Shellfish Decapod Crustacean Welfare Policy

DECAPOD CRUSTACEAN WELFARE POLICY

Macduff Shellfish Decapod Crustacean Welfare Policy

July 2024

In April 2022 the UK Animal Welfare (Sentience) Act was passed which legally recognised decapod crustaceans as sentient animals capable of feeling pain, distress and discomfort.

Management Commitment & Policy

At Macduff Shellfish we believe that decapod crustacea are sentient beings, that their humane treatment is vital, and that consideration of the welfare of crabs and lobster is an important aspect of handling and dispatching them. We have long recognised the importance of appropriate practices for both ethical and product quality reasons. We are committed to ensuring the welfare of the decapod crustacea we handle. We endeavour to employ practices designed to reduce stress and ensure the humane treatment of decapods at all stages through our company.

This welfare policy applies to all brown crab, European lobster and langoustine from all geographies, dealt with by the company in all our UK operations, covering all product formats in all Macduff Shellfish, Clearwater Seafoods and own brand packaging.

We recognise that decapod crustacea have species-specific needs that must be met during post capture transport and holding for processing that take account of each species’ physical, physiological and behavioural needs. We have worked to ensure that live crab and lobster at each part of the process from being received to dispatch are handled, transported, held and dispatched appropriately and in conditions appropriate to their species to ensure their welfare and minimise mortality.

Transport

Macduff Shellfish understands that for transport of decapod crustaceans, environmental conditions and maximum transport length are species-specific, dependent on the length of transport and must take into account other factors that vary by season (temperature, moult stage, etc.). Generally, we have two types of transport based on duration that dictate suitable environmental conditions to ensure maintenance of health and quality and to minimise physiological stress. Short term transport is best accomplished in air (emersion) in which the crustaceans are kept in a stable, high humidity, chilled environment to avoid elevated metabolic stress and to maintain gas and ion exchange at natural levels.

Longer term transport is best accomplished with immersion systems in which the water quality is managed by temperature control, aeration and water exchange/filtration to maintain optimum levels of temperature, oxygen and water nitrogen. In general, we ensure that in air and water the environmental temperature must be at or below the animals’ acclimation levels but above freezing, high humidity with protection from wind or sun if emersed, and oxygen levels above 75% saturation in water, and at 90% or more of ambient air oxygen levels.

100% of our crab and lobster live transport takes place within the time period determined as species specific maximums which take into account the factors outlined above. For information on how the ecology and physiology of brown crab and lobster influence their response to capture and live transport which Macduff has taken into consideration, you can view the SAGB Advisory Note on Crustacea Storage and Transport here - Crustacea-Storage-and-Transport-SAGB-Advisory-Note-2021.pdf (shellfish.org.uk)

Live crab & lobster facility

Our Mintlaw live crab and lobster systems are one of the most advanced in the UK with regular monitoring and reporting of oxygen saturation, water temperature, ammonia, nitrite, nitrate, salinity and water level to ensure that conditions are appropriate for the animal.

Crab and lobster are the only species held in our live facility. At Macduff Shellfish we hold and transport live European lobster; there is no dispatch or processing of lobster. We process langoustine; there is no live holding of langoustine in our live facility.

Dispatch

Macduff ensures that all brown crab are electrically stunned before cooking or processing. We have two Optimar electrical stunning machines specifically for crab incorporated into our factory and all brown crab passes through them and is electrically stunned to ensure instantaneous insensibility. We do not process or dispatch lobster at any of our sites.
We do not sell live crustaceans direct to the consumer or the public.

Governance & Management

Macduff established an Animal Welfare Committee in early 2023, with the first meeting held in June 2023. The cross-departmental Committee with membership from operations, procurement, transport, each Macduff site around the UK (Mintlaw, Stornoway and Exeter), sales, research & development and chaired by sustainability & public affairs, has oversight of the decapod welfare policy and its implementation.

Our Director of Sustainability & Public Affairs is ultimately accountable for the decapod crustacean policy and oversight is provided by the Animal Welfare Committee. The day-to-day management of this policy and its implementation is the responsibility of our operations and transport specialists.

The Animal Welfare Committee which has established a welfare action plan and assigned responsibilities within it, meets several times a year to check the monthly log of stunning percentage, monitor progress of the action plan, to hear updates from the different teams responsible for the day-to-day implementation of the welfare policy and to identify and implement appropriate actions where necessary. The Committee monitors progress of Macduff's welfare targets including our commitment to 100% electrical stunning of all brown crab before cooking or processing, and if the target has not been met it oversees identification of the reason and implements action on the solution to ensure 100% electrical stunning is resumed. The day to day monitoring of this is carried out by the operations team on the ground. The Committee checks the stunning log at every meeting and ensures that public reporting against these targets.

With the publishing of the Seafish, SAGB and CMG Codes of Practice in July 2024, the Animal Welfare Committee will benchmark the Codes against our own practices. The Committee will identify any areas where improvements could be made and oversee the implementation of these improvements. Committee members will also disseminate information on the Codes externally.

Electrical stunning targets

Macduff commits to reporting the percentage of brown crab electrically stunned prior to cooking or processing. We commit to a target of electrically stunning 100% of brown crab across all our sites (where relevant) prior to cooking or processing. We will report through our website on the percentage of brown crab electrically stunned over a 12-month period. We will monitor this from the 1st July 2023, with regular updates to the Animal Welfare Committee and report publicly on an annual basis.

We have 2 electrical stunners in place in the factory and have tracked the percentage of brown crab stunned prior to cooking or processing since July 2023. The operations team have responsibility for monitoring and reporting this to the Animal Welfare Committee. If the target of 100% is not being met the Committee will explore reasons why and implement measures to ensure that the target is met. If the target is not met, the reason why will be presented to the Committee and recorded to be published in the annual reporting, alongside the solution identified and action implemented.

Macduff Shellfish has electrically stunned 100% of its brown crab prior to cooking or processing since July 2023 until this policy was published at the end of July 2024. The table below shows the percentage electrically stunned on a monthly basis.

Future management and Industry Codes of Practice

The Seafish, SAGB & CMG commissioned Welfare Codes of Practice for decapod crustacea are now finalised and circulated and will soon be available to download from the Seafish website. The Animal Welfare Committee has responsibility for their implementation and for reporting on adherence to them. We will encourage businesses we sell to and buy from to adhere to these Codes and provide links to the Codes though our website. Macduff has been actively engaged in developing these codes through our Head of Sustainability & Science who is part of the Project Team that led on the development of the Codes and as an active member of the processor and transport panels, alongside our operations and R&D specialists.Macduff Shellfish has circulated the Codes to national membership bodies for both the catching and processing sectors for dissemination to members, and once the Codes are available to download from the Seafish website we will promote them on our social media channels and the Macduff team will signpost them to businesses we sell to and buy from.  

Decapod Welfare Training

Macduff are committed to ensuring all employees have appropriate awareness and training regards to animal welfare.  To this end, we have updated our training materials to include the importance of the humane treatment of decapod crustacea to include why and how we address this issue at Macduff.  This material has been added to the Macduff staff training for all employees who deal with crab and/or lobster across all Macduff sites.  All Macduff employees have received the Macduff Shellfish Animal Welfare Awareness Training slide deck and all new employees will now receive this training as part of their compulsory staff induction.

At Macduff Shellfish, we understand the importance of decapod crustacean welfare and commit to meeting our electrical stunning targets to ensure that 100% of all brown crab is electrically stunned before cooking or processing, this is clearly outlined in our staff training and policy.  We take non-compliance against our decapod crustacean welfare policy and commitments very seriously. In the event of non-compliance with the Macduff Shellfish Decapod Crustacean Welfare commitments, employees will be:
• reminded of the importance of Decapod Crustacean Welfare to the Company and/or,
• invited to complete our refresher training in areas identified as necessary for improvement to ensure that non-compliance does not reoccur and/or,
• a subject of the Company internal disciplinary procedures. 

Compliance sits with the Operations and Human Resources teams, with oversight by the Animal Welfare Committee. 

Leadership

Decapod welfare is a relatively new animal welfare issue with evidence on decapod welfare limited.  Research is needed to fill knowledge gaps and further develop appropriate technology to deal with decapod welfare.  At Macduff Shellfish we are working on a number of projects around decapod welfare as well as encouraging others to do the same. We are committed to the improvement of handling and dispatch of decapods across the shellfish sector.  Our Head of Sustainability and Science chairs the UK Crab and Lobster Management Group that, together with Seafish and the Shellfish Association of Great Britain, has developed industry Codes of Practice for the handling and dispatch of decapod crustacea.  The Codes of Practice cover the key stages of the supply chain; catching, processing, wholesale and live imports and exports.The development and adoption of these Codes of Practice will ensure that best practice in welfare standards operate across the entire shellfish sector.  More information can be found on the Seafish website here - Animal sentience and welfare (seafish.org). The Codes will be published on the Seafish website at the end of July 2024. 

Animal Welfare Week 2023

In March 2023 we participated in ‘Animal Welfare Week’, a collaboration between Marks & Spencer and Optimar bringing together key UK seafood suppliers to meet researchers, technology developers and companies addressing welfare issues in their business both on land and at sea to learn about current welfare practices and research, share best practice, information on developing technology and future needs of the seafood sector to address welfare concerns.  More information can be found here - Optimar Animal Welfare Week in Ålesund, Norway - it was a great success!

Welfare Week instigated discussion, in which Macduff were involved, on the current lack of appropriate technology for the langoustine sector  and the need for new species-specific technology to address welfare considerations.  From these discussions an innovative high level project plan was drafted and funding sought to carry out the research. Macduff has provided funding for this project and will continue to dedicate time to this project on developing onboard stunning options for langoustine, and feed into its development to advance research on the welfare of decapod crustaceans within the industry.  

Innovation

Macduff carries out internal research and development on decapod handling, storage and transport to ensure decapods are treated humanely and appropriately.  We also encourage external research and have hosted visits to our Mintlaw facility for researchers and technology companies to consider current and future technology needs and encouraged the development of innovative new technologies to address current gaps in decapod crustacean welfare technology. 

Macduff is a partner in a pioneering project to develop an onboard Nephrops stunning and tailing machine, facilitated by Fisheries Innovation and Sustainability (FAS). The ability to stun and tail Nephrops at sea will bring significant improvements to the fishery, including to the welfare of Nephrops. The technology to either stun or process seafood catches does exist but has not been used together at sea onboard UK vessels catching Nephrops. Project partners are confident of proof of concept and are working together to produce a prototype stunning and tailing machine which will be tested on a UK fishing vessel.

Performance Reporting & Impact

Macduff Shellfish has set the targets below which we will regularly measure throughout the year and report publicly on annually.
• 100% of our brown crab and lobster are caught using static gear.
• 100% of our brown crab is electrically stunned before cooking or processing.
• 100% of our langoustine is caught by trawl from UK waters. 

External Reporting – July 2023 to July 2024

In the period from July 2023 to July 2024:
• 100% of our brown crab and lobster has been caught using static gear.
• 100% of our brown crab has been electrically stunned before cooking or processing. See table above for month by month reporting. 
• 100% of our langoustine has been caught by trawl from UK waters. 

Bycatch Reduction

Macduff Shellfish is a funder and active participant in the UK Nephrops Fishery Improvement Project or FIP. The Nephrops FIP is working towards an environmentally sustainable future for UK Nephrops.  The FIP has identified areas where improvements can be made, including on monitoring and the reduction of unwanted bycatch in Nephrops fisheries.  More information on this can be found on the Seafish website and the Project UK website at www.projectukfisheries.co.uk/nephrops. Macduff Shellfish scallop vessels have worked with Cefas to trial the Clean Catch App.  The trial to feed into both the Nephrops and scallop FIPs is to test the App and progress its development for bycatch monitoring and roll out to the Nephrops and scallop Fleets more widely. 

Stay up to date

At Macduff Shellfish we use our social media channels to promote awareness of the importance of the humane treatment of decapod crustacea and the development of the Codes of Practice for decapod crustacea to drive welfare improvements across the industry. Now the Codes are developed and published, we will support and promote them through our website, on social media and in meetings as well as encourage others to use and implement them in their own businesses.

You can follow Macduff’s social media channels, and view our website, where we will provide updates on our decapod welfare policy and work.