Supplementary memorandum submitted by
Petsafe and Electronic Collars Manufacturers Association
REPLY TO THE COMMITTEE HEARINGS 7/8/9 SEPTEMBER
2004
ELECTRONIC TRAINING
AIDS
As we do not have the opportunity to present
the case orally for the safe use of electronic training aids,
we are following the advice of Mr Michael Jack and writing to
the Committee again.
Firstly we must point out that when Joan Ruddock
asked whether the manufacturers would notice a drop in sales if
the products could not be sold in the UK, The witnesses said
this would not happen but there are between three quarters of
a million and one million of the products in circulation and the
number sold is increasing by [ ] per annum. The correct reply
is "Yes". Neither witness, Animals in Mind nor Mitcham
Veterinary Clinic, knows enough about the products and the
market to make this judgement. [is in a position to give this
information.] PetSafe alone supplies goods to the market that
retail [out] at over £1.9 million per annum. There are six
other manufacturers in the market, not as AIM indicated all US
or maybe German based. There are French, Irish, Belgian and US
companies manufacturing all over the world.
In order for this growing industry to have a
single voice, ECMA (Electronic Collar Manufacturers Association)
has been formed. All of the major manufacturers who sell product
in Europe are members. ECMA's main aim is to promote the responsible
manufacture and use of pet training devices including static pulse,
sound, ultrasound, spray etc. The governing ideal is: "To
promote the positive use of electronic, educational devices for
the welfare of companion animals and their environments".
The Association will be self regulating with a Charter Code
of Standards and an Association logo will also be created to denote
that the products' specifications are within the Charter Code
of Standards.
The products in question are electronic training
aids using modern microchip technology and we wish to highlight
the word "Training". They are not an instant
fix[es] but actually require the owner to spend time with the
pet to achieve the desired relationship. They are an addition
to the normal method of training and not a replacement for it.
As PetSafe/Radio Systems and ECMA, we also wish
to state that the industry fully supports the Five Freedoms and
the duty of Care. We believe our products actually enhance the
Five Freedoms and we always emphasise responsible ownership
[wherever possible].
1. Freedom from Hunger and Thirst
We manufacture electronic pet feeders and both
cat and dog doors so that pets have access [to] both to
their food and drink indoors and to the world outside.
2. Freedom from Discomfort
If an animal is tied up, chained up, locked
or kennelled all day, does this [come under] qualify as
[the heading of] discomfort ? Our products give pets the choice
to move around at their own volition.
3. Freedom from Pain, Injury or Disease
Pets escaping and running into main roads do
cause traffic accidents with pain and injury to themselves and
the car drivers. (see work of Professor I Rochlitz, BVsC, MSc,
PhD, MRCVS, Animal Welfare and Human-Animal Interactions Group,
Department of Clinical Veterinary Medicine, University of Cambridge
on domestic cats/traffic accidents). The pet that chases livestock
or wild life risks pain and injury from being shot by the farmer
or run over as it chases over a road. The use of electronic training
aids can [obviate] prevent these traumas.
4. Freedom to Express Normal Behaviour
These are normal behaviours for pets: territory
marking and guarding, wandering about the garden, playing games
with owners, running off the lead on a walk, socialising with
other animals.
What about a dog's behaviour that creates a
problem for the owner?
Barking incessantly.
Jumping up and nearly knocking people over.
Fighting with other dogs.
Biting even playfully.
Chasing livestock, joggers, vehicles.
Running away from home or running off on a walk.
These are issues we are involved with. If [this
freedom] normal behaviour is for the pet to move freely
round its own garden, socialise with other animals, and run free
out on a walk, then the Radio Fence and the Remote Trainer provide
this for the pet and peace of mind for the owner [knowing] who
knows that their pet is safe.
5. Freedom from Fear and Distress
Most pets like to know their own boundaries.
A happy loving owner who does not worry that their pet will [not]
stray, run away or get hurt will be giving a happy loving home.
The pet living [here] in such a home will not be subject
to fear and distress.
WE COMMENT
BELOW ON
VARIOUS WITNESSES'
STATEMENTS
1. Ben Bradshaw, Minister
Mr Bradshaw has said on numerous occasions that
in the absence of any scientific evidence proving that "static
pulse" training products are harmful, a ban would not be
included in the proposed Animal Welfare bill. To this date, there
is no evidence of this nature.
2. Defra
At a meeting with Defra on 1 September 2004,
Radio Systems was told that the various studies put forward as
being scientific evidence against the use of electronic training
aids were not scientifically acceptable and that Defra would be
commissioning their own study into the effects of remote training
devices. It was agreed that such research should be undertaken
by a reputable veterinary based group and that the industry would
be consulted at all stages. Defra have kept this information confidential.
3. RSPCA
The RSPCA in their submission do not mention
static pulse collars in the introduction or executive summary,
suggesting that it's not high on their agenda. However they do
mention them in their written submission (paragraph 33) on Section
6—Regulations to promote welfare:
We have demonstrated the products to some employees
of the RSPCA but would welcome the opportunity to show them to
the Trustees who we feel may never have seen them for themselves
but have reacted on hearsay.
4. The Kennel Club
We have noted the frequent mention in the media
by the Kennel Club of the Dutch studies published in the Applied
Animal Behaviour Science Journal. We also know Defra's reaction
to these studies from our meeting with them. We include copies
of these studies together with rebuttals written by experts [not
printed].
Some of the simplest reasons why the study entitled
"Training dogs with help of the shock collar: short and long
term behavioural effects" is invalid:
(a) the study was not approached with an
open mind as the researchers were looking for "frightened"
dogs.
(b) The researchers could not identify which
dogs were and which were not receiving "shocks".
(c) It is not known what admitted harsh training
methods had been used on which dogs prior to the trial.
(d) The numbers of dogs being "shocked"
is inconsistent throughout the report.
(e) The results were drawn from the authors
own created measurements instead of the standard Bonferroni correction
because there was not enough significance using this method of
calculation.
(f) The study was conducted in 1999-2000;
the products used are not named; there has been no attempt to
update the information.
The "Behavioural, saliva cortisol and heart
rate responses to different types of stimuli in dogs" study
was also unacceptable in the case of "electric shock".
(a) Heart rate is a key behavioural measure
in this experiment but no use was made of it for "electric
shock" stimuli as only "before" rates were possible.
Heart rate monitors were not used while this stimulus was being
used.
(b) The test dog population was only composed
of 10 pre-conditioned test animals rather than pet animals.
(c) The maximum of 10 possible readings was
diluted to seven by the dismissal of three animals' test results
as being either dirty or abnormal.
When the Kennel Club go on to say in their Submission
that "We are only concerned with the remotely controlled
shock training collars and not the `freedom fence' devices",
it shows a distinct lack of understanding which we have tried
to dispel on numerous occasions. "Freedom Fence" is
one of the trademarks for the PetSafe radio fence. This is a boundary
fence system used by many families for their dogs and cats for
over 13 years now in the UK. Many hundreds of radio fence owners
are writing to their MPs to protest about any hint of a ban. They
feel that their pets' lives have been saved.
There are three categories of product using
a static pulse: containment ie the radio fencing, bark control
products to help train the dog to stop barking incessantly and
remote training devices used to make contact with the dog at distance.
In many cases, these products are the owner's last resort before
the pet is killed on the roads, shot [either or] for chasing
livestock or [else] has to be given away. If the dog is acquired
from a sanctuary [being rehomed], it almost certainly has
these same behaviour[al] problems plus those learned in the kennels
eg incessant barking, to take to its new home [plus] not to
mentionn the insecurity [of] brought about by the change
of environment.
It should also be remembered that the Kennel
Club run fee based accredited dog training clubs as part
of their business activities so they may view other training
methods as competition.
The Pet Advisory Council wishes for "an
urgent review" of this equipment. But again like the RSPCA
it is likely that they are not actually familiar with the products.
It is interesting that neither the Pet Care Trust nor Pets at
Home mentioned electronic training products at all.
5. The Mitcham Veterinary Clinic (Duncan
Davidson)
Animals In Mind (Andrew Constance)
Both organisations made major reference to the
banning or licensing of static pulse collars. Whilst we agree
that everyone has the right to their own opinion, we would prefer
that such opinions are based on fact.
In his summary, Duncan Davidson (Mitcham Vet
Clinic) states that these are his own observations. He only has
knowledge of a single sector of these products namely Remote Training.
We were very grateful for his support and his recognition of the
place of these products in training dogs.
We would also like to have heard from the RSPCA,
Dogs' Trust, Kennel Club or other organisation of any genuine
harm being inflicted on significant numbers of [any] animals
in the UK by the use of a static pulse product. It is strange,
as was said, that no such case has been presented. In fact,
we should like to point out that it would be ridiculous even to
think of banning or otherwise restricting a product where no proven
examples of harm done exist. The case against is entirely hypothetical;
the case for is based on the successful, practical use by hundreds
of thousands of concerned and caring owners over nearly two decades.
We agree with most of what Mr Davidson said
except where he suggests that the only suitable people
[suitable] to use the products are qualified animal behaviourists
or that the products should be licensed. The issue here is who
trains the user. The information provided with each product is
clear and in some cases videos are included. [It is inappropriate
to judge that a] A responsible pet owner is no [any] less
likely to understand these instructions than a professional trainer.
The other issue is who authenticates the behaviourist or trainer?
There are too many certifications given out without any length
of study or experience. Remember [It has] also [to be born
in mind] that behaviourists and [or] trainers are well
paid for their services and the owner using an electronic training
aid could be [deemed] viewed as [to be] taking away
some of their potential business. [away.]
Animals In Mind stated vehemently their opposition
to all forms of static pulse product and would like to see an
immediate ban. In questioning, however, Andrew Constance
indicated that they would agree to [accept] licensing of
the products.
It was interesting to hear and read of the examples
cited, all anecdotal. No one has interviewed the "police
officer" directly and in fact the police forces did not stop
using the products voluntarily. The Home Office made this decision
a few years ago and police and army dog handlers would very much
like to see this reversed. The kind and breed of dog required
for this work requires a completely different training to the
standard pet. If the trainer cannot hold the dog's attention at
all times, that dog will probably be shipped overseas for further
training or euthanased.
It is incorrect to say that "trainers
who still believe in beating, scruffing, kicking and string up
are acceptable". This is cruelty under the proposed bill.
The statement "As long as shock collars are acceptable,
other forms of abuse will be condoned" is illogical.
We believe that actual abuse of an animal in any form, kicking,
hitting with stick, tying up or even misusing [with] a
static pulse product should be prosecuted.
The AIM submission that three dogs wearing remote
training collars attacked other smaller dogs is clearly an "impossible"
situation and is easily refuted. The evidence given by the owner
of one of the small dogs killed states that the three Alsation
cross-breeds dragged their owner along until she fell and they
broke free. Therefore they must have been on some form of lead.
The products are not used by dogs on leads. It is also
[not] impossible for one person to hold and activate three
separate remote transmitters at the same time.
The article citing Rufus as being seriously
injured by the effects of wearing an electronic collar in the
rain is misinformed about the product and the owners neglectful.
Unfortunately, the dog was obviously left a very long time wearing
the collar for the battery to leak. But it has to be borne in
mind that this was only likely to have been a 6v or possibly 9v
battery and the amount of possible seepage is not as great as
the photos indicate. Exceptionally, [T]the owners never
installed the boundary wire or [tried any training] trained
Rufus at all. It is always advised to remove the collar, clean
the dog's neck and the contact points regularly and not to leave
it on 24 hours a day. If the collar is left on like this, it could
cause pressure necrosis which all the ECMA manufacturers warn
about. None of the products can "burn" a dog especially
if they are not live as in this case.
The AIM representative also alleged that the
sale of electronic collars was shrinking in the USA, citing the
American Humane Society as the data source. We would very much
like to know how they arrived at this statement when our sales
in the USA grow every year.
There are several reported statements by "many
owners", but reported to whom. We have not heard any of these
remarks and obviously neither have other animal welfare bodies.
We would also like to have seen the questions asked in both the
AIM survey and the fax poll proposing a ban. The validity of
the replies rel[y] ies on information supplied and
the turn of phrase used.
AIM also relies on the Dutch study in the Applied
Animal Behaviour Science Journal already mentioned as being
regarded as unscientific and inaccurate.
However, we do agree with AIM that "Violence
towards a pet animal can never be justified" and will be
happy to work with them to that end.
We also believe that a dog has the right to
learn to achieve the freedom to roam in its garden and off the
lead.
We trust that the Committee will appreciate
the very real benefit that these products achieve for pets and
owners.
15 October 2004
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