This is an informed, but personal view, of the passport legislation, its impact and repercussions, especially as it applies to Scotland.
The basic premise behind the original idea of horse passports was that horses are food animals and so just as certain drugs administered to cattle, sheep and pigs have withdrawal periods to ensure human food safety, so drugs administered to horses could contaminate the flesh of equines which enter the human food chain.
The drug companies which manufacture such equine drugs as wormers, anaesthetics and a host of other equine drugs, have not tested these drugs for Meat Residue Levels (MRLs), as there has been no need to do so in UK, because horses are not bred for meat production. The testing is costly and without licences issued by the government, the use of many equine drugs would not be permitted if horses were food animals. The protection of the safety of human food is very laudable, but horses in the UK are not food animals and are not regarded even as agricultural animals. The EU does not appear to take account of taboos or customs in its member countries and so EU legislation requiring horses to have passports was imposed on the UK in the same way as it was in other EU countries.
|Legislation and Implementation||
Since 1998, all registered horse and pony foals have been issued with passports by their breed society or discipline. This increased the registration costs for breeders. The owners of older horses and ponies could apply for passports at costs varying between £10 and £25. Unregistered equines and those of unknown breeding or breed type were not obliged to have passports, but could apply voluntarily to the relevant organisations, such as BHS, for a passport. The originally issued passports did not contain a section for recording medicinal treatments or for stating that an equine was not intended for the human food chain.
MAFFS and its successor, DEFRA, consulted with all the relevant equine organisations as to how the EU legislation could be implemented. These organisations were told that if they did not come up with implementation plans that DEFRA would impose its own. At this point the organisations should have refused to comply, but were worried that certain equine drugs could be withdrawn from use and that DEFRA would the impose other regulations on the equine industry. Their other concern was for feral herds of equines. Scare scenarios were rife: vets would not be permitted to treat equines which did not have passports; knackers would not be allowed to slaughter equines which did not have passports or to remove carcases of fallen stock; the use of certain essential equine drugs would not be permitted.
The EU then decided that identification, as contained within the passport, was not sufficient and that pages for medicinal records and certification as to whether or not the animal was intended for the human food chain were required. The passport requirement was then expanded to include all equines, whether registered or not. This legislation was due to come into effect on 31st December 2003, but a postponement has been granted till 1st July 2004 in both England and Scotland.
In the meantime, Scottish government was devolved, as was Welsh, and SOEFAD, later SEERAD, took over responsibility for passport implementation. SEA (Scottish Equestrian Association) was set up to give a single voice to the diverse Scottish equine industry and to speak on behalf of the industry to government. SEA also advised on the distribution of funds from Sport Scotland to equine groups and individuals. SEA's main focus was on sport and the disciplines and so SEBA, (Scottish Equine Breeders Association), came into being. This organisation of representatives of equine breeders in Scotland has seats on SEA and is dedicated to the interests of breeding and breeders in Scotland. Consultations of Scottish organisations with SEERAD have been less than productive, with many concerns still being unanswered.
By stealth, DEFRA has slipped in an extra requirement that the identification of the equine in applications for passports made after 31st January 2004 must be completed by a vet, unless the equine is microchipped. This has not happened yet in Scotland, but watch this space!
The horse has always been highly regarded in British society and the consumption of horse flesh has long been a taboo. Passport regulations should not apply to the UK. When it was decided that passports were required for cattle, MAFFS/DEFRA provided passports free to breeders and set up CTS and BCMS to issue passports and record movements of animals. In some EU countries of which I have personal knowledge, not all equines have passports. Only those involved in competition are required to hold passports. This legislation is simply another example of control and regulation by the UK government, which wishes to invade every aspect of the lives of the populace.
Our EU neighbours do eat horse meat and we are all aware of the dreadful conditions in which horses for slaughter are transported on the Continent. (We have legislation governing length of travel time and welfare in transit, but these regulations do not appear to be policed in Europe). Most of the horses for slaughter in the EU now come from eastern European countries.
Passport Issuing Authorities (PIAs) have been recognised by government agencies and these include breed societies and equine sport organisations. The administrative burden on these organisations is huge and at the end of the day, it will be the members who will foot the bill for increased staff wages. PIAs are required to issue passports which implement the European Commission Decision 2000/68/EC, the object of which is to ensure that horses which have been treated with unauthorised medicines within the previous six months do not enter the human food chain. The percentage of UK horses entering the human food chain is negligible. There is no abattoir licensed for the slaughter of horses in Scotland. The passports already issued to some equines will require to be returned to the PIAs to have extra pages added to comply with the regulation (which was not in force at the time of issue), concerning the intention for the animal to enter the human food chain.
The PIAs allocate an identification number for life to each equine. The latest passport contains sections for details of ownership, identification control, records of sport registration, gradings and winnings, identification, height measurement, vaccination, medication control, official laboratory health tests, health authority visas, customs visas, administration of medicines and a declaration as to whether the animal is intended for human consumption. The regulations as to who can declare on the passport that an equine is not intended for the human food chain and when this declaration should be made still have not been clarified by government agencies.
The maximum penalties for non-compliance of passport regulations is £5000 per offence or three months imprisonment. Local authorities are supposed to police this. Excuse my skepticism!
The financial burden of acquiring passports falls to the owners. Firstly there is the cost of registration for pedigreed animals (The Highland Pony Society, for example, charges £30 for fillies and £20 for colts). The passport for an older animal (again HPS) is £15. If the horse is microchipped, there is the additional veterinary cost. This may not be so crippling for the one horse or pony owner, but is a financial setback to breeders, riding schools and horse charities.
The owner applies and pays for the passport and if a horse is loaned, the "keeper" should hold the passport, according to the regulations. If a horse is sold, then its passport must be handed over to the new owner. One can see that it would be possible for a keeper to sell a horse which was only on loan and to provide the necessary documentation in the form of the passport. (HPS does state that the registration certificate is proof of ownership, not the passport).
The regulations state that if an owner does not supply a passport when the animal is being treated by a vet, then the vet will not be allowed to administer certain life-saving drugs, listed in Annex IV of Council Regulation 2377/90/EEC. Vets will have the moral dilemma of going against their professional code of conduct and responsibility to their patients or breaking the law (click to view the code).
Horses are not considered by DEFRA or SEERAD to be agricultural animals and are liable to VAT. Horses in Europe are classified as agricultural animals and are exempt from VAT. DEFRA and SEERAD, if they insist on passports, should then make horses VAT exempt. They can't have it both ways. There is also the question of on farm burial, which is now illegal in most areas of Scotland. However, the government agencies will allow pets to be buried, but have not yet come up with a definition of "pet"!
My personal view is that this legislation has been badly drawn up and should not have been applied to the UK in the first instance. My ponies are not intended for human consumption and I cannot see the need for passports for my older ponies, which will live their lives out here and be humanely put down at the end of their days. The passports of the younger ponies will need to be returned to the Highland Pony Society to be updated with extra pages, putting an added burden on already overworked staff. Financially, it will cost me a considerable amount of money, but to no advantage that I can see.
The breeding of my ponies and their identification diagram and text are on their registration documents. This is identical to the description which appears in the passport. If horse owners were made to keep a veterinary medicine record of all drugs administered to their animals, in the same way as farmers have to do for cattle and sheep, then there would be no need for the passport for pedigreed animals and all that would be required would be a stamp across the registration document stating that the animal was not intended for meat.
To view the full implementation document for Scotland, click here.
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