Memorandum submitted by the British Wildlife
Rehabilitation Council
SUMMARY
The Steering Committee of the British Wildlife
Rehabilitation Council wishes to make the following submission
in response to the request for written evidence regarding the
provisions of the Animal Welfare Bill. The submission is made
with particular regard to the regulation of wildlife casualty
rehabilitation units and incorporates the views of many workers
in this field.
The Council feels that there is a need for regulation
of such units but is concerned that any costs involved should
not force the closure of well-run, smaller units, which would,
thereby, reduce the availability of appropriate care for wildlife
casualties.
INTRODUCTION
1.1 The care of wildlife casualties within
rehabilitation units is primarily a welfare issue and, only rarely,
one of conservation. Any legislation regulating the rehabilitation
of wildlife casualties must ensure that their welfare is safeguarded.
1.2 Although sharing many similarities with
companion animal welfare centres, wildlife rehabilitation units
do have some important practical and ethical differences. Wildlife
casualties are handled with the principal aim of their return
to the wild in a fit state to survive and after a minimal period
of captivity. Casualties come from a wide range of species and
they usually require some form of treatment and often need specialised
handling facilities.
1.3 The majority of wildlife casualties
are found by members of the general public and rehabilitation
units provide a service to the community by acting as reception
centres for these casualties. Rehabilitation units vary widely
from a few, large, well-funded and professionally staffed units
that handle large numbers of casualties to the many, smaller,
poorly funded units that handle small numbers with little professional
assistance.
1.4 There is a need to ensure that the working
practices of wildlife rehabilitation units neither compromise
the welfare of animals in their care nor the health of the wild
populations into which their patients are released. Regulation
would assist with these aims.
REGULATION
2.1 If, under the new Act, regulations are
made regarding the operation of wildlife rehabilitation units,
then consideration must be made of the effects these regulations
will have on the welfare of wildlife casualties. A licensing and
inspection scheme would, inevitably, involve costs to the licensee.
If these costs were considerable they would present an additional
financial burden, which might force the closure of many units,
especially the smaller ones.
2.2 Closure of units would deprive the general
public of a readily available source of assistance when faced
with a wildlife casualty, which would inevitably compromise the
welfare of casualties. Lack of such assistance will put more pressure
on the animal welfare charities that offer assistance to wildlife
casualties and also on veterinary practices (many of which are
only equipped to act as reception centres for wildlife). A greater
concern is that the lack of readily available assistance might
encourage untrained and poorly equipped persons to "do-it-themselves",
again seriously compromising the welfare of casualties.
2.3 Consideration could be given to a two-tier
system, as suggested in the recent Companion Animal Welfare Council
report on Companion Animal Welfare Establishments, with licensing
and inspection of larger units and a simpler registration scheme
for smaller units. The threshold between units to be licensed
and those to be registered could be based on factors such as the
annual number of casualties handled, the employment of staff,
the annual turn-over and charitable status. However, such a scheme
would be thwarted with problems, especially with defining the
thresholds and in dealing with borderline cases. A registration
scheme for all units would simplify the situation.
2.4 A registration scheme could include
the following :
1. An undertaking to work to an approved
code of conduct.
2. A declaration of the maximum number
of casualties, specifying general groups or species, to be held,
for more than a specified period, such as 72 hours, at any one
time.
3. The nomination of an attending veterinary
practice.
4. The maintenance of records in an
approved manner.
5. To be open for inspection by appointed
inspectors.
6. An undertaking to participate in
training and continuing education.
2.5 A registration scheme should apply to
anyone who cares for wildlife casualties on a regular basis, for
example, over four casualties in any one year. Once a registration
scheme is functioning, consideration could then be given to limiting
the length of time a non-registered person or unit could hold
a wildlife casualty, such as 72 hours.
2.6 At the moment, it appears that the number
of wildlife rehabilitation units in this country appears to be
decreasing and, hence, it would be valuable for any form of regulation
to be shown to be an encouragement rather than a deterrent. The
recognition that registration would bring could facilitate negotiations
with grant-making bodies, allow units to publicise their services
to local veterinary practices, the police etc and could become
a condition of receiving charitable status.
2.7 Consideration should be given to the
role of veterinary practices within a regulation scheme. Many
veterinary practices act as reception centres for wildlife casualties,
making an assessment of a casualty and administering first-aid
before passing it on to a rehabilitation unit or performing euthanasia,
whereas others retain casualties for treatment. Consideration
could be given to the inclusion in the registration scheme of
practices that regularly hold casualties for treatment to ensure
that they have suitable facilities to accommodate wildlife patients
beyond an initial period for assessment and first-aid.
23 August 2004
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