A government advisory body has recommended that an independent animal welfare body for farmed animals be created. The Productivity Commission is holding a review of the recommendation and Vegan Australia has submitted a proposal calling for the new body to be tasked with the phasing out of animal agriculture within ten years. Read the full submission below.
Vegan Australia is pleased to have the opportunity to provide a submission in response to the draft report of the Productivity Commission public inquiry into the regulation of agriculture. We hope this submission assists the Commission in preparing the final report.
Vegan Australia is a national organisation that informs the public about animal rights and veganism and also presents a strong voice for veganism to government, institutions, corporations and the media. Vegan Australia envisions a world where all animals live free from human use and ownership. The foundation of Vegan Australia is justice and compassion, for animals as well as for people and the planet. The first step each of us should take to put this compassion into action is to become vegan and to encourage others to do the same. Veganism is a rejection of the exploitation involved in commodifying and using sentient beings.
This inquiry into the regulation of agriculture is an opportunity to reflect on our use of animals in the agriculture industry. It is an opportunity to consider alternative ways that land can be used, putting an end to the unnecessary suffering and killing of farmed animals.
It is important to emphasise that farmed animals suffer pain and their lives extinguished to produce products that are not necessary for human wellbeing. All these products, including those for food and clothing, can be replaced by plant-based products.
In this submission, Vegan Australia proposes significant changes to the agricultural system in Australia. We believe that these proposals are within the scope of the Productivity Commission's inquiry and we provide evidence to support our views.
The Productivity Commission covers a range of issues affecting the welfare of Australians. It helps governments make better policies, in the long term interest of the Australian community. It is "driven by concern for the wellbeing of the community as a whole." Vegan Australia submits that the Australian community includes all sentient beings, including farmed animals, and that the Productivity Commission's "concern for wellbeing" extends to these animals.
Animal welfare is within the scope of the current inquiry and the draft report includes a number of statements indicating that farmed animals are sentient, that is they experience the world and have the ability to perceive and to feel pleasure, pain and emotions. This further supports our view that the interests of animals should be seriously considered in the deliberations of this inquiry.
Regulations covered by this inquiry also include those protecting consumers from unsafe food and protecting the environment. While one of the goals of the inquiry is to improve productivity for farm businesses, it has obligations to maintain or improve the relevant objectives of regulations, such as those addressing social or environmental problems. Removing unnecessary regulatory burdens on the agriculture sector is a valid goal, but the key word here is "unnecessary".
Regulations are required to handle conflicting interests, such as between commercial interests and the environment or the interests of animals. The Commission should ensure that this inquiry is not used to weaken protections of the environment or animals.
Vegan Australia supports the establishment of an independent body for farmed animal welfare. The body should primarily represent farmed animals and their interests. The main objective of the body should be to plan for the complete phasing out of animal agriculture in Australia. We propose that a ten year phase out period be included in the terms of reference for the body.
The body's primary responsibility should be to ensure the protection of farmed animals in this country, irrespective of the short-term financial gains of harming those animals. Recognition of the sentience of animals should be explicitly included in the terms of reference in a similar way to the New Zealand Animal Welfare Act which stipulates that it is necessary to 'recognise animals as sentient'. In other words, to recognise that animals can experience both positive and negative emotions, including pain and distress.
Ending the use of animals in agriculture will have the greatest benefit to the welfare of farmed animals. Anything less will mean their continued suffering and death. Our proposal is based on science and ethics as we discuss below.
The new body for farmed animal welfare should coordinate with other departments, including agriculture, planning, education and treasury to ensure an orderly transition to a fully plant-based agricultural system. The body should continue the research begun by Vegan Australia into how a phase out of animal agriculture would affect a number of areas of Australian society, including land use, the environment, the economy and human health. An economic impact assessment of the phase out should be carried out. The animal agriculture industry only contributes 1% to the Australian economy and employment. Over a ten year period, any dislocations should be manageable and alternative industries would thrive. While much work remains to be done in ensuring a smooth transition to purely plant-based agriculture, doing so would be of benefit to Australia in the medium to long term, and, of course, of benefit to animals in the immediate term. See here for the research carried out by Vegan Australia: Moving to a vegan agricultural system for Australia.
The regulation impact assessment process to be carried out by the body must include the impact on animals. Merely assessing the impacts on the humans affected by changes would ignore the intended beneficiaries of animal protection legislation.
Vegan Australia supports Draft Recommendation 5.1, to establish a body for farmed animal welfare, as long as the body represents the true interests of farmed animals, sentient animals who value their own life and body and have an interest in continuing their existence and avoiding suffering.
The rationale behind the proposal to end the use of animals in agriculture is simply to avoid causing unnecessary suffering as much as possible.
All farmed animals suffer and they suffer in huge numbers. Currently 5 million pigs, 15 million cows, 20 million sheep and lambs and 500 million chickens are bred and killed in Australia each year. That's an incredible 1000 animals per minute. Some of the suffering endured by farmed animals is mentioned in the draft report, including these standard practices: intensive confinement, use of invasive surgical procedures without anaesthetic such as castration and mulesing (4 million lambs per year are mulesed without pain relief), sow stalls, farrowing crates and food and water deprivation during long painful transportation (up to 30 hours for bobby calves, some aged just 5 days old). Other horrific standard practices include: forced impregnation, continual pregnancy of female pigs, branding, dehorning, ear clipping, use of electric prods, tail docking, beak mutilation, declawing, gassing or macerating day-old male chicks, light-deprivation, permanent confinement, separation of mothers and infants, being scalded or cut open alive on kill lines, living in their own excrement, breeding chickens to grow so heavy their legs break, breeding cows to have udders 10 times natural size, and more.
After a life of intense suffering, all farmed animals are killed at a very young age, many as babies, drastically cutting short their normal life span. Each animal values their life and doesn't want to die. Even animals raised in "free range" systems end up at the same slaughterhouse. There is no such thing as the "humane slaughter" of an animal who doesn't want to die.
Breeding and killing farmed animals is not necessary. Humans don't need animal products to live healthy and fulfilling lives.
In this section we show that the wellbeing of animals and their commercial use in agriculture are incompatible.
We agree with the draft report's statement that "the use of animals for human benefit should minimise suffering of the animals involved". Here, the word "minimise" should be taken in an absolute sense. It does not mean "lower than before" or "as far as economically profitable". It is possible to attain zero suffering of farmed animals, but only by removing them from the agricultural system.
We refer to the diagram in Box 5.2 in the draft report. The diagram suggests that, at low levels of productivity, it is possible to increase the productivity and profitability of an animal business by improving the welfare of the animals. This hence gives producers an economic incentive to do so. This increase in profitability may be due to increased output from the better health and wellbeing of the animals or it may be from higher prices from meeting consumer demands for "higher welfare" animal products.
The diagram then shows that at a certain point, the only way to increase productivity is to reduce the welfare of the animals, such as by increasing housing density or reducing care. Animal businesses need to make a profit and so most producers will try to achieve the highest level of productivity without too much regard for the reduced welfare of the animals.
This view of the link between animal welfare and industry profitability is only approximate, but useful for our purposes.
The below diagram is a re-working of the original diagram, with the "W-min" line marked "Cruelty" being moved from below the "welfare-productivity" curve to above the curve and marked "Suffering/death".
We have made this change to indicate that in our view, and in the community's view if they were properly informed, it is unacceptable to deny the life and liberty of an animal without good reason. All points on the "welfare-productivity" curve represent at least the death of the animals concerned and in almost all cases a life of significant suffering.
Regarding the wellbeing of animals, we should treat animals as individuals, not as statistics. Statements in the draft report such as "high mortality rates (a simple but useful measure of animal welfare) are typically at odds with productivity" are offensive. It suggests that low (but non-zero) mortality rates are acceptable. It also completely ignores the fact that the mortality rate is actually 100%, since all animals are killed well before their natural life span.
When regarded as individuals, animals in the care of humans are often treated very well. The point at the top of our graph demonstrates this. It refers to animals such as pets and rescued farmed animals living in sanctuaries who are cared for properly, whose needs are met, who are treated when ill and who are allowed to live their full lives with as little stress as possible. Their "productivity" in terms of economic benefit is zero, yet they contribute in immeasurable ways to increase the wellbeing of the humans they interact with. Rescued farmed animals also serve as ambassadors for the millions of other animals processed by the animal agriculture system.
While the draft report mentions that some Australians believe that animals should not be used commercially, there is no followup in the report. It does not examine this possibility nor compare it to the status quo. We request that the final report look into this possibility further.
The report contains a number of references to the "public benefits of farm animal welfare". We reject the view that the wellbeing of animals should be measured by how much the community feels "concern or discomfort about the mistreatment of animals". The only valid measure of animal wellbeing is the animals themselves. We are dealing with the lives of millions of animals. We can not leave this to how much consumers are willing to pay. It is unethical to leave it to "the market" to determine how animals are treated. It is unfair to the animals to allow demographics (age, income and gender), the willingness to pay or consumers' knowledge of animal production systems (or lack of knowledge) to dictate their future.
The draft report states that the "NSW Farmers' Association suggested that the appropriate course of action is to allow changes in production practices to be guided by economic drivers in the consumer sphere." Vegan Australia rejects this as being selfserving and unethical.
In no other domain would the welfare of another being be thought of as "a public good in that all (or many) members of society derive a benefit from it." How is it relevant to the animals affected that some people "derive relatively little benefit from improved welfare"? This is an ethical issue that should be argued on its merits and not resolved by taking a public opinion poll. It is also wrong to use public opinion when the people have been misinformed about the issue so completely and for so long.
Vegan Australia supports the statement that "the challenge for policy makers is to determine the level of farm animal welfare that provides the highest net benefits to the community as a whole" only if animals are fully included in the term "community".
Farmed animal welfare regulations are currently woefully inadequate and any possible future changes will never be enough to ensure the wellbeing of the animals. Currently, commercially farmed animals are exempted from the overarching anti-cruelty and duty of care standards included in animal welfare legislation. Horrific acts which cause great suffering and which are illegal to perform on domestic pets, are quite legal and standard practice for farmed animals. It is completely illogical that the same suffering can be inflicted on the same animal and yet the legality of the act depends on whether the animal is a family pet or a production unit on a farm. The laws allowing this are, in effect, legalising cruelty.
Current regulations are barely enforced and any improvements would suffer the same fate. There are over 100,000 farms and hundreds of abattoirs in Australia, making enforcement of any standards almost impossible.
It is clear that the animal production system could not economically survive if the same animal cruelty laws applied as for pets. The financial costs would be too high. And proposed "higher welfare" practices are only a little better than current standard practices and are constantly being degraded by the pressure of competition to make a profit. And in any case all animals end up at the same slaughterhouse at the same young age.
Discussion and arguments about "free-range", stocking densities, range rotation, organic, the use of anaesthetics, etc, are diversions from the real issue. The animal industry will fight and delay at every change. No amount of tweeking regulations will ever be enough. The only ethical solution is to end the use of animals in agriculture.
Farm animals feel pleasure and sadness, excitement and resentment, depression, fear, and pain. They are far more aware and intelligent than we ever imagined ... they are individuals in their own right. ~ Jane Goodall
Vegan Australia agrees with the emphasis the draft report places on using credible scientific evidence to determine animal policy. In fact scientific evidence should form the basis of any new farmed animal welfare body's recommendations.
The evidence of animal cognition should be the primary factor in the determination of the recommendations. Evidence of productivity and profitability should be considered only after a determination is made based on animal science.
Scientific knowledge supports the common belief that animals are sentient, have emotions and can feel pleasure and pain. Animal welfare laws have existed for almost two centuries, so the fact that animals can suffer is not a new concept.
Scientific research has discovered that the pain and pleasure mechanisms in animals are very similar in all vertebrates, including humans. The pain-inhibiting mechanisms found in the human body are very similar to those found in other animals.
Professor of Bioethics at Princeton University, Peter Singer, states "it is surely unreasonable to suppose that nervous systems that are virtually identical physiologically, have a common origin and a common evolutionary function, and result in similar forms of behaviour in similar circumstances should actually operate in an entirely different manner on the level of subjective feelings."
Animal behaviorists have found that, given amenable conditions, farmed animals interact in socially complex ways, bonding with family members and developing friendships over time. They have "rich and deeply emotional lives". Many mourn the deaths of others, with the mother-calf bond being particularly painful when it is broken. Raising animals in crowded conditions is very stressful to them because it upsets their social structure.
There is some suggestion in the draft report that science supports how farmed animals are currently treated. The report states "there is a risk that unnecessary regulations will be imposed on farmers based on emotive reactions rather than evidence-based policy". The evidence actually supports the view that animals do not want to be bred and killed.
The draft report states that "the welfare of animals is judged on the basis of: how well the animal is performing from a biological functioning perspective; affective states, such as suffering, pain and other feelings or emotions; the expression of normal or 'natural' behaviours." Evidence suggests that none of these are met in any commercial agricultural system.
The farmed animal welfare body must be very careful as to what it accepts as "science". Industry funded, biased "research" should be ignored. Most livestock research in Australia is largely funded and controlled by industry bodies. The research is often commercially driven, to obtain productivity gains or defend current practices. Because of these conflicts of interest, research results can be biased towards industry.
Vegan Australia agrees that both ethical considerations and credible science are important in determining welfare standards. However we do not agree that these two concepts are mutually exclusive. We do not see a conflict between the ethical consideration that it is wrong to inflict unnecessary suffering on animals and the scientific fact that farmed animals are sentient beings capable of suffering.
See more about animal sentience, emotion and behaviour here:
Vegan Australia suggests the Commission visit Edgar's Mission in Victoria and spend a few hours getting to know the stories behind the rescued farmed animals who live there as valued individuals.
Science can also be used to show that humans have no need for farmed animal food products. In fact, there is a solid body of peer-reviewed scientific evidence to confirm that it actually benefits human health to consume a primarily plant-based diet. Changing to a plant-based diet can help people live a longer, healthier life, and significantly reduce risk of falling victim to many of the serious health threats facing Australians today.
Australia's peak health body, the National Health and Medical Research Council, recognises that a vegan diet is a viable option for all Australians. Australia's top health experts agree with those in other parts of the world that well-planned vegan diets are safe and healthy for all age groups. The Australian Dietary Guidelines state that alternatives to animal foods, such as nuts, seeds, legumes, beans and tofu, can "increase dietary variety and provide a valuable and affordable source of protein and other nutrients found in meats."
According to the US Academy of Nutrition and Dietetics, "Appropriately planned … vegan diets are healthful, nutritionally adequate and may provide health benefits for the prevention and treatment of certain diseases. These diets are appropriate for all stages of the life cycle, including pregnancy, lactation, infancy, childhood, adolescence, older adulthood and for athletes."
Not only are animal products unnecessary for optimal health, an increasing number of nutritionists and health professionals are acknowledging animal products are harmful to our health. This is supported by decades of good research. A healthy vegan diet helps reduce the risk of heart disease, stroke, cancer, obesity, and diabetes, some of Australia's top killers.
A recent issue of the Medical Journal of Australia, dedicated to the question "Is a Vegetarian [including vegan] Diet Adequate?", included the following statements. "A varied and balanced plant-based diet can provide all of the nutrients needed for good health." "Most vegans meet the recommended daily intake for protein." "Vegan diets generally contain just as much or more iron than mixed diets containing meat." "BMI and obesity was lowest for vegans."
The China Study by T Colin Campbell is one of the most comprehensive studies on nutrition ever done. Campbell provides compelling evidence linking animal products to disease, including cancer, heart disease, osteoporosis, diabetes, etc.
Every current vegan, by simply being vegan, proves that causing harm to sentient farmed animals is not necessary.
The draft report already contains some data about public support for the welfare of animals. In addition, a 2010 survey found that "99% of Australians are against cruelty to animals" (A Pound of Flesh, Vegan/Vegetarian Society of Queensland). The survey also found that 54% of Australians believe that vegan diets can be healthy. It also found that 56% of Australians say there are one or more things that would encourage them to become vegan, including evidence that many farming practices cause stress and pain for millions of animals every year and evidence they can be healthy on a vegan diet. Finally, 47% of Australians think making cows pregnant every year and taking their calves from them to obtain milk is unacceptable.
Other surveys have also shown that most people oppose testing cosmetics on animals. In fact, there is now widespread political support to outlaw the sale of all products tested on animals. The reform will bring Australia into line with Europe and New Zealand. Although in a different arena, this shows that when acceptable alternatives exist most people will choose compassion over cruelty.
The recent ban on greyhound racing is another example where the majority of people actively oppose the unnecessary suffering of animals. One of the major concerns with people is "wastage" - the majority of dogs who are killed because they are no longer fast enough to win. In other words, dogs are bred to be used for the trivial reason of entertainment and then killed. Most people rightly felt outrage when learning of this practice. The parallels with animal farming are clear - farmed animals are bred to be used for the trivial reason of enjoyment of the taste of their flesh or secretions and they die in the process.
We also note the surveys mentioned in the draft report: "A survey of Australians' relationships with animals found that '52 per cent of respondents thought that factoryfarming methods of producing meat, eggs, and milk (which are becoming dominant trends) were cruel'" and "30 per cent thought that animals deserve the same rights as people to be free from harm and exploitation".
Most people agree that causing unnecessary suffering and death of any sentient being is wrong and we should not participate in it if we can avoid it. We believe that given the right information about 1) the sentience of animals, 2) the unavoidable suffering of animals in agriculture and 3) the scientific evidence that humans have no need for animal food products, then there will be widespread public support for the complete phasing out of animal agriculture in Australia.
Vegan Australia agrees with the draft report's emphasis on research to find out more about community values and expectations around farmed animal welfare. However the community must be fully informed in this area so they can make valid conclusions.
We propose that the new farmed animal welfare body's research on community values include honest community education about animal agriculture and the lack of necessity for humans to consume animal products. The horrific realities of animal agriculture are unknown by many in the community due to the prevalence of miseducation beginning in childhood and continuing into adulthood. Some of this miseducation is perpetuated intentionally by supporters of the animal agriculture industry, however much of it is merely the passing on of falsities by well-meaning people. The situation is the same in the context of the belief that animal products are a necessary component in the human diet, despite this belief contradicting the Australian Dietary Guidelines and other major dietetic organisations globally. Failing to provide this education, informing Australians of the realities of animal agriculture and the lack of necessity of the consumption of animal products, would result in a skewed community perspective.
This education is a prerequisite for gauging community values on animal welfare. Failing to do so would bias the process in favour of cruel and unnecessary practices that are not known about, or understood by, members of the general public.
The content of the education should be guided by the end goal of phasing out animal agriculture within ten years. No part of the education should lengthen this process by suggesting movements to intermediate "higher welfare" systems, such as cage-free eggs or "happy" meat.
We disagree with the suggestion in the draft report that the body should "disseminate information to the community on best-practice farm animal husbandry practices". In our view "best-practice" still involves causing suffering and death to the animals.
People's views can change rapidly when presented with new information. In the experience of Vegan Australia we have found that it can take as little as reading one book or seeing one video that can completely change people's attitudes to animals as food. Community awareness is growing and we expect it to accelerate.
The report points out that people's ethical concerns are not always matched with their consumption decisions. For the reasons pointed out in the report, many people who are concerned about the welfare of farmed animals continue to consume their products and do not attempt to buy "higher welfare" products. This behaviour is due to tradition, convenience, widespread promotion by the animal industries, lack of information about the treatment of farmed animals and lack of knowledge of non-animal alternatives. Vegan Australia believes that strong public education campaigns will be effective in rapidly changing people's understanding and behaviour.
The success of this community education should be regularly measured. We agree with the report's recommendation that "general attitudes to welfare be monitored (including through a large-scale survey conducted every few years)".
The phasing out of animal agriculture would be of great benefit to the environment in Australia. Some of the environmental benefits are listed below.
Vegan Australia supports Draft Recommendation 3.2 (native vegetation and biodiversity conservation) to the extent that the costs of native vegetation retention and regrowth should be borne by the community as a whole and not fall solely on the landholder.
It is very surprising that the draft report contains almost no mention of climate change or greenhouse gases and completely ignores the contribution of animal agriculture to global warming through greenhouse gas emissions. Global warming is the greatest threat not just to agriculture but to all life in Australia and should be of primary concern in this report.
For more information on the impact of animal agriculture on global warming please refer to The Low Emissions Diet: Eating for a safe climate by Paul Mahony.
In order to remove the possibility of conflict of interest, the body should only include those who represent the interests of animals. There should be no place for those who profit from the exploitation of animals. To give representatives of the animal agriculture industry any say in the body would continue the conflict of interest that occurs in the current ineffective process of setting animal welfare standards.
Currently most members of advisory groups developing standards are representatives of the agriculture industry and departments of primary industries, whose principal objective is promoting the agricultural sector. As the draft report states "Animal welfare may be of secondary importance where the primary objective of the agency responsible for livestock welfare is to promote a productive and profitable agricultural sector." The report also mentions "concerns about significant input from bodies whose interests [are] described as 'essentially antagonistic' to those of animals."
The new independent body for farmed animal w
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