Supplementary memorandum submitted by
the Bio Veterinary Group
AGAINST PET
FAIRS/MARKETS
This document is submitted in accordance with
the invitation extended by the Environmental Food and Rural Affairs
Select Committee on 7 September 2004 and forms a supplementary
memorandum to the BioVeterinary Group's primary submission issued
to Efra Select Committee on 23 August 2004.
It is not our intention to comprehensively itemise
and comment on inaccuracies or misrepresentations or self-contradictory
statements contained in the evidence provided by others, although
many statements provided as evidence to the Committee by certain
contributors fall into the above categories. However, we would
be remiss in our duty of care to the Committee if we did not provide
some examples of the seriously problematic nature of certain information
presented to the Committee by several representatives of the pro-pet
trade lobby.
Pet fairs and public health
Contrary to statements provided to the Committee
from pro-pet trade representatives exotic pet animals are in fact
established major causes of human disease. In his evidence to
the Committee Mike Allen claimed [extract taken from the uncorrected
transcript]:
"The only disease which is recognised as
significantly associated with reptiles is salmonella. This is
very clearly stated on the websites of the major organisations
such as the CDC, the WHO, or our own Health Protection Agency.
I work day to day with these organisations and before coming I
put a supplement to the report that Chris submitted. I have spoken
to these people and quite honestly reptiles probably pose the
least risk to humans. Their physiology is so different to mammalian
species that the likely transmission of disease is minimal. Salmonella
is identified; we know how to deal with it; all the major groups
provide good guidelines; if they are followed, they will minimise
the risk almost infinitesimally. The issue really is that most
common pet species we keep, also farm animals, carry a far greater
range of zoonotic diseases of danger to man. You can look at history;
you can look at the present; and the precedents are there. Quite
simply, the organisation web sites, but I think it is very important
to go to the authoritative sources here, are very clear. If they
were that upset about reptiles they would advocate a ban, but
they actually provide guidance, and I find it quite annoying seeing
this overhyping of salmonella. I think it is dangerous. I am working
in an area where I am working with organisms like MRSA, vancomycins,
and enterococcus which you may pick up from hospital pathogens,
we can trace a lot of these back to our food chain and to commonly
kept pet species, and I think if we look at the balance of risk
we are probably at far greater risk from commonly kept pet species,
or going to a local market and buying fresh meat. If we are going
to have the same level of evidence to ban reptile fairs we should
ban people going to airports and places such as that because if
we look at things like SARS, which are clearly documented, and
other diseases like avian 'flu, we should ban people travelling,
and to be honest with you the level of evidence does not support
this as a key issue. As I say, I talked to the key players of
all these organisations; they have been instrumental in helping
me put this package together; and they are quite incredulous about
some of the evidence being presented.
. . . the fact is that reptiles are contained
in conditions, not like other pet species where the faecal matter,
which is the main cause of transmission, of, say, cats and dogs
is freely available in the environment. With a reptile you have
a controlled environment that you can clean. Lots of the other
animals are free roaming, certainly farm animals where a lot of
the contamination gets into our water sources and fields. So again
you have to look not only at what infections are being transmitted
but the means of catching those infections, and certainly other
species pose a greater risk in terms of access to those pathogens."
May the Committee please note that:
1. Dr Allen's claim that the CDC (Centres
for Disease Control), the WHO (World Health Organisation and the
HPA (Health Protection Agency) support his view that pet reptiles
are not an important cause of human disease is highly misleading.
Dr Allen's extra-ordinary claim warranted that the BioVeterinary
contact directly the organisations to which he referred and which
he claimed supported his view. Dr Allen's verbatim statements
were provided to each organisation respectively. Expectedly, NONE
of these organisations ventured any support whatsoever for Dr
Allen's claims nor accepted any formal communications had taken
place with Dr Allen on the subject. Indeed, the senior representative
for both the Health Protection Agency and the Public Health Laboratory
Service's "Salmonella Surveillance Unit" rejected Dr
Allen's sweeping view and specifically and strongly referred to
information contained in his evidence to the Committee as "Rubbish".
This firm rejection of Dr Allen's claims has subsequently been
echoed by numerous epidemiologists and veterinary pathologists
with detailed knowledge of salmonella infections.
2. The Centres for Disease Control and Prevention
(USA) and the Federal Food and Drug Administration (FDA USA) have
approved the principal research regarding pet reptile-related
salmonella infection which formally concluded these animals to
be "disproportionate", "significant" and "major"
risks to public health (historically 14% of all salmonellosis
cases were found to be attributable just to pet reptiles). Accordingly,
the USA and Canada banned the largest component of the reptile
pet trade and subsequently saw a 73% drop in reptile-related cases.
A total ban on all reptile pet keeping is now under consideration
in the USA.
3. In 1992 the Public Health Laboratory
Service (UK) stated that it would like the pet terrapin trade
banned in the UK due to the threats presented to public health.
4. Both the USA and the UK governments have
issued public health warnings against pet reptile keeping due
to human incidences (including fatal) of reptile-related salmonellosis.
5. Pet fairs present a disproportionately
serious risk to public health and these events are incapable of
being managed in a manner that significantly reduces their threat
to public health.
Positive vs negative side of pet keeping
Several pro-pet-keeping commercial representatives
gave evidence to the Committee asking that the Committee consider
the "positive side" of pet ownership. No doubt the Committee
will consider this matter. However, an objective view will consider
both the relevant positive and negative aspects of pet
keeping.
The positive aspects of pet-keeping centre on
two features: first, that people gain enjoyment from pet-keeping;
and second, some research shows that for instance stroking a domestic
animal such as a dog or a cat has a calming influence on the human.
The negative aspects (not referred to by the
pro-pet lobby) centre on four features: first, widespread and
increasing recognition of animal—human disease transmission;
second, grief—it is now recognised that individuals and
families often experience unexpectedly severe grief and associated
depression on losing an animal, with effects comparable to losing
a family member or close friend, indeed grief referral counselling
services are now promoted at most veterinary surgeries; third,
regardless of the enjoyment derived from pet keeping vast numbers
of animals suffer and die due to their co-habitation with people;
and fourth, there is a substantial gulf between domestic pet keeping
and exotic animal keeping—exotic animals (as sold through
pet fairs/markets) are certainly not considered to be domesticated
by biologists and behaviourists and further, while actions such
as stroking that are arguably beneficial to both human and pet
where mammals such as dogs or cats are concerned such actions
for exotic non-mammalian animals such as reptiles and birds frequently
causes them stress.
Inspections
The commercial pro-pet lobby argue that because
vets are not "omnicompetent" then they should not be
required to inspect pet shops wherein a great diversity of species
with differing biologies are held. While it is true that many
vets do not possess the level of biological or behavioural understanding
of the very few highly qualified independent scientists in these
fields, clearly vets are better placed to assess welfare than
regular environmental health officers and local dog wardens—both
of whom may have no relevant formal qualifications. The British
Small Animal Veterinary Association firmly agrees that vets should
be required to inspect pet shops.
The pro-pet trade lobby also stated that pet
shops are exposed to more scrutiny on a daily basis than any other
animal keepers! This is clearly again a false and misleading claim
as zoos, safari parks, aquaria, farm education centres and animal
re-homing centres are all scrutinised daily by visitors.
Absurdly, in their evidence to the Committee
the commercial pro-pet lobby stated that local "experts"
(typically these are other amateur pet keepers such as bird fanciers)
carry out pet shop inspections and, even more absurdly, that inspections
were not needed because "members of the public are better
judges".
On the one hand pet traders are admitting that
exotic animals are "too specialised" even for experienced
vets, and on the other hand they are proposing that ordinary members
of the public can be relied on to assess animal welfare. This
clearly irresponsible and incredible philosophy reveals the lack
of scientific understanding inherent to the pet trade as well
as their confused approach to enforcement.
Live feeding
Another example of the poor standard of biological
knowledge associated with the pro-pet trade lobby as well as confused
and contradictory thinking arose from the Pet Care Trust and Mr
C Newman in their evidence where it was claimed on the one hand
that there were no mammals at pet fairs because they are stressed
by the presence of the snakes (potential predators), and on the
other hand these same speakers attempted to state in response
to Committee questioning that feeding live rodents to snakes caused
the rodents no stress. One cannot have it both ways.
Pet fair/market or show?
Mr Newman and others stated that they faced
a difficulty in defining what constituted a pet fair (eg market)
and what constituted a show (eg Crufts), and in part their rationale
considered that some events contain elements of both these events.
However, professional observers appear to have no difficulty in
defining these events, as any event that offers for sale animals
as pets is de facto a market. The market facet is the most
objectionable and contentious matter and thus a continuing ban
on pet markets as described under Section 2 of the Pet Animals
Act 1983 and an accompanying emphasis on the illegality of pet
markets will resolve this issue for those enduring uncertainty.
NOTE: Substantiating scientific documentation
on technical matters presented herein is available to the Committee
on request.
CONCLUSION
We are extremely grateful to the Committee for
their patience in considering this Supplementary Memorandum. We
would certainly urge—if the Committee's eyesight can tolerate
the paperwork!—that the Committee refer again to our primary
submission of 23 August which provides detailed independent scientific
background and opinion.
Based on 14 years of professional investigation
of pet fairs/markets and substantial cumulative scientific qualifications
and experience it is our firm view that the potential consequences
of any legalisation of commercially oriented pet fairs/markets
are especially serious and negative against animal welfare. We
hold the view that pet fairs/markets represent the most destructive
and unmanageable sector of the exotic pet business and that these
events should hold no place in an otherwise progressive Animal
Welfare Bill. Indeed, a clear and authoritative rejection of pet
markets is a necessary part of any proactive animal welfare protocol.
We are confident of no overstatement when we
advise that should pet fairs/markets be legalised and thus inevitably
proliferate then the consequences for exotic animal welfare would
be severe and irreparable. Further, it is highly likely that any
legalisation of pet fairs/markets would invariably promulgate
a most memorable and regrettable blight on the Animal Welfare
Bill(Act) and its formulation.
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