10 July 2018
Chief Executive Comment - July 2018
Since July 2016, when the RSPCA first launched their proposed revisions to their laying hen standards, I have worked hard to make sure that the Farm Animals Department understood and took heed of members’ views of the new standards. In particular I have stressed the difficulties that many producers faced retro-fitting aerial perches into single tier houses.
As a result the RSPCA did provide more time for some industry consultation and made changes to some of the proposed revisions but maintained the most contentious revision of retro-fitting aerial perching. While most producers may be able to understand a standard that required new houses to incorporate aerial perching, very few flat deck producers understood the logic of retro-fitting them into houses for which they were not designed. Indeed it is virtually impossible to retro-fit them into some designs, for example in mobile houses.
We are now coming up to crunch time in terms of implementation. As we get closer to the deadline, some producers are being forced to give up looking after hens because they cannot see how to retro-fit perches to the defined criteria into their houses; others are looking to stop supplying RSPCA Assured packers and retailers and are finding other markets for their eggs; and others are converting to multi-tier systems. The final segment are still undecided about what to do.
I have written to Mia Fernyhough, of the RSPCA Farm Animals Department, to urge her to provide the support that these producers need to enable them to implement this new standard. These members tell me that RSPCA Assured assessors will not provide advice, when asked, as it conflicts with their auditing role, so it is up to the RSPCA Farm Animals Department to provide the resource to offer solutions as to how aerial perches can be installed when the structure of the house cannot support the weight of the extra perching and birds. For example, the aerial perching provision places a load of 2 tonnes per 1000 birds, and many house structures are not designed to take this extra weight. The ‘examples of perch placement’ diagram provided by the RSPCA (see next page) is helpful for perch design but does not explain how these perches can be supported within the structural constraints of many free-range sheds.
BFREPA is asking the RSPCA to provide the resource to show how to deliver this new standard that has been imposed on them. The RSPCA created this standard without taking heed of our views, so now we ask it to step up to the plate and provide the easy solutions that it claims are available. For example, BFREPA’s former Chairman, Roger Gent, has asked his assessor numerous times for advice from the Farm Animals Department and none has been forthcoming. He has been told that if he makes ‘an attempt to meet the criteria’ that this would be acceptable, but this makes a mockery of the standard and provides no certainty of passing a future audit.
My letter to the RSPCA asks it to provide formal time-limited concessions for those attempting to meet the standard, and derogations for those whose house structures are unable to take the loading for the health and safety of both birds and the farmer/staff. The types of flat deck housing that have health and safety issues include mobile houses, those with pan feeding systems, and those whose floors are supported by the house structure (suspended off the roof). If the RSPCA doesn’t have the time to see every single case with compliance difficulties, the standard should derogate in block for certain house types and structures, such as mobile houses.
All members with compliance difficulties should contact Mia Fernyhough, the RSPCA’s senior scientific officer, directly for support and advice in the first instance (please contact me for phone numbers or email addresses if you do not have them). If the RSPCA cannot provide a solution to your compliance issue, I recommend that you urgently request a derogation for the reasons explained above.