Memorandum submitted by the BioVeterinary
Group
EXECUTIVE SUMMARY
I. The BioVeterinary Group is a wholly independent
professional scientific consultancy incorporating specialists
in veterinary medicine, human medical science, animal biology
and animal husbandry. The Group, while offering broad support
to the Draft Animal Welfare Bill, with special reference to the
Bill's emphasis on "Duty of Care", however, offer express
opposition to:
II. Clause 6(2)(h) [and Annex B of the Regulatory
Impact Assessment "proposal to licence pet fairs"] which
provides for the legalisation through licensing of pet markets
(pet fairs etc); and
III. Annex L (pet shops licences) which
provides for the extension of pet shops licenses from 12 months
to 18 months; and
IV. Clauses 7 and 8 (Codes of practice)
include by relation to Annex B the accommodation of certain "relevant
interest groups" as advisors on animal husbandry practices,
and this inappropriately and de facto also includes categories
such as commercial pet dealers and hobbyists.
V. Pet markets are almost without exception
condemned by experienced investigative local authority advisory
and animal welfare organisations as well as independent biological,
veterinary and medical specialist. It is also widely recognised
that pet shop inspections are presently grossly deficient and
an extension in the duration of licences would likely increase
animal welfare problems. Commercial pet sectors and amateur hobbyists
are typically under-qualified to collaborate on codes of practice
and also manifest a vested interest that is inconsistent with
the aims of the Draft Bill.
VI. The legalisation of pet markets through
licensing, increased licence duration, and inclusion of pet trade
promoters as collaborative devisers of codes of practice would
without doubt incur gross and unnecessary suffering to animals,
create a substantial and an unnecessary expansion of risk to human
health at a time when responsible authorities and policies are
being structured to reduce primary and secondary sources of infection,
promulgate the emergence of diverse disease of threat to pet animals,
the human population and agricultural industries, and generate
massive and impossible burdens of inspection, evidence-gathering,
prosecution and enforcement generally while resolving none of
the existing problems associated with pet markets licensing, and
pet care information.
VII. We propose that NO provision be made
that would allow pet markets, that NO provision be made that would
extend licence duration, and that NO provision be made that would
permit commercial pet interests and hobbyists to draft their own
codes of practice.
VIII. Finally, the BioVeterinary Group respectfully
requests the opportunity to present oral evidence to the Select
Committee and be available to answer technical or other questions.
Introduction to the BioVeterinary Group and statement
of independence
1. By way of brief introduction the BioVeterinary
Group is a wholly independent professional scientific consultancy
incorporating specialists in veterinary medicine, human medical
science, animal biology and animal husbandry. Numerous of the
BVG's Associates are the premiere scientific authorities within
their respective fields. Further information on the BVG and the
status of its Associates can be found on www.bioveterinarygroup.com
PROVISIONS IN
THE DRAFT
ANIMAL WELFARE
BILL
2. The BioVeterinary Group, while offering
broad support the Draft Animal Welfare Bill, with special reference
to the Bill's emphasis on "Duty of Care", offer express
opposition to:
2(1). Section 6(2)(h) [and Annex B "proposal
to licence pet fairs"] which provides for the legalisation
through licensing of pet markets (pet fairs etc); and
2(2). Annex L (pet shops licences) which
provides for the extension of pet shops licenses from 12 months
to 18 months; and
2(3). Clauses 7 and 8 (Codes of practice)
include by relation to Annex B the accommodation of certain "relevant
interest groups" as advisors on animal husbandry practices,
and this de facto also includes categories such as commercial
pet dealers and hobbyists.
PET MARKETS:
ANIMAL WELFARE
3. Section 6(2)(h) [and Annex B "proposal
to licence pet fairs"] which provides for the legalisation
through licensing of pet markets (pet fairs etc)
3(1). Animal welfare at pet markets has
probably attracted some the most severe criticisms of any UK practices
associated with the exotic pet trade. The RSPCA, Animal Protection
Agency, Animal Aid, BirdsFirst in Aviculture, and the Captive
Animals' Protection Society are a few of the numerous widely respected
organisations and scientific and veterinary inspectors that have
conducted first-hand investigations of pet markets and found them
to be major causes of animal stress and morbidity, and also—disturbingly—found
that these events are unmanageable-regulatory recommendations
(both self-governing by organisers and imposed by local authorities)
have failed comprehensively to avert the myriad of problems associated
with pet markets. These problems include:
excessive transportation stress;
excessive handling stress;
inappropriate thermal variation and temperature
extremes and associated stress;
inappropriate moisture environments (artefactual
and haphazard humidity);
overly restrictive environments (small cages
and miniature containers);
restriction of capacity for animals to fulfil
their behavioural repertoires;
inappropriate photophase and scotophase conditions;
lack of adequate provision of food and water;
absence of appropriate qualified and specialised
monitoring personnel;
general unhygienic conditions;
inappropriately furnished environments;
infirm and unsafe containers;
inappropriate mixing of species and individuals;
and
public miseducation on animal care by poor example
and poor advice.
Pet markets: infections, animal disease and public
health
4. It is beyond doubt that pet markets are
a significant source of pathogen transmission between animals
and to humans. Incidences of contagious pathogen distribution
and disease acquired from pet markets are confirmed epidemiologically.
Only recently, however, has research work been done that attempts
to evaluate and present in detail the nature of pet markets as
a threat to animal and human health. Attached are examples of
recent published medical science reports that refer to pet markets
as an important reservoir and source of infection.
4(1). The BVG are also involved in further
epidemiological research, including transmission of animal-to-human
and animal-to-animal infectious disease via pet markets and both
the provisional and intermediate results reaffirm and additionally
indicate that:
(1) pet markets are disturbing pathogen
reservoirs;
(2) pet markets present readily viable
opportunities of animal-to-human and animal-to-animal infectious
disease;
(3) pet markets present disturbing opportunities
for the emergence of known or unusual and virulent pathogens of
potential threat to public health;
(4) pet markets present disturbing opportunities
for the emergence of known or unusual and virulent pathogens of
potential threat to agricultural industries such as poultry and
cattle;
(5) pet markets present disturbing opportunities
for the emergence of known or unusual and virulent pathogens of
potential threat to pet animals; and
(6) pet markets are preventatively unmanageable
in terms of the serious risks they present to both animal and
human health-the threat of spread of disease cannot be averted
under market conditions.
Extention of licences
5. Annex L which provides for the extension
of pet shops licenses from 12 months to 18 months.
5(1). We hold the view that pet shops currently
enjoy unnecessarily lax regulation and enforcement that results
in substantial real and potential suffering, morbidity and mortality
among animals in commercial pet establishments. Local authority
inspections are typically carried-out by persons other than specialists
and while certain authorities promote veterinary inspectors only
rarely are such individuals qualified in the highly specific fields
of exotic animal biology and behaviour so as to prepare a scientifically
valid and defensible report. Accordingly, pet shops typically
are under-scrutinised. Extending the duration of a pet shop licence
from 12 months to 18 months would in our view considerably exacerbate
animal welfare due to under-scrutiny.
5(2). We advise that no measures should
be voted for that release pet shop managers from existing legal
obligations and, further, that in express opposition to any new
relaxations in favour pet shops these establishments should be
instead be required to raise their standards of operations to
meet criteria comparable to those incumbent on zoological gardens
and veterinary practices. We see no reasonable argument for permitting
pet shop managers to be awarded special exemptions from standards
of responsibility and animal care that are inherent to other animal
managers.
5(3). Indeed, at a recent Associate Parliamentary
Group for Animal Welfare (AFGAW) meeting at the House of Commons,
Mr Ben Bradshaw MP, responding to open questions acknowledged
that he was receptive to the notion that pet shops should be required
to attain the same animal welfare standards as those legally expected
of zoological collections and veterinary practices. Both these
latter sectors are obliged not to leave animals unattended overnight
and must meet scrupulous standards of housing and care. Pet shops
typically maintain large numbers of animals in unattended conditions
overnight and with no realistic prospect of their removal in the
event of major fire outbreaks, and further maintain animals in
dense colonies that invite and facilitate the spread of disease
whereas zoological gardens and veterinary practices may be (rightly)
penalised should their own standards of animal protection fall
to those allowed of pet shops. This tolerance of the management
deficits inherent in pet shops represents an unreasonable imbalance
in the application of the law. Zoological gardens and veterinary
practices accept that their legal management obligations are warranted.
However, the fact that pet shops have historically evaded such
rigorous obligations is in our view unacceptable. In effect, pet
shops are allowed to keep animals in the worst conditions with
the least protection. Our recommendations for improved pet shop
regulations are outlined in Appendix 2 [not printed].
Codes of practice
6. Clauses 7 and 8 (Codes of practice) include
by relation to Annex B the accommodation of certain "relevant
interest groups" as advisors on animal husbandry practices,
and this inappropriately and de facto also includes categories
such as commercial pet dealers and hobbyists.
6(1). We hold the view that it is wholly
inappropriate for commercial pet sellers to be provided with the
opportunity to assist in the drafting their own codes of practice.
Neither the scientific integrity of pet dealers and hobbyists
nor the impartiality essential to oversee commercial animal management
can be guaranteed under this provision. We feel that codes of
practice on such matters as have direct affects on human and animal
health and life should be set only by properly qualified biological,
medical and veterinary specialists of clearly independent stature.
It is most unfortunate that almost without exception pet animal
dealers and keepers are composed of unqualified individuals whose
knowledge and advice are regularly dangerous to both animal and
keeper. Further, the proposed sale and dissemination of "leaflets"
from established commercial pet trade groups with vested interests
in promoting pet keeping is an irresponsible potential source
of information. The important and detailed scientific knowledge
and observational skills necessary to provide reasonable care
to captive (especially exotic) species is a subject domain of
only a small number of specialists and certainly not a "skill"
imparted to lay people though the convenient supply of "leaflets".
Also, such scant and grossly deficient media as leaflets will
lure members of the public into serious misperceptions that exotic
animals are "easy to keep", which is wholly untrue.
6(2). Codes of practice and information
dissemination that accommodate vested interests with a known poor
track record on animal welfare and trade (see RSPCA report 2004)
represents a serious error in the selection of collaborative enforcement
partners, and will create substantial new problems of animal and
human health and welfare.
Additional comment: inspections and enforcement
7. The Draft Bill presumes that through
the licensing of pet markets their management will be better regulated.
Our firm view is that this presumption is entirely erroneous.
The erroneous presumption essentially arises from the unfounded
beliefs that genuine measures can be devised in order to raise
pet markets to the (already extremely low) standards of pet shop
environments, and that inspections can be carried out by local
authorities that would be effective at identifying any problems.
7(1). Appropriate inspections of any exotic
animal facility require that the inspectors are recognised "specialists"
by both qualification and experience. Demonstrable independence
is a further valuable enhancement. There are only a very small
number of suitably qualified scientists capable of meaningful
inspections within the UK and their availability for pet markets
is highly unlikely.
7(2). It is highly improbable that locally
appointed inspectors (whether or not veterinarians) will possess
sufficient knowledge to ascertain the physical and psychological
health or otherwise of birds, reptiles and fish. Further, the
need for highly specialised professional scientific inspectors
increases where environmental conditions and provisions are at
their worst (such as at pet markets), because a greater diversity
of gross and subtle signs of stress and morbidity typically occur.
7(3). The inevitable gross deficiency of
appropriately qualified personnel would result in a substantial
expansion and exacerbation of pet market associated animal stress,
morbidity and mortality.
CONCLUSION
8. The legalisation of pet markets through
licensing, increased licence duration, and inclusion of pet trade
promoters as collaborative devisers of codes of practice will
without doubt grossly harm human and animal health and welfare,
promulgate the emergence of diverse disease, and generate massive
and impossible burdens of inspection, evidence-gathering, prosecution
and enforcement generally while resolving none of the existing
problems associated with these markets.
24 August 2004
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