Govt proposal to add rhino, elephants to list of animals that can be slaughtered for consumption
The Saturday Star
27th June 2020

Johannesburg – The government has proposed changes to South Africa’s meat safety legislation, suggesting that threatened species such as rhinos, elephants and giraffes end up on dinner plates.

The Department of Agriculture, Land Reform and Rural Development (DALRRD) has already received about 30000 comments before the deadline on Tuesday, it revealed in an answer to a recent parliamentary question on its draft amendment to the Meat Safety Act (MSA).

In February, it proposed expanding the 35 “domesticated animals” and “wild game species”, the commercial slaughter of which is already regulated under the MSA to a new list of more than 90 local and non-indigenous species, including rhinos, hippos, giraffes and elephants, as well as “all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption”.

This follows recent changes to the Animal Improvement Act (AIA) which promotes the intensive and selective breeding and cross-breeding of animals, listing 33 wild animal species, including lions, cheetahs and rhinos.

The Endangered Wildlife Trust (EWT) has launched an application in the Pretoria North Gauteng High Court challenging and seeking the review of the decision to list wild animals in the AIA.

Part of the controversy surrounding the proposed amendments to the MSA stems from its perceived linkages to the AIA amendments and associated concerns that the government is “laying the groundwork for the intensive breeding of various indigenous species”, said Dr Melissa Lewis, policy and advocacy programme manager at BirdLife South Africa.

Although the AIA’s expansion does not involve bird species, Lewis said BirdLife South Africa was “monitoring that matter closely due to the harmful precedent it could potentially set”.

Senior manager of the wildlife programme for WWF-SA Dr Jo Shaw said it had submitted its comments on the proposed MSA amendment.

“We are particularly concerned by the inclusion of threatened species, especially rhinoceros, which have not been typically harvested for meat, and the lack of clarity around how ‘animal products’ are covered by the act, especially in relation to conservation implications due to illegal trade in high-value products.

“We are also concerned about the lack of separation within broader taxonomic groups in which some species may be of conservation concern; the lack of clarity relating to the addition of ‘all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption’; and particularly by the lack of clarity relating to overlaps and potential gaps between the mandates of the departments of Agriculture and Environment in relation to species that will be impacted by different pieces of legislation.”

Ashleigh Dore, of the EWT’s wildlife in trade programme, pointed out that the amendment to the MSA as read with the proposed regulations on game meat, if and when they were promulgated, aimed to facilitate and regulate the processing of meat from game animals that had been hunted or culled.

The EWT recognises the value that wildlife ranching and the ecologically sustainable use of wildlife brings to the country, and promotes the value and role of wild animals in natural free-living conditions “as an alternative to the proliferation of captive and intensive breeding facilities which provide limited, if any, conservation benefit”.

“Accordingly, we do not support the increasing tendency for industrial-scale production and management of SA wildlife when these are not in line with the principles of ecologically sustainable use and have no conservation benefit.

“These practices, depending on the operation, may result in acute environmental harm and welfare concerns. While we wholly support the move to create a legal framework to support the commercial sale of game meat from wild animals from natural free-living conditions, we do not support the intensive and selective breeding of wild animals for commercial meat production,” Dore said.

In an article in The Conversation Africa last week, Ross Harvey of the University of Johannesburg and Chris Alden of the London School of Economics and Political Science argued that promoting the consumption of wildlife in South Africa will “only intensify the commodification of the country’s natural heritage”.

“And it will potentially create zoonotic spillover health risks for humans as well as from wild animals like wildebeest to domesticated animals such as cattle.”

Environmental futurist Prof Nick King agreed that the amendments “attempt to further commodify wildlife like so much inanimate manufactured merchandise”.

“The draft is so poor from a scientific perspective that it is wholly unworkable, and unenforceable, which begs the question whether it is intended to be regulated at all It ends with the statement, ‘This Act also applies to all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption’,” said King.

“What then is the point of the list provided, if it applies to ‘all other species’? Thus it is a completely nonsensical and unscientific listing and cannot possibly be legally enforced,” he said.

Lewis said BirdLife South Africa recognised the desirability of ensuring that animals slaughtered by humans for human or animal consumption were encompassed by a regulatory regime aimed at minimising health risks.

“We also accept the sustainable utilisation of wildlife resources and recognise the contribution consumptive utilisation makes to the economic value of wildlife.”

Its primary concern for bird conservation is ensuring that any such utilisation occurs in strict compliance with the applicable conservation laws. “DALRRD has clarified that the question of whether or not it is permissible to slaughter animals from particular species of wild animals will continue to be governed by legislation under the Department of Environment, Forestry and Fisheries (Deff). In addition, the draft amendments themselves specify that the slaughter of threatened species ‘must be in line with the relevant conservation provisions’.

“However, this language fails to reflect that the killing of wild animals is governed not only by Deff’s legislation, but also a myriad provincial conservation laws and the annual hunting proclamations published thereunder.”.

Lewis pointed out conservation laws did not only regulate the killing of “threatened” species, and conservation laws included requirements concerning not only the killing of animals from particular species but also associated activities, for example trade in certain animal products.

“We will therefore be recommending revised language, which makes very explicit that both the slaughter of all animals covered by national and/or provincial conservation laws, and any associated activities that are regulated by these laws, must occur in compliance with both the laws themselves and any notices, licences or permits issued thereunder,” she said.

Nelson Mandela University zoologist Prof Graham Kerley, said: “The reality is that few of the wildlife species considered can be managed to the point of being slaughtered in an abattoir, but are rather hunted, and typically then the carcasses are processed in a mobile field abattoir.”

Increasing the sustainability of SA’s wildlife resources is one crucial mechanism to improve the conservation of its biodiversity, he argued. “Well-managed wildlife systems can be based on and protect natural landscapes. Finding additional markets and mechanisms to safely and sustainably harvest wildlife meat (and other products) is important for the conservation of biodiversity.”

The amendment could possibly reduce the risk of zoonoses (diseases). “The devil is really in the details around enforcement of not just the meat aspect, but the entire wildlife industry. SA does not have a good record, as evidenced by the problems around the captive lion industry. So more legislation is not the only solution. We need more trained people and resources on the ground to manage the opportunity and its risks. And the wildlife industry, as the immediate benefactor, needs to take responsibility and contribute to solutions.”

Use of venison the healthiest choice

The Constitution explicitly provides for sustainable utilisation of South Africa’s natural resources, says Gery Dry of the Game Ranchers Forum, and this is a “thorn in the side of biocentric NGOs” who have called on the government to ban the slaughter, consumption and export of venison” following the Covid-19 pandemic.

The “venison initiative” will create 110 new processing plants by next year, increasing to 300 plants by 2030. It will strengthen rural economies and create a new market for game farmers through R650m by 2021 and R7 200m by 2030, he says. “This represents sales of 180 000 animals per year by 2021 and 2 million by 2030. It is estimated to create 1700 jobs by next year and 18 400 by 2030.”

SA’s venison value chain is based on proper meat safety standards. “If anyone follows the path of logic they will realise that mankind has historically used game meat long before agriculturally produced beef mutton and pork started. The use of venison was undoubtedly healthier.”

The SA Veterinary Association (SAVA) says it understands the importance of compliance with the standards set out by the MSA.

“Act 40 thus strives to ensure food safety of all meat and of all meat products that are brought into the market, independent of species, and SAVA does support the maintenance of high food safety standards.

“SAVA does of course also support the protection of endangered species and the keeping and breeding under conditions that are taking care of the needs of the different species.” 

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