where sufficient scientific evidence exists and practical experience has shown
that animal welfare is poor or unacceptable. These guidelines should promote animal
welfare, identify risk points and detail the most effective procedures. A Community strategy
should take a comprehensive, integrated approach to the operation of controls. In view of
the non-binding character of these guidelines to be established it is appropriate to set up a
consultative committee to draft this document. FVE wishes to assist the Commission in
drawing up such guidelines.

The guidelines may, in particular, contain recommendations regarding:

- design of unloading bays
- design, capacity and care in the lairage
- handling of animals before and during slaughter
- technical requirements for the design and operation of group stunning pens
- technical requirements regarding driving, restraining, stunning and killing
equipment

The slaughterhouse operator should monitor levels of welfare in each point and where they
are beyond acceptable limits, should identify the cause of the problem and correct it.

Any equipment or procedure used to for stunning and killing must be suitable for the
purpose and not depend on systematic use of electrical goads or similar aversive force.
Currently there is no mechanism for approval of equipment of procedures, which makes it
difficult for a slaughterhouse operator to ensure that they use/buy procedures and equipment
which is efficient and welfare friendly.

New methods (including new electrical stunning current or voltage, frequencies or gas
mixtures) for use in restraint, stunning or slaughter should be tested from an animal welfare
viewpoint and only methods seen as efficient and as such approved on a European level by

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the competent authority should be put in use. This may be based on information by the
manufacturers and/or independent research.

Professional advice on health and welfare aspects should be sought when the building of a
new slaughterhouse is planned, or an existing one is renovated. The design plan, the
proposed equipment and procedures to stun and kill should be approved by the competent
authority in relation to the species slaughtered. The approval shall include a maximum line
speed according to the species of animal, infrastructure and personnel capacity1.

Article 9
FVE believes that the Directive’s provision on slaughter outwith slaughterhouses needs to
be strengthened. All animals should be stunned in advance. Consideration must be given
by the competent authority as to how to protect animal welfare through training and audit.
Training and competence requirements should also count for all operatives dealing with
slaughter outwith a slaughterhouse.

Article 12
Animal welfare must take priority over food hygiene or financial concerns. The difficulty
of transporting an animal over 50kg without causing further suffering must be taken into
consideration.

1
Reason: often plants increase line speed afterwards and stunning equipment is not sufficient any
more]

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Annex A: Requirements for the unloading and lairaging of animals
in slaughterhouses.
Unloading
Efficient scheduling procedures should be implemented by slaughterhouse operators so that
animals do not have to wait to be unloaded.

If animals’ waiting time on lorries regularly exceed 30 minutes, the Official Veterinarian
must take necessary enforcement action2.

All slaughterhouses must have a well-designed, constructed and maintained unloading area
[a purpose built, raised unloading bay]. The design of the unloading ramp, especially the
floor and the maximum permitted incline/decline must prevent slipping and falling and be
such as to allow unloading without unnecessary stress to the animals. Scientific evidence
confirms that the maximum incline/decline should be 20˚. This figure should be included
either in the Regulation or in the supporting guidance.

The use of instruments that administer electric shocks should be in line with the Transport
Regulation; “The use of instruments which administer electric shocks shall be avoided as far
as possible. In any case, these instruments shall only be used for adult bovine animals and
adult pigs which refuse to move, and only when they have room ahead of them in which to
move. Shocks shall last no longer than one second, be adequately spaced, and shall only be
applied to the muscles of the hindquarters. Shocks shall not be used repeatedly if the animal
fails to respond.’ Slaughterhouse staff shall be trained and slaughterhouses should be
designed in a way that instruments administering electric shocks become unnecessary.

Lairaging
Lairage rooms should be constructed in such a way that animals demonstrate regularly
resting behaviour. However this may not be possible in establishments which utilise system
which move the animals, particularly pigs, continuously.

Milking of cows – animals in the first third of lactation should be milked prior to transport
and slaughtered on arrival or within 15 hours after leaving the farm.

Annex A, II, 5 (and Annex C, II, (c)): “Animals should not be taken to the place of stunning
unless they will be stunned and killed immediately.” However, by group wise stunning or
slow slaughter speeds, shorter waiting times of 1-5 minutes may facilitate voluntary
movement and avoid stressful handling, as long as the animals are not restrained or stressed
in other ways in the stunning room/boks (the animals may be more patient waiting for the
slaughter than the other way round).
Annex A, II, 9 & 10 Lairage time > 12 hours => “...must be given moderate amounts of
food at appropriate intervals”. Important that the food is also appropriate – and fed in an
appropriate way – or the feeding may cause additional stress. There should be adequate
feeding space for each animal in the lairage pen.

The non slip flooring should also apply for driveways/passageways, for example as an
amendment to Annex A, II 3.

All animals including tethered animals must have access to drinking water, see Annex A II
10].

2
Note: in some cases after 30 min there may be no problems, while other cases really require action
after 30 min.

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Restraint of animals before stunning, slaughter or killing
Appropriate restraint shall be applied to the animals before they are stunned or immediately
killed. In particular individual restraint is necessary when captive-bolt is used or when
animals are slaughtered without prior stunning. Restraining should last until the animal is
unconscious.

Automatic driving systems/pushing gates should always be supervised. The pressure used
should be verifiable.

Animals, with the exception of poultry, must be restrained for slaughter in the upright
position3.

The movement of an animal must be restricted in such a way that the stunning equipment
can be placed in the exact position without difficulties.

Any method of restraint which causes distress or pain to the animal should not be used.
This includes methods such as those deployed to rotate cattle from an upright position as it
has been demonstrated that this compromises the animals’ welfare while alternative
methods are available which provide better welfare conditions without additional costs.

Rabbits should not be suspended. (Annex B, para 2)

The EFSA report states that wing flapping stops 14-22 seconds after hang on. If birds are
left too long they start to flap again. The shackling to stun period should be less than one
minute.

The shackle design should be appropriate to the species and type of poultry being
slaughtered. Poultry shackling lines should be constructed in such a way to prevent wing
flapping and pre-stun electrical shocks, as much as possible.

Floor of the slaughter pen must be non-slip and approximately horizontal in both the
longitudinal and transverse direction, (a slope of 2-5 degrees in the transverse direction is
acceptable to facilitate drainage). Uneven floors or a sudden drop in floor levels at the
entrance to conveyor restrainers should be avoided. If necessary, a solid false floor should
be installed under the restrainer to provide an illusion of a solid and continuous walking
surface.

The floor just in front of the stunning pen must also be non slip and facilitate movement.
This point is often very difficult for the animals as these pens/traps require a certain level
above the floor and by consequence the incline just in front is often too steep. In Germany a
maximum incline of 7° (cattle) to 10° (pigs) is permitted, in Belgium a maximum degree of
11.5°.

Group stunning must be carried out in a manner that does not interfere with the stun-stick
interval.

The size of the pen and the size of the group must be appropriate to the species and the
weight of the animals and must prevent pre stun shocks as well as too much possible
movement of the last animals of the group before stunning.

3
The group members recognized the point that in Spain and Italy many small light lambs are lifted by
one leg as no effective restraint device exists. It should be possible for Member States to make
regional derogations possible based on scientific evidence or proven experience.

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ANNEX C Stunning or killing of animals other than animals reared
for fur
Stunning:
Amend methods of stunning to penetrative captive bolt, non penetrative captive bolt, manual
blow to the head, electrical stunning and gas mixtures. (Annex C, I A.)

Maintenance of all stunners (calibration of internal control units for gas stunning, change of
electrodes and cables, etc) must be carried out according to manufacturer’s instructions.

The slaughterhouse operator shall ensure that its records of maintenance carried out must be
retained for audit by the Official Veterinarian.

All equipment should also be identified with a unique number.

Where possible irreversible stunning method should be used as an alternative to reversible

methods.

Ineffective stunning - either by incorrect use of stunning equipment, insufficient

magnitude or duration or by the use of improper maintained equipment - is a major
cause of compromise of animal welfare at the time of slaughter. Monitoring for signs of
recovery in order to evaluate the effectiveness of the stunning method should be built
in the Food Business Operators Standard Operating Procedures.

Penetrative captive bolt

The option of shooting in the poll should be retained for use in buffalo4, small horned
ruminants and horned deer and on occasions in cattle when the initial shot has failed to stun
the animal. The common recommendation for “re-shooting” (e.g. HSA) the recommended
position is near the first, but slightly lower/higher or to the other side, depending on where
the first unsuccessful shot was aimed.

Non-penetrative captive bolt

It is not realistic to legislate ‘to produce an effective stun without fracture of the skull’.
(Annex C, II, 2 (a))

Electrical stunning
The device to measure impedance and prevent operation of the apparatus if the minimum
required current does not fulfil the intended purpose and leads to problems in practice. It
does exist commercially but measured impedance at low voltages cannot be compared to
what happens at the higher voltages during stunning. Moreover these devices often prevent
often current flow, though electrodes are in correct position and lead to unnecessary pain.
(Annex C, II, 3, A, 2 (a))

The use of constant current stunning devices is recommended over constant voltage
stunners.

The problem of water fowl ‘swan necking’ in electrical water baths should be addressed by
ensuring stun to kill rather than stunning.5

4
Water buffalos can effectively be shot in front by using the Schermer KL Captive Bolt.
5
Good backup stunning methods only exist for water baths for poultry when the speed of the line is
not too high. The head-only electrical tong (e.g. Schermer device) can be used but needs
approximately 10 seconds per bird (take apply and put away and cut) and thus is of limited use for

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A table should be required in the Regulation that lays down the minimum current/frequency
6
necessary to stun different species types as described in the EFSA/OIE recommendations.
The Competent Authority may derogate from these minimum requirements if evidence is
provided that an effective stun can be achieved at a lower level.

Alarm system have to be calibrated, reliable, effectively, user-friendly7 and have verifiable
alarm settings.

Exposure to gas mixtures

When non aversive gas mixtures are available for use under commercial conditions, they
should be introduced as an alternative to carbon dioxide.

Where possible, the aim should be to kill by gas mixture rather than stun.

The combination of gas concentration, dwell time, time interval between exposure to the gas
and sticking and the accuracy of sticking must guarantee, that the animals do not regain
consciousness before death by exsanguination supervenes.

Gas mixtures for poultry should be introduced in line with EFSA requirements.

Visible access to the stunning chamber must be possible during introduction until the
animals have lost posture. This will assist the responsible company employee and the
Official Veterinarian in their important task of assessing the effectiveness of the gas mixture
during the important induction phase where slight changes in concentration of one
component or differences between flocks may have enormous effects. Access can be
covered /closed in the case light can cause problems.

Killing
Amend methods to free bullet, electrocution, exposure to gas mixtures.
(Annex C, I, B)

Dislocation and decapitation

Dislocation of the neck should not be used routinely in licensed slaughterhouses. It should
however be retained for emergencies for birds of less than 3 kg when other techniques have
failed and after stunning e.g. by concussion.

Vacuum chamber
Remove reference to vacuum chamber.

ANNEX D Bleeding of animals

Properly stunned animals should not display signs of sensibility on the bleed rail. The
following signs of regaining consciousness must not appear after stunning and during
exsanguination: spontaneous eye movement, vocalization, rhythmic breathing, righting
reflex. More detailed information on recognising the signs of unconsciousness and regaining
consciousness in animals should be contained in the guidelines and the training objectives.

high speed lines . For high speed lines the only one practicable on line is decapitation for poultry up
to 3 kg..
6
Necessary to see current in relation to frequency
7
Should not tell the current used for each animal if you use a constant current stunning device.
Should only note the operator when the requested current is not met.

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Must involve either both carotid arteries or the vessels from which they arise (e.g. chest
stick). (Annex D, 2)8 (at least if a reversible stunning method is used)

Annex D, point 2 second sentence: “After incision of the blood vessels, no further dressing
procedures may be performed on the animals before movement has ceased”. Electrical
stimulation may only be used on animals after they have been checked for efficient
stunning.

Other remarks:
Slaughter without prior stunning
See FVE document FVE/02/104

Killing of emergency slaughter animals on farm

Carried out by or under the supervision of an authorised veterinarian – see hygiene
regulation.

Slaughter of deer
The current categorisation of deer into wild and farmer deer is not helpful in terms of animal
welfare. Alternatively, deer should be categorised as either domesticated, semi-
domesticated or non-domesticated since some types of deer while kept extensively are
highly domesticated and vice versa.

Non-domesticated, “Red and fallow deer should be killed on farm by shooting in situ unless
they are well adapted to human contact and hence not significantly disturbed by human
proximity. – EFSA Q2005-005, page 9, 3rd bullet point.” In this case, as in all others the
welfare of the animal is paramount, so shooting in the wild or suitable enclosure must be
permitted. Detailed information as to equipment to be used, calibre and bullet type for each
species, should be contained within notes for guidance.

Semi-domesticated deer, such as reindeer, are domesticated to the extent that they can be
easily handled. This means that they have an owner and are sometimes handled. As these
animals are slaughtered in rather great numbers, it is impractical to shoot them in the wild.
However, when first handled they can be stunned in the common positions. Large, horned
males can be shot like horned sheep, calves in the frontal position.

For domesticated deer, penetrative captive bolt can be used at a variety of positions
including temporal – especially elk and reindeer.

Slaughter of ratites
Recommendations contained in EFSA-Q-2005-005, page 10, 5.2.

Ratitis should be slaughtered in a slaughterhouse designed with the size of the animal in
mind. To restrain them they should be blinded in a welfare-friendly way.

Slaughter of fish
See OIE guidelines

8
The hygiene regulations recommend not to cut the trachea – this is not possible when cutting both
carotid arteries and as such from a welfare point of view not advisable.

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Today's practise varies from no stunning at all to different treatments (chilling, chemicals,
gas/gas mixtures, electricity) that may or may not result in unconsciousness - partly with
detrimental effect on meat quality and little or no control over animals regaining
consciousness before killing. Several procedures used to achieve electrical stunning seem to
end up with either immobilised animals or impaired meat quality. All people involved seem
to agree that CO2 is not acceptable for fish, due to a long induction phase and strong
aversive reactions.

The only reliable and practical method seems to be percussive stunning or the use of spikes
for some species. Mechanised concussion stunners/machines are operational as well in
Scotland as in Norway.

Killing methods for disease control

See OIE guidelines for the killing of animals for disease control purposes - appendix 3.7.6 .

Methods for killing for fur animals

From information provided, it appears that the principal method for killing foxes is an
electrical stun/killing method, where the current is applied through one electrode in the
rectum and another in the mouth (0.3 A for 3 seconds, based on research by Lambooj). The
method seems to be acceptable, as the animals are left for at least 30 minutes before further
procedures are carried out, without any reported problems with animals regaining
consciousness.
Ampere meters/recordings are usually not available.

For other species in the fur production, there are several methods in use:
• CO2 has been demonstrated to be aversive to animals and problematic due to very
simple equipment with poor control over gas supply and variation in the actual
concentration
• CO - reported to function well - may represent some hazards for operators
• Electrical stunning/killing: Some systems obviously do not result in a heart arrest,
as the animals regain consciousness relatively fast. Hence, methods are combined
with dislocation of the neck. It seems, however, that scientific data on whether the
animals are properly stunned or rather immobilised are scarce (no references in the
report from SCAHAW-2001).

Suggestion:
• All personnel using stun/kill devices on fur animals should be certified.
• CO2 stunning should only be accepted under controlled conditions (manometers,
sensors measuring the actual gas-concentration in the stunning-box.)
• Electrical stunners for foxes should be equipped with ampere and voltmeters.
• Electrical stunning-devices that do not result in a heart fibrillation should not be used.

If sick or injured animals have to be killed “out of season”, other methods such as a manual
blow on the head may be acceptable.

Killing of surplus chicks and embryos in hatchery waste

The same gas mixtures should be approved as for killing in a licensed slaughterhouse.

For killing surplus chicks and embryos there are two mechanical possibilities, which must
both lead to an instantaneously lethal destruction of the brain of every animal fed into the
apparatus
- rotating blades

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 - projections – the gap between the projections should be less than 10 mm9.

Hunting
FVE believes strongly that the provision added to this paragraph, which refers to “respecting
religious rites, cultural tradition and regional heritage” should not be used as an excuse for
condoning cruelty to animals. Normally hunting is not in the competence of the EU but we
could make a specific statement that FVE disapproves certain hunting practices.

9
In one bsi-investigation of a maceration device they found lethal destruction of the brain of 16 mm
chickens heads with projections with a gap of 8 mm, where the projections of each cylinder left a gap
of 3 mm. Humane Slaughter Association in the UK recommends 10mm.

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