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					OST Review of Defra                                                                  RSPCA


    RSPCA submission to the Office of Science & Technology Review of
                           Science in Defra
Introduction

The RSPCA welcomes the OST’s Review of Science in Defra, and this opportunity to submit
our views. Our interest as a charity lies in the prevention of cruelty, alleviation of suffering,
and promotion of kindness to animals: our comments will therefore be confined to that part
of Defra’s remit which relates to the welfare of animals, and will not extend to other areas of
policy.

General comments

We welcome Defra’s commitment, stated in the Science pages of the Department’s website,
to evidence-based policy making, and the intention to ensure that “Defra science is open and
transparent, and its aims and results are effectively communicated.” We hope that the OST’s
Review will rigorously test to what extent these intentions are fulfilled in practice, and trust
that the comments in this submission will be of some assistance in that.

The Defra research budget is very substantial, and makes a significant contribution to the
overall effort in research into animal welfare – as no doubt it does to research in other areas
too. Some high-quality research in animal welfare has resulted, and, from the RSPCA’s
perspective, the welfare of animals (primarily farm animals) has in some cases at least
benefited as a consequence. Whether or not the scale of Defra-funded research effort in
animal welfare is funded at an appropriate level compared to that in other policy areas is a
matter we would urge the OST to consider. The RSPCA itself is perhaps not best placed to
judge what is the appropriate balance – but we offer a few comments for consideration in this
submission.

The RSPCA’s Director of Science has had some correspondence with Defra’s Chief
Scientific Adviser on several issues of science policy, and attended the open meeting of the
Science Advisory Council in January, where animal welfare related issues were also raised.
The accessibility of the CSA and his staff, and the openness of SAC meetings, is welcome,
and we hope to be able to continue to use these channels of communication when appropriate.
The points raised in those discussions, however, are relevant to the OST Review, and are
referred to in this submission.

In their consultation letter, the OST list the 10 criteria under which they will consider Defra’s
effectiveness. The following comments, therefore, are grouped according to those criteria
that are of relevance to our interests.

Criterion 1: Clear overall science strategy

We find the overall strategy clear: Defra’s five priority areas are defined in the overall
strategy “Delivering the essentials of life”, and the linkage of Science to that overall strategy
is made apparent in the Science & Innovation Strategy 2003-6.

However, the RSPCA is concerned about the broad treatment of the issue of animal welfare
within those strategies, and the way in which animal welfare science may be affected both by
broad strategic decisions, and by the implementation of the strategy at a more detailed level.


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OST Review of Defra                                                                 RSPCA


We would suggest, and the results of a number of recent surveys of public opinion indicate,
that animal welfare is a matter of sufficient public concern to justify proper consideration in
strategic planning.

Defra’s five key priorities - Climate change & energy; Natural resource protection;
Sustainable consumption and Production; Sustainable Rural Communities; and Sustainable
farming and food - do not overtly address animal welfare issues. It may be argued that
“sustainable farming and food” could embrace at least the welfare of farmed animals; and
Defra’s more detailed strategy in this area does include a brief discussion of “animal health
and welfare”.

However, it was explained at the SAC Open Meeting in January that the “Sustainable
farming and food research Priority Group” had, in the development of its strategy,
specifically excluded any consideration of animal welfare. This, it was explained, was a
decision based on the expectation that the equivalent exercise under Defra’s Animal Health &
Welfare Strategy would encompass these issues. This latter strategy, as published, does
envisage the establishment of a Science Group - but it, and indeed its parent, the Strategy
Steering Group - have yet to be established.

Meanwhile, Defra’s Science & Innovation Strategy 2003-06 has only a section on “Public
and Animal Health”, which concentrates largely on diseases which pose threats to economic
or human health interests - there is no reference to the broader science of animal welfare.
This document, of course, preceded the Health & Welfare strategy, and in its text does note
that “plans may be changed” in the light of that document and the proposed Surveillance
Strategy. However, the Health & Welfare Strategy retains a considerable bias towards
animal health, and the Surveillance Strategy appears to be almost entirely concerned with
disease. Animal health and disease are clearly important components of welfare – but animal
welfare as a discipline is far wider.

Historically, Defra’s (formerly MAFF’s) interests have focussed largely on farm animal
issues when considering animal health and welfare. The Health & Welfare Strategy does
make mention of both companion and wild animals in setting out the scope of the strategy:
but the emphasis remains largely on farmed animals. The scope of the strategy in relation to
Wildlife is specifically restricted to where:
 there is risk of zoonotic disease
 there is risk of infection of farmed animals
 disease controls may affect wildlife
 there are issues of protection from cruelty
There is no cognisance of the welfare issues that may arise as the result of human activities
such as use of pesticides; wildlife management or control; field sports; road traffic; etc.

The Health & Welfare Strategy (Chapter 7) suggests that the Defra science research budget
amounts to £150m (although the Defra Science home webpage indicates a sum of £155m).
Of that £150m, it is suggested that £40m will be spent on animal health and welfare research.
However, of that £40m, only £3.5m (i.e. 2.3% of Defra’s total research budget) will be spent
on animal welfare: the rest will be spent on TSEs, TB, Exotic disease, Zoonoses, and
Veterinary medicines. Some of these latter, animal health issues will of course also have a
welfare component, but in most cases the primary interest lies either in human health or in
economic competitiveness. Defra does have some responsibility for the economics of farm
animal management, so the latter interest is relevant: but the OST Review may wish to


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OST Review of Defra                                                                RSPCA


consider whether it is appropriate for Defra to be allocating such significant sums on research
in which the primary interest is human health. It may be more appropriate for such work to
be done under the auspices of the Department of Health, the Food Standards Agency, or other
such body.

The RSPCA Director of Science raised the issue of prioritisation of animal welfare within the
Science Advisory Council at its Open Meeting in January. As noted in the draft minutes of
that meeting, the Chairman of the SAC responded only to say that, “as with other policy
issues, [animal welfare] may be picked up by the SAC under its work on strategy
development: Defra does have an animal health and welfare strategy. [There] is a qualified
veterinary surgeon on the SAC, with particular expertise on companion animals, and SAC
can co-opt additional members”. While fully recognising the expertise of the veterinary
member of the SAC, this response from the chairman seems to us to reinforce the concerns
we have expressed above. So far as we are aware, the absence of any specialist animal
welfare (as opposed to veterinary) scientist in the SAC is mirrored in the staff structures
within Defra.

The above comments are all based on the statements of principle and intent contained in
strategic documents. However, available data on current Defra research funding give some
indication of the current balance of priorities (although there may be some question about the
reliability of these data – see comments under criterion 4 below), and the way in which
strategies are implemented in practice.

The Defra website’s summary list of completed and current projects lists 35 subject areas,
with a total of 6,633 projects. It is not immediately apparent how these subject areas align
with Defra’s strategic priorities: however, our assessment is that these current and completed
projects would be assigned as follows:

Climate change                                       74
Natural Resource Protection                        2359
Sustainable consumption and production             2251
Sustainable rural communities                        87
Sustainable farming and food
(if animal health and welfare are included here)   1411

in addition, there are 451 projects assigned to “Science Policy”

Of the 1411 projects that may be assigned to “sustainable farming and food”, just 235 are
assigned to animal welfare; 630 to animal health, and 546 to “sustainable livestock farming”.
Thus in terms of numbers of projects, it would appear from the website that 235 out of 6,633
(3.5%) of current and completed projects relate to animal welfare.

If one examines the subject area of animal welfare in more detail, it is clear that only 29
projects are current, rather than completed, out of a total (according to the website) of
“approx. 2000 projects current at any one time”: that is just 1.45% of the total. Thus it
would appear from Defra data that not only has the research commitment to animal welfare
always been a small part of the whole; it has also declined in recent years.

Despite Defra’s publication of a variety of strategy documents over the past 3 years, the
RSPCA remains concerned that



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OST Review of Defra                                                                 RSPCA


a) animal welfare issues are not given sufficient priority within Defra’s strategic
   planning, and that this situation may be getting worse;
b) Defra as a whole, and Defra Science, is inclined to a narrow view of animal welfare
   which focusses on animal health, and tends to ignore the broader field of animal
   welfare science, which involves integration of a much wider range of scientific
   disciplines including animal behaviour, neuroscience and cognition, as well as the
   veterinary sciences;
c) Defra fails to recognise and/or commit research funding towards the areas of
   companion and wild animal welfare for which is has policy responsibility.


Criterion 4: Commissions and Manages new research

It is clear that Defra commissions large numbers of research projects: the RSPCA has limited
experience of the commissioning process, but that experience would suggest that the process
is thorough, open, and fair. Equally clearly, the management of such a large portfolio of
projects is a substantial administrative task. We feel unable to comment on the management
of individual projects, but as mentioned above, it appears, from some pages of the website,
that there are inconsistencies in the way that the overall portfolio is managed.

As noted above, the “Science and Research Projects” page lists 6,633 projects in 35 subject
areas. Of these, “Animal Welfare” is accredited 235 projects. However, following the link to
the more detailed listing of these 235 projects produces a list of only 120 projects. Either a
substantial number of projects (115) have no detailed listing, or the system for counting is
ineffective. We have not reviewed the situation for all 35 subject areas, but a sample reveals
many differences. Some (e.g. “Air Quality”, “BSE and other TSEs”, “Countryside and
Wildlife Initiatives”) show a count which tallies exactly with the detailed list. Others, like
“Animal Welfare” show considerable variance (e.g. “Arable Crops” – 353 or 199;
“Environmental Protection (Agriculture” – 885 or 480; etc). These discrepancies could lead
to significant confusion.

While it appears to us that the commissioning and management of individual research
projects is satisfactory, RSPCA believes there may be scope for improvement in the
administration of the overall portfolio.

Criterion 7: Publishes and debates results openly

While in many instances the RSPCA’s experience has been of a good degree of openness in
Defra over the results of their research projects, there have been some notable instances
where this has not been the case, where it appears that concern over either commercial
confidentiality or risks to peer-reviewed publication have led to a lack of openness. The
RSPCA is not convinced that the level of confidentiality that is imposed is always justified by
these concerns. One specific example may illustrate our concerns: that of Project AW0219
on Stocking Density and Welfare in Broilers. Further details are given in the annex to this
submission.

The RSPCA had serious concerns about several aspects of this research project, which were
represented to Defra: yet very little information, other than a brief publication in Nature, has
been made available, either during the project, or since its completion in March 2003.
Meanwhile, policy discussions on the future regulation of the broiler industry have been



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OST Review of Defra                                                                 RSPCA


proceeding in Europe, and we believe that the full results of this research have been used by
Defra officials in formulating and presenting the UK Government’s position. But the
RSPCA and other public bodies are unable to offer any comment on or analysis of the
research.

The RSPCA welcomes Defra’s commitment in principle to openness, but is concerned
that this principle may not be equally applied in all cases. We recognise that in some
instances commercial considerations, or the constraints of academic publication, may
restrict the information that can be made available: but we suggest that the scope of
such restrictions should be as restricted as possible, and we would urge the OST to
review Defra’s policy and internal guidelines on what information can and should be
made available on request in particular circumstances, and in what form (e.g.
“anonymised” to protect individual’s companies’ interests). Decisions “on a case by
case basis”, without guidance, may lead to unnecessary secrecy.

Criterion 8: Shares, manages and transfers knowledge

The RSPCA is aware of a number of instances within our own sphere of interest where
Defra-funded research has led to the development of practical improvements in animal
welfare, and we have used the results of a number of projects in the formulation of our own
policies and strategies. However, there appears to be no systematic process for ensuring that
such knowledge transfer does take place. We are not aware of any formal programme which
seeks to identify, collate, and transfer to the field the practical measures for improvement
which are identified by, or can be deduced from commissioned research.

For an organisation such as the RSPCA, with a wide interest in a range of research, it can be
difficult to track the progress of the large number of projects in which we might have an
interest, through the process of report, publication, and implementation. While specific Defra
Research Review seminars are helpful in providing an overview of project outcomes in
particular areas, they often cannot provide all relevant detail – and subsequent application of
results is not easy to gauge. The Defra web pages relating to research projects could offer
help in this, if they could provide not only a project report, but also links to published papers
and to information about practical implementation.

The RSPCA believes more could be done to ensure effective sharing and transfer of
knowledge. We would suggest that consideration being given to including in the
research project web pages - as well as a final report which is currently given where
available - links to published papers and to any information that may be available
about practical implementations of the results. Researchers should be required, as part
of the contract, to notify Defra of any successful application of the intellectual property
generated by the research.

The possibility of a periodic publication of a summary of practical applications and
benefits achieved as a result of Defra-funded research could also be considered.



Dr Arthur Lindley
Director of Science, RSPCA
April 6th 2005



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OST Review of Defra                                                                  RSPCA


                                                                                        ANNEX


    RSPCA submission to the Office of Science & Technology Review of
                           Science in Defra
              RSPCA Concerns over openness in Research Project AW0219


In 2000, Project AW0219 on Stocking Density and Welfare in Broilers was commissioned.
The work was to be done by Oxford University, using trials set up in established commercial
production units. Early in the development of the project, the RSPCA received a number of
complaints from industry representatives, alleging that they were being asked to establish
stocking densities that were sufficiently above the normal industry standard as to lead those
people to be very concerned for the birds’ welfare. Additionally, concerns were expressed to
the RSPCA by others with an interest in the industry that, as it was understood that at least
some of the raw data were to be gathered by staff at the production units, rather than by the
university’s researchers, there could be opportunities for biassed, inaccurate, or false data to
be gathered into subsequent analysis.

The RSPCA tried, on numerous occasions through correspondence and meetings with both
Defra and the researchers, to elicit information which might help us to evaluate these
concerns. Requests for information about the participating units, or the range of stocking
densities being trialled, and requests to visit sample units, were all refused on the grounds of
commercial confidentiality. Questions as to why, despite stocking densities that clearly
exceeded Defra’s own Code of Practice specifications - which is the usually accepted
benchmark for the difference between “normal husbandry” and “experimental procedures”,
the project had not been referred to the Home Office for consideration under the Animals
(Scientific Procedures) Act were passed from one Department to the other without a clear
response. Requests for information about what protocols were used to validate the quality
and accuracy of data gathered were refused on the grounds that it could prejudice peer-
reviewed publication (although we pointed out that it is normally pre-publication of results,
not methodologies, which can give rise to such problems).

During the early period of this research, the project was not listed at all on the Defra website
list of projects. Much later, it did appear, with an outline specification which included some
information, but not enough to answer all the RSPCA’s concerns. Following the completion
of the project, some results have been published (Nature, 22nd Jan 2004). Inevitably,
however, because of the nature of the journal, the paper was short, and only a few key results
were presented, and there was no substantive discussion of methodology.

In response to an email question from RSPCA’s Director of Science on this issue, the Chief
Scientific Officer said only that “requests for further information are considered on a case-by-
case basis, but commercial confidentiality…intellectual property rights…and publishing
research…are considerations taken into account.” He also said “In general, final project
reports are published within 2 months of receipt of a satisfactory report.” So far as the
RSPCA is aware, no final project report has been published, more than two years after
completion (none has appeared on the relevant web page) – although we understand that a
brief presentation on the project will now be given at the Defra Research Review Seminar
relating to on-farm poultry welfare in June.


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