12 June 2016
SUBMISSION BY CATRIONA MACLENNAN TO THE REGULATIONS REVIEW COMMITTEE ON COMPLAINT ABOUT ANIMAL WELFARE (LAYER HENS) CODE OF WELFARE 2012 BY SAFE (13 AUGUST 2015)
I note the committee’s request in its letter dated 12 May 2016 to Mr Ahluwalia that he limit his oral submission to the part of the complaint relating to Standing Order 319(2)(c). Accordingly, this submission is confined to that issue.
My apologies for this very late submission, as I have only recently become aware of the complaint made by SAFE to the committee.
This submission requests that the Regulations Review Committee under Standing Order 319(2)(c) draw to the special attention of the House the Animal Welfare (Layer Hens) Code of Welfare 2012 so that the code can be disallowed. The code gives priority to the economic welfare of hen farmers over animal welfare and is therefore contrary to the purposes and specific provisions of the Animal Welfare Act 1999 and based on a misinterpretation and misapplication of the law. The act was amended in 2015 but the code and the report by the National Animal Welfare Advisory Committee (NAWAC) accompanying the code have not been reviewed and amended to reflect the law changes and do not comply with the new law.
Standing Orders 318- 321 deal with the functions and powers of the Regulations Review Committee. Standing Order 318 (5) provides that the committee “investigates complaints about the operation of regulations, in accordance with Standing Order 320, and may report on the complaints to the House.”
Standing Order 319(1) provides that, in examining a regulation, the committee considers whether it ought to be drawn to the special attention of the House on one or more of the grounds set out in paragraph (2).
Standing Order 319(2)(c) provides that one of those grounds is that the regulation “appears to make some unusual or unexpected use of the powers conferred by the enactment under which it is made.”
As noted above, this is the ground on which the committee has decided to focus its consideration of SAFE’s complaint.
The Animal Welfare Act 1999 replaced the Animals Protection Act 1960. The preamble to the act, as amended by the Animal Welfare Amendment Bill in 2015, provides that the legislation is -
(a) to reform the law relating to the welfare of animals and the prevention of their ill-treatment; and, in particular,—
(i) to recognise that animals are sentient:
(ia) to require owners of animals, and persons in charge of animals, to attend properly to the welfare of those animals:
(ii) to specify conduct that is or is not permissible in relation to any animal or class of animals:
(iii) to provide a process for approving the use of animals in research, testing, and teaching:
(iv) to establish a National Animal Welfare Advisory Committee and a National Animal Ethics Advisory Committee:
(v) to provide for the development and issue of codes of welfare and the approval of codes of ethical conduct:
(b) to repeal the Animals Protection Act 1960.”
Both the title to the act and the preamble make it plain that the key purpose of the legislation is animal welfare. This is reinforced by the fact that the 2015 amendments to the preamble inserted a declaration of sentience (paragraph (a)(i)).
Nowhere in the title to the act; the preamble; the section 4 definition of physical, health and behavioural needs; the section 9 purposes; or the sections 10 and 11 obligations is there any reference to economics or to the welfare of the farming industry as being a purpose or concern of the legislation.
Part 4 of the act provides for the establishment of the National Animal Welfare Advisory Committee (NAWAC). Section 55(2) provides that the committee will, among other things advise the minister on issues relating to the welfare of animals; develop and advise the minister on codes of welfare; and recommend to the minister that regulations be made under section 183A prescribing animal welfare standards or requirements. Section 57 sets out the functions of NAWAC. Section 57(a) provides that the functions of NAWAC are –
“(a) to advise the Minister on any matter relating to the welfare of animals in New Zealand, including (without limitation)—
(i) areas where research into the welfare of animals is required; and
(ii) legislative proposals concerning the welfare of animals:”
NAWAC’s name has the word “welfare” in it. Sections 55 and 57 repeatedly refer to “welfare.” Nowhere in these sections is there any reference to economics or to the financial interests of farmers. It is accordingly plain that it is animal welfare, rather than economics, with which the legislation primarily requires NAWAC to be concerned.
The Interpretation Act 1999 sets out basic rules for interpreting New Zealand legislation. Part 2 of the Interpretation Act sets out principles of interpretation. Section 5 states that –
“5 Ascertaining meaning of legislation
(1) The meaning of an enactment must be ascertained from its text and in the light of its purpose.
(2) The matters that may be considered in ascertaining the meaning of an enactment include the indications provided in the enactment.
(3) Examples of those indications are preambles, the analysis, a table of contents, headings to Parts and sections, marginal notes, diagrams, graphics, examples and explanatory material, and the organisation and format of the enactment.”
The Interpretation Act makes it clear that the text, purposes, preambles and other parts of an act are to be used to ascertain the meaning of an enactment. The organisation and format of the legislation may also be taken into account in interpreting its meaning.
Section 73 of the Animal Welfare Act 1999 sets out the matters which must be taken into account by NAWAC in considering the content of a draft code of welfare and before deciding whether to recommend to the minister the issue of that code. Subsections (1) to (3) provide as follows –
(1) The National Animal Welfare Advisory Committee must, in considering the content of a draft code of welfare, and before deciding whether to recommend to the Minister the issue of that code,—
(a) be satisfied that the proposed standards are the minimum necessary to ensure that the purposes of this Act will be met; and
(b) be satisfied that the recommendations for best practice (if any) are appropriate.
(2) In carrying out its functions under subsection (1), the National Animal Welfare Advisory Committee must have regard to—
(a) the submissions made under section 71 and the consultations undertaken by the Committee; and
(b) good practice and scientific knowledge in relation to the management of the animals to which the code relates; and
(c) available technology; and
(d) any other matters considered relevant by the National Animal Welfare Advisory Committee.
(3) In carrying out its functions under subsection (1), the National Animal Welfare Advisory Committee may take into account practicality and economic impact, if relevant.”
Subsection (3) was inserted into the legislation by the 2015 amendment bill. It is noteworthy that the matters set out in subsections (1) and (2) are mandatory, while subsection (3) states that NAWAC “may” take into account practicality and economic impact, “if relevant.”
Accordingly it is not mandatory for NAWAC to take into account either practicality or economic impact in considering draft codes of welfare. Further, the ability for NAWAC to take those considerations into account is qualified by the words “if relevant.”
It is submitted that NAWAC has, since the act came into force, misinterpreted and misapplied the legislation. In developing codes of welfare, NAWAC has consistently emphasised practicality, the economic interests of farmers, and the impact on consumers of provisions in codes.
Such an approach is not supported by the act itself, by accepted rules of statutory interpretation, or by case law. The act clearly provides that it is the Animal Welfare Act. The preamble, purposes and other provisions referred to above all emphasise welfare. It is not until section 73 that the matter of economics is provided for in the legislation. As noted above, it is not mandatory for NAWAC to take into account practicality and economic impact, and they are, under the 2015 amendments, to be considered only “if relevant.”
However, NAWAC has failed to correctly interpret and apply the law since 2000. Instead, it has elevated economic concerns to being paramount. NAWAC’s interpretation of the act means that economic matters are not only placed on a par with welfare: they actually supersede it. This is plain from the way in which NAWAC has drafted and released codes relating to the welfare of hens and pigs. Sections 4 and 9 of the act require animals to be able to display normal patterns of behaviour. Pigs and hens confined to cages, crates and stalls cannot display normal patterns of behaviour. However, NAWAC has since 2000 approved sow stalls, farrowing crates, fattening pens, battery cages and colony cages because those are in the economic interests of farmers.
Section 73(2)(d) permits NAWAC to have regard to “any other matters considered relevant” in considering draft codes. It is submitted that NAWAC has elevated this provision to a paramount one and interpreted it so as to permit NAWAC to elevate the economic interests of hen farmers above animal welfare. That is contrary to the title, purposes and spirit of the legislation and is an incorrect interpretation of the act. Provisions such as subsection (d) of section 73(2) are included in legislation to cover issues which might not have arisen or been considered when the legislation was being drafted. The absence of such a general provision in the legislation would otherwise mean that an unforeseen occurrence or development would require an amendment to the law.
The inclusion of a general provision such as subsection (d) obviates the need for a law change, but it was not intended to be interpreted as giving NAWAC the ability to disregard the title, preamble and purposes of the legislation and to elevate financial matters above animal welfare.
In a letter dated 17 September 2013 to then-Primary Production Committee chairperson, Shane Ardern, MPI’s Manager Regulatory Reform and Animal Welfare, Colin Holden, provided an initial briefing to the committee on the Animal Welfare Amendment Bill. The letter stated -
Criteria for developing minimum standards in codes of welfare
30. Currently, before recommending a code of welfare to the Minister, NAWAC must have regard to a range of matters specified in the Act. ‘Practicality’ and ‘economic impact’ are important considerations, but these are not explicitly recognised in the Act. They are taken into account by NAWAC under a catchall “any other matters considered relevant” provision.
31. The Bill will improve the transparency of the Act by making it clear that when NAWAC develops codes of welfare, it may have regard to practicality and economic impact where these are relevant. The provisions will allow economic and practical factors to be considered alongside, but not outweigh, animal welfare issues.”
This letter reinforces the interpretation of the act outlined above: that it is protecting animal welfare that is the key concern and purpose of the legislation. Mr Holden’s letter specifically states that economic and practical factors can be considered alongside “but not outweigh” animal welfare issues. This is the correct approach to interpretation of the legislation and is what would be expected from application of the Interpretation Act and normal principles of statutory interpretation.
NAWAC reviewed the Animal Welfare (Layer Hens) Code of Welfare 2005 and released a draft Animal Welfare (Layer Hens) Code of Welfare 2012. NAWAC at the same time published a report dated 29 June 2012 under the name of Dr John Hellstrom, the chair of NAWAC. The report was titled Animal Welfare (Layer Hens) Code of Welfare Report. The report was written prior to the 2015 amendments to the legislation and was accordingly based on the old law. It is further submitted that the report’s interpretation of the previous law was in any case incorrect, as it elevated economic considerations to a paramountcy at variance with the purposes and spirit of the legislation.
Paragraph 20 of that report stated that -
“While the Animal Welfare Act does not provide for trade-offs between the physical, health and behavioural needs as defined in s4 of the Act, it qualifies needs by referring to a case-by-case application according to the species, environment and circumstances of the animal. NAWAC acknowledges that, in general, balancing between the needs of animals is inevitable in order to arrive at an overall optimum welfare outcome because the requirements to satisfy each need may be in conflict.”
It is submitted that this is an incorrect and unlawful interpretation of the act, which is inconsistent with normal principles of statutory interpretation. The phrase in section 4 “being a need which, in each case, is appropriate to the species, environment, and circumstances of the animal” should be given its plain meaning. This is that different animals have different types of needs and accordingly require different care. It is plain that the needs of fish are markedly different from those of hens, for example. This is no different from recognising that the needs of humans are different at different stages of human life – for example, the environment appropriate to a baby differs from that which is appropriate for an elderly person.
The report’s statement that, while the act does not provide for trade-offs between the physical, health and behavioural needs as defined in section 4, it “qualifies the needs by referring to a case-by-case application according to the species, environment and circumstances of the animal” is a grossly strained interpretation of the section. The section does not, in fact, qualify the needs. It simply states that needs differ according to species and needs are to be fulfilled in a manner appropriate to the species.
The subsequent sentence – “NAWAC acknowledges that, in general balancing the needs of animals is inevitable in order to arrive at an overall optimum welfare outcome because the requirements to satisfy each need may be in conflict” is incorrect. The legislation does not anywhere provide for trade-offs or balancing. The act is called the Animal Welfare Act and its purpose and provisions, as set out in the preamble, are to reform the law relating to the welfare of animals and the prevention of their ill-treatment and to require owners and persons in charge of animals to attend properly to their welfare.
The report goes on to state that –
“Layer hens will have each of their physical, health and behavioural “needs” met to different extents depending on the system that they are housed in. Each commercial egg-producing system has its own inherent advantages and disadvantages. Hens housed in cage systems are kept in a finely controlled environment, with the aim of controlling many aspects of their health. However, in achieving this controlled environment, the hen’s behavioural needs are restricted. Conversely, hens housed in barns, with or without outdoor access, are able to express an increased range of behaviours, but are exposed to greater risks to their health because their environment is harder to manage effectively. Each commercial egg-producing system has different welfare benefits and risks to the hens, be they health, physical or behavioural. The code provides NAWAC’s view as to what constitutes the acceptable range of “needs” in the environment and circumstances of layer hens.”
This is again a misinterpretation of the law. The act does not state that NAWAC’s task is to weigh up different egg-producing systems and evaluate them against each other. Nowhere in the legislation is there provision for the balancing of different animal needs. The act simply states in section 9 that owners and persons in charge of animals are to “take all reasonable steps to ensure that the physical, health and behavioural needs of the animals are met” in accordance with both good practice and scientific knowledge.
It is incorrect in the context of the Animal Welfare Act to state that “Each commercial egg-producing system has its own inherent advantages and disadvantages.” Battery cages have no advantages for hens – as has now been accepted both by the Government and by NAWAC. From the point of view of animal welfare, battery cages utterly fail to comply with the protections provided to animals by sections 4 and 9. The only advantage of battery cages is that they are a cheaper method of production for farmers. However, that is not a paramount criterion provided for in the legislation.
Similarly, colony cages do not allow hens to display normal patterns of behaviour. Their main “advantage” is that they are also cheaper for farmers than non-cage farming. Once again, this is not a consideration permitted by the act to be given priority.
The report states at paragraph 22 that “hens have a good level of physical health in cage systems.” However, that statement is contradicted utterly by the covert footage of both battery and colony cages which has been filmed in New Zealand in recent years and broadcast on television. That footage has shown hens in wretched conditions, with live animals crammed in next to dead hens. MPI devotes only a tiny fraction of its annual budget to animal welfare. As a result, the worst cases of animal suffering have in recent years been brought to public attention by voluntary organisations, which have filmed abuse and ill-treatment of animals covertly. The footage which has been broadcast on television – some as recently as 2016 – demonstrates that neither battery nor colony cages protect animal welfare. Their sole justification is financial benefit for farmers.
NAWAC’s strained interpretation of the act is epitomised by the last sentences of paragraph 25 of the report. These state that –
“There are many behaviours which the majority of domestic hens cannot express while being housed in any commercial egg producing system, be that cage, barn or barn with outdoor access. These behaviours include sexual courtship behaviour, brooding and chick rearing. Other natural behaviours of hens can be performed in some systems, but are restricted in others. These include wing stretch and flap, stretching their body to full height, flying, sunbathing and dustbathing in substrate. Some natural behaviours are unwanted in any system, and include flee behaviours in response to predators, shivering in response to extreme cold or distressed panting as a result of high environmental temperatures. The Act reflects this in the definition of the physical, health and behavioural needs that must be provided for an animal in order to meet the requirements of the Act. Section 4 states that the need (which must be provided for the animal), in each case, is appropriate to the species, environment and circumstances of the animal.
“It is not, therefore, essential that every hen is able to display all normal patterns of behaviour in every system. In fact, many birds choose not to express the behaviours that they have been given the opportunity to express (e.g. some birds do not exit the barn to walk on the range or roost in branches of trees, even if provided with the opportunity to do so).
“In every commercial system, the benefits of providing an environment in which the birds can perform their normal behaviours has (sic) to be assessed against the associated costs and likely affects (sic) on the bird’s productivity, health and well-being. The role of NAWAC is to ensure that this balance is acceptable in terms of the welfare of the hen in each system.
“As a result of the lack of space and facilities, cages effectively deny most of the behavioural needs of hens. NAWAC therefore considers that cages do not meet the requirements of the Act. However, although neither colony systems nor barn systems (with or without outdoor access), allow the birds to display their full repertoire of behaviours, NAWAC considers that they meet the requirements of the Act.”
Once again, this is an incorrect interpretation of the law. The interpretation of section 4 outlined in the passage above is wrong.
The statement that it is not essential that every hen is able to display all normal patterns of behaviour in every system, is also incorrect. This is not what the act provides. On the contrary, sections 4 and 9 specifically state that animals are to be provided with the opportunity to display normal patterns of behaviour. The act does not state that only some animals are to be provided with that opportunity. The act does not state that animals are to be provided with the opportunity to display only some patterns of behaviour. The act does not state that birds should have the opportunity to display normal patterns of behaviour only in some farming systems. The act makes no distinction between “essential” and “non-essential” animal behaviours. This is a distinction developed and applied by NAWAC, but it is not based on the law and accordingly cannot be supported.
The passage above states that “In every commercial system, the benefits of providing an environment in which the birds can perform their normal behaviours has (sic) to be assessed against the associated costs and likely affects (sic) on the bird’s productivity, health and well-being. The role of NAWAC is to ensure that this balance is acceptable in terms of the welfare of the hen in each system.” This is not what the act says. The act clearly states that animals are to be provided with the opportunity to display normal patterns of behaviour. The act does not provide for welfare to be traded off against economics.
The passage above concludes by stating that “NAWAC therefore considers that cages do not meet the requirements of the Act.” This submission agrees with that statement.
However, the report goes on to state that “However, although neither colony systems nor barn systems (with or without outdoor access), allow the birds to display their full repertoire of behaviours, NAWAC considers that they meet the requirements of the Act.”
This is a puzzling statement, given that colony cages – like battery cages – are in fact “cages.” The Wordsworth Concise English Dictionary defines a cage as “a box or compartment wholly or partly of open work for captive animals: a prison: a frame with a platform or platforms used in hoisting in a vertical shaft: a wire guard: any structure resembling a bird’s cage: a structure to protect garden fruit and vegetables from birds.” On any normal definition of the word, colony cages are in fact “cages.”
Additionally, earlier in the report, NAWAC itself repeatedly refers to “colony cages.” By page 10 of the report, however, “colony cages” have become “colony systems,” seemingly to enable NAWAC to say that cages are being phased out, but to continue to support the use of colony cages. This strained use of language is a clear indication of NAWAC’s failure to interpret the law correctly using normal principles of statutory interpretation.
In all of its work relating to layer hens, NAWAC appears very concerned about economics, both in terms of costs to farmers and of the financial cost of non-cage eggs to the public. However, on page 5 of the report, NAWAC itself states that “Free range eggs tend to market at a higher value than barn eggs.” The use of the word “tend” indicates that this is not invariable. In addition, examination of supermarket egg prices discloses a very large variation in prices within different categories of eggs, as well as between eggs produced by different systems.
Since the writing of NAWAC’s 2012 report, the Animal Welfare Act has been amended by the 2015 amendments. In particular, this submission draws attention to the amendments to section 73. Section 73(3) previously provided that NAWAC might, in exceptional circumstances, recommend minimum standards and recommendations for best practice that did not fully meet obligations relating to physical, health and behavioural needs of animals; obligations to alleviate the pain or distress of ill or injured animals; or obligations to be met in relation to the treatment, transport of killing of animals in order to avoid offences against sections 12, 21, 22, 23 or 29.
Section 73(4) provided that NAWAC must, in making recommendations under subsection (3), have regard to the feasibility and practicality of effecting a transition from current practice to new practices and any adverse effects that might result from such a transition; the requirements of religious practices or cultural practices or both; or the economic effects of any transition from current practices to new practices.
The approach outlined in the 2012 report accordingly does not comply with the current law. The Animal Welfare Amendment Act 2015 was passed by Parliament on 5 May 2015 and came into force on 10 May 2015. Accordingly, it would seem appropriate for NAWAC to review the current 2012 code and write a new report.
This submission supports SAFE’s submissions in relation to science and behavioural needs set out in paragraphs 13 to 28 of SAFE’s initial complaint to the Regulations Review Committee dated 13 August 2015. Accordingly this submission does not discuss in detail matters relating to science and specific behavioural needs of hens.
In addition to the 2012 report on the draft Animal Welfare (Layer Hens) Code of Welfare, NAWAC has also drafted a series of guidelines which set out its approach to drafting and considering codes of welfare. There are 12 of these guidelines. These include NAWAC Guideline 01: Approach to consideration of draft codes of welfare; NAWAC Guideline 02: Dealing with practices which might be inconsistent with the spirit of the Animal Welfare Act; NAWAC Guideline 05: Role of science in setting animal welfare standards; NAWAC Guideline 03: Setting minimum standards where section 73(3) applies; NAWAC Guideline 11: Principles of Consultation; and NAWAC Guideline 12: Prioritisation framework.
These guidelines were downloaded from MPI’s website on 12 June 2016. Many were initially drafted a number of years ago, and some appear to have been updated in 2011. However, the most recent update appears to have been a 2014 update to one guideline. Most of the guidelines are older than that, and none appears to have been updated – at least online – to take account of the 2015 law changes.
For example, NAWAC Guideline 01: Approach to consideration of draft codes of welfare states that, in drafting codes of welfare –
“4. There are certain things NAWAC is required to take into consideration
NAWAC must work within the requirements of the Animal Welfare Act 1999. Accordingly, there are certain things NAWAC must to take into consideration, and NAWAC may also consider any other matters that it sees as relevant. At present, the list includes:
(a) scientific understanding of animals’ needs;
(b) practical experience and available technology;
(c) good practice;
(d) practicality of making changes;
(e) international trends;
(f) societal ethical concerns;
(g) economic implications;
(h) religious and cultural practices; and
(i) whether any adverse animal welfare outcomes are reasonable or necessary.”
This paragraph does not reflect the current law.
Paragraph 6 of this guideline states that “Economic considerations may constrain the speed of implementation of a change that NAWAC desires, but cannot prevent it.” However, as outlined above, this does not appear to be the approach which NAWAC in fact applies in its work. Instead, it elevates economic factors to paramount concerns and at times places them above animal welfare.
NAWAC Guideline 02: Dealing with practices which might be inconsistent with the spirit of the Animal Welfare Act provides at paragraph 4 (d) that NAWAC will have regard to a number of other important matters, including “consideration of all five components of section 4 equally while recognizing that they cannot all be maximised at the same time.” That is not what the law says.
NAWAC Guideline 08: Balancing animal welfare needs states that, in order to achieve the best net welfare outcomes for animals in particular circumstances, “a restriction is sometimes imposed on one of these [five section 4] needs in order to achieve an animal welfare benefit in others.” This guideline was approved by NAWAC on 8 December 2004 and amended on 14 November 2012. Accordingly, it has not been amended to take account of the 2015 law changes.
NAWAC Guideline 10: Phasing out one animal management system in favour of another was approved by NAWAC on 9 September 2005 and is accordingly very outdated. It provides that, in consider phasing out a particular animal management system, NAWAC would only recommend change “ if the alternatives available to replace it confer a significant gain in net animal welfare status.” The guideline goes on to state that “When the net welfare status of animals managed under two or more systems cannot be clearly separated, there are no sustainable grounds upon which NAWAC could recommend phasing out one of those systems in favour of another.” This does not appear to be a correct statement of the law.
NAWAC Guideline 12: Prioritisation framework is dated 30 April 2014. It states that NAWAC must consider many risks to animal welfare as part of its work “but the Committee has limited resources. In order to determine an order of priority for the animal welfare issues that come to the notice of NAWAC, a framework has been developed. This allows NAWAC to take advantage of the best opportunities to improve animal welfare in New Zealand.”
The act does not envisage animal welfare being compromised by inadequate resources. Paragraph 2 of the guideline states that any request from the Minister for Primary Industries “automatically gives that issue highest priority.” The paragraph goes on to state that “Substantial public and media interest in an area of significant animal welfare compromise may also change NAWAC’s work priorities at short notice.” However, it does not appear that this part of the prioritisation framework is followed by NAWAC in practice, as there have been many examples in recent years of substantial public and media interest in areas of significant animal welfare compromise which have not resulted in action from NAWAC.
The Government has accepted that battery cages are unacceptable as they fail to protect the welfare of hens and are no longer acceptable to the public. Battery cages are accordingly to be phased out by 2022.
However, colony cages also fail to protect hen welfare and are unacceptable to those members of the public who understand how they operate. Covert footage of hens in colony cages on a Waikato farm was broadcast in April 2016. The pictures showed hens with virtually all their feathers pulled out, dead hens lying in cages and other unacceptable treatment of hens. The pictures drew widespread public condemnation. It is submitted that, once the public becomes aware that colony cages offer virtually no better welfare protection to hens than do battery cages, opposition to colony cages will grow.
The Government is requiring the industry to spend approximately $150 million to change from battery to colony cages by 2022. The industry will rightly feel aggrieved if lack of public support for colony cages leads the Government to supersede its decision to ban only battery cages and, instead, decide in the near future to ban all hen cages. There is a very realistic prospect of this happening. The Government might be at risk of legal action by the industry in such an eventuality, as it was reasonably foreseeable when the Government banned battery cages and required the industry to move to colony cages that colony cages would rapidly become unacceptable to the public and would also be banned within a fairly short timeframe.
12 JUNE 2016
 Standing Orders of the House of Representatives, 2014 - http://www.parliament.nz/en-nz/pb/rules/standing-orders/00HOHPBReferenceStOrders4/standing-orders-of-the-house-of-representatives-2014.
 Animal Welfare Amendment Act 1999 - http://www.legislation.govt.nz/act/public/1999/0142/latest/DLM49664.html.
 Interpretation Act 1999 - http://www.legislation.govt.nz/act/public/1999/0085/latest/whole.html#DLM31467.
 Ibid, page 4.
 Ibid, page 6.
 Wordsworth Concise English Dictionary, page 135.
 See, for example, page 6, Ibid.
 The Guidelines can be viewed on MPI’s website - https://www.mpi.govt.nz/protection-and-response/animal-welfare/codes-of-welfare/steps-to-developing-a-code/.