UK: Defra’s interpretation on WATOK 1099/2009 for Kosher and Halal slaughtering.

By Naved Syed, Yorkshire Asian Business Association

The important points that all slaughterhouse’s want to affirm is that the industry wants to be able to Sheepconduct ALL LEGAL FORMS OF SLAUGHTER in the BEST WELFARE-FRIENDLY WAY POSSIBLE without being prevented from doing so by the way the law happens to be worded or happens to be interpreted regarding the V restrainer.

Natural behaviour of sheep & V-Shaped restrainers

Some of the important points to note about the sheep’s natural behaviour and restraint, particularly in an abattoir environment.

1.       Sheep are prey animals, with prey instincts, so they always try to escape from any perceived threats.
2.       They are flock animals that like being together. Isolation causes them incredible stress, agitation and anxiety as it puts them in danger of being targeted by predators. Flocking provides a greater sense of security and comfort for the animal.
3.       Experienced sheep handlers use the sheep’s field of vision, prey instinct and flocking nature to guide sheep to where they want them to go. By standing in the correct position and providing the sheep with a visual exit to ‘escape’ from the human ‘threat’, sheep can easily be moved to where they are required with minimal, if any, physical handling.
4.       In an abattoir environment the objective is to take advantage of the sheep’s natural behaviour as much as possible so that the sheep move themselves into the target space, whilst minimising manual interventions by the handler/handlers. As well as minimising sheep stress, this also reduces handler fatigue and frustration, which in turn reduces the risk of potentially increased interventions as fatigue sets in later in the operative’s shift. Good lairage design and a clear ‘escape’ path for the sheep make it much easier for the animal and the operative.
5.       The V-shaped Restrainer is the best welfare-friendly restraint system for sheep that is commonly used in most slaughterhouses across Europe and certainly in all slaughterhouses of significance, as well as many large sheep farms here in the UK.

Defra (mis)interpretations

False arguments in Defra interpretation of WATOK 1099/2009

1.       Individual Restraint: “That animals must be individually restrained for slaughter without stunning and this means there can only be one animal in a restrainer”. This is a false interpretation. Multiple animals in a V restrainer are individually restrained i.e. they do not rely on other animals for restraint, they are restrained by themselves.
a.       By requiring one animal to be slaughtered in one restrainer Defra is deliberating obligating the need for multiple restrainers and thus a non-smooth transfer between a ‘feed’ restrainer from the lairage and a ‘slaughter’ restrainer in the killing area.
b.      If only one restrainer is used then the slaughterman being close to the lairage operative will increase the sheep’s ‘prey’ stress levels because there will be a reduced visual ‘escape’ (because the slaughterman is in the eye-sight of the sheep). The sheep will also not follow-on naturally into the restraint which would necessitate manual intervention to bring the sheep to the v-restrainer as the sheep will try to face as far away from the operatives as possible.

2.       Immediate Slaughter: “That animals must be slaughtered without stunning immediately they are put into restraint”. This again is a false interpretation. EU WATOK 1099/2009 preamble 32 simply says ‘However, restraining is likely to create distress to the animals and should therefore be applied for as short a period as possible.’ And Article 9 (3) says ‘Business operators shall ensure that animals are not placed in restraining equipment, including head restraints, until the person in charge of stunning or bleeding is ready to stun or bleed them as quickly as possible.’ There is no requirement for ‘immediate’. This requirement, which does not seem to be currently enforced, means it is no longer legal to have a feed restrainer and a slaughter restrainer and instead you can only have one restrainer, and the sheep must be slaughtered immediately after it is in restraint. As in point 1b above, this increases sheep stress levels.

3.       EU law: Defra is implementing EU law claiming they have no choice in ‘individual restraint’ or ‘immediately’. However this is false because other EU states such as Ireland, Spain and France who also implement the same legislation allow multiple animals in the v-restrainers. Therefore it is NOT an EU requirement but a Defra interpretation that is the problem. Secondly, in my opinion there is an agenda from Defra to curb Kosher and Halal slaughtering for the Jews and the Muslim community through the back doors.