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

Memorandum submitted by the Association of Circus Proprietors of Great Britain

  This Association, being the body representing the circus industry in Great Britain, has considered in detail the draft Bill.

  The Association recognises that the present legislation on the keeping and training of animals used in entertainment is inadequate. It welcomes any effective and workable proposals for standards of animal welfare in the entertainment industry. However the Bill as drafted gives considerable cause for concern. Regrettably the Bill does not seek to either impose standards or set down a procedure for assessing standards but merely empowers the Minister to make regulations. These regulations could be far reaching to the point that they seriously limit or altogether exclude the use of most performing animals, without there being full Parliamentary debate. This Association calls upon the Government to put forwards is proposals for licensing of performing animals and the monitoring of their welfare by primary legislation and not through steps which may reflect the views of the Minister at the time but not those of a large section of the public. Restriction on the use of all or some performing animals would amount to censorship and those steps should not be taken without full debate.

  There is a further point that Annex A, while not being part of the legislation, confuses the issue between licensing the trainer and licensing a circus ie the establishment containing the animals. The original Annex A refers to the licensing of Circuses which infers licensing animals whereas Annex L refers to the licensing of the Trainers. Consequently it is not made clear whether there is to be the licensing of the individual circus or trainers or whether the licensing is to be by reference to the specific animals which are used by an individual establishment.

  On the positive side this Association welcomes the indication from the Government that it considers that subject to adequate control, the use of performing animals should continue. It particularly welcomes the importance placed by the Government on code of practice and we have noted the acknowledgement in Annex A of the voluntary code of practice published by this Association as an example of better regulation. The Association also notes that, quite properly, there is a reference to animals used in entertainment generally and that the issues are not restricted to circuses.

  Proposals to have effective licensing animal trainers, eventually by reference to qualification, is also welcomed.

  The Bill as drafted is inadequate as it fails to lay down specific regulations or alternatively a system for the independent assessment of standards of animal welfare in respect of animals used in entertainment. It is unacceptable to provide for the Minister to make regulations at some time in the future without there being any guarantee that those regulations will be based on scientific opinion.

25 August 2004

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