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
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