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

Lord Campbell-Savours Excerpts

Tuesday 27th March 2018 Grand Committee

[Lord Gardiner of Kimble]

I will of course address that. I am grateful to my noble friend.

FAWC also identified the significant benefits of CCTV systems to slaughterhouse operators, from in-house review of their operations and effective staff training to providing evidence of due diligence, which can increase public confidence in the meat industry and its adherence to the UK’s high animal welfare standards. FAWC’s report provided a useful basis for the Government’s proposals on mandatory CCTV which we published last summer. We received nearly 4,000 responses to this public consultation, with more than 99% in favour of mandatory CCTV recording in all slaughterhouses.

These regulations will require all slaughterhouse operators to install and operate a CCTV system that provides a clear and complete picture of areas where live animals are present. This will include where animals are unloaded, lairaged, handled, restrained, stunned and killed. We would expect CCTV installations and their use to be proportionate to the size of premises and their throughput. Slaughterhouse operators will be required to provide access to CCTV recordings for the official veterinarian of the Food Standards Agency and other authorised inspectors. An official veterinarian is required in every slaughterhouse when in operation. Access to CCTV recordings for monitoring, verification and enforcement purposes is essential and will be especially useful where the official veterinarian is undertaking other duties in the slaughterhouse and does not directly witness an incident.

We would expect official veterinarians to carry out a timely review of CCTV to address any immediate welfare incidents and take advisory or enforcement action. Nevertheless, the slaughterhouse operator will need to retain recorded images and information for 90 days. This is in line with the requirements of some farm assurance schemes. While CCTV should not replace, reduce or be considered a substitute for the current inspection and control of slaughterhouse practices by official veterinarians, access to CCTV recordings will provide more opportunities to assess compliance with animal welfare requirements on a proactive and reactive basis. Requirements for mandatory CCTV recording should be applied to all approved slaughterhouses on the basis that all animals should be offered the same level of protection at the time of killing.

Ninety-five per cent of our meat is killed in abattoirs which have CCTV in some form. The regulations ensure that all slaughterhouses of whatever size must now have CCTV at all stages of the process.

[Lord Campbell-Savours (Lab)]

My Lords, I am sorry to intervene, but I want to clarify something at the beginning of the debate. The Minister said that the Government expected the arrangements to be “proportionate”. Can he explain what “proportionate” means, because it might worry some of us?

[The Deputy Chairman of Committees (Viscount Ullswater) (Con)]

My Lords, it may be for the convenience of the Committee if the Minister introduces the regulations. I can then put a Question to the Committee and we can have a debate.

[Lord Campbell-Savours]

Sometimes a debate is helped by an early intervention on the Minister.

[Lord Gardiner of Kimble]

My Lords, I would like the opportunity of finishing these remarks. I am afraid that I am not acquainted with the practice of not permitting a Minister to introduce regulations. I will be more than pleased to receive comments when I have unfolded the argument. That helps the flow for the Minister. My task is to give a respectable introduction, deploying all the points of the regulation. I will then of course be very pleased to answer the questions that come from it.

We are conscious that some of the businesses that will be affected by this legislation are small, so we thought it appropriate that the regulations should allow six months for them to become compliant. In view of the considerable gains to animal welfare and the many other benefits identified, particularly for the slaughterhouse operator, the Government consider that the benefits justify the costs involved and do not deem financial support to the sector to be borne by the taxpayer.

This legislation will introduce mandatory CCTV recording in all 270 slaughterhouses in England as an additional monitoring and enforcement measure to ensure that animals are spared avoidable pain, distress or suffering during the slaughter process in all approved slaughterhouses. These regulations form part of an important package of reforms that the Government are delivering to improve animal welfare, such as the new system of local authority licensing of activities involving animals and the publication of updated animal welfare codes of practice. The regulations are proportionate and targeted, and will help to improve animal welfare at slaughter.

These regulations have been widely welcomed. Indeed, following our recent announcements, I have heard from a number of farmers who are pleased that we have ensured a respectful end for the animals they have cared for throughout their lives. These regulations will also assist the Food Standards Agency, which has been most supportive, as has the British Veterinary Association as well as a large number of other interested parties. I want to emphasise once more that the regulations will work in the interests of the slaughterhouse operator. It is the case that many people will be reassured that with the enforcement of these regulations, animals are much more likely to reach the end of their lives in a manner which shows them respect.

Many noble Lords along with many Members of the other place have been extremely supportive of these measures. For all those reasons, I endorse the regulations. Again, they are proportionate. I have mentioned specifically that for smaller slaughterhouses, the extent and cost of their installations will clearly be less than those for larger enterprises with no CCTV provision. Again, 95% of our meat is killed in abattoirs that already have CCTV in some form. For those operations, the regulations may be about updating or if necessary upgrading their systems so that all the stages of the process are covered. For those with no CCTV provision, it will be a cost, but the Government believe that this measure is in the interests of the sector. I commend the regulations to the Committee.

[Earl Cathcart (Con)]

My Lords, the Minister has already said why the voluntary take-up of CCTV has been disappointing. I am certain that this regulation will satisfy customers, consumers, retailers, certification/assurance scheme operators, NGOs and animal welfare organisations who have been pressing for CCTV in 100% of slaughterhouses. I should probably declare that I farm in Norfolk and we have livestock. We like to give all the livestock a really good life while they are with us on our farm, and when they go to meet their maker, we want that to be to the best possible standards, stress-free and humane. If that does not happen in slaughterhouses, perhaps CCTV will help.

I want to concentrate on two areas. The first is the cost and the second is the effective viewing or reviewing of the CCTV footage. I know that the Government think that the installation will cost only about £2,500 per slaughterhouse, but I think that is way too low. Even a small slaughterhouse needs about five CCTV cameras to ensure that all areas are covered. At £1,000 per camera, that alone will come to £5,000. I have been told that it will cost between £5,000 and £10,000 per slaughterhouse to install.

In 2012, it was reported in the Scottish Parliament that the cost of installing CCTV in a slaughterhouse in Scotland varied between £6,000 and £25,000. Whatever the cost, it will be considerably more than the Government’s £2,500. For small plants, that cost may be prohibitive, and that is not the only cost. There is also the annual cost of maintenance, which will vary according to the number of CCTV cameras and could be between £500 and £1,000 per annum. Then there is the cost of a secure, locked cabinet to store the 90 days of footage per camera to prevent tampering with the evidence. Then there is the cost of training and employing CCTV monitoring staff.

That brings me neatly to my second point: who, if anyone, will be viewing or reviewing the CCTV footage? Obviously where there is a known incident the relevant footage can be pulled out and looked at, but CCTV is really effective only if it is viewed or reviewed, and here is the rub. One of the limitations of CCTV is that it is rarely viewed or reviewed in a systematic, consistent and effective manner by the slaughterhouse operator, enforcement agencies or the official vet. If it were, considerable costs would be incurred in training the staff required to view the footage in real time—that is, as it is happening—or to review large amounts of footage from multiple cameras. Whether this is done by the slaughterhouse operator or the official vet, ultimately the cost will be borne by the slaughterhouse, which already balks at the hourly rate charged by the official vet—£70 to £80 an hour or around £600 for an eight-hour day.

Twenty years or so ago, there were probably six or eight slaughterhouses near my farm in Norfolk; now there is one large one quite near me. In the past 20 years, about 100 small slaughterhouses have shut down, as have a further 100 medium-sized ones. This does no good at all for the welfare of animals as they must now travel further to their final destination. I can understand the need for this regulation, but I hope that an unintended consequence will not be that more slaughterhouses have to close down.

[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.

--- Later in debate ---

[Lord Gardiner of Kimble]

My Lords, this has been a really worthwhile debate. I have learned a great deal about the intricacies of this matter from some of the experiences of noble Lords, but I repeat that we are absolutely clear that these regulations require all slaughterhouse operators to install and operate a CCTV system that provides a clear and complete picture of areas where live animals are present. To directly reply and reaffirm to the noble Lord, Lord Curry, this will include where animals are unloaded, lairaged, handled, restrained, stunned and killed. It is the complete operation within the slaughterhouse.

Some really fascinating questions have been asked and I will take them in the order they were asked. The noble Lord, Lord Campbell-Savours, encapsulated that this is a matter of zero tolerance, in which nothing can be as important as ensuring that welfare during the operation at a slaughterhouse is of the top order. I will not go into the other questions associated with this because they are not directly germane to the CCTV issue, but this is precisely the point that the noble Lord, Lord Curry, spoke about and that noble Lords alluded to. If this country wishes to have a recognition and a reputation for high animal welfare standards, this is precisely the sort of area where we can say to consumers at home and abroad that we are doing everything possible to assure them that the meat they consume is of the top animal welfare quality through our farm assurance schemes, that it is produced and lives a life to good animal welfare standards—in fact, above the norm of animal welfare standards—and that the animal has met its end in a proper and dignified and respectful manner. The contribution that these regulations make is that it will be absolutely clear to everyone, from the operators and everyone engaged through to the official veterinarian, and indeed to the person undertaking the work, that this really is of prime importance.

For instance, the noble Lord, Lord Campbell-Savours, asked who would decide about the positioning of the cameras. FSA official vets will discuss with operators where the cameras should be sited in order to meet the requirements set out in Regulation 3(1) which states that the CCTV system must provide,

“a complete and clear image of killing and related operations”.

That is essential. The noble Lord, Lord Campbell-Savours, also talked about the FAWC recommendations being implemented. Those which were directed to the Government are precisely what is set out in the regulations and the guidance. They all address the challenges which have been posed to Government, which is why we are dealing with them today. I do not have in front of me the precise wording of the recommendations, but I identify what the noble Lord has said as being the very essence of the creation of these regulations. Let us remember that some of the FAWC recommendations were directed at the industry as well.

My noble friend Lord Cathcart asked about who will be viewing and reviewing. As a part of normal duties, official veterinarians will view about 10 minutes to 20 minutes of the footage, but I emphasise that the moment they think something needs to be looked at, they will be able to do so. The point of keeping these records is that they will be able to go back and review the situation. The FSA welfare assurance scheme will also review footage as part of any audit process, and the number of audits depends on the size of the operation.

[Lord Campbell-Savours]

The noble Lord is talking about viewing and reviewing the operation. There may be a dozen slaughtermen of whom just one has been identified as being at risk of bad practice. Surely a far more extensive backlog of material will be needed to nail that one slaughterman. You need to look at this selectively over a long period of time. That is the argument behind the 90-day period. It is not sufficient to gather enough material to identify one particular abuser of the law.

[Lord Gardiner of Kimble]

I understand the essence of what the noble Lord is saying. The FSA feels that 90 days is sufficient for its enforcement purposes. However, because I believe in zero tolerance in these issues, I contend that with all the CCTV provision, I expect that the official veterinarian will be able to identify someone who is not behaving properly very much earlier. The point about the 90-day period is that we are looking at the official veterinarian and the other means which I will come on to.

[Lord Campbell-Savours]

I am sorry to come back on this again, but I go back to my opening comments where I quoted from paragraph 42 of the FAWC recommendations which points out that in many cases the officials were unaware of what was happening in terms of animal abuse.

[Lord Gardiner of Kimble]

I understand that. It is why CCTV will cover all areas, and that will provide the extra scrutiny. The FSA and the official veterinarian will be able to enhance animal welfare and, if necessary, identify people in slaughterhouses who are not behaving properly. Obviously the CCTV will need to cover all areas of the operation and the official veterinarian will need to look at the footage. The whole purpose of this is to enable the official veterinarian to see when any elements of the operation are not being undertaken properly.

I think some of this will unfold in a way that I hope will satisfy the noble Lord that we are really keen to get this one properly sorted. As I say, the FSA will be viewing the tapes. The noble Baroness, Lady Jones of Whitchurch, and, I think, my noble friend Lord Cathcart may have raised this in terms of viewing the tapes. The FSA inspectors will include the OVs, meat hygiene inspectors and FSA auditors from the health and welfare angle. In addition, I will be mentioning random visits; it is somewhere in my papers.

The noble Lord, Lord Curry, asked whether it is an offence not to retain footage for 90 days. This is indeed an offence under Regulation 9(1)(b). The penalty for a breach is a fine of unlimited amount. I say to the noble Lords, Lord Curry and Lord Campbell-Savours, and a number of your Lordships who have raised this, official veterinarians must be on the premises at all times, but the FSA also undertakes random inspections and risk-based audit visits of slaughterhouses. So with the requirement of the official veterinarian being in place at all times, the random visits, the arrival of this new regulation and the work we will need to undertake in that respect, I believe this advances these points.