BEF response to Animal By Products Review

The British Equestrian Federation’s response to A Request for Views on the Review of the Animal By – Products Regulation (EC) No.1774/2002

 1. The British Horse Society (BHS) works to promote the interests of all horses and of the 4.3 million people in the UK who ride, or who drive horse-drawn vehicles, or who work with horses.  With the membership of its Affiliated Riding Clubs, the BHS is the largest equestrian charity in the UK.

2. The BHS is one of the 16 members of The British Equestrian Federation (BEF).  These members include the various equestrian disciplines and other equestrian sectoral interests.  This response is therefore made on behalf of the BEF.

Annex II:  Pet animals – Horses.

3. The BEF notes that the Proposal explicitly recognises that “for certain businesses, it is not possible to apply the full requirements relating to the collection, transport and disposal [of animal by-products] and that, in some cases, local arrangements can suffice…avoiding undue burdens on small businesses.”  If it is true that the Regulations can in certain circumstances, without harm to the overall imperative of securing uncontaminated water supplies, be applied with a lighter touch, and if it is recognised that the full application of the Regulations would unduly burden some businesses, then the same considerations must apply to private owners of horses.

4. The BEF does not consider that horses should invariably, and for every purpose, be classified as agricultural or farmed animals in line with other EU legislation where such classification is manifestly in conflict with the facts.  Where horses are kept as pets, being neither farmed nor raised for any other agricultural purpose, they should continue to be classified as pets.  The BEF notes that the definition of a pet animal given within the EU Animal By-products Regulation is  “any animal belonging to species normally nourished and kept, but not consumed, by humans for purposes other than farming”.  The majority of horses in the UK fall within this definition.  They are pets.

5. The Society sees no reason why the existing Regulation should be amended to exclude horses which are kept as pets.  The current Regulations and consent procedures for burying pet horses, under which local authority Environmental Health Departments assess whether or not there would be any watercourse contamination from any such burial, are sufficient.  Certainly, we have seen no evidence to the contrary.  Consequently, there is no public health justification for the removal of horses from the derogation.6. If horses were to be excluded it would impose additional costs for horse owners which, given the absence of a public health justification, would be wholly unjustified.   (Costs for carcass disposal vary greatly due to factors such as the method of euthanasia and method of disposal, from a minimum of £100 to more than £600, depending on the circumstances.) Furthermore, if the owner has the means and a suitable location to bury the horse on his own land, continuing to allow him to do so could mitigate the emotional distress and ease the loss of what is often a lifelong pet and companion.

7. The Government should also realise that, if the Regulation were to be amended such that pet horses could no longer be buried, there is a high probability that the number of carcasses being illegally dumped would increase.  Paradoxically, exclusion may also increase the risk of watercourses being affected if, instead of seeking the advice of the local authority, owners were simply to bury carcasses illegally.  Whatever the law might say, it would be impossible adequately to police a ban on the burial of horse carcasses on owners’ land.  To quote a former Defra Minister “The law cannot always prevent what the law prohibits.”

Yours sincerely, Graham M Cory,Chief Executive

August 18th, 2006