Memorandum submitted by Fredric Frye (Member
of the Bio Veterinary Group)
I am writing as an amicus populi in regard
to specific provisions of the draft of the Animal Welfare Bill,
especially those portions relating to the "Duty of Care."
While I am in enthusiastic support of most of the draft, I do,
however, urge reconsideration of the following clauses:
Clauses 7 and 8 (Codes of Practice),
including the relationship to Annex B.
As a veterinary surgeon with more than 40 years
of experience, including serving as an Epidemiologist with the
California Department of Public Health (Berkeley, California),
Clinical Professor of Comparative Medicine and Patho-biology at
several universities in North America, the UK, Italy, and Japan,
and practicing clinician, I have attended several pet fairs. During
those visits, I observed abuses to the animals that were on display
by some people who were attracted to these events. Not only were
the animals often displayed in cages that were clearly inadequate
to meet the minimal space requirements for their inhabitants,
but the lack of hygienic housing posed an imminent threat to both
the captive animals, as well as to the people who had access to
these animals.
Of particular and germane interest, were small
freshwater terrapins, turtles, and tortoises that were on display
in a manner that permitted ready access by small children who
were, if not directly encouraged to touch them, were certainly
not prevented from doing so. Since 1972, both the medical and
veterinary medical professions have known that reptile-associated
salmonellosis in humans is a threat to public health. Several
peer-reviewed journal articles have established this fact beyond
a doubt. More recently, the U.S. Centers for Disease Surveillance
and Control in Atlanta, Georgia, disseminated supplementary recommendations
for limiting exposure of children as well as adults who, because
of their compromised immune status, should not have contact with
animals which could serve as carriers of infectious zoonotic diseases.
These animals include the chelonians noted above, iguanas and
other lizards, snakes, caged birds, and small mammals. These animals
represent additional potential threats to public health and welfare
and must be included when "pet" fairs are considered.
These animals can harbour parasites for which humans may serve
as intermediate or definitive hosts, or they may directly harm
humans via bites, scratches, or ingestion of infective materials,
etc.
Animal "pet" fairs also pose a threat
to the animals owned by the persons who attend these venues inasmuch
as infectious diseases, particularly those induced by bacterial
and viral pathogens, can be readily brought home and, thus, infect
even those persons or animals that remained at home. That pet
fairs pose a threat to public health can no longer be denied.
Therefore, it is incumbent upon the appropriate authorities not
to license pet fairs and similar exhibits so that the public's
health can be protected.
When considering the overall effects that animals
have upon the commonwealth, I appreciate that to many persons,
their pet(s) may be an "anchor to reality." Strong human-animal
bonds are well recognised as being of substantial value. Therefore,
I am not advocating abolishing the pet trade. I am, however, advocating
support of the effective regulation of the pet trade and of its
dealers. This support is engendered by a genuine concern for both
the owners of domestic and non-domestic ("exotic," "zoological,"
"wild") animals, as well as for their "pets."
My concerns are further stimulated by the observation
that when a member of the public (often naive), is exposed directly
to very appealing non-domestic animals, the acquisition of such
animals is made easier. However, it is well recognised that:
(a) Many exotic animals are very poor candidates
for "pets." They may not accommodate to captivity and,
even under the very best husbandry conditions, they often languish
and eventually die.
(b) Many become "disposable" once
their novelty wears off.
(c) Numerous species are being lost at an
alarming rate due to overexploitation and habitat degradation
and loss. Even responsible captive breeding enterprises are unable
to address satisfactorily the continued drain on sustainable resources
because, in order to maintain viable genetic diversity, introduction
of wild genes is believed to be (and may, indeed, be) essential
to continued vigor and vitality.
As noted earlier, many of these non-domestic
animals represent a very real and present threat to human public
health because of certain zoonotic infectious diseases.
It is for these reasons that I urge the Select
Committee to promulgate and encourage the enforcement of the provisions
of the proposed Animal Welfare Act, but to exclude any permission
for "pet fairs/markets". It is entirely reasonable to
call upon the pet-animal dealers' trade association(s), as responsible
entrepreneurs in the public sector, to follow the lead of veterinary
surgeons in guarding the welfare of their animal charges. As such,
existing annual licensing of regular pet shops, rather than proposed
18-month licensing of pet shops, is also more appropriate. When
deficiencies in standards of care are repeated and/or left unsatisfactorily
resolved, the license must be forfeited. This "carrot and
stick" approach should prove to be effective.
Fredric L Frye, BSc, DVM,
MSc, CBiol, FIBiol
October 2004
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