Mandatory Use of Closed Circuit Television in Slaughterhouses (England) Regulations 2018

Debate between Lord Curry of Kirkharle and Lord Campbell-Savours

Tuesday 27th March 2018 Grand Committee

[Lord Campbell-Savours (Lab)]

My Lords, first, I will deal with the issue of cost. The costs of the CCTV equipment have dropped dramatically over the past seven or eight years. In many areas, they are a quarter of what they were. So it is quite probable that the estimates that have been given by the Government are not accurate, even though the ones that were given in Scotland will have been accurate at the time.

What drew me to this issue was paragraph 42 of the FAWC report of February 2015, where it says:

“Where examples of animal abuse have been brought to light … FBOs, AWOs and OVs”—


that is, food business operators, animal welfare officers and official veterinarians—

“have consistently asserted that they were unaware of such abusive practices”.

That is a shocking statement. Professionals went into slaughterhouses where the law was being breached, yet they were unaware of what was going on. I congratulate the Government on bringing in this extremely important measure, which I warmly welcome. I also welcome the policy position of my own party on this matter: the document produced by Sue Hayman, our spokesperson in the other place, which has come up with some fairly radical measures to deal with this problem in slaughterhouses.

In addition to that concern, I noticed in the Explanatory Memorandum the following statement, in paragraph 8.1, under the heading “Consultation outcome”:

“The responses from slaughter industry bodies and abattoirs were more balanced”—


when I hear those words, I always think, “Oh yes, here it comes”—

“with a number arguing against the proposal on the basis of proportionality of application of the requirements to all slaughterhouses regardless of size or record of compliance and the length of time records should be retained for”;

in other words, there was opposition. I would like to know what the scale of the opposition was. Perhaps it is reflected in the fact that, as we were told before, only 50% of slaughterhouses have even introduced these cameras. In the case of the ones that have introduced them, we are told, as I think the Minister alluded to, in paragraph 7.1 of the Explanatory Memorandum:

“Moreover, those slaughterhouses that have installed CCTV have not generally installed cameras in all areas where live animals are kept and where animal welfare could be compromised”;


in other words, there is a real problem out there and I regard these regulations as a good attempt to deal with it.

However, I have one or two concerns. One is about the retention of documentation. The committee recommended three months. In this measure, is it nine months?

[Lord Curry of Kirkharle (CB)]

It is 90 days.

[Lord Campbell-Savours]

Oh, it is 90 days. So basically we are talking about three months. So the Government followed that recommendation. But I wonder why not five years? We are talking about equipment which produces a tiny disk, I presume—why not keep it long term, unless it deteriorates? If we are talking about prosecutions, we may need more evidence than simply one or two occasions. It might be that consistent breaches can be revealed only in the event that there is far longer retention of the tapes in question. So I suggest not 90 days but five years—let us really retain this in case we have to prosecute.

Another issue that interests me is the question of visits. I heard someone refer earlier to a charge of £80 an hour for veterinarians to visit. I presume that there must be many slaughterhouses that rarely get a visit, if visits are charged up to them. Why do we not have more impromptu visits? So many visits in such areas are never impromptu. I remember when I was dealing with nursing homes some years ago, we found out that the managers were often informed in advance of when the so-called impromptu visits by the Care Quality Commission, or its predecessor, would be made. I presume that in these cases, too, information may well be provided to a slaughterhouse that there will be a visit by a veterinarian officer, charging for his services at £80 or £90 an hour. I would like more impromptu visits to these places. Then they would be more on guard against potential abuses.

Under “notices”, the regulations say:

“Any notice required or authorised to be served under these Regulations on any person may be served by … delivering it to the person; … leaving it at the person’s proper address; or … sending it by post to the person at that address”.


Can we presume that there are no options? In the case of slaughterhouses, a number of routes could be used to ensure that they actually received the notice. If the attitude of slaughterhouses is as my earlier quotation from paragraph 42 of the report suggests, it seems that there will still be some resistance in the industry.

As in all such cases, even with the presence of cameras, people will try to find their way round the regulations in some way. They may perhaps even position the cameras in such a way that they do not fully reveal what is happening in that slaughterhouse. Who decides where the cameras will be? Who decides whether a certain camera is going to point here or there? At the moment, this comes out only in the enforcement proceedings. I could not find anything in the proposed arrangement that said that the authorities—I presume that would be the veterinarians—would tell people where to put the cameras to ensure maximum coverage. There was one reference to requiring,

“any person to produce or make available for inspection any images or information retained and stored”,

and making,

“any enquiries, and take recordings or photographs”.

There is nothing really, although there is something about requiring,

“any person to provide such assistance, information, facilities or equipment as is reasonable, without delay”.

There is nothing about directing slaughterhouse owners to use the equipment in a particular way so that it will reveal fully what is going on. That is a bit loose in the regulations.

Perhaps, in winding up, the Minister can give us an assurance that that will be dealt with, and that more than guidance will be given. There should be requirements; there should be some sort of arrangement whereby, at the beginning of this process, people are required to place the cameras in a particular position so that there is no avoidance of what is intended under the law.

I have the FAWC recommendations here. They start in paragraphs 90 to 94, and there is then more detail. I want to go through them briefly. I am sorry if I am delaying the Committee. I normally speak quite briefly in such Committees, but I want assurances that all this is being implemented—that there has not been a selective acceptance of what is required. They say:

“CCTV systems should be installed in all live animal areas within the slaughterhouse including those used for unloading, lairage, moving live animals through the facilities, stunning and killing”.

I think the Minister said that before, but I was not absolutely sure whether a word or two had been missed. I would like an assurance that that will be the case—that that recommendation has been accepted. The recommendations continue:

“CCTV … should be recorded at all times when animals are present in the areas listed above … CCTV … should be installed so as to permit a clear and uninterrupted view of the processes being recorded at all times … Cameras should be installed in a manner that facilitates easy access and repair … CCTV cameras should record continuous visual images but, if audio is captured, should not record conversations between slaughterhouse personnel … footage should be viewed, whether in real-time or from recording, from designated areas that permit detailed review”.


I will stop at that point.

Can I assume that civil servants, in reviewing the debate, will go through that list of FAWC recommendations as a checklist from paragraph 90 right through to paragraph 101 and give us an assurance that they intend to implement every one of those recommendations fully? We will know then if any of the FAWC recommendations have not been accepted and that they will be subject to further scrutiny, perhaps at a later stage.

Finally, I repeat that I thoroughly welcome this. I think it will be one of the big changes from this Government. To some people it might not seem important but for people outside, animal welfare is a huge issue, as we know. I believe that if this policy is managed, organised and implemented properly, it will be a feather in the Government’s cap.

Water Bill

Debate between Lord Curry of Kirkharle and Lord Campbell-Savours

Tuesday 8th April 2014 Lords Chamber

[Lord Curry of Kirkharle (CB)]

My Lords, I have some concerns about the amendment. If I can describe the noble Baroness, Lady Parminter, and the noble Lord, Lord Krebs, as friends, I hesitate to object to their amendment, but I have concerns. I declare an interest in that I was, until two years ago, a chair of an insurance company.

My concerns are around the following issues. First, as a policyholder contributing to the funds that will be accumulated to create Flood Re, I am concerned that some of my contributions will be used to create resilience measures—which are, I assume, measures to reduce the risk of flooding—for a select group of properties. That is not why we will contribute the funds.

[Lord Campbell-Savours (Lab)]

Does the noble Lord not accept that in the long term the insurance company will benefit because it will save money?

[Lord Curry of Kirkharle]

Perhaps I may respond to that as I work through my argument.

Secondly, identifying the properties that will be subject to this special treatment will require the wisdom of Solomon and might create division and resentment among other property owners who are not able to benefit from the resilience measures used.

Thirdly—here I have some sympathy with the comments made by the noble Baroness, Lady Parminter—Flood Re needs a strategy for the amount of reserves that will be appropriate and need to be built up to cover flood risk. A strategic approach to the amount of surplus required is important. It will be very difficult to determine what the reserve should be to cover flood risk over a period of years, but it is essential that a reserve is established to maintain adequate funds to cover significant flood risk.

Finally, my most important point—I respond here to the comments made by the noble Lord, Lord Campbell-Savours—is that, as a policyholder, I do not want to continue contributing to a fund that has established a significant surplus. Once the surplus has been determined and achieved, I would hope that the Government and the ABI would have a mature discussion about reducing the contributions to the fund so that they do not establish an ever-increasing fund which may never be used. It would benefit the insurance companies if they did not need to continue collecting funds to contribute to this reserve. Resilience measures are essential and should be taken as properties are restored after flooding, but it is not the role of the fund to provide the resources to do that.