According to the Victorian Minister for Agriculture, "animal welfare matters". If the welfare of animals really matters then the only way to stop the suffering of the over 100 million animals bred and killed in Victoria each year is to stop farming them.
In its submission on Victoria's draft Animal Welfare Action Plan, Vegan Australia has recommended that the best way to improve animal welfare in Victoria is to phase out animal agriculture in ten years. Read the full submission below.
Submission on Victoria's Animal Welfare Action Plan
Vegan Australia is pleased to have the opportunity to provide a submission in response to the draft Animal Welfare Action Plan published by the Victorian Government Department of Economic Development, Jobs, Transport and Resources. We hope this submission assists the Department in preparing the final action plan.
Vegan Australia is a national organisation that informs the public about animal rights and veganism and also presents a strong voice for veganism to government, institutions, corporations and the media. Vegan Australia envisions a world where all animals live free from human use and ownership. The foundation of Vegan Australia is justice and compassion, for animals as well as for people and the planet. The first step each of us should take to put this compassion into action is to become vegan and to encourage others to do the same. Veganism is a rejection of the exploitation involved in commodifying and using sentient beings.
This consultation is an opportunity to reflect on our use of animals in a number of areas. In our submission we focus on the farmed animals used in the agriculture industry. The majority of the suffering and death of animals in Victoria occurs in the animal agriculture sector, with about 150 million animals bred and slaughtered for food every year. This consultation is an opportunity to consider alternative ways we can obtain food and fibre which do not involve the unnecessary suffering and killing of farmed animals.
It is important to emphasise that farmed animals suffer pain and their lives extinguished to produce products that are not necessary for human wellbeing. All these products, including those for food and clothing, can be replaced by plant-based products.
Animals are not ours to use. They value their own life and body and have an interest in continuing their existence and avoiding suffering. They should be treated with respect and justice and should not to be treated merely as commodities. Further, production of animal products necessarily results in their suffering and death.
In addition, humans have no need for any animal products and in particular are able to live healthily on a vegan diet. In fact, many people who adopt a nutritious vegan diet will enjoy significant health improvements by reducing the risk of major killers such as heart disease, stroke, cancer and diabetes and reducing the health care burden from these chronic diseases.
In this submission, Vegan Australia attempts to show two things. First, that any agricultural system that uses animals will cause suffering to those animals. And second, that humans do not need to consume any animal products, as has been shown by extensive research in nutritional science.
We also propose significant changes to the agricultural system in Victoria. We believe that these proposals are in the best interest of animals and are within the scope of the Animal Welfare Action Plan and we provide evidence to support our views.
We are encouraged by the opening words of the draft action plan, "Animal welfare matters", and the statement by the Minister for Agriculture Jaala Pulford that animal welfare is a high priority for the Victorian Government. As she states, "We all have a moral and ethical responsibility, as part of a fair and caring society, to ensure we have high standards of animal welfare."
We also welcome the acknowledgement in the draft action plan that animals are sentient. There is a growing body of evidence that all animals, including mammals, birds and fish are sentient, that is they experience the world and have the ability to perceive and to feel pleasure, pain and a variety of emotions, both positive and negative.
The goal of the Animal Welfare Action Plan
The draft plan states that it is important to protect animals. In the interests of best protecting animals, we propose that the goal of the Animal Welfare Action Plan should be the abolition of the use of animals, whether for food, fibre, entertainment or experimentation.
The end goal of animal welfare regulation should be ending all animal use by humans, in particular ending animal agriculture. This should be specified in the action plan, which should also set out steps for the complete phasing out of animal agriculture in Victoria. It should also specify a time scale for this process. We propose that a ten year phase out period be set for the plan.
Recognition of the sentience of animals should be explicitly included and acted on in the plan, in a similar way to the New Zealand Animal Welfare Act which stipulates that it is necessary to 'recognise animals as sentient'. In other words, to recognise that animals can experience both positive and negative emotions, including pain and distress.
Ending the use of animals in agriculture will have the greatest benefit to the welfare of farmed animals. Anything less will mean their continued suffering and death. Our proposal is based on science and ethics as we discuss below.
While focused on strengthening the Prevention of Cruelty to Animals Act, the plan will also require a broader range of measures and will need to call on a number of government departments, including agriculture, planning, education and treasury, to ensure an orderly transition to a fully plant-based agricultural system. The plan should continue the research begun by Vegan Australia into how a phase out of animal agriculture would affect a number of sectors, including land use, the environment, the economy, employment and human health. An economic impact assessment should be carried out, looking at how to phase out animal agriculture with the least impact on the economy and employment. Note that the animal agriculture industry contributes only about 1.2% to the Victorian economy. Over a ten year phase out period, any dislocations should be manageable and alternative industries could be set up. While much work remains to be done in ensuring a smooth transition to purely plant-based agriculture, doing so would be of benefit to Victoria in the medium to long term, and, of course, of benefit to animals in the immediate term. See the research into moving to a vegan agricultural system carried out by Vegan Australia.
Any regulation impact assessment process to be carried out for the plan must include the impact on animals. Merely assessing the impacts on the humans affected by changes would ignore the intended beneficiaries of animal protection legislation.
Rationale for phasing out animal agriculture
The rationale behind the proposal to end the use of animals in agriculture is simply to avoid causing unnecessary suffering as much as possible.
All farmed animals suffer and they suffer in huge numbers. Currently over 100 million animals are bred and killed in Victoria each year. That's an incredible 200 animals per minute. Some of the suffering endured by farmed animals includes these standard practices: intensive confinement, use of invasive surgical procedures without anaesthetic such as castration, ear notching, beak trimming, teeth clipping and mulesing, sow stalls, farrowing crates, food and water deprivation during long painful transportation, forced impregnation, continual pregnancy of female pigs, branding, dehorning, use of electric prods, tail docking, declawing, gassing or macerating day-old "surplus" male chicks, light-deprivation, permanent confinement, separation of mothers and infants, being scalded or cut open alive on kill lines, living in their own excrement, breeding chickens to grow so heavy their legs break, breeding cows to have udders ten times natural size, and more.
After a life of intense suffering, all farmed animals are killed at a very young age, many as babies, drastically cutting short their normal life span. Each animal values their life and doesn't want to die. Even animals raised in "free range" systems suffer many of the same practices and end up at the same slaughterhouse. There is no such thing as the "humane slaughter" of an animal who doesn't want to die.
Breeding and killing farmed animals is not necessary. Humans don't need animal products to live healthy and fulfilling lives.
Wellbeing of farmed animals is not possible
The wellbeing of animals and their commercial use in agriculture are incompatible.
Farmed animal welfare regulations are currently woefully inadequate and any possible future changes will never be enough to ensure the wellbeing of the animals. Currently, commercially farmed animals are exempted from the overarching anti-cruelty and duty of care standards included in animal welfare legislation. Horrific acts which cause great suffering and which are illegal to perform on domestic pets, are quite legal and standard practice for farmed animals. It is completely illogical that the same suffering can be inflicted on the same animal and yet the legality of the act depends on whether the animal is a family pet or a production unit on a farm. The laws allowing this are, in effect, legalising cruelty.
Current regulations are barely enforced and any improvements would suffer the same fate. There are over 30,000 farms in Victoria, making enforcement of any standards almost impossible.
It is clear that the animal production system could not economically survive if the same animal cruelty laws applied as for pets. The financial costs would be too high. And proposed "higher welfare" practices are only a little better than current standard practices and are constantly being degraded by the pressure of competition to make a profit. And in any case all animals end up at the same slaughterhouse at the same young age.
Discussion and arguments about "free-range", stocking densities, range rotation, organic, the use of anaesthetics, etc, are diversions from the real issue. The animal industry will fight and delay at every change. No amount of tweaking regulations will ever be enough. The only ethical solution is to end the use of animals in agriculture.
Use of credible scientific evidence about animals
Farm animals feel pleasure and sadness, excitement and resentment, depression, fear, and pain. They are far more aware and intelligent than we ever imagined ... they are individuals in their own right. ~ Jane Goodall
Vegan Australia agrees with the emphasis the draft plan places on using credible scientific evidence to determine animal policy. In fact scientific evidence should form the basis of any new animal welfare regulations.
The evidence of animal cognition should be the primary factor in making the plan. Scientific knowledge supports the common belief that animals are sentient, have emotions and can feel pleasure and pain. Animal welfare laws have existed for almost two centuries, so the fact that animals can suffer is not a new concept. This is supported by the draft plan.
Scientific research has discovered that the pain and pleasure mechanisms in animals are very similar in all vertebrates, including humans. The pain-inhibiting mechanisms found in the human body are very similar to those found in other animals.
Professor of Bioethics at Princeton University, Peter Singer, states "it is surely unreasonable to suppose that nervous systems that are virtually identical physiologically, have a common origin and a common evolutionary function, and result in similar forms of behaviour in similar circumstances should actually operate in an entirely different manner on the level of subjective feelings."
Animal behaviorists have found that, given amenable conditions, farmed animals interact in socially complex ways, bonding with family members and developing friendships over time. They have "rich and deeply emotional lives". Many mourn the deaths of others, with the mother-calf bond being particularly painful when it is broken. Raising animals in crowded conditions is very stressful to them because it upsets their social structure.
The Victorian Department of Primary Industries states that "all livestock species (and fish) have the necessary brain structures and nervous system to allow them to feel pain and suffer". In addition "all livestock species are capable of comprehending and desiring pleasurable experiences."
The draft report of the 2016 inquiry by the Productivity Commission into the regulation of agriculture states that "the welfare of animals is judged on the basis of: how well the animal is performing from a biological functioning perspective; affective states, such as suffering, pain and other feelings or emotions; the expression of normal or 'natural' behaviours." Observation suggests that none of these are met in any commercial agricultural system.
Both ethical considerations and credible science are important in determining welfare standards. These two concepts are not mutually exclusive. There is no conflict between the ethical consideration that it is wrong to inflict unnecessary suffering on animals and the scientific fact that farmed animals are sentient beings capable of suffering.
See more about animal sentience, emotion and behaviour here:
- Animal sentience (Voiceless)
- The Someone Project (Farm Sanctuary)
- Industrial farming is one of the worst crimes in history (The Guardian)
Vegan Australia suggests the those responsible for preparing the Animal Welfare Action Plan visit Edgar's Mission in Lancefield and spend a few hours getting to know the stories behind the rescued farmed animals who live there as valued individuals.
Use of nutritional science
Science can also be used to show that humans have no need for farmed animal food products. In fact, there is a solid body of peer-reviewed scientific evidence to confirm that it actually benefits human health to consume a primarily plant-based diet. Changing to a plant-based diet can help people live a longer, healthier life, and significantly reduce risk of falling victim to many of the serious health threats facing Australians today.
Australia's peak health body, the National Health and Medical Research Council, recognises that a vegan diet is a viable option for all Australians. Australia's top health experts agree with those in other parts of the world that well-planned vegan diets are safe and healthy for all age groups. The Australian Dietary Guidelines state that alternatives to animal foods, such as nuts, seeds, legumes, beans and tofu, can "increase dietary variety and provide a valuable and affordable source of protein and other nutrients found in meats."
According to the US Academy of Nutrition and Dietetics, "Appropriately planned … vegan diets are healthful, nutritionally adequate, and may provide health benefits for the prevention and treatment of certain diseases. These diets are appropriate for all stages of the life cycle, including pregnancy, lactation, infancy, childhood, adolescence, older adulthood and for athletes."
Not only are animal products unnecessary for optimal health, an increasing number of nutritionists and health professionals are acknowledging animal products are harmful to our health. This is supported by decades of good research. A healthy vegan diet helps reduce the risk of heart disease, stroke, cancer, obesity, and diabetes, some of Australia's top killers.
A recent issue of the Medical Journal of Australia, dedicated to the question "Is a Vegetarian [including vegan] Diet Adequate?", included the following statements. "A varied and balanced plant-based diet can provide all of the nutrients needed for good health." "Most vegans meet the recommended daily intake for protein." "Vegan diets generally contain just as much or more iron than mixed diets containing meat." "BMI and obesity was lowest for vegans."
The China Study by T Colin Campbell is one of the most comprehensive studies on nutrition ever done. Campbell provides compelling evidence linking animal products to disease, including cancer, heart disease, osteoporosis, diabetes, etc.
Every current vegan, by simply being vegan, proves that causing harm to sentient farmed animals is not necessary.
Public support for avoiding unnecessary suffering of animals
Nearly all Australians believe that we should avoid causing unnecessary suffering to sentient beings as much as possible.
According to the draft plan there is strong public support for the welfare of animals, stating that 98% of Victorians rate protecting the welfare of animals as important or very important and 75% feel the welfare of animals should be better protected.
In addition, a 2010 survey found that "99% of Australians are against cruelty to animals" (A Pound of Flesh, Vegan/Vegetarian Society of Queensland). The survey also found that 54% of Australians believe that vegan diets can be healthy. It also found that 56% of Australians say there are one or more things that would encourage them to become vegan, including evidence that many farming practices cause stress and pain for millions of animals every year and evidence they can be healthy on a vegan diet. Finally, 47% of Australians think making cows pregnant every year and taking their calves from them to obtain milk is unacceptable.
Other surveys have also shown that most people oppose testing cosmetics on animals. In fact, there is now widespread political support to outlaw the sale of all products tested on animals. The reform will bring Australia into line with Europe and New Zealand. Although in a different arena, this shows that when acceptable alternatives exist most people will choose compassion over cruelty.
The recent ban on greyhound racing in NSW is another example where the majority of people actively oppose the unnecessary suffering of animals. One of the major concerns with people is "wastage" - the majority of dogs who are killed because they are no longer fast enough to win. In other words, dogs are bred to be used for the trivial reason of entertainment and then killed. Most people rightly felt outrage when learning of this practice. The parallels with animal farming are clear - farmed animals are bred to be used for the trivial reason of enjoyment of the taste of their flesh or secretions and they die in the process.
We also note the surveys mentioned in the draft report of the 2016 inquiry by the Productivity Commission into the regulation of agriculture: "A survey of Australians' relationships with animals found that '52 per cent of respondents thought that factory-farming methods of producing meat, eggs, and milk (which are becoming dominant trends) were cruel'" and "30 per cent thought that animals deserve the same rights as people to be free from harm and exploitation".
Most people agree that causing unnecessary suffering and death of any sentient being is wrong and we should not participate in it if we can avoid it. We believe that given the right information about 1) the sentience of animals, 2) the unavoidable suffering of animals in agriculture and 3) the scientific evidence that humans have no need for animal food products, then there will be widespread public support for the complete phasing out of animal agriculture in Victoria.
Community expectations and education
Vegan Australia agrees with the draft plan's emphasis on basing animal welfare regulation on community values and expectations. As indicated above, the community expects strong protection for animals. We also agree with the plan's support for activities such as communication and education and to influence behaviour change. The community must be fully informed in this area so they can make valid conclusions.
We propose that the plan include deliverables covering honest community education about animal agriculture and the lack of necessity for humans to consume animal products. The horrific realities of animal agriculture are unknown by many in the community due to the prevalence of miseducation beginning in childhood and continuing into adulthood. Some of this miseducation is perpetuated intentionally by supporters of the animal agriculture industry, however much of it is merely the passing on of falsities by well-meaning people. The situation is the same in the context of the belief that animal products are a necessary component in the human diet, despite this belief contradicting the Australian Dietary Guidelines and other major dietetic organisations globally. Failing to provide education informing Victorians of the realities of animal agriculture and the lack of necessity of the consumption of animal products would result in a skewed community perspective.
This education is a prerequisite for gauging community values on animal welfare. Failing to do so would bias the process in favour of cruel and unnecessary practices that are not known about, or understood by, members of the general public.
The content of the education should be guided by the end goal of phasing out animal agriculture within ten years. No part of the education should lengthen this process by suggesting movements to intermediate "higher welfare" systems, such as cage-free eggs or "happy" meat.
People's views can change rapidly when presented with new information. In the experience of Vegan Australia we have found that it can take as little as reading one book or seeing one video that can completely change people's attitudes to animals as food. Community awareness is growing and we expect it to accelerate.
At the moment, people's ethical concerns do not always match their consumption decisions. Many people believe it is unacceptable to deny the life and liberty of an animal without good reason but they continue to consume animal products. This behaviour is due to tradition, convenience, widespread promotion by the animal industries, lack of information about the treatment of farmed animals and lack of knowledge of non-animal alternatives. Vegan Australia believes that strong public education campaigns will be effective in rapidly changing people's understanding and behaviour.
Food labelling as education
Consumers want to gain as much information about the products they are buying as possible. One of the aims of food labelling laws is to support consumer decisions about buying food products, including production processes. Misleading labels can result in consumers making choices that do not reflect their preferences.
Vegan Australia proposes that labelling of meat, dairy, eggs and other animal products must include an honest description of the suffering the animal endured during the production process. The current situation, where most labels contain no information about the treatment of the animals used in the production process, is deceptive and likely to mislead potential buyers.
The proposed animal suffering descriptions should be detailed listings. An example that may suit most dairy products sold in Victoria, describes the suffering endured by a typical dairy cow and her calves:
Another form of this labelling could use the model of cigarette packaging which has a graphic image and a warning in bold such as "Cigarettes kill" or "Quitting will improve your health" and on the side of the pack a more detailed description. This should level the playing field somewhat. We are incessantly bombarded with dishonest marketing to purchase animal products and that should be countered to allow consumers to make informed rational choices.
We also propose that honesty in labelling be extended so that pictures of "happy" animals on animal products, such as "happy hens" on egg cartons, be replaced with a graphic description how the animal suffered and died very young.
No input to animal welfare plan from animal industries
In order to remove the possibility of conflict of interest, those responsible for preparing the Animal Welfare Action Plan should only include those who represent animals and their interests. There should be no place for those who profit from the exploitation of animals. To give representatives of the animal industries any say in the plan would continue the conflict of interest that occurs in the current ineffective process of setting animal welfare standards.
Currently most members of advisory groups developing standards are representatives of the agriculture industry and departments of primary industries, whose principal objective is promoting the agricultural sector. As the Productivity Commission draft report states "Animal welfare may be of secondary importance where the primary objective of the agency responsible for livestock welfare is to promote a productive and profitable agricultural sector." The report also mentions "concerns about significant input from bodies whose interests [are] described as 'essentially antagonistic' to those of animals."
Concerns about the draft action plan
The draft action plan does not treat all animals equally. Even though it states that animals are sentient and should be treated ethically, it has a blind spot regarding farmed animals, and particularly animals raised in industrial farming systems.
Of the 14 photographs of animals in the plan only five show farmed animals and none of these show how the majority of animals live in Victoria - confined in sheds, never to see the light of day. As well as visually ignoring the plight of farmed animals, the words used in the plan are also biased. There are three mentions of the word "wildlife", four of the word "pet", two of the word "dog" and yet there is no mention of any animal normally bred for food.
The plan also gives a number of example deliverables, covering topics such as humane control methods for wildlife, caring for animals in domestic violence situations, assisting animals in emergency situations, making Victoria a better place for pets, the ethical care and use of animals for research, the impact of mental health and domestic violence on animals and responsible pet ownership. No examples are given which refer to the largest group of animals which suffer in Victoria: those who are bred and slaughtered for food. Vegan Australia believes that the plan should be rewritten to explicitly cover farmed animals and place emphasis on the real welfare of these animals.
The plan emphasises making "continuous improvements in animal welfare". But it does not define an end-point to this sequence of improvements. So there is no way to know when this process of continuous improvement is complete. Instead of discussing vague "continuous improvements", the plan should set an end goal.
The plan also lists a number of "outcomes" it is attempting to achieve. These state that animals should be treated ethically and the treatment of animals should improve over time. These two goals are in fact mutually exclusive. If treatment of animals improves in the future, then it means that the current levels of animal welfare are inadequate, that is, animals currently in the care of humans are suffering. What the plan should do is set a target goal and work towards that goal in a fixed time. The goal of the plan should be the protection of animals, not economics and not human pleasure, convenience or tradition. The plan should be clear about its goals.
Criticisms of calling for ending animal farming
While Vegan Australia has received good support for this submission and others like it, we have received some criticisms, such as: we are unlikely to get everyone to go vegan, we are unlikely to convince the Victorian government to ban animal agriculture, it sets us up for failure and not being taken seriously and so we should strive for a more achievable goal.
By "more achievable goal", people usually mean advocating for some sort of better conditions for the animals who are suffering now. We expect there will number of excellent submissions to this inquiry on this topic and we in no way want to undermine those. However we would like to point out that there have been animal cruelty laws for about 200 years and yet the conditions most farmed animals suffer under now are worse than ever. Rather than regulating animal use, a better way is to stop using animals in the first place. To advocate for anything less is to sell the animals short.
While Vegan Australia is one of the only organisations currently calling for the phasing out of animal agriculture, we expect to be soon joined by others. By calling for an explicit acknowledgement in animal welfare laws of the end goal of ending all animal farming, we are sending a clear and consistent message to the public that suffering is unavoidable in any agriculture system that uses animals.
The aims of Vegan Australia are to help bring about a world where all animals live free from human use and ownership. In this submission we propose that the goal of Animal Welfare Action Plan should be the complete phasing out of animal agriculture in Victoria.
Animal welfare laws should not suggest "better" ways to dehorn, disbud, tail dock, castrate, induce, remove calf from their mother, tie up, brand with a hot iron, tag, tattoo, electro-ejaculate, inseminate, intensively house, pen and kill animals by shooting, captive bolt or cutting the throat. They should state that none of these procedures should be necessary. They should give guidance on how to eliminate this industry and replace it with an industry based on compassion for animals, people and the earth.
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