A report (May 2014) by the UK’s Farm Animal Welfare Committee (FAWC) – a UK government advisory body – calls on the EU to amend its existing animal welfare legislation to end inhumane methods for killing farmed fish.

Farmed fish should be stunned before slaughter

The FAWC report Opinion on the Welfare of Farmed Fish at the Time of Killing argues that all farmed fish should be stunned before they are killed to avoid suffering during killing:

The humane stunning of farmed fish is necessary to remove fear, pain and distress at the time of killing. FAWC believes that all farmed fish should be stunned before killing, whether or not death accompanies the stun (as in stun/kill methods) or when death follows some short time after the stun but before the fish has the time to regain consciousness.

Stunning may be achieved percussively (by a blow to the head) or electrically. The FAWC report argues that the following methods of killing cause suffering and are therefore unacceptable:

  • leaving fish to asphyxiate or bleed to death with prior stunning
  • killing with carbon dioxide and
  • killing by rapid chilling.

The FAWC report contains 6 tables which describe the principle humane methods that have been developed for salmon, trout, halibut and tilapia, together with descriptions of inhumane methods still used in the EU and beyond for comparability. The information has been collated from peer-reviewed publications.

Farmed fish slaughter in the UK

FAWC notes the large number of animals impacted by UK fish farming and estimates that over 100 million fish are being grown in farms at any particular time. [Fishcount estimates that up to 110 million farmed fish were killed for food in the UK in 2010]

FAWC believes that, in the UK, salmon, trout and flatfish are normally percussively or electrically stunned at slaughter. In the UK industry, the normal method of stunning/killing salmon and larger trout is to apply a mechanical percussive stun from which the fish will not recover. Smaller trout are normally stunned electrically with sufficient current and duration to disrupt their respiration for long enough to cause death. Flatfish are usually stunned/killed with a percussive blow.

There are no statutory government codes to regulate farmed fish slaughter in the UK, but there are a number of certification schemes with a variable focus on fish welfare. FAWC note the wide uptake of RSPCA Freedom Food standards for farmed salmon and the recent publication of RSPCA Freedom Food standards for farmed trout. The RSPCA schemes permit only humane methods of killing during slaughter for food and when fish are culled for any other reason.

Growing recognition of farmed fish welfare during killing

The FAWC report notes the fish welfare codes published by the International Organisation for Animal Health (“The OIE”), whose “guidance is a baseline for farmed fish production on a global basis” : 

   Introduction to recommendations for the welfare of farmed fish
   The welfare of farmed fish during transport
   The welfare aspects of stunning and killing of farmed fish for human consumption
   The Killing of farmed fish for disease control purposes.

These codes recommend that:

The use of fish carries with it an ethical responsibility to ensure the welfare of such animals to the greatest extent practicable
and that
as a general principle, farmed fish should be stunned before killing, and the stunning method should ensure immediate and irreversible loss of consciousness. If the stunning is not irreversible, fish should be killed before consciousness is recovered.

FAWC notes the publications of the European Food Safety Authority (EFSA) concerning welfare during slaughter for several species of farmed fish:

   Species-specific welfare aspects of the main systems of stunning and killing of
      farmed Atlantic Salmon
      farmed turbot
      farmed carp
      farmed eels (Anguilla Anguilla)
      farmed seabass and seabream
      farmed rainbow trout
      farmed tuna

and on the ability of fish species to experience pain and fear:
      General approach to fish welfare and to the concept of sentience in fish

and on knowledge gaps and research needs for the welfare of farmed fish:
      Knowledge gaps and research needs for the welfare of farmed fish.

Current EU Legislation on farmed fish welfare

The welfare of farm animals during slaughter is covered by the European Council Regulation No. 1099/2009 on the protection of animals at the time of killing, which came into force on 1 January 2013. In the UK, this will be supported by domestic legislation (2012 in Scotland and 2014 in England, Wales and Northern Ireland).

Under this Regulation, fish are covered by the key principle that “Animals should be spared any avoidable pain, distress or suffering during their killing and related operations” (Article 3(1)). However, Regulation 1099/2009 specifically excludes detailed provisions for fish, which means that inhumane killing methods are not explicitly prohibited – FAWC calls for this to be addressed.

An EU Commission report on the possibility of introducing certain requirements regarding the protection of fish at the time of killing, taking into account animal welfare aspects as well as the socioeconomic and environmental impacts, is due to be submitted to the European Parliament and to the EU Council no later than 8 December 2014. This may be accompanied by legislative proposals for the protection of farmed fish at the time of killing.

FAWC recommendations

The FAWC report makes several recommendations relating to use of humane methods of killing and for reducing welfare impact during pre-slaughter feed withdrawal, crowding, handling and transport.

The FAWC report calls on the EU to include detailed provisions for the protection of farmed fish at time of killing. The tables 1-6 in the FAWC report are set out in the format of Annex 1 of European Council Regulation 1099/2009 to indicate how parameters for fish might be included in welfare at killing legislation.

The welfare of farmed fish during rearing is covered by Council Directive 98/58/EC concerning the protection of animals kept for farming purposes which has a general requirement that animals are not caused any unnecessary pain, suffering or injury. However, as with Council Regulation No. 1099/2009, fish are excluded from the detailed provisions set out in its Annexes. FAWC has called for this to be addressed in its separate Opinion on the Welfare of Farmed Fish (2014).