Memorandum submitted by Jim Clubb, Director,
Heythrop Zoological Gardens Ltd
GENERAL
On the whole the Bill will bring into place
regulations and laws that I and the bodies I have been involved
with, Animal Consultants and Trainers Association and Association
of Circus Proprietors, support. I believe that, generally speaking,
the Bill will benefit serious animal institutions, the general
public and animals. However, I am concerned with certain areas
that need to be better clarified and others which I can see might
cause future problems in our democratic society.
CLAUSE 1
Subsection 2: How can we police our own employees?
I agree that a company has some level of responsibility for its
employees. Company policy on Animal Welfare and Animal Welfare
in accordance with the law should be made clear to all employees
from the beginning of their employment. However, larger institutions
would find it difficult to supervise their employees at all times.
In fact, there are documented cases of Animal Rights groups who
use infiltrators to create Animal Welfare problems in order bring
a company into disrepute. I give Berosini v PeTA,
in Baltimore USA 1981 as a famous example of such an episode.
Subsection 4: Will mutilation constitute castration
and spaying performed for non-medical reasons by veterinary surgeons?
Both of these operations are necessary to control the population
of species in captivity and also aggression in species ie the
forming of all male groups. We have found that vasectomies, although
an effective method to control breeding, does not cure the aggression
issue. Therefore I believe castration, even if not performed for
strictly medical reasons, benefits Animal Welfare.
CLAUSE 13
Subsection 2 (a) and Subsection 3: I believe
all animal institutions need an assurance that all inspectors
and constables are qualified and experienced in the care and disposal
of animals. There is nothing in the clause to say that an inspector
or constable should destroy an animal humanely. This needs to
be addressed. In a worse case scenario we could have an inexperienced
person making unqualified judgement over the fate of animal, and
then destroying the said animal in unnecessarily inhumane fashion,
all within the confines of the law.
ANNEX A
Paragraph 1: I am in direct opposition to the
RSPCA' s proposed ban of all animal circuses. I believe the word
"circus" is banded a bout with undue prejudice in our
society. Their establishments should be viewed in the same light
as any that promotes live animal entertainment such as horse and
dog shows. I also object to the generalisation of smaller circuses
being considered to have inferior welfare standards. One of the
smallest circuses in the country, Giffords, which has only two
horses, has very high Animal Welfare values.
Paragraph 2: I welcome regulation and compulsory
inspection of all circuses.
Paragraph 3: I think greater clarification needs
to be made over what these standards will be. The standards need
to be realistically achievable.
Paragraph 4: Agreed.
Paragraph 5: A list of inspectors should be
issued to all registered establishments. This list should be made
available for travelling establishments to obtain.
Paragraph 6: I do not believe that small amateur
theatrical productions should be exempt. This means only tax paying
establishments are subject to inspections. Through my experience
in various forms of animal entertainment from live shows to film
work, I have encountered situations where companies have used
animals provided by amateurs to cut down on costs. Their exemption
promotes the illegal use of animals and is contrary to the objectives
of the Animal Welfare Bill.
ANNEX B
I believe that pet fairs should be licensed,
but caution should be taken that over stringent regulations and
high licence fees will only encourage the practice to go underground.
ANNEX C
I believe this to be a responsible proposal
and am in complete agreement with the raising of the age to 16
and also support the compulsory issuing of animal care literature
to consumers.
ANNEX D
I believe that the sale of animals over the
internet should be regulated and licensed in the same manner as
normal pet shops.
ANNEX E
I would like to bring a comparison between the
attitude taken with Annex A and Annex E. According to Annex A
smaller animal establishments are more likely to have lower Animal
Welfare standards. Why, then, are smaller animal sanctuaries being
encouraged by having to pay a "one off" smaller fee
than the larger establishments. Surely such "one off' methods
are being done away with by the Animal Welfare Bill, as in the
case of the Animal Trainers Certificate 1925.
I am in total agreement with the licensing,
registering and regulation of animal sanctuaries. Although I have
had dealings with very responsible examples of these establishments,
I believe there to be severe Animal Welfare issues at stake in
some so-called sanctuaries.
ANNEX F
I am in agreement with this.
ANNEX G
I am in firm agreement that all surgical procedures
should be carried out by qualified veterinary surgeons. I support
the Kennel Club's work on the breeding and docking issues. It
is against my trade association's (Animal Consultants and Trainers
Association) policy to perform any form of mutilation for the
purposes of filming. I support the regulation of dew claw removal
by veterinary surgeons only.
ANNEX H
No comment.
ANNEX J
Paragraph 1: Agreed.
Paragraph 2: Agreed.
Paragraph 3: Agreed.
Paragraph 4: I don't support any regulation
that hasn't been passed first through Parliament. This is inconsistent
with democracy.
Paragraph 5: 1 need better clarification on
this in order to comment. What constitutes obstruction?
Paragraph 6: Agreed.
Paragraph 7: Agreed.
DEPRIVATION
Agreed.
DISQUALIFICATION
Depending on the severity of the case, I agree
that a person should be given the opportunity to sell animals
that are his property if he has been forbidden to own the said
animals.
ANNEX K
A database of all licensed premises should be
held by the government and not by the RSPCA. I don't believe in
handing such power to a pressure group, it would be inconsistent
with the laws of fairness, especially when the said group campaigns
against certain animal industries as a whole.
I am in agreement with Option I for the reasons
outlined in Annex K.
ANNEX L
Agreed.
August 2004
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