Memorandum submitted by D R Wise, MA Vet
MB PhD MRCVS
1. The Bill appears to have been stimulated
by the view that scientific knowledge has taught us that animals
are more prone to suffering than we had previously believed. This
may be the impression given by lobby groups and the greatly expanded
activities of so-called animal welfare scientists. However, the
latter very seldom define precisely what they mean by animal suffering
and convey the impression that both its range and intensity are
likely to the equivalent of our own. Recent advances in the core
or pure sciences of neurobiology and experimental psychology have
made clear that non-human animals lack reflexive consciousness
(a theory of mind) and are therefore extremely unlikely to suffer
from emotions of the same type or intensity that we do. Further,
even painful sensations may be less oppressive because non-primate
animals lack the pain pathways that, in primates, lead to the
executive (conscious) parts of the brain (see attachment entitled,
Welfare Ratchet) [not printed]. It is suggested that animal welfare
science, which has a vested interest in promoting its own existence
and which depends largely upon anthropomorphic judgements (arguments
from analogy—if an animal behaves as we would in an unpleasant
situation, it must feel as we would), should not be considered
as a source of objective expertise.
2. Having made the above general point,
it should be acknowledged that there appears to be little that
is draconian in the general proposals in the Bill and there has
been a consolidation of previously disparate legislation. Also,
there have been some sensible new safeguards such as banning animals
as prizes, mandatory provision of care leaflets etc. However,
it will prove impossible to make a detailed case by case assessment
until codes of practice and regulations are produced at a later
stage (although all of these, in turn, will apparently be subject
to prior consultation).
3. It is clear that the Bill will impose
the need for licensing and/or regulation and increase the bureaucratic
costs of animal keeping. As so often happens with statute law
of this kind, the major costs will be borne by those whose animal
management needs no regulation and the guilty are likely to evade
control. It should be appreciated that poor welfare is almost
invariably associated with impaired animal health and function.
Thus, it is unlikely that any sensible commercial stockman would
wish to keep animals badly, if only for the simple reason that
it would adversely impact upon his profits.
4. There is mention of the Five Freedoms
in the Bill. This is currently only used in the context of farm
animals but will be extended to cover other captive stock. The
Five Freedoms are only aspirational, as is appreciated by the
State Veterinary Service which is responsible for inspections
of farmed livestock. There is no way, for example, that humans
or wild animals could expect always to be provided with these
freedoms (see attachment entitled Five Freedom Fatuity). It is
feared some inspectors might take too literal note of them.
5. The Bill will make it an offence to keep
animals in a manner likely to cause suffering. Potentially, this
is open to very wide interpretation and could make the lives of
animal keepers intolerable, depending upon the attitudes of those
empowered to make the judgements.
6. Probably the greatest cause for concern
over the Draft Bill relates to the qualifications of those appointed
Inspectors by The Secretary of State and the Local Authorities.
What are the criteria for suitability? It is here relevant to
distinguish between SVS and, for example, the RSPCA. Generally,
the former are adjudged by reasonable animal keepers to be knowledgeable
and lacking an ethics-based prejudice against them. However, the
RSPCA as an organisation, is usually the focus of deep distrust.
Its Council contains a majority with animal rights views. Its
2003 Policy Document is extreme and reflects the views of these
Trustees. (Any who doubt this assertion should read the document
for themselves. It can be viewed on the internet at http://acpsr.chat.ru/).
While, in the past, the organisation was regarded favourably and
continues to employ a majority of sensible and pragmatic inspectors,
it is now more often seen as sharing the views (but not the violent
tactics) of those organisations whose membership the government
currently wishes to imprison. Notwithstanding, the Secretary of
State has recently signed an agreement with the RSPCA, giving
the latter Independent Prosecutor Status on animal welfare matters.
While this is not a direct consequence of the Animal Welfare Bill,
it is sufficient to cause profound disquiet among many stakeholders,
particularly as the RSPCA appears to have been heavily represented
on all the Working Groups formed to discuss the Bill. How, for
example, can traders in exotic pets be expected to have any confidence
in the impartiality of an inspector sympathising with RSPCA policy,
which is to ban them from selling animals, when he will make judgements
on the possibility of future suffering?
18 August 2004
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