Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by the British Wildlife Rehabilitation Council


  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.


  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.


  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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