Memorandum submitted by BirdsFirst
1. INTRODUCTION
AND MAIN
POINTS
1.1 BirdsFirst welcomes the concept of a
"duty of care" which is at the heart of this Bill. We
also welcome the concept of enabling legislation, so that a programme
of further legal improvements to the conditions in which animals
are kept can be introduced. Our comments here are confined to
our group's remit: the welfare of all captive birds, other than
birds in agriculture. Our main concern is the concept of legalising
pet fairs and pet markets and any such itinerant events which
this Bill seeks to introduce. Our main areas of objection with
regard to such pet fairs and markets are as follows.
1.2 Animal welfare.
1.3 Disease control.
1.4 Consumer protection.
1.5 Ecological aspects.
1.6 Other aspects.
2. ANIMAL WELFARE
2.1 The Draft A W Bill does not acknowledge
the special and particular conditions required to maintain non-domesticated
animals (such as most species of birds) kept in captivity. Species
commonly traded at itinerant one/two-day pet fairs and markets
include wild caught birds from tropical countries, mainly parrot-like
and passerine species, plus captive-bred specimens of these orders.
We note that the Bill exempts mammals from such proposed itinerant
sales but understand that Defra has no scientific basis for doing
this. That is one would assume that Defra feel that mammals should
not be sold at itinerant events because they would suffer more
that birds, fish or reptiles. We suspect however, that the reverse
is the case. That domesticated mammals such as cats and
dogs would suffer less than wild, non-domesticated (non-companion)
"exotic" species by being offered for sale at such events.
Domesticated mammals are accustomed to the close proximity of
humans and are regularly handled by people. In contrast, the mere
act of handling birds can cause distress. Birds sold at itinerant
sales have to be handled repeatedly for each event and
this exacerbates the problems they experience. Traders regularly
transport birds hundreds of miles to these events. Birds
may travel from Cornwall (eg North Cornwall Aviaries near Bodmin)
and the southeast (eg Safari Select) to venues in the midlands
and beyond. We are of the view that Defra has not taken into account
matters of travelling distances involved in the itinerant trade
and their effects on the birds. On arrival, birds may then be
transferred again to "display" cages for the sale day(s).
Most cages holding medium to large species of parrots at these
events already contravene the Wildlife and Countryside Act 1981
due to their small size. Display cages of a legal size are inconvenient
(impractical) for traders to use. When distressed, caged birds
may fly repeatedly at the cage bars, causing trauma around the
head and sometimes the wings. Bleeding can occur readily since
avian skin is paper-thin. At large events, birds die in their
dozens. However, deaths are likely to be under-recorded since
traders find deaths embarrassing. With regard to pet fairs and
markets we are of the view that mortality and trauma would be
seen less in domesticated mammals than is the case with
exotic species. In devising a draft policy on pet fairs and markets,
Defra have provided no evidence that exotic species can be traded
in such a way while ensuring their welfare under the ethos of
a "duty of care". Furthermore, Defra has provided no
evidence that mammals should be excluded from such sales on any
grounds of welfare. To devise even such a draft policy
(which revokes the provisions of the 1983 amendment to the Pet
Animals Act 1951) without a basic knowledge of the welfare requirements
of the species concerned, is in our view irresponsible. We feel
Defra have been derelict in their duties on this matter. Due to
the huge range of exotic species comprising several orders of
birds, there is a vast range of conditions they require in order
to be sold without being distressed. Birds have higher metabolic
rates than mammals and succumb more rapidly to the onset of illness.
Birds are commonly seen at these events showing extreme fear behaviours.
These include growling in grey parrots and "fear huddles"
in cockatoos, poicephalus, aratinga and Amazona species.
Colleagues from Animal Aid and Captive Animals Protection Society
have previously submitted written evidence and video recordings
acquired at these events, to Defra. When birds are under such
conditions of distress, their immune system is seriously compromised.
At this point, infections which earlier may have shown no symptoms
can become acute and lead to illness and/or death. Since a "duty
of care" is supposed to be at the heart of this Bill, we
strongly suggest that the government adopt a precautionary principle
with regard to practices involving the trading of animals. By
this, we mean that the onus lies with those making such a suggestion,
(such as pet fairs, markets, auctions and any other forms of itinerant
trading) to prove that the practice is acceptable with regard
to the animals" welfare needs. BirdsFirst wishes to see all
forms of trading in birds restricted to fixed, pet shops or breeders'
premises. Any loopholes in the current legislation which allows
for the trading of "pets" from venues other than these
should be removed.
It is known that parrot-like birds are highly
aware of events going on around them. They also show a degree
of intelligence comparable to that of higher primates (Pepperberg,
1992, 1994). They have complex social structures (Bond & Diamond
1999) and an equally complex repertoire of behaviours (Rowley,
1990, Meehan, Millam and Mench 2003). Parrots are generally neophobic.
They appear to derive much of their "security" from
living as a coherent flock. The process of trapping such animals,
then confining them and transporting them to a successions of
makeshift venues where they are offered for sale is completely
at odds with their most basic welfare needs. Where such animals
are to be sold, this should be done from fixed premises only;
not from makeshift itinerants' venues. It is common to see very
young, often hand-reared birds offered for sale at pet markets
and fairs. These birds have not reached the age at which they
would have fledged. Hand-rearing is done as this reduces the costs
for the breeder. It is known that the methods typically employed
to hand-rear parrots results in deformities to their skeleton
(Harcourt-Brown, (2004). Measures should be taken to ensure that
birds cannot be sold unless they are both fledged and fully able
to feed themselves, independently of their parents.
2.2 Disease control
Where any collection of any animals is placed
in any restricted common airspace, the risks of spreading diseases
is increased greatly. Diseases can include zoonoses such as psittacosis
and avian influenza. In recent years, the UK, along with many
other countries, have been subjected to a range of disease outbreaks
which have major medical, financial and social implications. These
have had serious consequences, mainly for agriculture but with
avicultural interests also affected. While birds in "conventional"
breeders' premises and pet shops also share a common airspace,
they are not subjected to the distress caused by travelling to
and from itinerant events, and it is easier to control the spread
of infectious diseases in fixed premises. It is the combined
effect of travelling, plus the makeshift nature inherent at bird
markets and pet fairs which results in seriously compromising
the birds' immune systems and result in "unnecessary"
deaths at itinerant events. Where outbreaks of disease occur (including
zoonoses) it is difficult to trace these from itinerant events.
With disease-control measures in mind, we feel it is irresponsible
for Defra to facilitate pet fairs and markets through some "licensing"
system. Rather than relaxing conditions in which birds can be
sold by repealing the 1983 amendment to the PAA `51, this provision
should be strengthened and reinforced so as to ensure no
animals (no vertebrates) are sold at such events. Again, due to
the makeshift nature of pet fairs and markets, it is most naive
to assume that any so-called "licensing conditions"
could actually be enforced at these events. The country does not
have officers trained to recognise distress and other medical
conditions in the huge range of exotic species present at these
events. Furthermore there are not sufficient veterinary surgeons
specialised in this area of work. Indeed most UK vets receive
little or no formal instruction in avian medicine before
graduating (Pers comm, Stanford, 1997).
2.3 Consumer protection
The whole ethos of itinerant events is one of
casual trade, with minimum restrictions on vendors as "bargain
birds" are sold. Attempts to "licence" these events
does not address the problems faced by buyers of the birds. Typically,
vendors fail to give any guarantee with any bird, and receipts
are almost never given. Buyers attend many of these sales hoping
to purchase a "bargain". Birds which survive to point
of sale sometimes fall ill and/or die a few days or a few weeks
after the sale. At this point, the buyer often has no recollection
of who they bought their bird from. Contact with the trader will
have been lost and redress for the customer is, invariably, not
possible.
2.4 Ecological effects
Due to the travelling and multiple transfers
from one cage to another involved in the itinerant trade, birds
are more likely to escape than if they were being traded via conventional
premises. Where hundreds or even thousands of birds may be involved
at a sale day, escapes will always occur. Some of these birds
achieve liberty and are lost for good. The UK already has a number
of alien bird species. Ring-necked parakeets Psittacula krameri
have established themselves with an estimate of around 10,000
breeding in England. These are already classed as a "pest"
species by Defra. Blue-crowned conures Aratinga acuticaudata
appear to be breeding in Kent and monk parakeets Myiopsitta
monachus are believed to be breeding in several locations.
Itinerant trading in birds therefore increases the chances for
birds to escape and establish themselves in the UK as successful
alien species. It is known that ring-necked parakeets compete
with other, native hole-nesting species such as stock doves. Since
most parrots are hole-nesting, this trend looks set to continue
with unknown implications for British wildlife. These events are
also venues for buyers to obtain relatively cheap imported wild-caught
birds. Most of these come from tropical countries, but British
birds are also sold. The itinerant trade thus facilitates the
sale of wild-caught birds who will already have suffered considerable
distress since the point at which they were captured. These birds
are therefore at the greatest risk of dying than other (captive-bred)
birds.
2.5 Other matters
2.5.1 The "educational" value
of pet markets and sales. It has been suggested that one of
the "advantages" of these events is that people pick
up more information about bird-keeping. The evidence for this
is poor. It also presumes that good information resides with those
selling birds. It should be remembered that the prime function
of these events is for traders to make money by selling birds,
while buyers attend looking for "bargain birds" to buy.
Prices of birds are lower at these events than from normal retail
outlets, since conventional outlets have to cover their higher
running costs. The quality of information from vendors is generally
very poor. Vendors will be able to advise on some matters of diet
and minimal housing conditions but consistently fail to inform
buyers of common problems associated with non-domesticated species
as "pets". In birds, these problems include behavioural
issues such as noise levels, biting, nervousness and tendencies
to self-mutilation. Where bird keepers exchange information amongst
themselves again, the standard of knowledge on birds' needs, particularly
their behavioural needs is very poor. A better case can be made
for the use of events where no sales take place (exhibitions and
other meetings arranged by specialist clubs and veterinary bodies).
BirdsFirst has no objection to exhibitions of birds. Here,
birds do not change ownership; owners have a much higher incentive
to care for their birds (so as to win awards in their category)
and birds return to their familiar home/cage at the end of the
event. The grounds for justifying pet fairs and markets on "educational"
grounds are therefore spurious. The very conditions in which many
birds are displayed and transported are testament to the lack
of knowledge (and/or care) typically seen at these events.
2.5.2 Defra's Animal Fairs Working Group.
BirdsFirst suspects that civil servants may have behaved improperly
in appointing certain persons to this Group. Also, the Group's
remit was, in our opinion seriously flawed. From conversations
with some of the Group's members, it was clear that they were
under a remit to "legalise" itinerant events such as
pet fairs and markets. We believe restricting discussions to pre-conceived
notions regarding legalising such events is a serious error. The
Group should have had an open remit to look at the matter as they
saw fit with the only "constraint" being an adherence
to an ethos of a "duty of care" regarding how animals
are sold.
2.5.3 Eighteen-month licensing periods.
The idea of attempting to reduce costs by opting for 18 month
licensing periods for the various licenses proposed (pet shops,
animal sanctuaries etc) is, we feel a flawed concept (it is virtually
non-sensical with regard to itinerant events). Licensing periods
should be for a year as the maximum duration.
2.5.4 Licensing of sanctuaries etc.
BirdsFirst supports the proposals to have animal sanctuaries licensed
and/or registered. We feel this will assist with improving animal
welfare matters.
3. SUMMARY AND
MAIN POINTS
3.1 BirdsFirst supports the move to modernise
animal welfare law and in particular, the concept of a "duty
of care" within the draft Bill. We support the idea of sanctuaries
being licensed and/or registered. We support the concept of enabling
legislation which can be updated as needed. We hope that once
the new legislation is introduced, the momentum will not be lost
to ensure that practical improvements for the welfare of animals
is introduced through further, detailed measures.
3.2 We object to any notion of legalising
any form of pet markets, auctions or pet fairs or any form of
itinerant trading in any pet animals. This proposal in the draft
Bill should be withdrawn. Trading in pet animals should only be
done from licensed, fixed pet shops and breeders' premises.
3.3 Our objections to pet fairs, auctions
and markets etc are on grounds of animal welfare and the prevention
and control of diseases, including zoonoses. We feel Defra have
made serious errors in failing to understand the complex needs
of non-domesticated species which are sold at such events
and have not taken into account the welfare implications regarding
the distances animals are transported to and from these events.
From our knowledge and information of conditions at these events
(previously submitted to Defra) we are of the view that if itinerant
trading is incompatible with a "duty of care" for pet
mammals, it is even more the case for non-domesticated species
which have special requirements. A precautionary principle
should be adopted with regard to practices concerning animal welfare,
particularly methods of trading.
3.4 We also object to such methods of trading
on ecological grounds. The itinerant trade poses greater risks
of escapes of non-native species into the wild and is also a means
to facilitate more trade in wild-caught birds, including those
from tropical countries.
3.5 We feel that consumers are treated very
poorly with regard to livestock purchased at itinerant events
and that the very makeshift nature of this trade is not compatible
with a concept of licensing. It is our view that the UK does not
have suitably trained officers and veterinary staff (specialised
in non-domestic animals) to enforce such legislation as licensing
of itinerant pet sales. Pet shops etc should be licensed for one
year at a time as the maximum period (not eighteen months).
3.6 It is our view that the Animal Fairs
Working Group set up by Defra was improperly constituted and was
required to work under a seriously inhibited remit. With this
in mind we feel this Group's contribution to the debate should
be discounted.
3.7 We wish to see licences being issued
for a maximum period of one year, not 18 months as proposed.
REFERENCES:
Bond A & Diamond J. Kea; Bird of Paradox.
Pub. Univ of California, 1999.
Harcourt-Brown N. 2004. Development of the
skeleton and feathers of dusky parrots (Pionus fuscus) in relation
to their behaviour. Veterinary Record, Vol 142 No 2 January
2004.
Meehan, C L, Millam, J R and Mench, J A, 2003
Foraging opportunity and increased physical complexity both
prevent and reduce psychogenic feather picking by young Amazon
parrots. Appl Anim Behav Sci 80, 71-85.
Pepperberg I M 1992. Proficient Performance
of a Conjunctive, Recursive Task by an African Grey Parrot (Psittacus
erithacus). Journal of Comp. Psychology 1992. Vol 106 No 3.
Pepperberg, I M 1994. Vocal Learning in Grey
Parrots (Psittacus erithacus): Effects of social interactions,
reference and context. The Auk, 111 (2): 313, 1994.
Rowley, I. The behavioural ecology of the
galah. Pub. Surrey Beatty & Sons 1990.
Stanford, M MRCVS. Personal communication with
G Glendell, 1997.
24 August 2004
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