Memorandum submitted by New Life Parrot
Rescue and Helpline Service
ANNEX B. PROPOSAL TO LICENCE PET FAIRS
EXECUTIVE SUMMARY
Having first hand experience at bird sales markets/fairs/shows,
currently operating with or without council licensing, we oppose
the idea of any proposal to licence trading outside of conventional
pet shops. It is unethical and detrimental to animal welfare and
supports the cruel, barbaric trade in wild-caught parrots and
birds. It poses a public health risk through the transmission
of zoonotic diseases. It serves to increase unwanted animals through
the encouragement of impulsive, ignorant buying, which drains
rescue sanctuary resources, and strongly poses the question: "Why
create a licensed market for reptiles, fish and birds, all
of which are vertebrates, but exclude mammals, such as dogs, cats,
and rabbits?"
Annex B negates the fundamental purpose
of this bill and its concept, and does not comply with expected
animal welfare standards of the 21st Century, but perpetuates
abuse, neglect, and suffering.
Birds, particular psittacines, are highly intelligent,
sentient creatures which easily succumb to even low levels of
stress, from which inherent stress-induced diseases occur when
extreme environmental changes are brought about.
Scientific studies of psittacines have shown
that these birds have the intellectual ability of a 4 year old
human child. See papers by Dr Irene Pepperberg from the University
of Arizona, US, and Jane Goodall PhD, DBE, Founder of the Jane
Goodall Institute & UN Messenger of Peace.
Sanctuary licensing is a welcome addition to
this bill. As exotic animal species require specialised care and
understanding, it should also extend to all keepers.
We strongly oppose the Licensing of Pet Fair for
the following reasons:
1. The stress imposed upon psittacines during
travel and public exhibition causes "unnecessary suffering"
and thousands of deaths per annum.
(a) Vendors who prioritise a quick sale over
the welfare of their charges sell un-weaned parrots to the ignorant
public. Naïve people are not aware of the damage they can
inflict on the un-weaned chick, as they have neither the knowledge
nor experience of the proper care and attention to their feeding
regime, nor of the precarious weaning stage to independent feeding.
Veterinary records show that such people have unwittingly killed
baby birds by burning their crops with over-heated food and/or
caused serious infections and under-development. This causes unnecessary
suffering and misery to both the bird and purchaser.
(b) Due to the inherent conditions at fairs
they cannot be properly monitored. There is also a total lack
of expertise required in the welfare of exotic birds, reptiles
and fish in order to recognise illness and suffering.
(c) There is great probability of causing
confusion and a rise in offences under the newly proposed bill,
which would be an extra strain on prosecuting authorities.
2. Fairs further exploit companion animals.
They increase and support an outlet for the publicly opposed trade
in wild caught parrots and other exotic birds, and transmit disease
to healthy birds and the attending public.
(a) They perpetuate the trade in exotic animals,
whose threat of extinction rises daily on a global scale.
(b) They create ideal conditions for vendors
to openly sell both sick birds and those carrying latent diseases.
(c) They involve the gathering of hundreds
or thousands of birds under one roof, creating ideal conditions
for transmission of airborne diseases, including zoonosis, and
the cross contamination of non-airborne diseases through confined
conditions and handling.
(d) It is common knowledge that pet fairs
are often used by unscrupulous traders to sell stolen creatures.
(e) They allow vendors trading in wild-caught
birds at public venues to continually exploit this cruel trade
to the full by selling them to the unsuspecting public as tame
pets, contrary to the Trade Descriptions Act. Wild caught birds
are nervous, traumatised, and very fearful of humans, and often
carriers of disease. When stress levels are high, disease is spread
to sufficient proportion to risk both the health and well-being
of other birds and the public, especially in the presence of airborne
diseases such as psittacosis in a human. This causes unnecessary
suffering and deludes the ignorant public to the health status
of their purchase and of the health risk from zoonotic diseases.
(f) This will not decrease or stabilise prosecutions
but rather increase pressure on prosecuting authorities, animal
welfare organisations, and rescue sanctuaries who suffer from
the aftermath of these venues.
(g) 55% of the birds we handle originate
from bird sale shows. All of which were purchased by ill-informed,
ignorant people.
3. Annex B specifically nominates
three groups of pet animals for legal market trading; birds,
fish and reptiles, without any scientific justification to explain
why mammals (and amphibians) have been excluded.
(a) It is predilection void of scientific
debate.
(b) It fails to protect the welfare of birds
as vertebrate, sentient animals.
Bird markets are incompatible with the basic
welfare needs of both captive and wild-caught birds, nor to the
ignorant buying public. Annex B should be re-worded to
have these aspects specifically removed and outlawed.
It is to this end that we strongly oppose the
licensing of Pet Fairs, markets, auctions of any pets and any
other sales of pets outside of conventional, fixed, pet shops
or breeders' premises operating under new and more stringent controls.
The concept of a "duty of care" is completely incompatible
with any selling of pet animals at itinerant events such as pet
markets, fairs, auctions etc.
ANNEX C: PROPOSAL
TO LICENCE/REGISTER
ANIMAL SANCTUARIES
1. We support the licensing/registration
of sanctuaries but would ask the government to be mindful when
setting the cost, as voluntary organisations rely on generosity
and fundraising activities in which to provide a standard of care
for their beneficiaries and maintain other aspects of their organisation.
2. Exotic species require specialised care
and understanding beyond the scope of domestic companion animals.
We recommend the implementation of a keeper's license for exotic
animal species for pet shop proprietors, vendors, breeders and
pet owners.
(a) This would aid in the promotion of responsible
"ownership" and "Duty of Care" and help curb
the current over-population of unwanted pet parrots, thereby
reduce the burden on rescue sanctuaries.
(b) As psittacines are the world's most threatened
group of birds, it has the possibility to create a data base for
the amount and type of species bred and kept in England and Wales.
(c) This has the potential to provide extra
revenue for governing authorities.
BREEDING PRACTICES
Charter to outlaw the selling of un-weaned psittacines,
the taking of eggs and offspring dependent on parental feeding
and nurturing
SECTION 1. Explanation
The Animal Welfare Bill 2004 bears no legal
protection pertaining to the selling of: 1. un-weaned psittacines
2. taking of individual eggs, or one or more clutches from a pair
of breeding birds and 3. taking of offspring dependent on parental
feeding and nurturing by either commercial breeders or hobbyists.
Animal welfare legislation has incorporated
welfare provisions over the years for the sale of infant, pet
mammals, making it unlawful to sell infant mammals that are dependent
for food by animal assistance or hand-feeding.
The practice of taking eggs from a pair of breeding
birds and selling un-weaned chicks is tantamount to puppy farming
and the battery hen industry.
The practice of taking offspring dependent on
their parents' rearing and nurturing causes trauma and distress
to both the adults and chicks. It is only now that more is understood
about the ramifications of separating parent birds from their
dependent offspring.
In the case of selling and rearing un-weaned psittacines:
(a) Inexperienced hand feeders often do not
know how easy it is for a parrot chick to accidentally inhale
liquid formula. Food inhaled into the lungs can result in immediate
drowning or a serious, often lethal infection called aspiration
pneumonia.
(b) Crop burns are caused by feeding formula
that is too hot. These injuries can form an opening to the outside
of the bird's body, requiring surgery and/or leading to serious
bacterial and fungal infections, often resulting in death.
(c) Forced weaning—refusing to feed
a begging chick with the assumption that when it gets hungry enough
it will eat—is often the choice of those who tire of hand-feeding
before the chick is ready. Parrots in the wild are weaned by their
parents over a period of months, or even years, as they learn
to forage on their own. Forced weaning can result in malnutrition,
starvation, and permanent behaviour problems such as rigid eating
habits, nervousness, and chronic begging. This practice causes
Unnecessary Suffering*.
In the case of taking psittacine eggs, or one
or more clutches:
(a) The taking of eggs or clutches causes
trauma and stress to a bonded pair of birds, resulting in the
unnatural need for the hen bird to replace her missing eggs. Where
the taking of one, two or more clutches is involved the hen bird
becomes exhausted in her need to replace them. This compromises
her health and in severe cases results in a traumatic death. This
practice causes Unnecessary Suffering*.
In the case of taking offspring dependent on their
parents for rearing and nurturing:
(a) Conventionally, parrot breeders employ
artificial incubation and hand rearing for primarily economic
reasons. This practice results in greater numbers of eggs—and
therefore birds—being produced over a given period by each
female. Repeated removal of eggs from a breeding female induces
her to produce yet more eggs due to her "stolen" clutch.
Following artificial incubation, the chicks are hand reared. There
are (commercial) pressures to force-wean the birds so as to sell
them at as young an age as is possible. This reduces cost significantly
for the breeder. As with any animal which is dependent on an extended
period of parental care—by its natural parents. such a process
is incompatible with the Bill's premise of owners having a "Duty
of care" over their animals. Therefore, the practice of hand-rearing—other
than on veterinary advice from a specialist avian vet—should
not be permitted. Immature birds should not be removed from their
parents before they have been fully weaned and had an extended
post fledging period. This can be determined fairly easily
on examination of the immature birds' flight feathers, as none
of these will be "blood" feathers, but fully mature
feathers which have lost all their blood supply.
(b) Offspring depend on their parents for
the correct balance of nutrients that only Mother Nature can provide;
it is a physical need for healthy development. Evidence has shown
that offspring taken away from the nest incur bone malformation;
enlarged livers and other related ailments.
(c) Offspring require vital, inherent transmission
from their natural parents for healthy socialisation, imprinting
and self-identity.
(d) he vast majority of offspring deprived
of parental rearing and nurturing later become confused, aggressive,
unsociable, self-harming by habitual feather plucking and flesh-
mutilation, both of which have never been recorded in wild flocks.
The current practice of taking eggs from a pair
of birds is for reason of:
(a) A Hen bird repeatedly replaces eggs that
have been taken.
(b) Maximum production and profit with little
financial outlay. The financial loss through the demise of an
over-laying, wild caught psittacine hen is insignificant against
the financial income she produced.
The current practice of selling un-weaned chicks
is for reason of:
(a) Cost effective thus maximising profit.
The current practice of taking offspring dependent
on their parents rearing and nurturing is for reason of:
(a) A hen bird producing a replacement.
(b) hand-raised birds fetch a higher price
than parent-raised birds.
SECTION 2. Definitions
For the purposes of this Proposal:
(a) "Bird" means any order of Psittaciformes
bird.
(b) "Hand-feeding" means the process
by which a bird is manually fed by a human through the use of
hand, spoon, oral gavage, or any other type of machinery.
(c) "Pet shop" means a retail pet
shop primarily engaged in retailing pets, pet foods, or pet supplies.
(d) "Time of sale" means the calendar
date the retail purchaser removed the bird from the premises of
the pet shop or a vendor following the retail sale of that bird.
(e) "Un-weaned bird" means any
bird that is reliant for some or its entire nutritional intake
from another animal or human hand-feeding.
(f) "Vendor" means any person or
entity, including, but not limited to, a broker, agent, aviary,
or breeder, who sells birds directly to the retail purchaser.
(g) "Weaned" means a bird that
is able to sustain itself completely with regard to feeding itself
and maintaining its own body weight without the assistance of
animal or human hand-feeding.
(h) "Taking of eggs" means vendors
and hobbyists who breed birds, purposely take eggs, or one or
more clutches from a pair of breeding birds.
(i) "Hobbyist" means any person
indulging in a leisure activity.
(j) "Offspring" means infant animals/birds.
SECTION 3. Sale of Un-weaned Birds
(a) A pet shop may not sell or give away
a bird unless the bird is weaned.
(b) A vendor or hobbyist may not sell or
give away a bird, unless the bird is weaned.
(c) At the time of sale, a pet shop, vendor,
or hobbyist shall document the weight of any hand-fed bird under
one year of age, and note the weight on the sales receipt.
SECTION 4. Taking of eggs, or one or more clutches
A vendor or hobbyist may not take by purposeful
deprivation of eggs including one or more clutches away from a
hen bird unless by good reason it is in the interest of: (i) the
health of a hen bird; (ii) a hen produces more eggs than is normal
of her species in which she is physically unable to rear; (iii)
that it is undertaken to avoid the production of unwanted offspring,
after accommodations are made to ensure the physical and behavioural
needs of the brooding hen are met by the provision of infertile
or artificial eggs; (iv) that it is undertaken on the advice of
a specialist avian veterinarian.
SECTION 5. Taking of offspring dependent on parent
rearing and nurturing
A vendor or hobbyist may not take by purposeful
deprivation any offspring dependent on parental rearing and nurturing
unless by good reason it is in the interest of: (i) both parents
not able to raise one or more offspring for the matter of compromising
their own and the offspring(s) health; (ii) that it is life-threatening
to one or more offspring; (iii) that it is undertaken on the advice
of a specialist avian veterinarian.
SECTION 6. Records
A pet shop or vendor shall maintain a written
record on the health, status, and disposition, age at time of
acquisition and at sale of each bird for a period of not less
than one year after disposition of the bird. Those records shall
be available to law enforcement officers, public animal welfare
authorities for inspection during normal business hours.
SECTION 7. Penalties
(a) Any person violating any provision of
this Charter shall be subject to a civil penalty of up to one
thousand pounds (£1,000) per violation. The action may be
prosecuted under law enforcement officers and public animal welfare
authority within the region where the violation occurred.
(b) Nothing in this chapter limits or authorises
any act or omission that violates the Crown's anti-cruelty laws.
The following organisations support the inclusion
of this Charter to the Animal Welfare Bill 2004
Jane Goodall PhD, DBE, Founder of the Jane Goodall
Institute & UN Messenger of Peace
Animal Protection Agency—UK
BirdsFirst in Aviculture—UK
Animal Aid—UK
Captive Animals' Protection—UK
People for the Ethical Treatment of Animals—Global
membership of 800,000 with 44,000 members in the UK
Advocates for Animals—UK
Avian Welfare Coalition—US organisation
non-profit
Foster Parrots—US 501 (C)(3)non-profit
organisation
Ravens Haven Exotic Bird Rescue—US 501
(C)(3) non-profit organisation
Mid-west Avian Adoption and Rescue Services—US
501 (C)(3) non-profit organisation
23 August 2004
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