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Dear Sir/Madam

CONSULTATION ON A PROPOSAL FOR A COUNCIL DIRECTIVE ON THE WELFARE OF CHICKENS KEPT FOR MEAT PRODUCTION

I am writing to invite your comments on the enclosed EU proposals for a Council Directive on the welfare of chickens kept for meat production.

I also attach a list of consultees and an initial Regulatory Impact Assessment ( RIA).

General welfare legislation applies to meat chickens but the meat chicken sector is a major area of intensive livestock production not so far covered by the species-specific programme of EU farm animal welfare standards.

The European Commission has put forward a new proposal introducing improvements in the welfare of intensively farmed chickens by means of technical and management requirements including enhanced monitoring on the farms and an increased flow of information between the producer, competent authorities and the slaughterhouse, based on welfare-specific monitoring of the flocks after slaughter.

It sets conditions for the keeping of chickens for meat production from the time chicks are brought to the production sites until they leave for slaughter. It does not cover parent flocks nor brooding and hatching of chicks. The proposal focuses on the welfare problems in intensive farming systems with a minimum threshold of 100 chickens.

Luxembourg held a working group meeting on the proposals on 14 June. The first working group during the UK's Presidency of the EU Council of Ministers was held on 14 July with further meetings envisaged from September through to the end of the year. Although we have provided a 12 week consultation period, it would be helpful if comments were received as soon as possible so as to allow us to consider them before the working groups start up again after the summer break.

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Proposal for a COUNCIL DIRECTIVE laying down minimum rules for the protection of chickens kept for meat production
europa.eu.int/eur-lex/lex/LexUriServ/site/en/com/2005/com2005_0221en01.pdf

We would particularly like your comments on the following questions but please do not restrict your response to just these points. We are interested in your views on the whole proposal, and the RIA.

• Would you prefer the proposal to be a Directive or Regulation?
• Do you agree with the stocking density levels of 30 and 38 kilogrammes liveweight per square metre?
• What are your thoughts on the proposed light regime?
• What monitoring arrangements should take place at the slaughterhouse?
• How should the Competent Authority manage the obligation to follow up slaughterhouse reports in practice? Could the current proposal be streamlined?

Responding to this consultation paper

We are inviting written responses to this consultation paper by 14 October 2005. Please send your response to Pam Kennedy by post to Room 350, at the above address, by email toPam.Kennedy@scotland.gsi.giv.uk or by fax to 0131 244 6616. If you have any queries contact me on 0131 244 6117. or by fax to 0131 244 6616. If you have any queries contact me on 0131 244 6117. or by fax to 0131 244 6616. If you have any queries contact me on 0131 244 6117.or by fax to 0131 244 6616. If you have any queries contact me on 0131 244 6117.

This consultation, and all other Scottish Executive consultation exercises, can be viewed online on the consultation web pages of the Scottish Executive website at http://www.scotland.gov.uk/consultations. You can telephone Freephone 0800 77 1234 to find out where your nearest public internet access point is.

The Scottish Executive now has an email alert system for consultations ( SEconsult: http://www.scotland.gov.uk/consultations/seconsult.aspx). This system allows stakeholder individuals and organisations to register and receive a weekly email containing details of all new consultations (including web links). SEconsult complements, but in no way replaces SE distribution lists, and is designed to allow stakeholders to keep up to date with all SE consultation activity, and therefore be alerted at the earliest opportunity to those of most interest. We would encourage you to register.

Handling you response

We need to know how you wish your response to be handled and in particular, whether you are happy for your response to be made public. Please complete and return the Respodees Information Form which is enclosed with the consultation paper/attached to this letter as this will ensure that we treat your response appropriately. If you ask for your response not to be published we will regard it as confidential, and we will treat it accordingly.

All respondents should be aware that the Scottish Executive are subject to the provisions of the Freedom of Information Scotland Act 2002 and would therefore have to consider any request made to it under the Act for information relating to responses made to this consultation exercise.

Access to Consultation Responses

We will make all responses available to the public in the Scottish Executive Library, unless confidentiality is requested. All responses not marked as confidential will be checked for any potentially defamatory material before being logged in the library or placed on the website.

Other Information

If you are aware of any other organisations or individuals who might be interested in seeing and commenting on this letter but who have not received it, please contact me on the above telephone number and I will arrange for a copy to be sent to them. If you have any questions relating to this consultation exercise, please do not hesitate to contact me.

We look forward to hearing from you.

Yours faithfully

ALLAN MCFARLANE
Animal Welfare Branch

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Scottish Conservative and Unionist Party
Scottish National Party
Scottish Liberal Democrats
Scottish Labour Party
Scottish Green party
Eric Liddell Centre
Catholic Parliamentary Office
Actions Against Churches Together in Scotland
Church of Scotland
Scottish Churches Parliamentary Office
Scottish Executive Library
Rural Development Committee
Port Administration Building
Scottish Parliament, European Committee 5.22
Scottish Inter Faith Council
Convention of Scottish Local Authorities
Scottish Egg Producer Retailers Association
British Society of Animal Science
Poultry Club of Great Britain
Scottish Agricultural College, Ayr
Grampian Country Chickens (Rearing) Ltd
Institute of Animal Physiology & Genetic Research
Scottish Homing Union
Scottish Rural Property & Business Association
Mr E Shamash
Daylay Foods Ltd
Grampian Country Food Group Ltd, Banff
Moredun Research Institute
University of Glasgow, Veterinary School
Scottish Agricultural College, Aberdeen
Royal Highland & Agricultural Society of Scotland
Scottish Agricultural College, Penicuik
Muirfield Hatchery
Crofters Commission
British Falconers Club (Scottish ranch)
Scottish Women's Rural Institute
Scottish Agricultural Organisation Society Ltd
Women's Farming Union
National Farmers Union of Scotland
Highland and Islands Enterprise
Royal Environmental Health Institute of Scotland
The Hawk Board
E & O Farms
Poultry Health Services
World of Wings
Strathblane Falconry
Scottish Society for the Prevention of Cruelty to Animals
Scottish Agricultural College, Edinburgh
Institute of Auctioneers and Appraisers in Scotland
British Veterinary Association (Scottish Branch)
Scottish Consumer Council
British Poultry Council 2002
Lantra
Rowett Research Institute
Royal (Dick) School of Veterinary Studies
Ostrich Kingdom Ltd
Glenrath Farm
Poultry First
Grampian Country Food Group Ltd
Royal Society for the Protection of Birds Scotland
Kezie Limited
Game Conservancy Trust
Joseph Mitchell (Letham) Ltd
Scottish Academy & Falconry Related Studies
British Domesticated Ostrich Association
Q-One Biotech Limited
Aviagen Ltd
Aberdeenshire Poultry Ltd
Brochneil Farm
Grampian Country Foods
Deans Foods Ltd
Hamish Morison Farming Ltd

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1. Title of Regulatory Proposal

1.1 Proposal for an EU Council Directive laying down minimum rules for the protection of chickens kept for meat production.

2. Purpose and Intended Effect

(a) Issue and Objective

Issue

2.1 General welfare legislation (Council Directive 98/58/ EC transposed through the Welfare of Farmed Animals (Scotland) Regulations 2000 (as amended)) applies to all farm animals. On top of that the EU has agreed specific rules for pigs, calves and laying hens. Meat chickens (broilers) are the last major intensive sector not to have their own rules and the Commission is aiming to fill the gap with this proposal. Diverging legislation and quality assurance schemes (containing certain welfare related aspects) exist at national level throughout the EU.

2.2 The EU Scientific Committee on Animal Health and Animal Welfare ( SCAHAW) published its report on the Welfare of Chickens Kept for Meat Production in March 2000. Since then, Expert and Commission working groups have discussed the framework for a draft proposal and the Commission has also undertaken a series of stakeholder consultations.

2.3 UK meat chicken production is expected to continue at around 850 million birds per annum for the next 2 years with a value of about £880 million per annum. So it is a significant economic activity and also important as one of the cheapest and most popular sources of meat protein for consumers. Chicken represents over 30% of meat sold by weight. A SEERAD Welfare Code for meat chickens was published in 2004.

2.4 The Farm Animal Welfare Council and welfare groups have long had concerns over the welfare of meat chickens. There is a history of skeletal, cardio-vascular, and skin problems, which they claim is associated with the intensive way they are kept, and modern genotypes which reach slaughter weight in 6 weeks as opposed to some 8 weeks twenty years ago. There is some truth to this, but in recent years the same breeding techniques which have improved growth rates have been used to address the genetic sources of skeletal and cardio-vascular problems. Improvements in nutrition and disease control and environmental control have also played a role in the improvement of welfare of broilers. Currently we assess the major problem in broilers as those associated with lameness and infectious disease.

2.5 Contact dermatitis, including pododermatitis and hock burn are commonly reported conditions in meat chickens which affect the skin covering the feet, ankle joint and the breast muscle respectively. In all these conditions the skin becomes hard and scaly, exhibiting discolouration and lesions or ulcers. These lesions cause pain and distress and, in conjunction with mortality rates, have been demonstrated to be indicators of poor welfare on farm. The State Veterinary Service carried out 471 welfare inspections on broilers and broiler breeders during the period 1 January 2002 - 31 December 2004. Of the eleven welfare criteria which are assessed during a welfare visit, the criterion "environment" is associated with the highest percentage of non-compliance and unnecessary pain and unnecessary distress. This criterion represents a broad category of issues but predominantly covers litter quality and lighting levels. Litter quality can often be associated with the severity and quantity of foot lesions.

2.6 Currently, broiler producers are required to submit health production reports with each consignment of broilers sent to slaughterhouses. The Meat Hygiene Service ( MHS) submit feedback reports to producers. However the content of such reports varies between slaughterhouses and generally does not contain prevalence data for contact dermatitis, unless a penalty is imposed. This has led to variation across the country with regard to how the problem of contact dermatitis is tackled.

Objective

2.7 The proposal lays down, for the first time, EU wide standards for the welfare of meat chickens. It attempts to address commercial issues with scientific evidence. It sets conditions for the keeping of chickens for meat production from the time chicks are brought to production sites until they leave for slaughter. It does not cover parent flocks nor hatching of chicks. The proposal focuses on the welfare problems in intensive farming systems with a minimum threshold of 100 chickens.

2.8 Two sets of standards are set using stocking density as a criterion for the level of intensity of production. Firstly, producers who stock up to a maximum of 30kg liveweight per m_ have to comply with standards relating to drinkers, feeding, litter, ventilation and heating, light, inspection, cleaning, record keeping and mutilations. Second, producers who seek to stock beyond a limit of 30kg liveweight per m_ (up to a maximum of 38 kg) will have to comply with an additional set of standards including an assessment of their production site, specific training requirements and a surveillance system based on welfare indicators collected at the slaughterhouse. This proposal builds on the new "farm to fork" EU Hygiene Regulations which provide a framework for the collation and sharing of data between farms and slaughterhouses. It allows the competent authorities (i.e. the central authority of a Member State competent to carry out veterinary or zootechnical checks or any authority to which it has delegated that competence) to use this data to monitor and where necessary improve on farm welfare by optimising the feedback of welfare information collected at the slaughterhouse.

2.9 If adopted, we will be required to introduce implementing legislation, which will apply to establishments keeping chickens for meat production. It will not apply to establishments with less than 100 meat chickens or those keeping breeding stocks and hatching broilers. This assessment is, therefore, based on the impact of the proposals as they relate to the commercial production of chickens for meat for human consumption.

(b) Risk Assessment

2.10 The risk in this context relates to the public concerns about the welfare of broilers and the need for a level playing field for producers. There are currently around 850 million chickens produced for meat in the UK each year.

2.11 In 2004, Compassion In World Farming ( CIWF) challenged the implementation and enforcement by Defra of the general animal welfare Directive 98/58/ EC and its impact on the welfare of meat chickens, particularly in respect of fast growing genotypes and restricted feeding practices for broiler breeders. A Judicial Review and subsequent Appeal both found in favour of Defra. However, campaigns continue both through CIWF and the RSPCA as well as regular correspondence from the general public.

2.12 A variety of voluntary and legislative standards exist for broiler production within the EU. Minimum standards legislation would avoid potential distortion of conditions of competition and ensure the smooth running of market organisation and fair competition.

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3. Identify Options

3.1 Option 1: Do nothing: Difficult, both from a Presidency and welfare perspective. The Commission will look to the UK to take forward this proposal during its Presidency and we would be criticised, [particularly by welfare groups,] if we were to hold up negotiations. There are some welfare concerns associated with intensive broiler production and these will not be resolved through existing legislation and Codes.

3.2 Option 2: Non-statutory approach: The broiler market is highly competitive and there are commercial pressures to produce broilers at the expense of welfare. Member States have different ways of controlling broiler welfare. There have been attempts to harmonise standards through the private sector by voluntary schemes such as Freedom Foods, Assured Chicken Production and organic schemes. UK producers could be placed at a disadvantage if an EU wide level playing field is not established.

3.3 Option 3: Proposal: The impact on the industry and the welfare benefits of the proposals are currently being assessed through two separate pieces of work. Administrative and enforcement systems and costs are also being considered.

3.4 Option 4: Proposal plus changes: We can look to amend the proposals in respect of mortality rates and light/dark periods, and administration and enforcement aspects with a view to introducing a regulatory system with the lightest possible touch, based on an ethos of education and discussion. If the higher stocking density figure decreases significantly, the cost of the proposals may increase with limited welfare benefit.

3.5 Option 5: Proposal plus role of Assured Chicken Production: A possible role for the private voluntary Assured Chicken Production Scheme in assessing the density at which producers can stock is being considered. This would avoid unnecessary duplication of inspection and visits to producers and fits well with the partnership theme of the Animal Health and Welfare Strategy and aspects of biosecurity.

3.6 Option 6: Gold plating: The proposals are minimum standards. Member States can take more stringent measures. Therefore, we could over implement the proposals when transposing into national legislation. However, we have no intention of "gold plating" this EU legislation.

4. Costs and benefits

4.1 It is important that the costs and benefits of the proposals are fully appraised before a final recommendation is made. Costs to industry are currently being analysed in a joint study by Exeter University and ADAS. The non-market benefits accruing to the public from differing levels of improved broiler welfare are being analysed in a separate study which will be completed by September. Information gained from the public consultation exercise will also be considered.

4.2 The following discussion of costs and benefits considers the general issue of improving broiler welfare standards, since at this stage it is not possible to quantify the differences between the options. Once rigorous cost and benefit information has been gathered, a preferred option can be recommended whereby the benefits are commensurate with the costs.

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5. Business Sectors affected

5.1 It is estimated that there are approximately 1,800/2,000 establishments with meat chickens in the UK and currently, over 800 million chickens are produced for meat in the UK each year, of which:

• Approximately 4 % are produced at stocking densities below 30kg/m_ - these establishments would need to comply with the minimum standards.
• Approximately 80% are produced at stocking densities between 30kg/m_ and 38kg/m_ - these establishments would need to comply with the enhanced standards.
• Approximately 16% are produced at stocking densities above 38kg/m_ - these establishments would need to reduce stocking density and comply with either the minimum or enhanced standards.

6. Costs

Economic

6.1 In a report in 2000 ¹ the Scientific Committee on Animal Health and Animal Welfare presented a basic model based on French production systems which estimated the costs of complying with various welfare standards. The model predicts that a typical producer's total costs can be expected to rise by around 5% if they move to a stocking density of 30kg. However, this is likely to be a high-end estimate of the impact of the Directive since holdings may opt for the higher stocking density. An estimate of 2% average increase in total costs is a more reasonable estimate.

6.2 A study by Exeter University provides a basis for assessing the cost implications in England. If producers' costs across England increase by 2%, based on an average producer output of 650,000 birds ², the cost per producer of new welfare standards would be around £15,000 a year. The cost to the broiler industry as a whole is likely to be between £15M and £20M per year.

Social

6.3 We will consider any potential negative impact on the number of people employed in the industry including differential impacts on different groups (e.g. part-time and female employees), and any significant impact on the welfare and conditions of employees e.g. difficulty in handling birds. Any social issues arising in relation to compliance and conflict will be considered.

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Environmental

6.4 It can be seen from the Exeter University study that a combination of possible reduced stocking densities, combined with additional requirements relating to temperature control and ammonia emissions could lead to a need to expand housing capacity if the industry is to maintain current production.

6.5 The additional housing capacity could come from either extensions to existing broiler housing, from new broiler housing development on green-field sites, or from a combination of both.

6.6 Extensions to existing buildings, whilst probably cheaper are not always possible. The layout and fabric of some existing buildings do not easily lend themselves to being extended, and in some instances, physical restrictions place a barrier in the way of extension.

6.7 In many instances, therefore, the preferred choice is to build a new purpose-built building to house the additional birds. Planning controls are in place to ensure that the negative environmental impacts of new poultry buildings are minimised. For example, the impact of new buildings on the landscape will be minimised through appropriate siting and screening measures aimed at blending the structures into the landscape. However these controls do give rise to administrative costs which must be taken into account.

6.8 Overall, there could be an increase in the use of electricity and gas in the UK broiler industry through the introduction of the Directive. However, the increase is likely to be relatively small - perhaps less than a 5% increase. If more energy is being consumed, it can be assumed that there will be a very small increase in the emission of greenhouse gasses.

6.9 Climate change may affect the impact of the Directive. For example, with potentially hotter summers, an increasing number of poultry buildings could face difficulties in complying with the Directive requirement of a maximum 3 degrees centigrade differential between indoor and outside temperatures, when temperatures outdoors are in excess of 30 degrees centigrade. If these predicted rises in summer temperatures do actually occur, an increasing number of poultry houses, particularly the older designs of house with less sophisticated ventilation equipment, could struggle to meet the "temperature lift" requirements of the Directive. On the other hand, if global warming only gradually occurs over an extended time-frame, the industry's difficulty in coping with the temperature requirements of the Directive will be minimised, as new buildings with more sophisticated ventilation and cooling will gradually replace the older, outdated, buildings.

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7. Benefits

Economic

7.1 If successfully negotiated, the welfare of chickens kept for meat will achieve the higher standards expected in the UK without our producers being disadvantaged by imports produced to lower standards elsewhere in Europe.

7.2 Consumers will have greater reassurance as to the welfare standards, which have been applied in the production of chickens for meat. The welfare of broilers can be considered more widely as a public good. It is important that the value of this public good is estimated, and this will be done by carrying out economic analysis to elicit the public's "willingness to pay" for welfare improvements. This is likely to be a significant benefit which will accrue to the public, and particularly to those members of the public who are most concerned with broiler welfare. We have commissioned research to quantify the benefits of alternative levels of broiler welfare and to assess the extent to which they might be reflected in market prices.

7.3 A recent Eurobarometer survey on Attitudes of Consumers towards the Welfare of Farmed Animals, found that laying hens and meat chickens were the species for whom respondents wanted most to improve current levels of welfare and protection.

Social

7.4 Results from the benefits project work (above) will provide evidence to quantify and value the animal welfare impact of the proposals, which is categorised as a social benefit.

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Environmental

7.5 There is a very small possibility that wildlife habitat could be improved if ammonia levels within the poultry houses are reduced as a result of the regulation.

8. Issues of Equity or Fairness

8.1 The fundamental principle underlying these proposals is the need to be 'fair' to farm animals (in this case chickens kept for meat production) and to protect their welfare.

8.2 Within this context, it is also necessary to take account of the fairness of imposing economic costs on the industry and on consumers, not all of whom are necessarily interested in or concerned about animal welfare and/or concur with the view that changing standards will bring welfare benefits. Individuals would be negatively affected if they do not value chicken welfare highly but do consume chicken and would pay higher prices.

8.3 The proposal will apply equally across all keepers of meat chickens in the EU. Those with fewer than 100 broilers or keeping breeding stocks and hatching broilers will be exempt from the terms of the Directive.

8.4 However, the proposal is for a two-tier system of minimum welfare standards based on stocking density. Minimum standards will apply to all establishments stocking to a maximum of 30kg/m_. For producers wishing to stock at levels above 30kg/m_ to an upper limit suggested at 38kg/m_, it would be necessary to meet enhanced welfare standards. Investigation is under way to identify the likely impact and business response, and whether any particular categories of producer would be more seriously affected.

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9. Small Firms Impact Test

9.1 Approximately 60-70% of broiler production is under the complete control of the processing companies, with production farms owned by the company and managed and run by company employees. Most of the remaining 30-40% of producers are individual growers supplying these same producers under contract ( UFAW Farm Handbook 4 ^th Edition). These individual growers will either own outright or rent their buildings. Any investments in building structure or equipment would normally be paid for by the individual grower. Whilst the processing companies will generally have more than 250 full time equivalent employees, virtually all of the contracted producers will fall within the small firms definition.

9.2 If the Directive increases the current costs of production, this could have a disproportional effect on small producers. A reduction in stocking density from the industry norm of 38 kg/m ², would lead to additional capital expenditure through the need to provide additional buildings if the producer wanted to keep the same number of birds, or a reduction in turnover if the producer achieved the reduction in stocking density simply by keeping less birds in the existing housing facilities. Production costs could also increase as a result of the need to install additional ventilation equipment to comply with the 3 degree temperature lift, for example. Gas and electricity usage could be slightly higher too, which also adds to the cost of production.

9.3 Given that margins are already very tight in the UK broiler sector (at around 3 pence per bird profit according to the University of Exeter - The Structure and Economics of Broiler Production in England 2002) (top third was + 10.9 pence, bottom third was - 5.3 pence) any increase in the cost of production would impose financial difficulties on producers. This could have a disproportionate effect on smaller producers who would not be able to take advantage of the benefits of scale that larger producers could use to drive input costs to a lower level to survive. A major concern expressed by non-company respondents (i.e. small firms) in the 2002 Exeter study was "profit margins insufficient to invest with confidence in the future."

9.4 Similarly, if large capital items were required to be purchased in order to comply with the requirements of the Directive, smaller producers may face more difficulties in financing any loans taken out for equipment purchase.

9.5 ADAS held a series of workshops in early 2004 with small and large broiler producers in order to gain their thoughts on the implications of the possible content of an EU Broiler Welfare Directive. Concern was expressed by smaller producers/contract growers that there simply was insufficient profit being made from broiler production in the UK to fund projects involving significant amounts of capital.

9.6 The work undertaken by Exeter University and ADAS will involve both small and large producers and will provide further opportunity to assess the impact on smaller producers. We will also be carrying out a 12 week full public consultation exercise.

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10. Enforcement, Monitoring and Evaluation

10.1 In order to ensure uniform application of EU legislation, the EU Commission has responsibility for monitoring enforcement by Member States. It is also required to draw up a code of rules to which Member States should adhere in carrying out inspections, including the form and contents of reports and the frequency with which they are submitted.

10.2 Member States are, in turn, responsible for taking the necessary measures to ensure that the competent authority carries out inspections to monitor compliance with the provisions of the Directive.

10.3 We are exploring with the SVS, MHS, EMI and Assured Chicken Production, ways to develop an effective strategy for practical risk based enforcement and surveillance of any new welfare output measures which minimises administrative burdens and avoids the creation of further red tape.

10.4 In most circumstances, advice and warnings with a timescale for compliance (followed up as necessary) will be given before a decision is taken to initiate prosecution action. The maximum penalty on conviction for an offence is £2,500 or three months in prison.

10.5 The effectiveness of national enforcement procedures is kept under review. Any evidence of failure to enforce in other Member States will be drawn to the attention of the Commission.

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11. Results of Consultation

11.1 A full public consultation will be conducted on the proposal, the results of which will help to further inform the Regulatory Impact Assessment. We have consulted previously within the broiler industry (directly and via the British Poultry Council), the RSPCA, breeding companies, the main delivery agents and the Devolved Administrations. We are also considering our engagement strategy on an EU basis not only with longer standing Member States but also with newer ones, in particular Hungary, Poland and the Czech Republic. We have met with the Commission, Council Secretariat and the Luxembourg Presidency. An initial briefing has been delivered to MEPs and we will meet with them again once the composition and rapporteur of the Agriculture Committee are known. We are in regular contact with UKREP.

12. Competition Assessment

12.1 More information on the structure of the UK Broiler industry would need to be collected before a thorough competition assessment can be carried out. In the UK the poultry meat industry is characterised by a high degree of concentration, with five companies controlling 80% of chicken production. At present, it is unclear whether the proposals will affect some firms significantly more than others, although the Exeter University/ ADAS study should allow an assessment to be made in this area. It is unlikely that there will be any extra set-up or ongoing costs to firms entering the industry when compared to the costs that existing firms will need to meet under the Directive.

12.2 The Exeter University/ ADAS study will help inform a more rigorous competition assessment to be made at a later date. We are also in discussion with OFT on this issue.

13. Summary and Recommendation

13.1 We welcome the draft proposals for a welfare Directive as an innovative and praiseworthy attempt to address a difficult issue of public concern. However, more information is required on the justification for some of the technical details and on the economic, compliance, enforcement and administrative costs in relation to the welfare benefits before we can draw a firm conclusion.

SEERAD ANIMAL HEALTH AND WELFARE BRANCH

July 2005

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1. " The Welfare of Chickens Kept for Meat Production (Broilers)" , Committee on Animal Health and Animal Welfare, March 2000

2. "The structure and Economics of Broiler Production in England" Andrew Sheppard, June 2004

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