Memorandum submitted by The British Association
of Leisure Parks, Piers & Attractions (BALPPA) Zoo Group
EXECUTIVE SUMMARY
The British Association of Leisure Parks, Piers
& Attractions (BALPPA) is a professional organisation representing
leisure attractions in Great Britain and Ireland. BALPPA welcomes
the Draft Animal Welfare Bill and the concept of duty of care.
The main comments made by the organisation centre around:
— Ensuring that the ZLA and its accompanying
Secretary of States Standards for Modern Zoo Practice are the
regulations use to promote welfare in zoo animals under this act,
and that the codes of practise used are those recognised by experts
in this field.
— Ensuring that only those with relevant
expertise act as inspectors, and veterinary surgeons with expertise
in zoo animals, act as experts in any cases concerning animals
in zoos.
EVIDENCE
1. BALPPA is the professional organisation
for leisure parks and attractions in Great Britain and Ireland
and leads and supports its members in their conservation and education
work having a zoo group to promote the values of good zoos.
2. BALPPA welcomes the Draft Animal Welfare
Bill and the concept of a duty of care. However we feel that precautions
needs to be taken to ensure that regulations accompanying the
legislation pertaining to exotic species do not conflict with
existing documentation, in particular the Secretary of State's
Standards of Modern Zoo Practice (SSSMZP) that accompany the Zoo
Licensing Act 1981 (Amendment) (England and Wales) Regulations
2002. Currently these standards are reviewed and updated by the
Zoos Forum and therefore are the best available Standards pertaining
to the welfare of animals in zoos. The specific needs of zoo animals
must always be addressed by those with expertise and experience
in this specialised area.
3. Some of the wording of the Act is loose
and could be misinterpreted. For example, Clause 1.(1)(a)—"causes
an animal to suffer" is a somewhat subjective phrase and
could be the subject of differing interpretation. Therefore clear
references to known guidelines for exotic species must be used.
Many of these guidelines are referenced in the SSSMZP—which
should be the codes of practice as referred to in 1.(3)(b). Similarly
care needs to be taken with the term "mutilates" 1.(4)(a).
Care need to be taken so that some routine management practices,
such as the pinioning of certain species of birds, are clearly
covered through 1.(5). The Federation has produced a position
statement on the pinioning of certain species of birds which might
be useful as a Code of Practice which would be useful for 1.(5),
regarding this topic.
4. Clause 3.(4). These five "needs"
are better covered for zoo animals in the five principles' provisions
of the SSSMZP and it is these that should be referred to. This
is especially true of (c) which in the SSSMZP is phrased as "provision
of opportunity to express most normal behaviour". This is
much more realistic, eg we would not put a live antelope in a
lion's enclosure to allow it to exhibit "normal" hunting
behaviour. This makes 3.(5) redundant regarding zoo animals.
5. Clause 6. As mentioned above the SSSMZP
should be the regulations referred to here for zoo animals and
the many available husbandry guidelines, many of them references
in the SSSMZP, should be the codes of practice as referred to
in Clauses 7 and 8. The Federation has many suitable guidelines
already available and would be most willing to assist in this
process, and should be a relevant interest group under clause
8 subsections (1) to (4).
6. Clause 11.—Animals in distress.
Again care needs to be taken with the meaning of "distress".
In the case of zoo animals the "inspector" and the veterinary
surgeon MUST have some experience and knowledge of the species
in question to be able to ascertain if the animal is in distress
and is suffering. It is also unclear what "take into possession"
means—if it is to physically remove this may not be realistic
in the case of zoo animals with specific enclosure requirements
(eg large carnivores and elephants) and therefore 16.(2)(c) would
normally come into effect, but consultation must be made with
those who have expertise with the species concerned. Similarly
with Sections 12 and 13, and for 13 the veterinarian should have
experience in the care of the species concerned.
7. Clause 19.(1)(b), The person marking
the animal must have expertise in dealing with methods of marking
for the species concerned, with zoo animals this can be somewhat
specialised.
8. Clauses 37 and 39. Again it would be
important that this was carried out using the ZLA.
9. Clause 44. As the nature of keeping animals
in zoos is specialised it would be important that the recognised
inspectorate was that appointed by the Secretary of State for
the Licensing of zoos under the ZLA, ie that the inspectorate
have been trained and have the necessary expertise.
10. Annex L Page 99-100 lays out the bodies
that would fall within an inspection regime and it is suggested
a similar process that the ZLA applies of peer bench marking would
ensure a progressive improvement in the quality of these bodies.
The organisations as laid out in this Annex should be licensed.
August 2004
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