This statement describes a campaign started by the Vissenbescherming (the Dutch Foundation for the Protection of Fish), the Dierenbescherming (the Dutch Society for the Protection of Animals) and the Sea First Foundation in collaboration for the fast stunning and killing of fish on fishing vessels. We work together in this campaign with Eurogroup for Animals, that has made the improvement of fish welfare one of their twelve strategic goals for 2015-2020.
In this statement, we would like to inform you of the objective of this campaign, to provide you background information on stunning fish on board, and to inform you about the current and future developments in Dutch and European laws and regulations. We do proposals to the fisheries in the Netherlands and Europe how the stunning method can be introduced quickly and we request the support of other animal welfare organisations.
a. The campaign’s goal
The goal of the Vissenbescherming, the Dierenbescherming, the Sea First Foundation and the Eurogroup for Animals strive is that every fish that is caught by Dutch, and at a later stage by European fishers, is stunned and killed as quickly as possible so that the fish does not suffer unduly. This is now our main priority.
b. Why this campaign?
Scientific research over the last few years has clearly demonstrated that all fish regardless of their species are animals that feel pain, stress and fear. Every year, trillions of fish are caught around the world, of which probably more than one hundred billion is caught by European Union fisheries. The large majority of these fish are likely to suffer immensely, first by the method of capture and thereafter in the long struggle with death that awaits them on the fishing vessel. In terms of scale, the suffering of these trillions of fish is the largest that humans inflict on animals. By stunning the fish immediately when taken on board, they are saved from enduring a slow death from suffocation. It also avoids the live filleting of fish and the removal of their innards while alive, as often happens at present.
c. Background information about this campaign and about the stunning of fish on board
For more than twenty years, animal protection agencies have demonstrated that the way in which fish are caught and killed entails much animal suffering, and that this cannot continue. Scientific research using brain measurements has demonstrated that many fish remain conscious for many minutes up to several hours before dying, even if they are placed on ice on board. Awareness is slowly growing among the public, scientists, politicians and even in the fisheries that a radical change is needed in the fisheries in order to improve the welfare of fish.
These developments have triggered research programmes into fish stunning techniques. Together with Norway, the Netherlands is at the forefront of this work. Initial research was mainly in the aquaculture sector, and over the last couple of years this sector has adopted good stunning methods for salmon, eel and catfish. With Dutch and European funding, a research project called PALSED recently developed a method to stun captured flat fish and cod on board in the wild fisheries sector using electric current. IMARES, the University of Wageningen’s research institute, has defined the strength of current that is needed to stun the animals. If the fish are killed shortly thereafter, they do not regain consciousness. This on-board method is currently being fully developed by IMARES and Ekofish, a fishery from Urk in the Netherlands which had commissioned the PALSED research. Tests are currently being carried out to refine the dosing method that ensures that not too many fish in one time enter the stunning unit.
Ekofish was one of the first fisheries to recognise that fisheries have a huge impact on the welfare of captured fish and that this is a serious problem. Ekofish has made significant investments to change this. The company hopes that it will be able to use the stunning method on one of its vessels by the end of this year and is planning, once the financing has come through, to eventually install stunning units on all its vessels.
Fortunately, major changes are taking place elsewhere in the fisheries sector. Scienta Nova, the research institute that led the PALSED project, states on its website that this stunning and killing method will be the new standard in the fisheries in the near future.
There is relatively little flat fish caught in the European Union. Much more of the fish caught are pelagic fish such as mackerel and herring. These make up about one quarter of all captured fish. This means that it is now important that research is carried out into whether and how a stunning method can be used for pelagic species. As these are completely different types of fish and they are caught simultaneously in far larger numbers – about 50 tons per haul compared to 4 tons for flat fish – it will take a few years for this to be researched thoroughly and for a stunning method to be designed for these species. Because of this we already started in the Netherlands talks with businessmen from the pelagic fisheries if they’re prepared to help develop such a stunning method.
The research done to date and examples in practice can be found on http://fishcount.org.uk/recent-developments/research-paper-on-board-stunning.
d. The next steps in the Netherlands
We, as animal protection agencies, strive to alert the Dutch fisheries to their responsibilities. The Dutch fisheries benefit largely from nature but present themselves as a sector that strives to treat nature with respect. That’s an image that the fishers like but that doesn’t correspond with letting fish suffer in current fishing methods. This is even more so now that stunning methods will exist for a few fish species or hopefully will be available soon for much other fish species to dramatically reduce the suffering of fish.
All fishers, initially in the Netherlands and after that in the rest of Europe, should stun their fish as quickly as possible. Much persuasion will be needed and many hurdles need to be removed before fishers are convinced to adopt stunning methods. And it’s difficult at present for many fisheries to obtain credit to invest in their companies. But such obstacles can also be taken away.
For us, the primary reason for stunning fish is to avoid the fish suffering. But there are also major advantages for the fishers. The stunning method can greatly improve the quality of the meat for consumers as the fish experience far less stress. If the animal can be put into a container of ice cold water after stunning, the meat will stay fresher and the animal can be kept longer. Further, a stunned fish is far easier to process than a struggling fish, creating improved labour conditions on board.
From 1 January 2015 onwards, it will be regulated by law that all eels, both wild captured and farmed, must be stunned in the Netherlands. This will prevent them from suffering a long struggle before death. We would like to see this type of regulation applied to all farmed and wild captured fish. To this end we have approached the Dutch political scene. Partly as a result of our persistence, this subject was brought forward by a number of Members of Parliament in the committee for Economic Affairs during a consultation about animal welfare on December the 2nd 2013. Minister Dijksma, in a previous letter to the Parliament stated that she would make 150,000 Euro available every year for research into stunning methods. This is a good step, but it is not enough to enable us to reach our objective. During the consultation, Dijksma added that she would first await the results of the research and for the time being will not stimulate the fisheries to quickly adopt a stunning method.
As animal welfare agencies, we will press ahead and have started to discuss our plans with the large Dutch fishermen associations, like VisNed and the Nederlandse Vissersbond. We want to know what they think of the new stunning and slaughter method and what they will do to implement this method on Dutch fishing vessels. We would also welcome other organisations from the fisheries sector to be involved in these discussions.
We would like to see the fisheries sector defining a plan as to how the stunning method can be adopted on board of every fishing vessel in the Netherlands. The plan should also outline the possibilities of financing the necessary investments. We will encourage it being produced as quickly as possible. A plan like this will increase the chance of getting the government to take action on regulating the stunning method and to help find funding for the necessary investments.
This will also allow us to seek support for stunning methods among others who are interested in fish or fisheries. Conservation agencies and chefs can express their preference for stunned fish and, in so doing, levy additional pressure for the new method to be adopted. We would like to start discussions with supermarkets and their organisations, and with the hospitality industry, and ask them to choose stunned fish above non-stunned fish, as soon as it is on the market.
e. European politics, the law and fish welfare
The European Union (EU) has made a number of clear declarations about fish welfare and related subjects. In a 2009 document, the European Food and Safety Agency (EFSA) stated: ‘the concept of welfare is the same for all animals, i.e. mammals, birds and fish, used for human food and given protection under the Treaty of Amsterdam’. Also in 2009 in the ‘Council Regulation on the protection of animals at the time of killing’, the EU regulated in article 3.1 that ‘Animals shall be spared any avoidable pain, distress or suffering during their killing and related operations.’ This article also applies to wild captured and farmed fish. On behalf of the European Commission in 2009, Commissioner Vassiliou answered a question in writing as follows: ‘The Commission acknowledges that there is now sufficient scientific evidence that fish are sentient beings and that they are subject to pain and suffering notably when they are killed.’ These are clear European statements about the welfare of fish, but unfortunately, they are not reflected in European policy.
The new Common Fisheries Policy have been debated for several years, but in April 2014 the European Parliament laid down the law for the next seven years, and the Council of Ministers has done the same a month later. We have done our best to have at least some aspects of the changes needed to avoid animal suffering in the capture and killing methods included, but despite the statements of the EU above, we were unsuccessful. That said, the basic regulations of the new policy do state that ‘The Common Fisheries Policy should pay full regard, where relevant, to animal health, animal welfare, food and feed safety.’ The European Maritime and Fisheries Fund was appointed to ensure that these regulations are adhered to. The European Parliament, with our encouragement, has been able to add to this Fund as a criterion for funding: ‘reducing the negative influence of fisheries on animal welfare’. This addition simplifies the subsidizing of research into new capture and killing methods and can be used in all EU countries.
In the Netherlands, the government has clearly stated the need for good stunning or killing methods for fish. Our request now to the Dutch government is that it really makes an effort to enforce these methods. The political scene at European level has not taken a firm position on good stunning or killing methods. The first steps need to be taken at that level. The lobbying to recognise the need for stunning and for subsequent research will be started now the new European Parliament is installed and there soon will be a new European Commissioner for Fisheries. Our ultimate aim is that all fish throughout the European Union are stunned when hauled on board fishing vessels.
It is therefore important that efforts, originating in the Netherlands and Belgium, made to have captured fish stunned on board and for more attention to be paid to fish welfare in general are now supported and progressed with even more power by the Eurogroup for Animals with his more than forty member organizations.
A good opportunity to raise this issue is the feasibility study that the European Commission is currently doing for the preparation of a possible European Animal Welfare Framework Law. This opportunity will also be used by the Eurogroup for Animals. In 2012, the Commission had already proposed research into the welfare of fish in its Animal Welfare Strategy 2012-2015, and this proposal needs to be implemented.
Now that there are finally concrete options to adopt stunning methods in the not too distant future, these must be prioritised. We can now really take action to reduce the enormous scale of poor welfare conditions for captured fish. It is a huge step forwards if stunning on board is enforced.
But next to this, we need to continue advocating for good stunning or killing methods in aquaculture and the development of capture methods that cause less suffering to fish.
g. A major change for fishers
As animal welfare agencies, we are aware that the new stunning method and everything needed to improve fish welfare will bring a major change to fisheries. This change will need to be implemented by the fishers who will have to handle the fish with much more care. They are used to being their own boss at sea and can do what they like to the fish. This is no longer acceptable and they are now required to handle these animals with respect. This asks a shift in mentality among fishers throughout Europe and the world. We will encourage them to do this for the welfare of fish and we call all the fisheries do adopt these new methods as soon as possible.
Much thought and effort over the years will be required of us all if we are to achieve this. The Eurogroup for Animals, Sea First Foundation, Vissenbescherming and Dierenbescherming are prepared make this effort, and we hope for collaboration with other parties.
Eurogroup for Animals, Vissenbescherming, Sea First Foundation and Dierenbescherming, 26-9-2014.