To the

Scientific Committee of Animal Health and Animal Welfare,

You adopted the report on "The Welfare of Animals Kept for Fur Production", Thursday the 13th of December, 2001, and on Wednesday the 19th of December this adopted report was made public. As members of the Working group, we hereby inform you that the adopted report is unlike the report we made in some crucial and major points. For example, it now contains several errors of fact which are, to be frank, simply embarrassing. We would also like to protest the lack of consultation that has typified the last few months, and the removal of a vast number of references from large sections of the final report. We dedicated much time to this report over the past 1_ years, and are all recognised scientists with experience in fur animal research. Therefore we feel disappointed and dismayed by how the Committee has acted since we submitted our document. .

Since our last meeting in May, there has been no communication or discussion between the members of the Working group and the Sub-committee. Robert Dantzer (head of the Working group, member of the Sub-committee and Scientific Committee) can confirm this silence. Two weeks ago we were informed that this was because of perceived 'conflicts of interest' within the Working Group. We find this objectionable on two grounds. First, it is insulting: we are scientists, not politicians; and any suggestion that our scientific views are affected by views of the industry is simply unacceptable. Second, it is procedurally highly unorthodox: if conflicts of interest were perceived to be an issue, they should have been discussed and aired when the Working Party started its work – not invoked in this ad hoc manner long after our last meeting.

This lack of consultation has not only been objectionable, it has also compromised the scientific quality of the final report, as we detail below. We take issue with three aspects of the final report. First, it seems to have become politically slanted against fur farming, especially mink farming. Second, large numbers of references have been removed. Third, it contains several errors of fact or interpretation, some of which are potentially important for animal welfare, and others of which are so ridiculous that they compromise the report's credibility. Our draft of the report was based solely on scientific knowledge and scientific judgements, and we find these aspects of the final report surprising and disappointing, especially given how easily they could have been avoided.

The chapter on mink welfare, and its conclusions, have been changed dramatically, with a consistent elimination of positive welfare aspects of mink farming, and additions of text unknown to the Working Group (all negative towards mink farming, and with no references). As an example, the Working Group document (W) concluded that "The welfare of farmed mink is reasonably good". This conclusion is missing in the adopted version of the report (R). While we (W) concluded that lack of swimming water for mink was a possible welfare problem, because the research so far is not completely conclusive, in your report, the conclusion is: "An adequate fur-farming system for provision of swimming water has to be designed.", implying that it is definitely important. Another example: The conclusion of our working document "Young mink are weaned after nutritional independence, in contrast to many other agricultural animals" is missing in R. R also concludes: "Weaning before nine weeks leads to a variety of welfare problems", with no supporting data, in contrast to the Working group conclusion: "Mink should not be weaned before 8 weeks of age.." based on solid data. This last is particularly important, as it is used to recommend not weaning before nine weeks (p. 184, R) - yet leaving a large litter together in a standard cage until this age is potentially dangerous, as we make clear in our report (W). Several other points are listed below.

The chapter on mink welfare (Chapter 9) has also lost most of its references. This gives the report a highly amateur, unsubstantiated feel, and also means that readers can no longer distinguish between work published in refereed journals and that published in internal reports etc. We can see no excuse for this. All the references supporting this chapter (around 200) were supplied to the EC in May, giving the Committee over six months to incorporate them. They were provided in alphabetical order, and were divided into refereed and un-refereed articles, as requested. If they could not after all have been typed in by staff at Brussels, they could have been returned to us for typing. There was ample time for this. Instead, we simply heard nothing, and none of these references have been used.

Finally, we are concerned at the factual errors which have now slipped into the report. For example, nursing sickness is not a problem for mink (cf.p. 116, R) – for example, it has not been seen in Denmark for over six years. There are no strains of mink which suffer from 'blindness' (cf. P. 117) – this is a complete fiction. Mink farming has not been banned in the Netherlands (cf. p. 47). Group-housing has been adopted commercially (cf. unsubstantiated claim on R, p. 117). Again, several other points have been listed below.

Overall, we feel that the Committee has chosen to focus only on a few examples showing welfare problems (for example studies from the 1980s expressing a high degree of stereotypy in mink), and that Committee has chosen to downplay the vast amount of studies showing positive aspects of welfare. Below are some of the further points where we find the changes and added text un-acceptable. There are several welfare problems in fur animals like in most confined animals, but most of these can be reduced by the present scientific knowledge. The reduction or elimination of the remaining welfare problems must be based on further research, not on anecdotal evidence.

We sincerely hope that you will consider withdrawing the report and asking the Sub-committee to do a more objective job based on the scientific evidence provided in the final draft from the last meeting of the Working Group. We are willing to help with this process. If you choose to keep the adoption of the report as now stands, the following authors of this letter withdraw from the Working Group and request that our names are deleted from the list of the Working Group members.

03.01.02
Assoc. Prof. Dr. Vivi Pedersen, Zoological Institute, University of Copenhagen
(VPedersen@zi.ku.dk),
Prof. Bjarne Braastad, Agricultural University of Norway (bjarne.braastad@ihf.nlh.no)
Dr. Vet. Erik Smeds, Finland (Erik.Smeds@kolumbus.fi)
Dr. Teppo Rekila, Agricultural Research Center of Finland, (teppo.rekila@mtt.fi)
Dr. Georgia Mason, Dept. of Zoology, Oxford University, (Georgia.mason@zoo.ox.ac.uk)
Dr. Gerrit de Jonge, The Netherlands, (leipoldt@rulsfb.leidenuniv.nl)

Comparisons of the working group document W and the adopted version R.

• In R, chapter 2 you state that "this report contains only scientific assessments and scientifically based conclusions on how their welfare can be improved" but you fail to fulfil this statement. Below the evidence for this failure is further documented
• In R, chapter 6.3 conclusions and in conclusion, chapter 17, no. 11: You have removed "blue foxes" in your sentence: "Selection for reduced fearfulness towards humans is successful and results in positive welfare effects in the species studied : silver fox and mink". To support yourself, you have removed a whole chapter with scientific evidence that selection for reduced fearfulness is successful in blue foxes too, namely chapter: 10.14 page 159-162 in W. And actually you conclude in 15.6 that selection against fearfulness is effective in foxes, chapter 15.6.
• In R, page 42, chapter 6.2.2 you state that "the farm breed blue fox …. is less domesticated than the blue fox", which is very different from the sentence in W, page 41, lines 27-29: "The farm breed blue fox is not domesticated sensu stricto, although it is claimed to be adapted to captivity."
• In R, page 47, chapter 7, you state that fur farming is banned in the Netherlands. This is not true. Only Great Britain banned fur farming as the W correctly mentions.
• On the same page you have deleted 4 sentences in R, expressing in W that enclosures to foxes gave rise to hygienic and parasite problems in the 40'ies (with a reference)
• On page 86, in R, you have changed a sentence into something much broader: You have deleted the word "food" in front of deprivation (in W, page 94, line 25)
• In R, page 86, second paragraph on abnormal behaviours II self chewing, you have added a new paragraph. It is unknown text to us and not documented with references (no data).
• On the same page you have changed a past tense to present, again making another meaning of the statement. We refer to an old survey of mink fur-chewing from 1984 stating that these kind of problems existed on every farm in those days (W, page 94, line 34). You changed it to "exist on every farm" (R, page 86), which there is no data to support.
• In W, chapter 9.2, page 99: This later report concluded that compared to the pig and poultry industries the fur industries practices are relatively benign. We agree with that view here, but also emphasise….." This paragraph is deleted in R, page 89.
• In W, sentence 18-20, page 99 chapter 9.2.1 "Pregnant mink are generally quiet and well-fed and prenatal stress which can have long term effects on the offspring's HPA function is unlikely to be a major issue for mink" This has been removed in R, page 89.
• In R, page 90, you have added 4 sentences from a study and you have deleted a sentence from W page 99, line 34: " ….though in normal practice it is unlikely to represent a major welfare issue for the typical farmed mink"
• In R, page 90, chapter 9.2.2 you have deleted the words "and during nursing" ignoring the results of the referred study (W, page 99, line 42)
• In R, page 92, you have deleted a paragraph in W, page 102, chapter 9.2.2 "…only some appears directly attributable to poor husbandry or welfare"
• In R, page 92, you have deleted a sentence in W, page 102, line 25/26 " …suggest that infancy is a time of high welfare for mink"
• In R, page 93, you have removed:" In conclusion, however, the welfare of growing infant mink seems to be good; morbidity and mortality are low, with good farm management and levels of playing and social interactions are high (W, page 103, line 28-30)"
• In R, page 94, you have removed a whole paragraph "….we recommend that weaning never occurs earlier than 8 weeks and preferably later….." (W, page 105, line 24 and on) To complete this you conclude that weaning should not take place earlier than 9 weeks of age, despite our conclusions that it should not take place prior to 8 weeks of age (which is supported by data)
• In R, page 99, welfare of family housed kits, you have added a lot of new text, praising group/family housing despite the data documenting welfare problems with this system. You have also chosen to erase all reference by Danish researcher (published in AABS, ACTA) on mink and group/family housing, despite the fact that you continuously refer to de Jonge (published in Dutch in national magazines or un-published). The scientific references are in W in that chapter. Why chose to eliminate them? You also refer wrongly to de Jonge on results from the Danish studies (scientifically published) several times on page 100-101.
• In R, page 103 you have deleted a sentence from W (page 113) " Adult mink is generally healthy….."
• In R, page 111, you have removed a sentence from W, page 121:"female stereotypy is low during pregnancy."
• In R, page 109, reference from Hansen and Jeppesen, 199, 2000, 2001 is deleted from the text, though they are referred to (published in scientific journals) (W, page 118).
• In R, page 113, 114, 115, Scientific publications from Danish research team are again ignored, though in W, page 121-123.
• in W (9.2.12, 1) and (16,30) it is stated that "The welfare of mink is reasonably good, at least compared with other intensively farmed animals". This statement is deleted in R, page 116, 9.2.12
• W (9.2.12,4) and (16,33) states that "Mink shows little fear of humans, and despite being naturally solitary, largely seems to adapt well to the enforced proximity of conspecifics." This statement is deleted in R, page 116, 9.2.12. On the contrary it is suggested/concluded in several places (e.g.17,39) that "inability to avoid social contact" is a problem, which impairs mink welfare.
• W (9.2.12,3) and (16,32) states that "Breeding of farmed mink is generally unproblematic". This statement is deleted in R, which reads instead (R page 116): "The mortality of mink kits during nursing period has been reported to be up to 30% with a mean of 20%. - - - Lactation is a period of high risk especially because of nursing disease". Nursing sickness is no longer a major problem, as we detail in W; for example, it has not been reported in Denmark for the last six or seven years.
• W (9.2.12,5) and (16,34) is changed: "Locomotor stereotypies can occur in farmed mink. However, their prevalence can often be reduced by simple measures such as high levels of feeding" to R (page 116): Stereotypies, largely locomotor in nature, are widespread on mink farms. - - "
• Similarly, R now concludes, on the basis on negligible data, that gastric ulcers are widespread in farmed mink (p. 116).
• W (9.2.12,6) and (16,35) is missing: "Young mink are weaned after nutritional independence, in contrast to many other agricultural animals". Instead: R (page 116): Weaning before nine weeks leads to a variety of welfare problems.
• W (9.2.12,8+9) and (16,38+40) talk about possible welfare problems and aspects that can impair welfare: "- Several aspects of husbandry can impair mink welfare. - - Possible welfare problems include.." R generally omit the reservations (possible and can) and mentions problems as if they were well documented facts, e.g. (17,39): "The typical mink cage - - impairs mink welfare -. Particular problems are -."
• R (page 116) mentions self-mutilation of tail or limb tissue as widespread. This was not part of W and is not supported by scientific evidence.
• When it comes to group housing and swimming water the presentation in R is apparently extremely twisted. W gives a warning against group housing (9.2.12,10 " The welfare consequences - are not yet fully assessed") and mentions "lack of water to swim in" as a possible welfare problem (9.2.12,9). R (page 116 "None of these systems has yet been adopted commercially") leads to the impression that it is regrettable that group housing is not yet introduced in practice, and R simply claims that: "Adequate fur-farming system for provision of swimming water has yet to be designed" on page 116, but on page 178 (no. 32) it states "has to be design", which has a very different meaning.
• Contaminated food is NOT give to mink (R., p. 117) – where is the evidence for this? Botulin poisoning is only a potential risk because of the nature of the food (as with any meat-based products), but to claim that farmers deliberately risk poisoning or use seriously condemned meat is inaccurate.
• What colour types of mink experience 'blindness'? (R., p. 117). This is a fiction.
• In R, page 122 new text have been added: Farmed silver foxes have been claimed to express extreme fear…." Not in W page 131. Fearfulness in foxes is a welfare problem, as is also concluded in W. But "extreme" fear is only rarely seen in some foxes, for example when a group of unfamiliar humans approach the cage.
• In R, page 125, added sentences "…. Needs of foxes for locomotor….." Not in W, page 134.
• In R, page 141, added new text on a German survey with no references, Not in W.
• In R, chapter 10.11, page 150: the following paragraph (5 in W, 10.15) is missing: "Mortality and morbidity are generally low and foxes are generally in good physical health"
• The following paragraphs are also missing in R (W, page 161/162): "Transportation is rare since slaughter is carried out on sight";"Ways of reducing fearfulness based on selection are available";"Ways of improving the physical and social environment to attenuate reproductive disorders and reduce monotony are available";"Losses on farms appear to be less than those in the wild…"
• Paragraph 4 on chinchilla conclusion, page 157 in R is a new one, no data in W (page 167) support this new statement.
• In R, page 172, no. 7, a warning stated in W has been deleted: "However, selection which produces excessive exploratory tendencies could have negative effects on welfare"
• In R, Recommendations, chapter 18, page 159 this text is added: Until there is sufficient information on the welfare of raccoon dogs, keeping of this species on fur farms should be discouraged" . The following is the conclusion on welfare of raccoon dogs from W, chapter 12.2: 1 Although raccoon dogs are in general treated like foxes, there are not enough data to determine whether their welfare is at risk in commercial conditions. 2 Their reproduction in captivity appears to be good, and raccoon dogs are generally in good physical health. 3 Possible welfare problems include wire floors, barren environments, weaning age, pre-clinical conditions, foot problems, lack of mate choice and monogamy
• In R, conclusions no. 12, page 176 have been dramatically changed. In W it said: Generally, compared to other farm animal species, fur animals have been subjected to low or moderate breeding intensity. Furthermore their environmental conditions have changed little over years and are similar for breeding and growing animals. These are both positive factors for the health, coping ability and welfare of fur animals". In R, it says now: "…..species of farmed fur have been subjected to relatively little active selection…."
• The kit mortality of 20% is used as evidence that mink experience poor welfare (p. 183), despite the evidence given in W. that this level is the same as that displayed in zoos, and lower than that seen in the wild.
• The recommendation that kits be left together until nine weeks (p. 184) is potentially dangerous unless this is limited to small litters only, or conducted in enlarged cages, due the risks of aggression. We make this quite clear in W.

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