Violence during animal transport in Belgium and the Netherlands

Experts from the Council for Animal Affairs (RDA) assert that farmed dairy cows and beef cattle share the same fundamental needs and behaviors as their wild counterparts. To understand their natural needs and behaviors, scientists observe groups of feral cattle. By comparing their natural living conditions with those found in the meat and dairy industry, we can effectively evaluate animal welfare within the industry.^[4][5]

The term "cattle" describes a group of ruminant mammals that includes cows, buffalo, and bison. In the wild, cattle typically form mixed groups of dozens to hundreds of animals. Within these large herds, they create smaller subgroups. Each subgroup has a stable hierarchy. Outside the mating season, mother cows and their calves stay separate from the bulls. Young bulls, aged 3 to 4 years, often form bachelor groups on the outskirts of the herd, while older bulls usually live alone.

Individual animals in herds form social relationships. A cow can recognize between 50 and 70 other cows. An individual's rank in the hierarchy is influenced by physical factors like age, body size, and horn size, along with personality traits such as temperament and self-confidence.

The hierarchy in a group is established through rank-order fights. Once this hierarchy is set, fighting happens infrequently. Cattle respect their relationships by keeping a physical distance from one another. This distance varies based on their relationship, ranging from a few decimeters to several meters. Researchers notice more conflicts when living space shrinks or group size grows.

In a group, some animals interact more closely than others, and family ties are a big factor in this. Mother cows in a herd tend to stay close to their offspring, even when those offspring are adults with their own calves. Cattle that played together as calves often develop lifelong friendships. They show their bond through positive interactions, like licking each other.

Cattle are naturally herd animals, but heavily pregnant cows often isolate themselves to give birth. They look for a sheltered nesting area among trees and shrubs. Newborn calves can walk within an hour, but they stay hidden in the nesting area for the first few days of their lives. After a few days, the new calf joins the herd.

Around two weeks old, calves start to play. They run, jump, kick, and engage in mock fights. Playtime is great for fitness and crucial for learning social skills. However, young calves also need plenty of rest. Until they reach five weeks, they spend 90% of their time lying down. This percentage drops to 75% when they are five to six months old.

In the wild, calves nurse from their mothers five to fourteen times a day during their first few days of life, with each nursing session lasting about eight minutes. After ten months, they still nurse about three times a day. Female calves can suckle for up to 14 months, while male calves typically stop suckling sooner. Between 10 and 11 months of age, male calves start to form groups with other young bulls in the herd. In contrast, female calves at that age tend to stay close to their mothers.

Cattle spend a lot of time grazing and ruminating. They like to ruminate while lying down, preferably under the shelter of trees and shrubs. To graze freely, they can walk up to 13 kilometers each day, depending on how grazing areas are spread out in their habitat. These walking distances are crucial for their leg and hoof health. To maintain healthy feet, cattle need to walk about 3 to 4 kilometers daily.

Like all prey animals, cattle experience fear as a strong emotion. They instinctively fear predators, including humans. Cattle tend to be cautious around anything new, unknown, or unpredictable. They take their time to carefully examine and explore unfamiliar objects, other cattle, or new environments. Their keen senses help them in this process.

Cattle have an impressive sense of smell. Bulls can detect when a female is in her fertile period. Mother cows recognize their calves by scent, and herd members can identify each other through their unique smells. When a cow experiences stress, other cattle can sense it through the pheromones and urine she releases.

Cattle have highly developed vision that differs from human perception. They can see a panoramic field of over 300°, which helps them spot predators. However, they do have blind spots behind them and just in front of their mouths. Cattle struggle with depth perception, causing them to react more dramatically to shadows than humans do. They tend to avoid shady areas, dark spaces, and slopes because they can't determine if these places are safe. Additionally, cattle have a strong need for a refuge zone, requiring enough space around them to flee if they sense danger. When cattle feel anxious or stressed, they need even more space to escape.

Cattle are prey animals, and they rely on their herd for safety. Being socially isolated or separated from the group is one of the most stressful and frightening experiences for these animals. In the wild, strong group cohesion is essential for their survival. Cattle in a group work together; while some graze, others stay alert to spot potential predators. When one animal feels stressed, the entire group experiences stress. Stressed cattle typically need at least half an hour to recover somewhat.

Even domesticated cattle experience fear as a strong emotion. These animals have excellent memories. They remember negative experiences with people, which affects their behavior. Young calves can easily tell the difference between those who treat them well and those who do not. Regular, friendly interactions with people can help reduce anxiety in calves as they grow. However, trials revealed that the benefits of consistent contact between calves and humans are less significant for calves that nurse from their mothers. Calves separated right after birth and without contact with their mothers showed less fear of humans. In contrast, calves that nursed from their mothers experienced more stress during human interactions.

Hidden camera investigation in 4 collection points The Ongehoord research team filmed the loading and unloading of calves and cows. They placed hidden cameras in export collection points. In collection points, animals from various livestock farms are brought together for further transport to breeding farms, fattening farms, or slaughterhouses. Due to the active animal trade between the Netherlands and Belgium, research was conducted in both countries. The transport of animals is subject to legal regulations. For example, according to European animal welfare legislation, only properly trained personnel may handle animals in a collection point.^[6] Allowing children to assist with the herding process is prohibited. Scaring, hitting, or kicking animals is prohibited, as is pulling on tails, ears, horns, fur, or heads. Electric shocks (tasers) may not be used on calves. In adult cows, electric shocks may only be administered to the muscles of the hind legs, and not repeatedly. Sick or injured animals must receive "appropriate veterinary treatment" as quickly as possible or, if necessary, "be killed in a manner that does not cause unnecessary suffering." Our images painfully demonstrate that animal welfare laws function primarily on paper: none of the four locations studied enforce the rules.

Origin and destination of animals

Veal fattening started as a way for dairy farming to manage its surplus calves. To produce milk, farmers artificially inseminate mother cows every year. A cow only begins to produce milk after giving birth. Once a calf is born, farmers separate it from its mother to sell the mother's milk. The calves receive artificial milk from buckets with pacifiers. Over 50% of these calves are bull calves, which have no use in dairy farming. Some female calves stay on the original farm to replace older mothers later. The surplus female calves and bull calves are then transported to various fattening farms.

The veal industry operates through integrated groups. Large veal producers buy calves and transport them to veal fattening farms via collection points. These fattening farms usually have contracts with the integrator and fatten the calves using feed provided by the integrator. After about six months, the calves are slaughtered at the integrator's slaughterhouse.

Many fattening farms in Belgium are located in the Kempen region, which borders the Netherlands. Major producers from both Belgium and the Netherlands have contracts for fattening farms in each country. Ongehoord filmed footage at two Belgian export collection points where calves from dairy farms are gathered for transport to the various fattening farms.

Location 1: Collection point Vanlommel, Tielt-Winge

At Binkomstraat 90 in Tielt-Winge (province of Flemish Brabant), you will find the assembly center of Vanlommel, Belgium's largest veal producer. Here, 14-day-old calves are gathered for transport in large groups to Vanlommel's contract fatteners in Belgium and the Netherlands.^[7] Over a span of four days, the following abuses were captured on hidden cameras: - calves being systematically herded with tasers - calves being kicked - calves being pushed forward with knee thrusts - a calf being forcefully pushed against the side of the farm with knee thrusts - calves being struck with sticks on sensitive areas such as the head; sticks are slammed against the calves' flanks/ribs - a calf struggling to walk is lifted by the tail and dragged along - a group of calves is cornered, where workers kick them and administer electric shocks - calves falling during herding - a worker intimidating calves with a stick inside a large plastic bag.

About the company

The Belgian veal market is primarily controlled by two producers, with Vanlommel being the largest. The Vanlommel family amassed their wealth through veal production, which is currently estimated at nearly 23 million euros.^[8] It is troubling that the abuses at this specific company were captured on film. Vanlommel asserts that it is a leader in animal welfare, promoting its own "Well and Fair" quality scheme. The specifications of Well and Fair include "extra-legal rules" concerning animal health, feed, housing, staff training, and transport. Compliance with Well and Fair's regulations is overseen by an (anonymous) "independent party."^[9][10] Vanlommel states that the transport of the calves “always occurs under optimal conditions, prioritizing the welfare of the calves.”^[11] Vanlommel operates its own animal feed factory in the Netherlands (Verveka), an export collection point in Tielt-Winge, its own transport vehicles, and a calf slaughterhouse in Olen. The company has contracted calf fatteners in both Belgium and the Netherlands. It supplies purchased calves and feed from its own factory to its regular calf fatteners. At around six months of age, the calves are gathered for slaughter at Vanlommel's facility. Seventy percent of the meat produced is intended for export.^[12][13] Vanlommel compensates its contract fatteners with a monthly fee. As Belgium's largest volume producer, Vanlommel benefits from indirect government support. In Flanders, contract farmers receive subsidies for “producing veal calves,” funded by European subsidy money.^[14] Veal sales are promoted through the government's VLAM campaigns, which are also financed with European subsidies.^[15][16][17] In 2011, Vanlommel received subsidies for investments aimed at "energy savings or environmental objectives." The specifics of the project and the amount remain undisclosed. The funding originated from the Flemish Agricultural Investment Fund (VLIF) and the European Agricultural Fund for Rural Development.^[18] In 2022, the Vanlommel slaughterhouse was awarded €4,500 in Flemish subsidies for training and advice, along with employer support (VOP); an additional €2,500 in VOP was allocated to Vanlommel's transport company.^[19][20]

Location 2: the Kempen Export Stable, Merksplas

The Kempen Export stable, owned by the Van der Walle family, is a Dutch operation that includes many fatteners and livestock traders. It is located at Bosstraat 11 in Merksplas, in the Antwerp province. Over a week and a half, hidden cameras captured several abuses at the Kempen Export Stables, including:

• Calves being pulled by their tails and thrown from wagons
• Calves being struck on sensitive body parts with sticks
• Calves receiving knee blows to push them along
• Calves being kicked
• Calves frequently pulled by their tails while being herded through the assembly area
• Calves being pulled by their ears
• Calves being pushed away from the watering hole
• A child being allowed to help hit and push calves

About the company

The Kempen Export Stables are owned by the Dutch Van der Walle family. Ben van der Walle was a significant figure in the Dutch veal market for many years. He traded calves, managed numerous barns, and had calves fattened under contract. He generated a turnover exceeding 51 million euros.^[21] In 2016, Van der Walle sold “a number of activities” to the Dutch Vandrie Group, with whom they had collaborated intensively for years.^[22] It is unclear exactly which activities were sold and which remained under the Van der Walle family's ownership. According to the Dutch Chamber of Commerce, “Vee- en kaverhandel Ben van der Walle” is still active at Schaluinen 20, 5111 HB Baarle-Nassau. What is certain is that Ben's calf farm, housing over 2,000 calves, at Ghil 13 in Baarle-Nassau (NL), and the Kempense Exportstal collection center (BE) are still owned by the family. In Hoogstraten (BE), they own the Belgian livestock trading company "Hertog Vee," managed by Ben's daughter Tanja.^[23][24][25] The Van der Walles receive European subsidies from both the Dutch and Belgian governments. Europe allocates agricultural funds to member states, but it is the national governments that manage and distribute the subsidy money to companies. According to the RVO (Netherlands Enterprise Agency) database, 87,400 euros in European subsidies were paid out over the past two years to "Livestock and Calf Trade Ben van der Walle BV in 5110 AG Baarle-Nassau".^[26] The Ben van der Walle cattle and calf trading company is also listed in the Belgian database, but with a different postal code: 5111 HB Baarle-Nassau (NL). In Belgium, the company received an additional €2,800 in European subsidies.^[27] The databases do not specify which business locations are receiving subsidies. Postal code 5111 HB corresponds to the address Schaluinen 20, Baarle-Nassau. Postal code 5110 AG, where the majority of subsidies were channeled via the Netherlands, corresponds to a post office box address.^[28] We also checked the FTM database (Follow the Money, a Dutch platform for independent investigative journalism). Unlike governments that only publish the last two subsidy years, FTM has subsidy amounts available from 2014 onwards. We discovered via FTM that cattle and calf trader Ben van der Walle received over €230,000 in subsidies between 2014 and 2021, for their post office box address 5110 AG.^[29] # Netherlands - lame and sick cows severely abused

Origin and destination of animals

Cows are transported from dairy farms to slaughterhouses when their health and milk production decline. A livestock farmer aims to avoid spending more on feed and medication for a cow than the income she generates from milk. A quarter of the discarded mother cows are sent to slaughter through a collection point. From these collection points, the cows are transported to both domestic and foreign slaughterhouses. According to BuRo (Bureau for Risk Assessment and Research), 4 to 10% of the mother cows are shipped abroad, with Belgium being the primary destination.^[30] The meat from these finished cows is tough and is typically used in inexpensive meat products like hamburgers and snacks. Hidden cameras were installed at two Dutch cattle collection points. Both locations are licensed to collect and export breeding cattle, beef bulls, cattle calves, and dairy cattle. During the investigation, primarily finished cows were transported through both collection points.

Location 3: Dane and Son, Oudemolen

The livestock trading company Dane en Zoon has its collection center at Stadsedijk 44 in Oudemolen, North Brabant. They collect and trade cattle for both domestic and international markets. Over two weeks, Ongehoord filmed several abuses, including:

• Delivering seriously ill cows that cannot stand
• Pulling on the ears and snouts of these sick cows
• Dragging a seriously ill animal by its tail and legs, with multiple workers involved
• Administering electric shocks to sensitive areas of seriously ill cows, including their flanks and anus
• Dragging sick animals using ropes
• Tying a cow with straps to a shovel for dragging
• Hoisting a terminally ill cow that was left alone all night with a hip clamp attached to a shovel the next morning
• Killing a cow outside on the property and pushing it away with a forklift
• Herding a group of young cattle with a pitchfork while shouting loudly and beating the animals with it

About the company

Dane en Zoon is a recognized name in the animal industry.

In September 2021, members of the House of Representatives made a pre-announced working visit to the assembly point. Caroline van de Plas expressed her gratitude to Dane for their transparency.^[31] Helma Lodders, chair of Vee & Logistiek (the Dutch interest group for livestock traders, collectors, and transporters), also visited and openly commended the Dane family for their "professionalism in livestock."^[32] Dane collects cattle for slaughter and breeding intended for both domestic and international exports. In partnership with the Belgian livestock transporter "Vervoer de Backer," Dane supplies milked-out cows to Belgian slaughterhouses. Alongside VAEX, a global livestock trader, he provides pregnant heifers to dairy farms in Russia, Pakistan, and Turkmenistan.^[33][34][35] Livestock trading is the primary focus of the Dane family, but they also participate in animal husbandry: at Westmiddelweg 1 in Oudemolen, they operate the "Ruigenhilvlees" farm, where they fatten cattle and broilers. The animals are processed, packaged, and sold at their farm butchery.^[36][37] The Dane family also benefits from European subsidies. According to the FTM subsidy database, Dane received over 400,000 euros from 2015 to 2021. During the corona crisis, Dane was granted 8,744 euros in NOW support.^[38]

Location 4: Livestock farm Kuiper VOF, Hoogblokland

The livestock transporter Teus Kuiper operates from Beemdweg 5 B in Hoogblokland. Over the course of a week, the following abuses were recorded at the company:

• Delivery of an extremely thin and sick animal
• Delivery of lame cows
• Cows being struck hard with a stick, including sensitive areas like the head
• Sticks being driven into the flanks and ribs of cows
• Cows being kicked
• Animals slipping and falling on the slippery, wet concrete floor

About the company

“Veebedrijf Kuiper V.O.F.” in Hoogblokland operates a livestock transport company and a cattle collection point.^[39][40] Teus Kuiper is the owner, and he collects and transports cattle for various livestock traders and breeders. Similar to Dane en Zoon, we primarily observed the transport of milked-out cows at the Kuiper VOF cattle collection center. Our camera also captured footage of horned cows from organic livestock farming. Kuiper collects all export cattle for Groen Livestock, a major livestock trader that ships cattle to various countries, both within and outside Europe.^[41] For Heijdra Vleesvee (the IJsselstein fattening farm that raises milked-out dual-purpose cows), T. Kuiper transports cattle to the Ameco slaughterhouse.^[42][43] According to the FTM database, Veebedrijf Kuiper VOF has received €13,358 in European subsidies since 2014.

Inspection reports show failure of government oversight

Ongehoord invoked the Freedom of Information Act to request inspection documents from the Flemish Animal Welfare Service regarding animal transports between Belgium and the Netherlands. We investigated the violations that occurred during the export of cattle for slaughter in both directions. This represents only a small fraction of the transports, as most animals are moved within national borders. However, it became evident that both the NVWA (Netherlands Food and Consumer Product Safety Authority) and the FAVV (Federation of Belgian Food and Consumer Product Safety Authorities) frequently disregard animal transport regulations. NVWA : Export permits were granted for lame and sick cows from Oudemolen (Dane and Son). Inspection documents reveal that in 2022, the NVWA (Netherlands Food and Consumer Product Safety Authority) approved the transport of lame and sick cattle at the Dane en Zoon collection point in Oudemolen on multiple occasions. Upon arrival at a Belgian slaughterhouse, these animals were observed and reported by the Belgian inspectorate, the FAVV (Federal Agency for the Safety of the Food Chain). FAVV veterinarians documented seven cattle with large abscesses, three with bleeding or suppurating wounds, one severely lame animal, and one cow suffering from suppurative mastitis. Two cattle were unable to stand and were euthanized in the truck. Additionally, a cow that had died en route was discovered in the same truck. Given the severity of the injuries, it is inconceivable that the NVWA overlooked these animals. All these animals originated from Dane en Zoon in Oudemolen and were destined for the Moerbeke slaughterhouse (East Flanders, Belgium). Due to the short duration of this journey, the injuries could not have occurred during transport. The transports were conducted by Vervoer de Backer, a Belgian livestock transporter based in Rumst. The issues surrounding the export of unfit animals have a long-standing history. Since 2019, the NVWA has repeatedly announced stricter measures for export inspections, such as two-eye supervision (where inspections are conducted jointly by two veterinarians) and the implementation of European guidelines for assessing suitability for transport. Inspection documents released by Ongehoord in September 2021 indicated that the NVWA 's measures were ineffective. Even at that time, seriously ill animals were being transported to Belgium.^[44] The NVWA 's response was that the reported abuses were outdated because new "stricter rules had been introduced in the meantime to further safeguard animal welfare."^[45] However, six months later, in March 2023, a news article on the NVWA website acknowledged that the number of reports of sick Dutch cows in foreign slaughterhouses is not decreasing, despite the implementation of more stringent supervision.^[46]

FASFC: dozens of heavily pregnant cows approved for transport to the Netherlands

Ongehoord also requested inspection documents regarding the supply of unfit Belgian animals to Dutch slaughterhouses. We found that veterinarians from the Federal Agency for the Safety of the Food Chain (FASFC) approved dozens of heavily pregnant cows for transport to Dutch slaughterhouses. Dutch NVWA veterinarians who examined the cows at the slaughterhouse determined that the cows were more than 90% through their gestation period (over 8 months). This meant that, according to European regulations, they were not allowed to be transported.^[47] After slaughter, unborn calves were removed from the wombs of their deceased mothers. Photos in the inspection reports show calves nearly a meter long. The animals are fully furred and already have incisors. Transporting heavily pregnant cows to slaughterhouses not only causes suffering for the mother during the journey, but also creates a welfare issue for the unborn calf. When the mother is slaughtered, the calf is deprived of oxygen and dies of asphyxiation in the womb. European researchers agree that fetuses can experience pain and stress from as early as six months of gestation.^[48] In total, NVWA veterinarians reported around thirty heavily pregnant cows being transported from Belgium to Dutch slaughterhouses in 2021-2022. In addition to the heavily pregnant animals, FAVV veterinarians issued export permits for two sick calves and seven permits for severely lame, injured, or sick cattle.

Violence during loading and unloading is unavoidable

Why do livestock transporters exert so much force when herding cattle? To understand this, we need to consider the animals' natural needs and instincts. From the literature review (Natural Behavior of Cattle), we know that cattle are herd and prey animals. Transport is an unnatural and stressful situation for them, which they instinctively seek to avoid.^[49][50]

Separated from their herd, the animals face unfamiliar situations, including the truck, strange drivers, and loud noises like the clatter of metal truck doors and shouting from people. They may also encounter unfamiliar animals in the loading area or inside the truck, which they instinctively want to avoid. Additionally, cattle naturally seek an escape route, but that option is unavailable in a truck.

When the truck arrives at a collection point or slaughterhouse, the doors open, and the cattle face an unfamiliar environment. Their keen sense of smell picks up the scents of stressed animals nearby. Strangers approach and block their escape routes. The cattle must exit the truck using a demolition loading ramp. Because of their poor depth perception, they struggle to tell the slope of the ramp from a cliff. It can take a long time before the first cattle dares to leave the truck.

Cattle transported through assembly points face stressful conditions multiple times. These animals have strong memories and recall every negative experience. At each stop, their stress increases, making them more reluctant to enter and exit trucks. Even young calves have well-developed memories. In tests where a calf received a shock from a stun gun, the calf could recognize the person who administered the shock for several days afterward.

Cattle do not willingly get loaded and unloaded. When faced with unfamiliar and stressful situations, they instinctively freeze or struggle. They don’t have time to calmly assess what's happening; the truck needs to leave for the next customer, and the loading docks must be clear for the next transport. As a result, coercion and violence often occur during loading and unloading.

Transport of sick and injured animals is unavoidable

Transporting weak and sick cows to slaughter is a common practice. Farmers rely on healthy, fit cows for milk and income. Only when a cow becomes weak, sick, or injured, leading to a drop in milk production, is she sent for transport.

The Dutch BuRo report compiled data on the transport of cows that had completed milking from 2017 to 2020. During this time, an average of 423,850 cows that had finished milking were removed from Dutch dairy farms each year. BuRo estimates that 30 to 75% of cows (averaging between 127,155 and 317,887 animals) are slightly ill or injured, while between 0.05 to 5% (averaging from 212 to 21,193) of cows have serious abnormalities.^[52]

The primary reason for the health issues that cows face in dairy farming is the production system: cows are selectively bred to produce increasingly larger quantities of milk. Production levels continue to rise each year. In 1910, cows produced around 2,500 kg of milk annually. Currently, the average annual production in the Netherlands and Belgium exceeds 9,000 kg per cow, which is about 30 liters per day.^[53][54][55] High milk production takes a toll on the cow. All their energy is directed towards milk production, compromising other bodily functions that also need energy. As a result, the animals become very thin and have low resistance to disease.^[56] Coupled with the unsanitary and unnatural living conditions on dairy farms, the average cow lives no longer than 6 years, while they can naturally live up to 20 years.

The top three health problems of dairy cows are lameness, udder disorders and fertility problems.

Approximately 25% of cows on dairy farms suffer from serious hoof issues and/or lameness. This statistic has remained consistent for the past 20 years.^[57] Factors contributing to this problem include poor hygiene in barns, inappropriate surfaces like concrete slats, and contaminated barn floors, which expose the cows' hooves to manure and urine. Unsanitary and damp cubicles also negatively impact hoof health. The warm and moist environment of stables, combined with the presence of manure, creates an ideal breeding ground for bacteria.^[59][60] Cows with severe lameness produce up to 36% less milk, making them unprofitable. Consequently, lameness is a significant reason for sending these animals to slaughter.^[61]

28.6% of cows suffer from mastitis, leading to painful swelling of their udders.^[62] Cows develop mastitis due to exposure to bacteria present in the contaminated barns where they reside. Bacteria can also spread from cow to cow through milking facilities. Udder infections result in significant economic losses for livestock farmers and are a major reason for the early culling of cows.^[63][64]

Thirty percent of early culling of cows in the dairy industry is due to fertility issues.^[65] A mother cow can be inseminated again seven weeks after giving birth. Often, the first insemination attempt is unsuccessful, leading to a second attempt. When inseminations continue to fail, the cow is culled because she only produces milk after giving birth (66).

Conclusion

Ongehoord's investigation clearly shows that there are no humane ways to transport animals. Modern climate-controlled vehicles, skilled drivers, and improved welfare measures do not alleviate animals' fear and reluctance to enter and exit unfamiliar environments and trucks. As a result, the use of force during loading and unloading becomes unavoidable.

Banning sticks and stun guns won't solve the problem. Instead, it often results in more hitting, kicking, or pulling on ears and tails. If the industry continues, animal transport will remain necessary, and unfortunately, animal cruelty will persist.

Selective breeding of cows for high milk production forms the backbone of the dairy industry. However, this focus on milk yield often harms cow health. Stricter inspections during transport won't address the root issue of weak and sick cows in the dairy industry. When fewer sick and injured animals reach slaughterhouses, it leads to more animals being euthanized or dying on dairy farms. Right now, over 12,000 mother cows die on Dutch dairy farms each year, resulting in a mortality rate of 0.8%.

Continuing to consume dairy and meat will lead to significant animal suffering.