insufficient headspace

Undue Suffering during Animal Transports due to

Insufficient Headroom

© Animals’ Angels e.V. Rossertstr. 8, D - 60323 Frankfurt

[email protected] www.animals-angels.org

Published 15.09.2010

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________________________________________________________________________ Place and Date of Report: Frankfurt am Main, Germany, September 2010 © Copyright Animals’ Angels

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Table of Contents

1. Introduction 3

2. Legislative Provisions for Minimum Height of Compartments concerning the

Protection of Animals 3

3. Problems Inherent in Insufficient Height 3 4. Facts Found during Empirical Investigations 4

4.1. Transport of Lambs 5 4.2. Transport of Sheep 8 4.3. Transport of Cattle 11 4.4. Transport of Poultry 13 4.5 Transport of Rabbits 15

5. Recommendations on Minimum Height Requirements for the Different Species

based on Scientific Research and Empirical Investigations 16

5.1. Sheep 16

5.2. Pigs 17

5.3. Cattle 17

5.4. Poultry 17

5.5. Rabbits 17

6. Conclusion 18

Annex 19

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1. Introduction Insufficient headroom above the animals during transport is a frequent problem and a major factor causing severe animal suffering.

Being a commercial activity, animal transports are usually conducted as economically as possible. Therefore, animals are loaded on multideck vehicles to carry the highest number of animals possible on one vehicle with the aim of reducing the costs.

This problem of insufficient headroom is not restricted to certain transport companies, routes, countries of departure or species.

The present report summarizes examples of transport conditions found during Animals’ Angels’ investigations in different EU Member States and on different transport routes where the space above the animals has been insufficient. Many of the animals observed during these investigations touched the ceiling with their heads, several even with their backs. For many hours and up to entire days, these animals were unable to stand in a comfortable and natural position. The lack of headroom even caused physical injuries in the animals and the lack of space prevented sufficient ventilation and thus, significantly endangered the safety and health of the transported animals.

The Food and Veterinary Office of the EU Commission (FVO1) come to the same results during their missions in the Member States: The official investigation teams regularly find transport conditions where the ceiling height is insufficient for the animals. Thus, the transport conditions are contradicting the legislation on the protection of animals during transport.

2. Legislative Provisions regarding the Minimum Height of Compartments concerning the Protection of Animals The provisions concerning the necessary space above the animals during transport are stated in Council Regulation (EC) 1/2005 on the protection of animals during transport and related operations:

Sufficient floor area and height is provided for the animals, appropriate to their size and the intended journey (General conditions for the transport of animals, Chapter I, Article 3 lit.(g))

Sufficient space shall be provided inside the animals’ compartment and at each of its levels to ensure that there is adequate ventilation above the animals when they are in a naturally standing position, without on any account hindering their natural movement (Annex 1, Chapter II, 1.2.)

3. Problems Inherent in Insufficient Height According to the TECHNICAL REPORT submitted to EFSA2, “too low deck height” can cause prolonged thirst, thermal discomfort, locomotion problems, injuries, disease and behavioural disorders in mammals and caged animals (for e.g. poultry, rabbits). Animals´Angels observed that insufficient headspace causes a complex of problems for the transported animals and can result in poor welfare:

The unnatural and cowered posture prevents the animals from maintaining their balance. The risk to fall down during transport and thus the risk of injuries and also of having trouble standing up again increases. Furthermore, to keep balance during transport is very important for the animals as in

1 Henceforth referred to as FVO 2 TECHNICAL REPORT “Project to develop Animal Welfare Risk Assessment Guidelines on Transport”. submitted to EFSA, November 2009

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general they attempt to avoid contact with other animals or with the vehicle walls (Scientific Committee on Animal Health and Animal Welfare3 (SCAHAW), 20024). If the animals are forced to remain for many hours in an unnatural posture, general pain as well as fatigue and falling, muscle damage or muscle fatigue frequently occurs and injuries or wounds on their heads or backs are not rare (SCAHAW 20025). Furthermore, the disease susceptibility increases significantly.

A sufficient height above the animals´ backs and heads is necessary for effective ventilation, in particular for adequate temperature regulation and removal of ammonia gases. The presence of strong ammonia gases and dense air conditions lead to respiratory disorders and cough and increases the susceptibility to illness and disease.

Moreover, animals may not be able to reach feeding and drinking devices during long journeys since changes of position may be impossible or painful when the animals’ backs are scratching on the ceiling. Furthermore, animals may be hindered to urinate in their natural position.

Where ceiling heights are too low an adequate inspection of the animals is made impossible. (EFSA 20046)

4. Facts Found during Empirical Investigations That the lack of head space is a prevalent, not solved problem in animal transports is shown in the FVO Mission Reports from the last years. There, the investigation teams regularly assess infractions of Council Regulation (EC) 1/2005 due to insufficient headroom in the animals’ compartments. During two different welfare missions in Slovenia, insufficient headroom in transports of sheep was found7, as well as insufficient cage height in poultry transports8. Also during the missions in Spain, France and Hungary, the FVO inspectors assessed in poultry transports: “the height of the crates did not allow the birds to stand in their natural position, contrary to the requirements of …Regulation EC 1/2005, Annex I, Chapter II, 1(2)”9. In Germany and Lithuania, FVO assessed insufficient ceiling heights in transports of cattle10 and in Greece, insufficient ceiling height was found in sheep transports11.

The following photographs taken during Animals’ Angels’ investigations12 supply conclusive evidence for the fact that insufficient over-head space is a common and persistent problem in animal transports: 3 Henceforth referred to as SCAHAW 4 Report of the Scientific Committee on Animal Health and Animal Welfare (SCAHAW) “The Welfare of Animals during Transport”, March 2002, page 38, 56 5 Report of the Scientific Committee on Animal Health and Animal Welfare (SCAHAW) “The Welfare of Animals during Transport”, March 2002, page 38, 56 6 Opinion of the Scientific Panel on Animal Health and Welfare on a request from the Commission related to the welfare of animals during transport, 30th March 2004, The EFSA Journal (2004) 44), p.11 7 DG SANCO 2009/8241-MR-Final (Slovenia, insufficient head room sheep, p.12); DG SANCO 2007/7335-MR-Final (Slovenia, insufficient head room sheep, p.16) 8 DG SANCO 8038/2006 – MR- Final (Slovenia, insufficient head room poultry, p.8) 9 DG SANCO 2007/7330 –MR-Final (France, insufficient head room poultry, p.10); DG SANCO 2007/7328-MR-Final (Spain, insufficient head room poultry, p.10); DG SANCO 2007/7331-MR-Final (Hungary, insufficient head room poultry, p.11) 10 DG SANCO 2009/8252-MR-Final (Lithuania, insufficient headroom cattle, p.11); DG SANCO 2007/ 7581- MR-Final (Germany, insufficient head room cattle, p.7) 11 DG SANCO 8042/2006 – MR-Final (Greece, insufficient head room sheep p.6) 12 Detailed reports and information on Animals’ Angels’ investigations are available at [email protected]

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4.1. Transport of Lambs Generally, lambs loaded on 4 decks have insufficient headspace. The lambs can not stand in their natural position touching the ceiling with their heads and backs. The natural and mechanical ventilation in these transports is hindered, which leads to unbearable ammonia concentration, cough and respiratory disorders in the animals.

Transport of lambs from Romania to Italy, March 200513

The animals spent approx. 30 hours on board of the truck.

Transport of lambs from Spain to Italy, August 2005.14 Exact origin and destination unknown. The animals spent

more than 8 hours on board of the truck.

13 Animals’ Angels Report, 21.03.2005 14 Animals’ Angels Report, 02.08.2005

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Transport of lambs on 4 decks from Romania to Spain, November 2005. 15

Road transport of approx. 2.576 km. The animals spent clearly over 50 hours on board of the truck.

Transport of lambs on 4 decks from Spain to Italy, February 200616

Road transport of 1,321 km. The animals spent over 24 hours on board of the truck.

Transport of lambs on 4 decks from Hungary to Italy, April 2006. 17

Road transport of approx. 1.132 km The lambs spent approx. 19 hours on board of the truck.

15 Animals’ Angels Report, 16.11.2005 16 Animals´Angels Report, 27.-28.02.2006 17 Animals´Angels Report, 11.05.2006

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Transport of lambs on 4 decks from Hungary to Italy, March 200718

The lambs spent more than 13 hours on board of the truck.

Transport of lambs on 4 decks from Romania to Italy,

March 2007 19 The lambs spent approx. 28 hours on board of the truck.

Transport of lambs from Romania to Italy, March 201020.

Estimated transport time: approx. 21 hours

18 Animals’ Angels, Investigation March 2007 19 Animals’ Angels Investigation, March 2007 20 Animals’ Angels Report, 31.03.2010.

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Transport of lambs from Hungary to Italy, August 2010.21

Estimated transport time: approx. 18 hours

4.2. Transport of Sheep Generally, sheep loaded on 3 decks have insufficient headspace as the sheep cannot stand in their natural position touching the ceiling with their heads and backs. The natural and mechanical ventilation in these transports is hindered, which leads to unbearable ammonia concentration, cough and respiratory disorders and exhaustion in the animals.

Transport of sheep from Spain to Greece, January 200322 Road transport of a minimum of 2.689 km + 12 hours sea

transport. The animals spent at least 50.5 hours on board of the truck.

21 Animals’ Angels Report, 01.09.2010 22 Animals’ Angels Investigation, January 2003

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Transport of sheep from Spain to Italy, September 2005.23 Transport from Spain to Italy, July 2008.24 The programmed journey time can be estimated with Road transport of 1,834 km. The animals spent 34 hours, including sea transport. approx. 29 hours on board of the truck.

Transport of sheep from Spain to Greece, September 200825

Road transport of 2.525 km + 12 hours sea transport. The animals spent approx. 70 hours on board of the truck.

National sheep transport, Spain, February, 200926

23 Animals’ Angels Report, 13.10.2005 24 Animals’ Angels Investigation, July 2008 25 Animals’ Angels Report, 30.11.2008 26 Animals’ Angels Report, 05.02.2009

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Transport of sheep on 3 decks from Spain to Greece, October 200927

Road transport of at least 1,667 km in France and Italy + 12 hours sea transport + unknown distance covered by road transport in Spain and Greece. The animals spent far more than 37 hours on board of the truck.

Transport of sheep from Spain to Italy, October 200928 Transport of 1,974 km. The animals spent at least 28.5 hours on board of the truck

27 Animals’ Angels Report, 29.10.2009 28 Animals’ Angels Report, 16.11.2009

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4.3. Transport of Cattle Generally, fully grown cattle loaded on double – deck trucks have insufficient head room. In the same way, calves loaded on three decks have generally insufficient head space. As a result, the animals cannot stand in their natural position, touching the ceiling with their heads and backs. In several cases, the insufficient head room has led to injuries on the animals’ backs and tail roots, in other cases, for days, the animals could not even urinate in a normal position due to the low ceiling height. Furthermore, the ventilation within the compartments is hindered.

Transport of heifers from Germany to Greece, January 200429

National cattle transport, Germany, December 200730

29 Animals’ Angels Investigation, January 2004 30 Animals’ Angels Report, December 2007

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Transport of unweaned calves from Northern Ireland to Spain, February 201031

Road transport of 1,645 km + 18 hours sea transport. The animals spent at least 41.5 hours on board of the truck.

National cattle transport, Germany, April 201032

Transport of heifers from the Netherlands to Spain (Canary Islands), May 201033

Road transport of 2,415 km + 38 hours transport by sea. The animals spent 88 hours on board of the truck.

31 Animals’ Angels Report, 23.04.2010 32 Animals’ Angels Report, April 2010 33 Animals’ Angels/ ANDA Report, 27.05.2010

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Transport of heifers from France to Morocco, July 201034

Road transport of 1,685 km + 2 hours sea transport + 8 hours waiting at harbours (exit EU, entrance Africa).

The animals spent at least 39 hours on board of the truck.

4. 4. Transport of Poultry In general, the height of the containers used for the transport of poultry is too low for the animals in such a way that the animals cannot stand during transport but have to endure hours in a cowered position. As a result, the natural ventilation within the transports is hindered and the mortally rates in birds during transport is extremely high.

National poultry transport, Holland, December 200235 National poultry transport, Italy, August 200336

34 Animals’ Angels Report, 09.07.2010 35 Animals’ Angels Report, December 2002 36 Animals’ Angels, Investigation August 2003

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National poultry transport, Hungary, May 200437 National turkey transport, Portugal, November, 200438

National chicken transport, Germany, April 200739 National chicken transport, Spain, April 2007 40

National chicken transport, Italy, April 200741 National chicken transport, Italy, May 201042 37 Animals’ Angels Investigation, May 2004 38 Animals’ Angels Report, December 2004 39 Animals’ Angels Report, 04.04.2007 40 Animals’ Angels Report, April 2007 41 Animals’ Angels, Investigation, April 2007 42 Animals’ Angels, Investigation, May 2010

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National chicken transport, Spain, July 201043

4. 5. Transport of Rabbits In general, the height of the containers used for the transport of rabbits is too low for the animals. The animals touch the top of the containers with their ears and often even with their heads and backs. Consequently, they cannot stand in their natural position and the natural ventilation within the vehicles is blocked. High mortally rates in rabbit transports are a result of this transport practice.

National rabbit transport, Hungary, May 200444

National rabbit transport, France, June 200845 National rabbit transport, Spain, July 201046 43 Animals’ Angels/ ANDA Report, July 2010 44 Animals’ Angels Investigation, May 2004

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5. Recommendations on Minimum Height Requirements for the Different Species based on Scientific Research and Empirical Investigations The practice shows that insufficient headroom is a common and persistent problem in animal transports which leads to severe animal suffering and injuries and can even lead to death during transport.

It is obvious that the requirements concerning the headspace above the animals stipulated in Regulation (EC) 1/2005 are insufficient to guarantee the animals’ health and safety during transport. As quoted above (point 2.), the Regulation solely indicates that the headroom must be “sufficient”. Only for horses transported on double-deck trucks specific requirements are defined (Annex 1, Chapter III, 2., 2.3., Sentence 2). The undefined legal term “sufficient” offers wide space for interpretation which is – as practice has shown – laid out to the disadvantage of the animals. This is in spite of the fact that SCAHAW gave detailed recommendations concerning the minimum head room requirements for the different species. By not regarding these Scientific Recommendations Council Regulation EC 1/2005 is contradicting itself. Ground 8 of Council Regulation EC 1/2005 requires that - based on the opinion of SCAHAW adopted on 11 March 2002 – “Community Legislation should be amended to take into account new scientific evidence while giving priority to the need for its enforceability to be properly ensured in the immediate future”. In this regard, it should further be mentioned that the Community Action Plan on the Protection and Welfare of Animals 2006- 2010 has not been realised, as well. This Action Plan allows inter alia upgrading existing minimum standards for animal protection and welfare in line with new scientific evidence and socio-economic assessments and that consideration will also be given to the simplification and clarification of the existing legislation where reports and experience highlight the need for revisions or updating47. It is obvious that the term “sufficient” has to be specified. The minimum of heights for the different animal species must be laid down. Doing this, as a general principle it shall be considered: “None of the animals should be able to touch the ceiling with its head being held up and having its four legs on the ground.”48

5.1. Sheep Following the recommendations by SCAHAW and confirmed by the European Commission (Annex 1) the space above the top of the head (as the highest point of them) should be 15 cm for vehicles with good forced ventilation systems and at least 30 cm for vehicles without forced ventilation.49

45 Photo Gnadenhof Erzbach, Germany, June 2008 46 Animals’ Angels/ ANDA Report, July 2010 47 Compare e.g. item 3. “Areas of Action”, No 1 and item 4. “Future Steps” of the Community Action Plan 2006-2010; http://ec.europa.eu/food/animal/welfare/com_action_plan230106_en.pdf 48 Letter SANCO, dated 04.09.2009 49 Report of the Scientific Committee on Animal Health and Animal Welfare (SCAHAW) “The Welfare of Animals during Transport”, March 2002,, page 98; confirmed by the European Commission (Annex)

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5.2. Pigs The height of compartments for pigs needs to be calculated in relation to height above the highest part of the body. The highest point of the body of young pigs is the top of the head and for older or larger pigs it is the centre of the back. Following the recommendations by SCAHAW and confirmed by the European Commission (Annex 1) the space above the highest point of pigs should be 15 cm for vehicles with good forced ventilation systems and at least 30 cm for vehicles without forced ventilation50. 5.3. Cattle In case of cattle, the highest point of the animals is the head being held up and in case of horned animals the ends of the horns. According to SCAHAW, an appropriate specification should be a minimum of 20 cm clear space above the highest part of the tallest animal carried51. These specifications apply for calves as well as for adult animals and this minimum height proposed by SCAHAW should be significantly increased in journeys exceeding 8 hours. Furthermore, following SCAHAW, the figure of 20 cm clear space should apply for all vehicles52, so for vehicles with good forced ventilation systems as well as for vehicles without ventilation. 5.4. Poultry Animals’ Angels noticed that the height of containers used for poultry is extremely low. At most, the birds are able to stay in a low standing position, or they are transported in extreme confinement and have to endure in a cowered position for hours. High crating densities increase the economic gain of the transporters, but birds are less able to cope with their environment with behavioural adaptation, e.g. by regulating their body temperature. Especially in hot weather conditions stocking densities have to be reduced in order to facilitate air movement and protect birds from increasing heat and humidity within the crates. In this case the over-head space and therefore the height of the crates have to be additionally taken in consideration53.” Therefore, it is crucial and logical to lay down the minimum heights of the containers used for the transport of poultry according to the height of the comfortably standing bird. To the height of the naturally standing bird the space must be added that permits airflow throughout the containers. The average height of a comfortably standing “laying” hen is 35 – 40 cm. The height of the containers used for the transport of chicken should thus be at least 45 – 50 cm. (Height of the naturally and comfortably standing animal plus 10 cm space for free air flow.) 5.5. Rabbits The height of the crates for the transport of rabbits should be different according the breed, age and size of the rabbit and of such size that rabbits can stand in a natural posture, and never less than 35 cm for rabbits going to slaughter54.

50 Report of the Scientific Committee on Animal Health and Animal Welfare (SCAHAW) “The Welfare of Animals during Transport”, March 2002, page 47, 57, 98; confirmed by the European Commission (Annex) 51 Report of the Scientific Committee on Animal Health and Animal Welfare (SCAHAW) “The Welfare of Animals during Transport”, March 2002, page 79, 99; confirmed by the European Commission (Annex) 52 Report of the Scientific Committee on Animal Health and Animal Welfare (SCAHAW) “The Welfare of Animals during Transport”, March 2002, page 99 53 TECHNICAL REPORT “Project to develop Animal Welfare Risk Assessment Guidelines on Transport”. submitted to EFSA, November 2009 54 Opinion of the Scientific Panel on Animal Health and Welfare on a request from the Commission related to the welfare of animals during transport, 30th March 2004, The EFSA Journal (2004) 44), p.26

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6. Conclusion Based on the aforementioned facts and the proofs supplied, it is clear that new scientific evidence have been neglected when passing Council Regulation EC 1/2005. The further failure to transpose scientific recommendations in the EU-legislation on the Protection of Animals would be a breach of Article 13 of the Treaty on Functioning of the European Union, according to which animals are sentient beings and full regard has to be paid to their welfare requirements. The protection of animals is an avowed goal of the European Union. The Union should act according to this goal and stop prioritising economic interests over the – at least basic - requirements of animal protection. Animals’ Angels calls upon the veterinarians of the EU Member States to immediately enforce at least the requirements of the current legislation, i.e. - veterinarians at places of departure to stop authorizing transports where the head space for the animals is clearly insufficient; - veterinarians at places of destination to impose sanctions for transports with insufficient head space. Animals’ Angels calls upon the European Legislators and the EU Member States to urgently lay down the specific minimum requirements for the space above the animals for the different species on the means of transport during transportation.

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Annex

I

insufficient headspace

Documents

protection of animals

transported animals

animals angels investigations

copyright animals angels

transport of poultry

transport of rabbits

transport of sheep

transport of cattle