Memorandum submitted by Animal Aid
1. While the draft Animal Welfare Bill contains
a number of positive measures, there are several serious deficiencies.
Not least of which, is that there will be no additional government
funding or manpower to ensure monitoring and enforcement.
2. Most of the burden will fall upon already-stretched
local authorities—while Defra acknowledges that the RSPCA
will find its workload increased.
3. On the plus side are bans on the sale
of pets to anyone under 16 years of age, the prohibition of giving
pets as prizes and enhanced powers of entry. Most positive of
all is the so called "duty of care" provision, which
allows the authorities to take action where an animal is likely
to come to harm, rather than having to wait until actual harm
occurs.
4. The negative aspects of the Bill are
considerable. In addition to a failure to commit extra resources,
the Bill will legalise one day fairs at which exotic animals,
such as reptiles and wild birds, are put on sale by itinerant
traders. Such fairs are currently illegal, although certain rogue
councils permit them. The only protection afforded such animals
under the proposed measures will be a Code of Practice modelled
on the current, self-serving Guide drawn up by the traders themselves.
5. Currently, the rearing of pheasants for
"sport shooting" is governed only by a non-compulsory
industry Code of Practice. The Bill intends that this thoroughly
inadequate code will be the only "protection" afforded
the millions of pheasants who are bred intensively every year,
principally so that they may be shot down for pleasure.
6. As well as the issues of animal fairs
and pheasant rearing, we are making a series of recommendations
relating to the welfare of thoroughbred performance horses.
THE CASE
FOR A
BAN ON
THE PRODUCTION
OF PHEASANTS
AND OTHER
BIRDS FOR
"SPORT SHOOTING"
7. The introduction of a code, initially
the industry's own, is not the way forward. Animal Aid, instead,
urge the government to introduce a ban on the production of pheasants
and other birds for "sport shooting". Such a ban already
operates in the Netherlands.
INTRODUCTION
8. The image that Britain's pheasant shooters
try to project is one of tweedy Edwardian elegance; of responsible
custodianship of the countryside. But rather than "harvesting"
a natural resource, the birds are mass produced inside hatcheries
and rearing sheds. From the sheds, they are moved to large pens
before being released to serve as feathered targets for shooters
who are often charged a day-rate of more than £1,000. Every
year in Britain, this is the fate of 20-40 million pheasants (no
reliable figures exist). The pro-"country sports" newspaper,
the Daily Telegraph, itself acknowledged (7 December 2002)
that the shooting of these birds is "done largely or solely
for pleasure".
9. Because of the enfeeblement that results
from being reared in sheds, many of the released pheasants die
before they can be gunned down. They perish from exposure, starvation,
disease, predation, or under the wheels of motor vehicles. And
not all the birds who are shot are actually eaten. Some die from
their wounds unretrieved. While, some of those who are retrieved—according
to a Country Life magazine editorial (1 February 2001)—are
regarded as "surplus" and buried in specially dug holes.
10. In an effort to eliminate aggression
caused by the crowded conditions in the rearing sheds and release
pens, gamekeepers fit the pheasants with various devices that
limit their vision and prevent them pecking at their cage mates.
These include masks, beak clips and plastic "specs".
They also have the ends of their beaks burnt or sliced off.
11. The excesses of the pheasant industry
go further still. Large numbers of wild birds and mammals are
killed annually with snares, poison and body-crushing traps in
"predator control" programmes. Gamekeepers deliberately
target foxes, stoats and weasels, because these animals are attracted
to the unnaturally large number of semi-domesticated pheasants.
But species ranging from badgers to cats—even protected
birds of prey like owls and kestrels—are caught and killed.
12. Because of the confusion across government
Departments about whether shooting is sport or agriculture, not
even the meagre animal protection measures that are supposed to
govern the production of poultry apply to the rearing of pheasants.
The birds' main form of "protection" is the voluntary
industry welfare code. The new Animal Welfare Bill proposes that
this self-serving Code is effectively adopted as a mandatory requirement.
BACKGROUND TO
THE DUTCH
BAN
13. There is no hunting with horses and
hounds in the Netherlands. Shooting game with a shotgun is called
hunting.
14. In the 1980s, public surveys were commissioned
by Dierenbescherming Nederland (The Dutch Society for the Protection
of Animals) to gauge public opinion about the support for a ban
on the release of game for hunting. There was also considerable
concern in the Netherlands about the potential for damage to the
environment by large releases of pheasants for hunting. More than
half of the land area of the Netherlands is used for agriculture.
Damage to crops and the agricultural environment are major issues.
Dutch ideas about the natural environment run counter to how the
British shooting industry strives to connect shooting with conservation.
15. Earlier Acts of about 10 years ago preventing
the release of pheasants for hunting are now superceded by the
Netherlands Flora and fauna Act of 2002. This forbids the breeding
and release of pheasants so that they can be hunted. Between 1986
and 2002, it was permissible to breed and release pheasants to
replace any destroyed by agricultural activity. (Such as the destruction
of nests during mowing) Now, even that exception is disallowed.
16. It is not forbidden to breed pheasants
or keep them as pets. But any pheasants reared for food must be
humanely slaughtered and/or sold to a poulterer.
17. Commercial game shooting is forbidden.
EXTERMINATION OF
PREDATORS
18. The Dutch recognise that predation is
a natural phenomenon, and do not allow unnatural releases of prey
species to create an imbalance. Consequently, there is no scope
to claim that the extermination of artificially engendered predators
is contributing to conservation or biodiversity.
19. All netting, trapping and snaring is
prohibited, except for the live-trapping of crows, using cages
and reared decoys.
20. "Pheasants: feathered targets or
food?"
Editorial from Country Life, 1 February
2001.
". . . many large estates now shoot four
or even five days a week from November to the end of January,
killing as many as 2,000 birds a week. Shooting on such a large
scale can be justified if there is a ready market for the birds
bagged. This no longer exists. During this past season the price
paid by game dealers for a brace of pheasants has fallen to between
60p and 80p a brace. In some areas, over-supply has led to shoots
being forced to give away their bags, or, worse still, bury their
surplus . . . There is one simple reason for the slump in demand
for pheasants: over-supply. About 13 million pheasants were shot
during this past season, which is probably twice as many as the
market can absorb . . . Worryingly, on many commercial shoots,
pheasants and partridges are regarded as feathered targets, not
food. Many people who shoot even decline to take home their traditional
brace of birds . . . Demand for big bags has led to considerable
overstocking with tame, hand-reared birds . . . the ecological
impact of releasing 20 or more birds per hectare—a common
stocking figure on many commercial shooting estates—is serious.
It not only reduces the breeding success of wild stock, but leads
to crop damage, soil erosion round release pens, and a greatly
increased risk of disease . . . Rearing and releasing game for
shooting has already been outlawed in Holland, and there seems
little doubt that coming years will see the threat of similar
legislation in this country."
21. Animal Aid calls for a ban on the commercial
breeding of pheasants for sport shooting.
PROPOSAL TO
LICENCE PET
FAIRS
22. We consider this proposal to be retrograde
and inconsistent with the Bill's objective to advance animal welfare
in Britain.
23. In the past five years we have gathered
abundant evidence at bird and reptile fairs which demonstrates
that the makeshift set-ups, overly restrictive housing and excessive
transport and handling associated with itinerant trading, are
incompatible with high animal welfare standards.
24. Filmed evidence at the National Cage
& Aviary Birds Exhibition in 2002 and 2003 showed birds routinely
kept in tiny cages, unable to spread their wings, in direct contravention
of the Wildlife & Countryside Act, 1981. This event is the
largest and most "prestigious" in the bird dealers'
calendar. Many smaller birds such as finches and budgerigars were
kept in severely overcrowded cages that did not afford enough
space for each bird to perch. Precariously positioned cages were
frequently interfered with by members of the public and fell to
the ground. These stressful conditions are compounded by the fact
that parrots are neophobic—fearful of new situations. The
constantly changing environment and replacement or removal of
cage mates accelerates the suffering endured by parrots at pet
markets.
25. Video documentation from more than a
dozen reptile markets shows animals stacked in tiny plastic boxes
and cardboard take-away containers with ventilation holes that
are blocked by the box above. Little regard is given to the temperature,
lighting and humidity control necessary for reptiles' complicated
biological functions. At most reptile fairs the animals are freely
available for public handling, greatly increasing their level
of stress and suffering.
26. Although some bird and reptile dealers
also run pet shops that are licensed and inspected, most do not
and, instead, travel from one pet market to another. Little is
known about the temporary accommodation used by these dealers
to house animals between markets. At the very least, these premises
should also be licensed.
27. The impact of this proposal on wild
populations of birds and reptiles would also be devastating. According
to the RSPB, the EU is the world's largest market for wild-caught
parrots, with more than 10,000 birds imported into the UK last
year. Ninety-nine species of parrots are currently listed as globally
threatened, 45 of whom are specifically threatened by the pet
trade. The majority of CITES listed bird species imported into
the UK are still wild-caught. Similarly, capture from the wild
is still the main source of imported reptiles into Britain. The
Animal Reception Centre at Heathrow has reported an alarming 49%
increase in reptiles imported, up to 100,000 in 2002. The World
Wildlife Fund for Nature recently stated that: ". . . wildlife
criminals see the UK as a soft touch". The legalisation of
pet fairs would only reinforce this view.
28. An increase in the number of exotic
pets in Britain will also lead to an increased number of non-native
species released into the wild. Much of the exotic pet trade relies
on impulse buying and buyers' ignorance. When these pets become
too troublesome or large, they are often released by their owners
into the environment. Unintentional escapes also occur as these
wild animals seek release from captivity. The ecological problems
associated with alien species are well established. Among those
which can be directly attributed to pet sources are: European
pond terrapin (Emys orbicularis), red-eared terrapin (Trachemys
scripta elegans), American bullfrog (Rana catesbiana)
and ring-necked parakeet (Psittacula krameri). According
to Dr Chris Butler of Oxford University, Britain's wild parrot
population currently numbers 20,000 and is increasing by 30% annually.
Sadly, but not surprisingly, they are now considered "pests"
by farmers concerned about commercial fruit crops. At a time when
Britain is being criticised for its failure to meet targets under
the EU Habitats Directive, a relaxation of pet fair legislation
will do little to convince critics that this government is committed
to preserving biodiversity.
29. Legalising pet fairs would also bring
with it the prospect of more cruelty and neglect cases. The RSPCA
report a shocking 200% increase in the number of exotic animal
rescues in 2000 compared with 1999. Most of these cases involved
ill-informed owners who were unaware that they were causing any
suffering. Our investigations at bird and reptile fairs reveal
that the average stallholder possesses neither relevant qualifications
nor experience in bird or reptile husbandry. Customers are often
given misleading and inaccurate advice about the animal's full-grown
size, lifespan and complex physiological and behavioural needs.
When the six inch iguana they purchased reaches six feet in length,
they are unable to cope and either abandon the animal or dump
him/her on an already overcrowded rescue centre.
30. Many animals purchased at pet fairs,
sometimes costing hundreds or even thousands of pounds, become
sick or die within a few days. Pet markets provide an ideal environment
for the spread of disease between animals and from animals to
people. Highly stressed animals suffer from reduced immune competence
and increased incidents of common infections. A number of these
infections have the potential to result in serious epidemics and
can cross species boundaries. Psittacosis in birds and salmonella
in reptiles are just two of the pathogens easily transferred to
humans. In the US, it is estimated that up to 140,000 people annually
contract salmonellosis from direct and indirect contact with reptiles.
Zoonotic infections are of particular concern with pet fairs as
they are usually held in public venues such as sports halls, community
centres and schools. As these pathogens can persist in the environment
for long periods, many more people will be put at risk when the
building reverts to its usual functions.
31. The unrealistic enforcement burden that
this proposal would put on local authorities would inevitably
mean that many fairs would not be monitored and any licence conditions
designed to prevent animal suffering would be unenforced. Many
taxpayers would surely question the use of limited council funds
to administer and licence these commercial events.
32. Legalising pet fairs would be a giant
step backwards for animal welfare in Britain. Animal Aid calls
for this proposal to be removed from the Animal Welfare Bill.
WELFARE OF HORSES USED IN THE RACING INDUSTRY
INTRODUCTION
33. Many people believe that betting on
a horse is a harmless flutter. But around 300 horses are raced
to death every year on British courses or whilst training—they
are shot following falls, suffer fatal heart attacks, or sustain
some other injury that makes them commercially unviable.
34. Those who continue racing are pushed
to their limits. Serious racing-related illnesses such as bleeding
lungs and gastric ulcers are now endemic. 82% of flat race horses
older than three years of age suffer from exercise induced pulmonary
haemorrhage (EIPH)—ie bleeding in the lungs. Gastric ulcers
are present in no fewer than 93% of horses in training, in whom
the condition gets progressively worse. When horses are retired,
the condition improves.
35. Some 15,000 foals are bred for racing
in Britain and Ireland every year, but only one third are deemed
sufficiently strong and healthy actually to be entered into racing.
Most of the others are discarded. They are killed for pet food,
fed to hunting hounds, used for less testing equestrian events,
or repeatedly changing hands in a downward spiral of neglect.
A similar fate awaits the thousands who leave racing every year
and who are not retained to serve as breeders. Only a small number
enjoy a decent, properly financed retirement.
36. The above indicates why Animal Aid regards
commercial horse racing as being intrinsically exploitative. Calling
for a ban, however, would at this juncture be an empty gesture.
We recognise that we must play our part in encouraging meaningful
debate and help build public and political support for the view
that supporting commercial horse racing is incompatible with a
concern for animal welfare. In the meantime, we wish to submit
for incorporation into the new Animal Welfare Bill, some practical
recommendations to improve the welfare of performance horses.
BAN ON
WHIPPING
37. The "whip" is a narrow plastic
rod that is used to beat racehorses. A new, cushioned whip has
been mandated for National Hunt (jump) racing, but this requirement
does not apply to All Weather or Flat racing. Furthermore, there
is already evidence that jockeys using the new "shock absorbing"
whip are hitting harder and more often to compensate for the reduced
"purchase".
38. Our report, "A Hiding to Nothing"
studied 161 races, involving 285 jockeys and 1,500 horses. It
is probably the most comprehensive survey of its kind ever conducted
in Britain. It details the whip being used on young horses during
their first ever race. Horses in a state of total exhaustion and
out of contention were also beaten. The whip was used on the neck
and shoulders, as well as the hind quarters. Horses were observed
being whipped 20, even 30, times during a race.
39. A statistical analysis showed that whipping
decreases the chances of a win. And our filmed evidence shows
whipped animals become distracted, unbalanced and lose concentration.
In response to our evidence, the Jockey Club (JC) has admitted
that "more races are lost rather than won through use of
the whip".
40. The JC allows use of the whip for "safety
and encouragement". Safety is a valid concern, but our evidence
demonstrates that whipping often causes rather than prevents accidents.
The vast majority of whip use is self-evidently for "encouragement".
Inflicting deliberate pain and stress on an animal while attempting
to secure a better outcome in a "sporting" event, must
surely qualify as "unnecessary suffering"—a criminal
offence under both 1911 Act and the proposed legislation.
41. Animal Aid calls for an outright ban
on the use of the whip. This would create a "level playing
field" and mean that all riders could race to the best of
their abilities without resorting to beating the horses.
REHABILITATION OF
RETIRED RACEHORSES
42. Thoroughbred horses have been selectively
bred for racing. In retirement they have very particular psychological
and physical needs.
43. The industry's retirement project—Rehabilitation
of Racehorses (RoR) is just four years old and we understand it
devotes something like £200,000-250,000 for horse "rehabilitation"
each year.
44. It costs about £4,000 merely to
retrain a retired racehorse for a new career (The Independent,
12 April 2000). This means that £200,000 could retrain only
50 horses. According to research conducted by the British Horseracing
Board itself, there are at least 350 ex-racehorses per annum in
need of "retraining". We regard that total as conservative.
45. The Thoroughbred Rehabilitation Centre
in Nateby reports (The Guardian, 8 February 2002) that
they, alone, turn away "two or three" horses every day
during the winter months because the animals cannot be accommodated.
We calculate that this adds up to around 300 horses annually—from
just one centre that is part of the RoR scheme. Also missing from
the BHB's calculations are all the horses who fall by the wayside
at varying ages and who are simply not tracked.
46. The number of ex-racehorses disposed
of each year and in need of care is clearly substantial. But even
if we assume the figure to be 1,000, given that around £4,000
per horse is required for retraining, we see that £4 million
is needed for that task alone. Our research indicates that another
£1,000-plus per horse is needed by way of a contribution
to feeding, stabling, veterinary bills, care of hooves, teeth
and so on. We now reach a total of £5 million per annum.
47. Such an amount is a pittance in the
context of an industry where the prize money for a Derby winner
is more than £500,000, and where the horse racing-related
income of the major bookmakers runs to hundreds of millions of
pounds every year. These Big Three, nonetheless, are reported
to have refused to give more than a token amount to the industry's
retirement scheme. (Daily Telegraph, April 2000)
48. Animal Aid calls for the industry to
be legally required to provide sufficient funds for the rehabilitation
of all racehorses.
PUBLICLY ACCESSIBLE
DATABASE OF
THOROUGHBRED HORSES
AND THEIR
FATE
49. It is extremely difficult to track the
identity, ownership and whereabouts of thoroughbred horses who:
50. Were bred to be raced but who failed
to make the grade and thus dropped out of the system.
51. Have retired from racing.
52. Race horses, for instance, not infrequently
arrive at sanctuaries with names that do not show up on any of
the records. We are also concerned by reports of horses passed
from owner to owner and suffering a downward spiral of neglect.
The horse passport system seems to have done little to improve
the situation.
53. Animal Aid calls for the development
of the "passport", on which is logged key identification
details, injuries, veterinary treatments, races run and transfer-of-owner
details.
54. Record-keeping should be open to public
scrutiny and should continue after the horse leaves racing—or,
indeed, be undertaken even if a young animal fails to "make
the grade". The animal's ultimate fate should also be logged—whether
slaughtered for pet or human food, used as a source of meat for
the local hunt, or employed in a secondary career in point-to-point
racing or at a commercial stables.
55. The British Horseracing Board and the
Jockey Club (or their successor body) should have a duty to ensure
such records are properly maintained, centrally located and be
open to public inspection. Defra and/or local authorities should
be assigned powers of enforcement with respect to offences of
abandonment, neglect, cruelty and the failure to maintain proper
records.
19 August 2004
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