Mandatory Closed-Circuit Television (CCTV) in Slaughterhouses

Animal welfare is a priority for the Welsh Government. Our Programme for Government includes a commitment to require closed-circuit television (CCTV) in all slaughterhouses.

We are consulting on proposals to require CCTV in all approved slaughterhouses in areas where live animals are present. Our proposals include requirements for slaughterhouse operators to allow enforcement agencies to access footage and requirements for footage to be stored for a specified period.

This is a 12-week consultation starting on 14 November 2022 and closing on 6 February 2023. 

Animal welfare is a priority for the Welsh Government. Our Programme for Government includes ambitious commitments to improve animal welfare[1]. One of these commitments is a requirement for closed-circuit television (CCTV) in all slaughterhouses.

Our Animal Welfare Plan for Wales (2021-2026)[2] sets out how we will deliver our Programme for Government commitments, building on the significant progress we have already made to improve animal welfare.

The aims of our Animal Welfare Plan are strategically aligned to the Wales Animal Health and Welfare Framework Implementation Plan[3] which seeks to maintain and improve standards of animal health and welfare for kept animals, protect public health, and contribute to the economy and the environment. In realising these goals, the Framework strives to achieve five strategic outcomes:

• Healthy productive animals
• Animals have a good quality of life
• Public confidence in the way we produce food and protect public health
• A thriving rural economy
• A high quality environment

[1] Programme for Government: Programme for government: update | GOV.WALES

[2] Animal Welfare Plan for Wales (2021-2026): Animal Welfare Plan for Wales 2021 to 2026 | GOV.WALES

[3] Wales Animal Health and Welfare Framework: Animal health and welfare framework: implementation plan 2022 to 2024 | GOV.WALES

EC Council Regulation 1099/2009 on the protection of animals at the time of killing (‘Regulation 1099/2009’) came into force in the UK and all other member states of the European Union from 1 January 2013, increasing welfare protection for animals at the time of slaughter[1].  Regulation 1099/2009 has been retained following our exit from the European Union. In Wales, the Welfare of Animals at the Time of Killing (Wales) Regulations 2014 (‘the 2014 Regulations’) provide the powers to fully enforce Regulation 1099/2009 and our longstanding stricter national rules which give greater protection than the retained European Union regulations[2].

Regulation 1099/2009 establishes minimum rules for the protection of animals at the time of slaughter or killing. The 2014 Regulations set down specific requirements which must be complied with at all stages of slaughter or killing processes.

Slaughterhouse operators are primarily responsible for the welfare of animals on their premises. The Food Standards Agency (FSA) monitors and enforces welfare compliance in approved slaughterhouses on behalf of the Welsh Government. The FSA’s role focuses on ensuring slaughterhouses are compliant with all specific requirements in hygiene and animal welfare legislation. These requirements are monitored and enforced by Official Veterinarians (OVs) of the FSA to ensure that animals are spared avoidable pain, stress or suffering during the slaughter process. In addition to this, any red meat slaughterhouse that slaughters more than 1,000 livestock units a year, or white meat slaughterhouse that slaughters more than 150,000 birds or rabbits a year, must also appoint an Animal Welfare Officer[3] to assist them in ensuring compliance with the rules laid down in Regulation 1099/2009.

OVs have legal powers under the 2014 Regulations to seize CCTV footage if they have a reasonable suspicion that a breach of the regulations has occurred.  Failure to provide information (including CCTV footage) which is requested and reasonably required by FSA may constitute an offence. Unrestricted access for authorised officers, e.g. OVs from FSA and staff from organisations approved by the Welsh Ministers, would provide better proactive and reactive opportunities to assess compliance with the regulations.

[1] EC Council Regulation 1099/2009: Council Regulation (EC) No 1099/2009 of 24 September 2009 on the protection of animals at the time of killing (Text with EEA relevance) (legislation.gov.uk)

[2] The Welfare of Animals at the Time of Killing (Wales) Regulations 2014: The Welfare of Animals at the Time of Killing (Wales) Regulations 2014 (legislation.gov.uk)

[3] Some animals count as a whole livestock unit, others count as part of a unit: Red and white meat slaughterhouses: standard operating procedures - gov.uk

The Farm Animal Welfare Committee (now the Animal Welfare Committee) opinion on CCTV in slaughterhouses, published in 2015, identified CCTV as offering real benefits as an important complement to physical observation and verification of slaughterhouse practices[1].

The Farm Animal Welfare Committee recommended that all approved slaughterhouse operators should install CCTV in all areas where live animals are kept and where animals are stunned and killed. It also recommended CCTV cameras should be installed so as to permit a clear and uninterrupted view of the processes being recorded at all times; that CCTV footage should be accessible to and viewed on a regular basis by slaughterhouse staff, Animal Welfare Officers and OVs to ensure business compliance, particularly in those areas and for those processes where the risk of non-compliance is higher; and that CCTV footage should be retained by the slaughterhouse for a period of three months and be available to authorised officers.

The Farm Animal Welfare Committee were clear that CCTV should not replace, reduce or be considered a substitute for current controls of slaughterhouse practice undertaken by OVs, Animal Welfare Officers, slaughter operators and others. It recognised the added value of CCTV towards protecting animal welfare and benefiting the slaughterhouse operator, including:

• providing evidence of due diligence and compliance with legislative and commercial standards and responsiveness to consumer concerns increasing public trust;
• contributing to slaughterhouse operator reviews of effectiveness of operations (including improving handling and reducing stress in animals) and enable them to make improvements to processes and operating instructions;
• providing a valuable training tool for slaughterhouse staff;
• encouraging collective responsibility in slaughterhouse staff;
• providing evidence for disciplinary action; and
• enabling disputes to be resolved including relating to spurious allegations.

In 2016, a Task & Finish Group, established by the Welsh Government considered the need for and possible implementation of a workable system of CCTV in all slaughterhouses in Wales[2]. Based on the evidence available at the time, the group concluded there was not sufficient basis on which to make CCTV a mandatory requirement in slaughterhouses. The group did conclude there was reason to encourage the installation and use of CCTV for training purposes, for example, if the stun area is hard to observe, and if a site has a CCTV system, then cameras in the unloading and lairage area may record injuries sustained during transport. The group recommended grants should be made available to assist small sites to invest in the equipment.

The British Veterinary Association (BVA) produced a Policy Statement, published in August 2020[3], setting out its position on the welfare of animals at slaughter. The BVA recommended all UK administrations should introduce mandatory CCTV in abattoirs in all areas where live animals, or animals being slaughtered, are present with unrestricted access to real time and stored footage for OVs.

[1] Farm Animal Welfare Committee: Opinion on CCTV in slaughterhouses - gov.uk

[2] The Safeguarding Animal Welfare at Slaughter Task and Finish Group: cctv-in-slaughterhouses-report.pdf (gov.wales)

[3] BVA position on the welfare of animals at slaughter: full-position-bva-position-on-the-welfare-of-animals-at-slaughter.pdf

In response to a recommendation by the Task & Finish Group, the Welsh Government made funding available through the Food Business Investment Scheme to support small and medium sized slaughterhouses to, amongst other things, install and upgrade CCTV systems. The scheme closed November 2018.

Our larger slaughterhouses, which process the vast majority of animals, already have CCTV and adhere to a voluntary protocol jointly developed and agreed by the FSA and industry bodies to enable OVs access to CCTV footage. In Wales, 95% of sheep are slaughtered in three premises, all of which have CCTV, 96% of cattle are slaughtered in three premises, all of which have CCTV, and 98% of poultry are slaughtered in three premises with CCTV[1].

In January 2022, the FSA carried out a survey on behalf of Welsh Government to assess the current CCTV facilities in every slaughterhouse in Wales. 23 slaughterhouses were surveyed (one of the premises surveyed has been non-operational since July 2021). The survey found:

• 17 slaughterhouses have some form of CCTV in place (including all poultry slaughterhouses).
• Six slaughterhouses have no CCTV (all red meat).
• Of the 17 slaughterhouses that have CCTV, 10 have setups that would comply with the current requirements for CCTV in slaughterhouses in England and Scotland (see below).

In March 2022, the FSA carried out a survey of all slaughterhouses operating in England and Wales, on behalf of Defra and the Welsh Government[2]. The survey was completed by the OVs based at the slaughterhouses and similar to surveys carried out by FSA in 2011, 2013 and 2018 for comparison purposes. The main issues addressed in the survey are: The numbers of animals slaughtered in approved slaughterhouses and method of slaughter, including slaughter without stunning; the source of the animals that are slaughtered and the destinations of the meat from these animals, including domestic and export markets.

[1] Food Standards Agency, March 2022

[2] Farm animals: slaughter sector survey 2022 - GOV.UK (www.gov.uk)

The Mandatory Use of Closed Circuit Television in Slaughterhouses (England) Regulations 2018 came into force in 2018[1]. The regulations apply to slaughterhouses in England who must:

• Install and operate a CCTV system in all areas of the slaughterhouse where there are live animals.
• Keep CCTV images for 90 days from the date taken.
• Make CCTV images available to inspectors to view, copy or seize[2].

The Mandatory Use of Closed Circuit Television in Slaughterhouses (Scotland) Regulations 2020 came into force in July 2021[3]. The regulations only apply to slaughterhouses in Scotland who must:

• Install and operate a CCTV system in all areas of the slaughterhouse where there are live animals.
• Keep CCTV images for 90 days from the date taken.
• Make CCTV images available to authorised persons to view, copy or seize.[4]

There are no requirements for mandatory CCTV in slaughterhouses in Northern Ireland.

[1] The Mandatory Use of Closed Circuit Television in Slaughterhouses (England) Regulations 2018 (legislation.gov.uk)

[2] Guidance on the Mandatory Use of Closed Circuit Television in Slaughterhouses (England) Regulations 2018 (May 2018)

[3] The Mandatory Use of Closed Circuit Television in Slaughterhouses (Scotland) Regulations 2020 (legislation.gov.uk)

[4] Guidance on the Mandatory Use of Closed Circuit Television in Slaughterhouses (Scotland) Regulations 2020 (15 June 2021)

We have made a commitment to require CCTV in all slaughterhouses during this Government’s term.

CCTV cannot replace direct oversight by slaughterhouse staff, Animal Welfare Officers and Official Veterinarians (OVs) but it can improve the efficiency of monitoring and enforcement activity with associated animal welfare benefits. CCTV can provide OVs with the information they need to monitor compliance with regulations more readily and more conveniently, record individual events and support audits. This will support improved consumer confidence that welfare standards are being delivered.

CCTV footage can have authenticity and transparency as evidence and can be retained for long periods. It can also enable slaughterhouse staff, Animal Welfare Officers and OVs to observe animals in high welfare risk areas as well as those that are dangerous or inaccessible to people, and identify animal behaviours that might be hidden from human observers.

Detection of animal welfare breaches can result in consequences that act as a deterrent to future poor practice and/or feedback and continuous improvement to slaughterhouse practices.

FSA enforcement data for England and Wales for 2020/21[1] indicates that at least 10% of slaughterhouse non-compliances are identified either by live or retrospective CCTV viewing and CCTV is routinely used as evidence to support enforcement action.

CCTV also plays an active role in suspension and revocation of Certificates of Competence[2]. Thirty-nine certificates were suspended or revoked in 2020/21 of which 13 utilised CCTV to support determination of the outcome, this equates to 33% of all suspensions and revocations (FSA data).[3]

We propose to introduce regulations to require:

1. CCTV cameras be installed in all approved slaughterhouses in areas where live animals are unloaded, kept, handled, stunned and killed.  The cameras must be placed to make sure there is a complete and clear view of all areas of the slaughterhouse where live animals are present and picture resolution must be good enough so people can be identified in the pictures and recorded images. If other CCTV cameras are present on the premises, for example for security or fault-finding reasons, these would not be considered part of the CCTV system for monitoring areas where live animals are present.
2. Recorded images are kept by the slaughterhouse operator for a 90-day minimum period. This is in keeping with a recommendation from the Farm Animal Welfare Committee. If being used as part of an ongoing investigation or prosecution, recorded images could be kept for longer periods by the relevant enforcement agency.
3. Recorded images should be available to authorised persons to view, copy or seize. To enable enforcement, authorised officers, such as OVs from FSA and staff from organisations approved by the Welsh Ministers, could be given power of unrestricted access to live or recorded footage for the purpose of monitoring and verifying animal welfare standards in the slaughterhouse.

[1] Food Standard Agency – Business Committee Meeting Animal Welfare Update: Board Paper Template 2020 inc checklist (food.gov.uk)

[2] Slaughterhouse operatives need a Certificate of Competence from the FSA to undertake certain activities in an FSA-approved slaughterhouse: Slaughter licensing | Food Standards Agency

[3] Food Standard Agency – Business Committee Meeting Animal Welfare Update: Board Paper Template 2020 inc checklist (food.gov.uk)

Mandatory CCTV recording in all approved slaughterhouses in areas where live animals are present as an enforcement measure may be required through regulations made under the Animal Welfare Act 2006.

The FSA monitors and enforces animal welfare regulations in slaughterhouses in line with a hierarchy of sanctions, ranging from verbal and written advice through to reporting offences for prosecution. Penalties under the proposed regulations would be proportionately applied by the FSA and limited by the requirements of the Animal Welfare Act 2006.

The FSA would make use of CCTV as part of its existing enforcement role at slaughterhouses. The same level of OV resource would be involved as now but would sometimes be engaged in different activities.

One of the primary benefits of CCTV is improved compliance with animal welfare at slaughter requirements, resulting from the deterrent effect of CCTV combined with increased information to aid enforcement by FSA staff.

There will be implications for those involved in and concerned with the slaughter of animals for human consumption. We have prepared a Regulatory Impact Assessment to assess the financial and practical impacts of the proposed regulations for affected parties including industry and the public sector (Annex 1).

We estimate an initial one-off cost of £2,500 for premises without CCTV and £500 per additional area without coverage in plants with CCTV at present.

The Regulatory Impact Assessment considers the costs of installation and maintenance of CCTV systems as well as the cost of storage of CCTV footage. This assessment has been based on limited information on costs and we would welcome more information on this (questions 5 to 8).

Anyone may reply to this consultation. We would particularly like to hear from organisations and individuals involved in and concerned with the slaughter of animals for human consumption. Campaigns resulting in stock responses will be recorded but may not be individually acknowledged.

Those who may have an interest include slaughterhouse operators; other trade representatives in the livestock and meat industries; the veterinary profession; animal welfare organisations; animal welfare enforcement bodies; farm assurance schemes; and retailers.

Please respond by answering the questions at the end of this consultation document. Responses can be submitted in a number of ways.

Email: Animalwelfarewales@gov.wales

Post: 
Animal Welfare Branch     
Welsh Government 
Cathays Park 
Cardiff 
CF10 3NQ

Alternatively, an online form is available on the Welsh Government website at: https://consultations.gov.wales/

Enhanced Animal Welfare Provision

Question 1  

We have made a commitment to require CCTV in all slaughterhouses. Do you agree CCTV cameras should be installed in all approved slaughterhouses in areas where live animals are present, including areas where animals are unloaded, kept, handled, stunned and killed? Please give reasons for your response.

Question 2

Do you agree with the benefits to animal welfare we have identified from requiring CCTV in all slaughterhouses? Please tell us about any other potential benefits to animal welfare.

Enhanced Animal Welfare Enforcement

Question 3

Do you agree with the proposed requirement for slaughterhouse operators to retain CCTV footage for 90 days?  Please give reasons for your response.

Question 4

Do you agree there should be unrestricted access to authorised persons to view (in real time and stored), copy or seize recorded images? Please give reasons for your response.

Cost to Businesses

We have prepared a Regulatory Impact Assessment to assess the financial and practical impacts of our proposals for all affected parties including industry and the public sector (Annex 1).

Question 5

Do you agree with our assessment of the cost of mandatory CCTV to (a) individual slaughterhouses and (b) to the Welsh slaughter industry as a whole?  Please provide evidence to support your response.

Question 6

Do you consider that the costs of introducing mandatory CCTV in slaughterhouses are reasonable and proportionate for individual businesses, irrespective of size? Please provide evidence to support your response.

Question 7

Are there any other economic benefits or costs not mentioned in the consultation document or Regulatory Impact Assessment?  Please explain what these might be and provide evidence to support your response.

Question 8

Are you content for the Welsh Government to contact you for further clarification of the financial impacts that you have estimated?

Welsh Language

Question 9

Please consider and outline the effects (whether positive or adverse) that our proposal to require CCTV in all slaughterhouses would have on:

• Opportunities for persons to use the Welsh language, and on treating the Welsh language no less favourably than the English language.
• How the policy under consideration could be formulated or revised so that it would have positive effects or increased positive effects.
• Opportunities for persons to use the Welsh language, and on treating the Welsh language no less favourably than the English language.
• How the policy under consideration could be formulated or revised so that it would not have adverse effects, or so that it would have decreased adverse effects on opportunities for persons to use the Welsh language, and on treating the Welsh language no less favourably than the English language.

Additional Information

Question 10

We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please let us know.

E-mail: Animalwelfarewales@gov.wales

The Welsh Government will be data controller for any personal data you provide as part of your response to the consultation. Welsh Ministers have statutory powers they will rely on to process this personal data which will enable them to make informed decisions about how they exercise their public functions. Any response you send us will be seen in full by Welsh Government staff dealing with the issues which this consultation is about or planning future consultations. Where the Welsh Government undertakes further analysis of consultation responses then this work may be commissioned to be carried out by an accredited third party (e.g. a research organisation or a consultancy company). Any such work will only be undertaken under contract. Welsh Government’s standard terms and conditions for such contracts set out strict requirements for the processing and safekeeping of personal data.

In order to show that the consultation was carried out properly, the Welsh Government intends to publish a summary of the responses to this document. We may also publish responses in full. Normally, the name and address (or part of the address) of the person or organisation who sent the response are published with the response. If you do not want your name or address published, please tell us this in writing when you send your response. We will then redact them before publishing.

You should also be aware of our responsibilities under Freedom of Information legislation.

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• to be informed of the personal data held about you and to access it
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• to (in certain circumstances) data portability
• to lodge a complaint with the Information Commissioner’s Office (ICO) who is our independent regulator for data protection.

For further detail about the information the Welsh Government holds and its use, or if you want to exercise your rights under GDPR, please see contact details below:

Data Protection Officer:
Welsh Government 
Cathays Park 
Cardiff 
CF10 3NQ

Email: Data.ProtectionOfficer@gov.wales

Information Commissioner’s Office: 
Wycliffe House 
Water Land 
Wilmslow 
Cheshire 
SK9 5AF

Tel: 01625 545745 or 0303 123113

Website: https://ico.org.uk/

Large print, Braille and alternative language versions of this document are available on request.