Memorandum submitted by the British Koi
Keepers Society
I would like to take this opportunity to reply
to some points in the draft act on behalf of the British Koi Keepers
Society (BKKS). At this juncture I would like to make the relevant
point that we as a society do not sell koi, our members do not
breed koi for sale and all our shows are competitions only. No
fiscal prizes, just trophies and certificates. We work were possible
with the Professional Koi Dealers Association (PKDA) whose members
attend our shows for the purpose of selling their koi. We charge
all dealers attending our shows for stand space on the various
show grounds to help offset the cost of putting on the show. All
these dealers are primarily holders of a "Pet Shop License"
and are regulated by their local councils. All BKKS shows are
run under our own code of practice, namely the BKKS Show Rules
and Guidelines (these have been submitted to Defra). These rules
cover all aspects of a show from welfare, health, water conditions
and judging. We have an in-house training programme for Health
and Judging officials. The Health side was set up via professional
input for examinations and tests/grading.
With regard to the proposed act we are looking
for a licensing system for our shows which will come under the
new proposed heading of "Pet Fairs". We as a society
putting on a show would seek a license for such having fulfilled
some pre stated conditions ( a code of practice). Having been
granted a license for a show we would then envisage a license
for dealers to be able to sell koi at the show.
Some parts of the proposed act need clarification
before the second tranche comes into being:
Section 1 |
(4)(b) | The word "mutilated", does this include "cosmetic" surgery.
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| (10)(a)(ii) | When an exhibitor enters a koi into a show he hands over the "duty of care" to the show committee and has no control over his koi until the end of the show. There would need to be a demarcation line for responsibility.
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| (10)(b) | There could be anomalies here. As we do not breed our koi, when they spawn we let the other koi eat the fry. This could be construed as an act of cruelty?
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| Section 3 | (4)(a) | The term "suitable environment", who will qualify this.
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| Section 6 | (2)(a)(ii) |
"During transport" needs clarification. Is there a time limit or a mileage limit. We have our own recommendations for our members regarding this and are in the process of writing a code of practice on this.
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| (2)(b)(iv) | The numbers of animals kept in an "accommodation" will vary according to the water filtration system in use so it will be very hard to legislate a set of parameters other than water quality.
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| (2)(h) | As previously stated we see the licensing system as the way forward.
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| (2)(i) | The proposed registration clause. Will this be for the Society, Show Chairman, Show Committee or et al. Is the license not a registration in its own right.
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| (3)(b) | Is this section to be used in conjunction with Annexe L regarding the attendance of vets at shows. We have previously stated to Defra that our society holds over 25 shows around the county (approximatly 50% of all koi shows in the UK) and we know of only about five vets in the UK who have any knowledge of Koi. If a vet was in attendance to observe water quality etc it would be a very expensive operation and might preclude a smaller show taking place. All our shows give an open invitation to their local Environmental Health Officer and the RSPCA.
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| Section 36 | (1) | There is no intimation to which records will be required by a license, or indeed which license will require record keeping.(license for a show or license to sell).
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| Section 44 | (2) | Will an inspector appointed by a local authority have relevant knowledge of a given species or just have an overall knowledge.
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It is noted that there is no definition for the word "commercial".
We as a society would like to see no license granted for the sale
of any animal to someone who does not hold a "pet shop license"
and is therefore not accountable. We see too many itinerant traders
at various animal shows around the UK.
The proposed wait until 2006 for the phasing in of "Pet
Fairs" will leave us in limbo for 2005. There will be an
uneven approach to letting shows take place. Shows, some of which
cost many thousands of pounds to put on are only allowed to take
place under the wish's of the local council. Shows which will
bring in much revenue to the local community and business's.
The BKKS was formed in 1970 and I am the current president
of the society. I have been a member since 1980 and have been
a koi keeper for the last 25 years. My interest in the hobby is
the judging of the koi and to this end I have judged around the
world. Our society has links with relevant societies globally
and we disseminate knowledge wherever we can.
Gary Pritchard
23 August 2004
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