Industry anger at understudied RSPCA Assured revisions
Published on : 29 Jan 2024Two months after announcing their new standards for laying hens, RSPCA has extended the deadlines for compliance and rowed back on their requirement for installing verandas on new build and refurbished free range houses.Verandas on new build and refurbished free range houses are no longer required, or at least not until more UK research is undertaken. The provision of natural light remains in the rules, with guidelines stating that this must be equivalent in size to 3% of the total floor area. Popholes can count towards natural daylight provision. However, if they must be closed for some reason (e.g. a housing order), natural daylight must still be able to penetrate the house. Therefore, alterations will need to be made. Farmers have until 1 January 2031 to install the rest.Since the initial revisions to the RSPCA laying hen standards were announced last November, RSPCA Assured have been the focus of criticism for the scale of investment needed to deliver the proposed amendments, the weak scientific evidence to back up their perceived benefits and, crucially, the absence of suitable consultation with industry. Officials from the certification scheme and RSPCA met with trade representatives at the RSPCA’s London office on 22 January. BFREPA Chairman James Baxter made the journey, joining around a dozen industry leaders in the room and scores more online. Following the meeting, RSPCA Assured immediately issued a press release, suggesting that revisions were in response to the feedback received and represented the conclusions of their discussions with the industry. However, this was not the case when speaking with participants in the meeting. "They're not listening," said one frustrated farmer, adding, "They haven't even been to a farm!" referring to the astonishing admission by RSPCA Assured interim chief operations officer Kelly Grellier that she has yet to visit a free range premise herself, although the scientific officers at the RSPCA who write the standards have spent time on both barn and free-range systems.The latest iteration of the rules now states that while barn egg units will need to installverandas by 1 January 2030, free range producers refurbishing their buildings or building new houses will not. Instead, "The RSPCA and RSPCA Assured will jointly engage with industry to conduct an in-depth review of installing verandas on free-range systems," according to the statement. An admission that perhaps the scientific backing for such proposals does not exist after all? It certainly indicates that verandas remain in the long grass, to be revisited in future years. This is one of many examples of assurance schemes re-writing the rulebook with inadequate consultation from their subscribers. In recent months, BEIC and Red Tractor have caused outrage among memberships as sweeping amendments have been attempted without market acceptance. No sooner had their Greener Farms Commitment been publicly announced than Red Tractor were forced to suspend development of the environmental module and instead take input from businesses up and down the supply chain as well as Government, supervised by NFU.Whilst Lion Code version 8 remains in force, the animosity created by gold-plating already high administrative standards at the expense of farmers has not gone away. At least, the focus is on the far more capital-intensive requirements suggested by the RSPCA standards. Assurance schemes need market share to remain viable. Without farmers producing to the standards, there is no product to which their labels can be applied, and therefore, no licensing fees to be charged to upstream customers.Why has RSPCA Assured decided to press ahead with the demand for verandas in barn houses from 1 January 2030? The Ranger understands that a tiny number of barn producers are accredited today, and the consequence to all parties of these farms exiting the scheme is minimal; almost certainly, there will be no accredited barn farms by 2030.The threat, on the other hand, that free range egg producers could walk away from RSPCA Assured standards is substantial and real. In a recent survey of BFREPA members, nearly 90% of respondents stated that they operated within the RSPCA Assured scheme. This high degree of participation is owed to the fact that, until now, there was no significant capital cost of adherence to the scheme. Packers could demand accreditation from farmers without even paying a premium for the eggs; approval was a necessity and a given for retail-orientated trade. Similarly, in the transaction between the packer and their customer, such is the ubiquity of RSPCA Assured approval that the accreditation standard would be a lower determinant in pricing discussions below supply and demand, feed raw material price, egg size and even packaging specification. For the supermarket, the badge gives the comfort of an independently qualified first response should any concern be raised; it doesn't command a higher price, at least today.For farmers to remain in the scheme, the market will need to establish a clear price structure to support the investment and to reward the risk of unintended consequences of poor welfare and, therefore, productivity outcomes. Such concerns were raised during the meeting using the scientific evidence RSPCA pointed to in justifying the rule changes.RSPCA reference evidence in scientific studies. In one of the cited papers, Possible risk factors for keel bone damage in organic laying hens by Jung et al., the relationship between keel bone damage and potential influences is explored, taking data from over one hundred flocks in eight European countries. Whilst the absence of natural light is listed as a factor associated with higher damage (and no one is advocating the absence of light), it'll surprise few hen keepers that in ten of the twenty-one flocks recorded without daylight, 'windows were shaded because of feather pecking and cannibalism problems'. "They need to show us the evidence that these changes benefit welfare, and it's simply not there. The studies they refer to are irrelevant to our geography, breeds, scale or farming system," said one BFREPA member.RSPCA Assured said, "Extending the timeline for introduction will enable us to work with industry to share evidence. Building a body of case studies will allow us to demonstrate how natural light can be installed effectively and practically managed and showcase the positive benefits for hen welfare".BEIC, BFREPA NFU Scotland, and Ulster Farmers Union issued a joint statement acknowledging the revised proposals but highlighting the concerns of implementing standards without validation. They said, "Industry strongly feels that joint practical farm case studies, based on UK conditions, should be conducted to understand better how increasing natural daylight will benefit bird welfare in free range systems, particularly given the natural light variations between the north and south of the UK, before this standard is implemented," adding, "British egg producers are fully committed to the welfare of their hens and their objective is to ensure that any revisions to the welfare standards truly benefit bird welfare based on UK conditions. This will ensure that British eggs continue to be produced to the highest welfare specifications without imposing unnecessary costs."All parties appear to agree that evidence of welfare benefits is required, but does the will exist to collaborate? RSPCA Assured responses to questions posed by BFREPA are telling. Asked whether changes were agreed by industry, a spokesperson for RSPCA Assured said, "The revisions we announced are final, and this was made clear at the meeting." Why would industry participate in studies if there is no scope for further discussion or applying learnings from evidence? It should be kept in mind that there are already several other welfare contentions for the industry to navigate at some point in the coming years, including day-old male chick culling, bird handling and, front of mind when increasing light levels, a potential outlawing of infra-red beak treatment. Has the industry and assurance body reached a stalemate, and is this the end of the RSPCA Assured scheme for eggs? The decision maker is likely to be the customer, conspicuously absent in the discussions. What do the retailers or restaurant chains want, and what are they prepared to pay for it? Today, an estimated 70% of UK free range farms are certified by RSPCA Assured, but the proportion of eggs actually marketed as such is much lower. For the convenience of the supply chain, most packers with one customer demanding the logo on pack certify all farms to the same standard.If farmers are to cut holes in sheds and possibly convert popholes to translucent materials (how else can they allow in light during lock-ins?), a ringfenced premium needs to be established and recovered from the market. This premium needs to provide a return on the actual cost of completing the works and act as an incentive or co-insurance for the perceived adverse welfare and productivity outcomes and the subsequent mitigation of those outcomes. Easier said than done and only feasible in a small proportion of the overall market. We're heading for a tiered free range category. Costs will be conjured up, and the major customers will be asked how they'd like their RSPCA Assured logos. Over the whole lot, a few select lines, or not at all? Considering that several are still wrestling with how to deliver next year's voluntary cage ban that they enacted nearly eight years ago, it's unlikely that this will be a priority decision soon.Moreover, with the inevitable cycles of supply and demand, it would probably suit the customer to stand on the sidelines for a few years; who's to say that by 2030, we won't be back to a surfeit of eggs, making a premium for Assured approval harder to protect? Between now and then, the industry will convene to discuss the merits of an alternative welfare stamp of approval.Subject to repetitive and frequent audits, producers have long called for a simplified, consolidated approach. BEIC and the Lion Code could provide this, and conceiving a sufficiently robust standard to provide the comfort and credibility needed by both trade customers and consumers could be invaluable. The creation of Version 9, with the full engagement of the world-leading expertise in free range egg production, the UK farmer, alongside those further up the value chain, could be a powerful and unifying undertaking. A shot at redemption for the UK egg administrator?Tension between code authors and actors is par for the course. When introducing alterations, an ability to listen and to compromise will be the hallmark of successful debate. No stockperson has ever wanted anything other than high standards of welfare for their animals. Equally, farmers would recognise that requirements evolve and progress can only be made through change. It's just that an awful lot of it is going about suddenly.