Consultation on animal welfare reform in Victoria needs our ideas


Source: Victorian Government

The Victorian Government is consulting on animal welfare reform. Submissions to Improving the Welfare of Animals in Victoria. Draft Action Plan 2016-2021 are due on 11 October.


I have just emailed my submission, and if you live in Victoria, I encourage you to have your say, too.

Here is what I wrote to The Hon Jaala Pulford MP, Minister for Agriculture, and Ms Lizzie Blandthorn MP, Member for Pascoe Vale (I have not commented on all aspects of the draft plan):


Dear Minister Pulford and Ms Blandthorn,

Thank you for the opportunity to comment on the “Improving the Welfare of Animals in Victoria. Draft Action Plan 2016-2021”.

Overall comments

I agree with the broad three action areas proposed in the draft plan. I also share your view that Victoria needs a proactive plan that promotes evidence-based animal welfare practices and reflects community expectations, and that we need a collaborative approach to accomplish this. To achieve all this, it is of utmost importance that the animal welfare portfolio and the regulation of animal welfare are free of conflict of interest. Currently, this is not the case while these roles sit within the Department of Economic Development, Jobs, Transport and Resources. To be effective, fair to the animals and responsive to community expectation, the animal welfare portfolio has to be independent of the agriculture and industry portfolios. An independent office of animal welfare, set up as a statutory authority, is needed.

In the draft plan, you point out correctly that “Animals are able to perceive their environment, and experience sensations such as pain and suffering, or pleasure and comfort”. Our knowledge of animal sentience and cognition is constantly increasing. For example:

  • fish perception and cognitive abilities often match or exceed other vertebrates, and fish experience pain in a manner similar to the other vertebrates (1)
  • animals suffer psychological pain in the form of fear and stress, caused by conditions such as captivity, confinement, physical harm, loss of social bonds, and isolation (2)
  • in 2012, a group of cognitive neuroscientists, neuropharmacologists, neurophysiologists, neuroanatomists and computational neuroscientists declared “that humans are not unique in possessing the neurological substrates that generate consciousness. Non-human animals, including mammals and birds, and many other creatures, including octopuses, also possess these neurological substrates” (3).

Thus animals deserve moral consideration and it is our obligation to protect them from human-inflicted pain and suffering. For example, animal use for sport and entertainment that results in pain, suffering and/or death is morally indefensible and should stop. Consequently, as a first step, recreational shooting (in particular duck shooting), jumps racing and greyhound racing should be disallowed in Victoria. Some states have already banned duck shooting, and greyhound racing will be banned in NSW and possibly the ACT from next year. If it is possible in other states, why not in Victoria?

In regard to the action areas as outlined in the draft plan, I offer the following comments:

Action area 1: Victoria has contemporary animal welfare laws

As you state in the draft plan, it is important that welfare legislation in Victoria is contemporary. The community expects that animal welfare legislation is developed with compassion and fairness. Therefore, the development of animal welfare legislation should be led by a body free of conflict of interest, such as an independent office of animal welfare.

The development of regulation and legislation should be, as you note, evidence-based and consequently free of conflict of interest. Therefore, the plan should spell out clearly that on relevant panels and decision-making groups those individuals and groups with a financial or other personal interest in the use of animals (such as recreational shooters) should be in the minority, if consulted at all.

In your list of stakeholders you include animal owners, industries, stakeholder and enforcement groups and the community. Where are animal welfare/ animal advocacy groups? The words “animal advocacy” or “animal advocate” do not appear in this document. Given that this document is concerned with improving the welfare of animals, and not improving the use of animals for the benefit of humans, and that animals can’t speak for themselves, animal advocates need to be given greater prominence in the document.

Codes of practice have in the past been developed by industry. They are part of industry self-regulation and have not served animals well. For example, the commercial production of “food animals” allows practices that the community finds abhorrent, such as tail docking and castration without anaesthesia or pain relief. The development of appropriate and humane animal husbandry practices should not be left for industry to decide. An independent office of animal welfare, as suggested above, should take a leading role in the development of codes of practice and animal husbandry regulation.

A review of Victoria’s current animal welfare legislation is timely. For example, Victorian primary and secondary schools are required to obtain approval from an animal ethics committee (AEC) for educational projects that involve live animals. However, there is no such requirement for early childhood services. Thus, for example chicken hatching projects undertaken in schools require ethics approval, but the same projects undertaken in early childhood services do not. This must have been an oversight when the legislation was introduced, and early childhood services should be brought in line with schools.

Action area 2: Collaborative approaches underpin knowledge, commitment and investment in animal welfare

A collaborative approach works best when it is free of conflict of interest. As noted above, it is crucial that the animal welfare portfolio is independent of industry and other groups with an interest in the commercial or recreational use of animals.

2.1 a) Identify opportunities for innovation, collaboration and investment, on activities that promote and implement sound animal welfare practices.

Animals that are used for their meat, eggs and milk comprise by far the largest number of animals whose welfare depends on humans. The large number of “food animals” is unsustainable for three reasons:

  1. The conditions under which animals in factory farms are kept are inhumane: confinement, overcrowding, surgical procedures without anaesthesia or pain relief, the creation of “waste animals” (such as male chicks and male calves). If we kept our pets in such conditions, we would be rightly accused of animal cruelty. Many common practices in factory farming are legalised animal cruelty.
  2. The over-consumption of animal products is one of the factors that have led to a public health crisis in Australia. Dairy and meat products have been linked to various cancers, cardiovascular disease, diabetes and Alzheimer’s (e.g., 4, 5, 6). Further, the emergence of antibiotic resistant bacteria is largely due to the non-therapeutic use of antimicrobials in factory farming. It leads to the development of drug resistance and is already a serious problem for our health system (7, 8).
  3. The negative impact of meat and dairy production on the environment has been well documented (e.g., 9, 10-12). For example, it contributes to the pollution of our land, air, and water, and to climate change.

The fact that factory farming is unsustainable has also been identified by the finance industry (e.g., 13, 14). It is therefore in the best interest of the community and the animal agriculture sector for governments to support producers to transition to plant-based products.

2.1 d) Ethical care and use of animals for research, testing and teaching

Ethical care and use of animals in research and teaching requires transparency and making information that is of interest to the community publicly available. Given that much animal research is publicly funded, transparency is also part of accountability to the public. For example, why does Victoria not make the names of licence holders publicly available, like some other states do (e.g. Tasmania)? Why are the licensed institutions’ annual reports to the state government not publicly available (identifying details redacted)?

I suggest that you add to this section a statement declaring the intention to provide greater transparency in regard to animals used for scientific purposes and teaching. Further, I suggest that Victoria work together with other states/territories to achieve consistency in reporting of animal use data in research and teaching.

The Australian code for the care and use of animals for scientific purposes (15) states that opportunities to rehome animals should be considered wherever possible. I suggest that Victoria go beyond the “should be considered” and require serious rehoming efforts for suitable animals at conclusion of their use in research and teaching.

Action area 3: Compliance and enforcement is efficient and effective

Compliance and enforcement relies on adequate resources. The compliance and enforcement system needs to be better funded and supported to do its important work. A commitment to adequate funding should be included in the plan.

3.2 b) provide training and advice to applicants and holders of licences to use animals for research, testing and teaching

Further to the training courses and best practice guidelines as suggested in your draft plan, I propose training for institutions and AECs not only about the Australian code for the care and use of animals for scientific purposes and its interpretation, but also about non-animal methods to strengthen implementation of the 3Rs (Replacement, Reduction and Refinement) as required by the Code.

Overall, most of the deliverables as outlined in the draft plan appear worthy of support, but I have not commented on these to keep my submission brief or because I do not know enough about the issues to be able to comment (e.g. wildlife management).

I commend your initiative to develop this plan and am looking forward to a Victorian animal welfare plan that promotes strong protection and that will improve the welfare of animals in our state.


Monika Merkes PhD (public health)


  1. Brown C. Fish intelligence, sentience and ethics. Anim Cogn. 2014 2014/06/19:1-17. English. Available at:
  2. Jones RC. Science, sentience, and animal welfare. Biology & Philosophy. 2013;28(1):1-30. Available at:
  3. Low P, Panksepp J, Reiss D, Edelman D, Van Swinderen B, Low P, et al. The Cambridge Declaration on Consciousness. 2012. Available at:
  4. Song M, Fung TT, Hu FB, et al. Association of animal and plant protein intake with all-cause and cause-specific mortality. JAMA Internal Medicine. 2016 (1 August). Available at:
  5. Satija A, Bhupathiraju SN, Rimm EB, Spiegelman D, Chiuve SE, Borgi L, et al. Plant-based dietary patterns and incidence of type 2 diabetes in us men and women: Results from three prospective cohort studies. PLoS Medicine. 2016;13(6):e1002039. Available at:
  6. Grant WB. Using multicountry ecological and observational studies to determine dietary risk factors for Azheimer’s disease. Journal of the American College of Nutrition. 2016 2016/07/03;35(5):476-89. Available at:
  7. O’Neill J. Antimicrobials in agriculture and the environment: Reducing unnecessary use and waste. Wellcome Trust and UK Government, 2015. Available at:
  8. World Health Organization. The evolving threat of antimicrobial resistance. Options for action. Geneva: WHO, 2012. Available at:
  9. Westhoek H, Lesschen JP, Rood T, Wagner S, De Marco A, Murphy-Bokern D, et al. Food choices, health and environment: Effects of cutting Europe’s meat and dairy intake. Global Environmental Change. 2014;26(May). Available at:
  10. Springmann M, Godfray HCJ, Rayner M, Scarborough P. Analysis and valuation of the health and climate change cobenefits of dietary change. Proceedings of the National Academy of Sciences. 2016 March 21, 2016. Available at:
  11. Djekic I. Environmental impact of meat industry – Current status and future perspectives. Procedia Food Science. 2015 //;5:61-4. Available at:
  12. Steinfeld H, Gerber P, Wassenaar T, Castel V, Rosales M, de Haan C. Livestock’s long shadow. Environmental issues and options. Executive summary. Rome: Food and Agriculture Organization of the United Nations, 2006. Available at:
  13. Farm Animal Investment Risk & Return, Share Action. The future of food: The investment case for a protein shake up. 2016 Briefing. 2016. Available at:
  14. Alembakis R. Australian Ethical Investment engages on sustainability of meat: The Constant Investor; 2016 [updated 6 October 2016; cited 2016 9 October]. Available at:
  15. National Health and Medical Research Council. Australian code for the care and use of animals for scientific purposes. 8th Edition 2013. Canberra: NHMRC, Australian Government, 2013. Available at:



One thought on “Consultation on animal welfare reform in Victoria needs our ideas

  1. Zerin Knight

    Monika, I applaud your considered and intelligent response to the draft plan for animal welfare. Let’s hope your suggestions are implemented. Thank you for being a voice for the voiceless.


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