Member survey highlights potential for RSPCA divide

Published on : 27 Aug 2024

Seeking direct feedback from farmers to inform future dialogue with policy makers, BFREPA polled our members to take stock of the reaction to 13 of the proposed changes within the revised RSPCA standards for Laying Hens. Analysis of results after the survey closed on 27th July, perhaps unsurprisingly, suggests an industry with an uncertain outlook towards this voluntary assurance scheme. A full breakdown of responses is available in the Members Area on the BFREPA website.

As a reminder, the RSPCA standard revisions were announced in the run up to the 2023 BFREPA Conference, sending shockwaves throughout the industry. Since their first iteration, through discussion with farmers and wider trade, some modification and concessions to previous timelines have been made. The demand that verandas be fitted to new-builds, for example, has gone by the wayside.

In their current guise, requirements such as the provision of natural light for 8 hours every day through apertures equivalent to 3% of floor area are due to be included in the February 2025 publication of the standards, and enforceable by 1st January 2031. Other aspects, including the extension of natural vegetative cover such as trees or shrubs to 20% from the existing 5% of total range area, come into force much sooner. At least 20% of the range must be planted by 1st May 2026, although 63% claim that this is unworkable, owing in combination to limiting tenancy agreements, biosecurity concern or co-grazing requirements.

As discussions raged in the BFREPA forum community across the Telegram social media platform, we asked our 600 strong free range producer members to provide anonymised replies to questions touching on each of the main amendments or areas indicated as still ‘to be reviewed’ such as stocking densities or hen catching methodology. The RSPCA have indicated that areas in review will be consulted on if they decide progress with them in the future. To aid informed answers, BFREPA provided the RSCPA proposal together with a summary of early industry challenge. Farms had the same four options of response to every question, in summary:

A) Implementation would be extremely difficult / impossible due to cost, or impact on income or existing farm layout

B) Implementation is possible with changes to house or range

C) Already compliant or see no issues with implementation

D) More information required

The RSPCA Assured proposal to review (reduce) the stocking density of laying farms drew the most polarised reaction, with 80% of respondents saying that this would be extremely difficult or impossible.

67% of responses said that the provision of natural light, either fully or partially delivered by existing pop holes, was extremely difficult or impossible, although 20% felt that it would be possible with changes and a further 5% foresaw no issue. RSPCA Assured have provided guidance as to how to measure existing daylight provision from pop holes, depending on whether houses are equipped with multi-tier or flat-deck systems, and an online calculator is being developed to help everyone check their own status.

Other areas generating an emphatic level of concern include the proposal to review alternative handling methods during depopulation, specifically upright catching. 73% of responses said this was extremely difficult or impossible, and a further 22% seeking more information. Only 5% felt such a method was feasible, either under current circumstances or with changes to their house.

New rules reaching beyond an existing remit?
RSPCA encourages the future proofing of houses to allow for whole house gassing as a last resort in times of notifiable disease, although this is not mandatory. They aim to develop future standards to ensure on-farm mass culling is effective and humane. This is why the standards include non-mandatory information boxes on how producers can do this. In response to the ask that houses be designed with this in mind, 60% of farmers stated that this was impossible or extremely difficult. A further 22% sought more information.

Linked to biosecurity control measures, the RSPCA have introduced clauses to mandate the implementation of a written Wild Animal Control Plan (WACP), to partially control access of domestic animals and to forbid long-term baiting as a rodent control measure. In all three cases, the scheme appears to go beyond a threshold of focus on laying hen health and welfare, to the befuddlement of the surveyed farmers. Of the WACP, 30% said they didn’t have enough information to comment on. The RSPCA states that wild animals can have a direct impact on the health and welfare of hens, for example a fox attack or the spread of disease, as such the inclusion of these measures is relevant to hen health and welfare.

According to RSPCA Assured, farm dogs and cats are allowed access to the poultry unit, despite the known food safety risks this presents. Other domestic animals are barred, but it’s not clear how this would be interpreted; is co-grazing of, say, a horse a problem? Again, 36% of farms said they couldn’t answer whether they could abide by such standards without more information, although 41% felt it wasn’t a problem.

Farmers were clearer on the removal of permanent baiting. Again, as a clear food safety risk, rodent control is imperative. More than half of replies said doing without long-term baiting was impossible or very difficult, and 20% needed more information.

New standards will state that the pop holes in pre-existing houses that are greater than 40cm above the permanent floor will require ramps. For new houses, the base of the pop hole must be no more than 20cm from the floor. Industry feedback has challenged the evidence base for such a move, raising concerns of litter containment with low walls and red mite or floor eggs with ramps. Consistent with such feedback, over 59% of survey answers said it wouldn’t be feasible, although 14% did say they are already compliant.

Once on the range, under new rules, hens would be given at least 4 shelters per hectare although 54% of farms said this was either impossible or very difficult to provide. Industry concern surrounded the practicality of enforcement, the threat of disease or storm damage and the lack of evidence to support an increase in provision.

The requirement that any in-range fencing have no obstruction below 45cm in height, meaning hens have permanent access to 100% of the fields at all times. The counter argument is that such a rule takes no account of rotational management or co-grazing. 58% of responding producers agree, claiming such a clause impossible or extremely difficult to implement. 34% felt it was achievable, including 18% already compliant.

For new scheme entrants, the shape of the range and the position of the building within it is now within the scope of RSPCA Assured, aiming to ensure the birds have as direct access and visibility of the full range without the need to be funneled along a thoroughfare. Whilst this applies to new developments, it is likely to be complicated by planning constraints and act as another barrier to an already perilous access to market. In the responses, it’s noted that only a third of farms presently comply, with 42% saying it would be impossible, indicating just how significant such a ruling might be in limiting growth. The industry concern is that if we cannot meet the volume demands of our market, imports abiding by totally different rules will once again take a place on the shelves.

Ranger comment
155 producers took the time, typically 7 minutes, to complete the survey. A turnout of around 25% is disappointing, and at odds with the perceived frustration that this potential imposition of far-reaching requirements has stirred.

It’s telling that of 13 clauses, 6 left at least 20% of responding farmers unable to determine whether the new rules could be implemented until further clarification or information had been provided, indicating perhaps that some of the new standards are simply not clear enough.

According to feedback in the most recent BFREPA packer price survey, over 80% of free range farms are accredited by both Lion Code of Practice and RSPCA Assured. Both protocols are voluntary, but they act as a license to operate in the commercial egg market. If your eggs are destined for anywhere other than a local market, a small wholesaler or a processor, the chances are that your customer requires that you abide by these rulebooks. Any changes to either code, therefore have the potential to impact a large majority of the trade. It’s therefore important that due consideration and consultation, supported by meaningful evidence, is provided ahead of any installation.

A two-tier trade?
Initial reaction to the RSPCA Assured beefed-up policies was one of disillusionment and rejection. Farmers calling for the wholesale removal of the scheme questioned why the Lion Code of Practice could not be repositioned to create a single all-encompassing standard. Retailers have been silent in expressing their views, but sources close to supermarket agricultural teams say that the likelihood of a unified, single code of practice is low. There is too much value in the consumer perception that the RSPCA Assured program is protecting farmed animals, and it remains a marketable point of difference in an otherwise indistinguishable and commoditised arena.

This thinking, however, applies to a nil-cost option, as is the current situation. If farms refused to comply, it would require packers and retailers to provide financial incentive to drive uptake. Dependent on the prevailing market conditions and the balance of negotiating power between producer and purchaser, the cost of could be a couple of coppers, or it could be tens of pence per dozen. Either way, coverage of the majority of the market seems highly improbable, leading us to a more clearly defined split between retail chain supply groups.

The survey can be found in the members area.