Memorandum submitted by the Guide Dogs
for the Blind Association
The Guide Dogs for the Blind Association is
the largest breeder and trainer of assistance dogs in the world,
caring for up to 5,000 qualified guide dogs, 1,200 trainee guide
dogs, and 1,500 puppies at any one time. As a leading expert in
dog care, welfare, and canine research, we would like to put forward
our comments on a number of clauses contained within the Bill
which relate directly to our own policies, practices and procedures.
CLAUSE 1—CRUELTY
Guide Dogs has stringent health and welfare
policies in place for all our dogs, and strictly prohibits the
use of shock-training tactics or devices. Any breach of this policy
by clients or staff results in the withdrawal of the guide dog,
or instant dismissal.
We are deeply concerned by the common use of
electric shock collars by pet owners and trainers. We believe
that as a shock collar is intended to train a dog to suppress
undesirable behaviour out of fear of further punishment, it causes
unnecessary pain and distress to the animal. As such, we believe
that the provisions contained within this clause do not go far
enough to protect against cruelty to animals, and call upon the
Committee to recommend an outright ban on the sale and use of
shock collars.
CLAUSE 3—WELFARE
We support the proposals contained within this
clause to protect an animal's welfare. We do however feel that
further clarification is needed to determine "reasonableness"
with regard to steps taken to ensure the animal's welfare. We
are concerned that the Courts would not have sufficient expertise
to determine what actions were or were not reasonable, and therefore
ask the Committee to recommend that provisions be made within
the Bill to enable Ministers to appoint suitable advisors to the
Courts. We believe that guidelines should also be drawn up to
advise them on this process, which we would expect to be subject
to consultation with relevant organisations and individuals at
draft stage.
CLAUSE 4—SALE
TO PERSONS
UNDER 16
We do not agree that a person's ability to care
properly for an animal can be determined by virtue of age and
therefore do not support this clause.
As I am sure you are aware, the core service
of Guide Dogs is to provide mobility to blind and partially sighted
people through guide dog partnerships. The characteristics of
each partnership—trust, companionship, and independence—is
underpinned by the sense of ownership and responsibility for the
dog that we give to each guide dog owner. Our number of partnerships
currently stands at around 5,000, and it is our aim to provide
this very special form of mobility assistance to as many blind
and partially sighted people as possible.
We currently "sell" our guide dogs
to their owner for a nominal fee of 50p, and are very concerned
that prohibiting the sale of animals to under-16 year olds would
in future prevent us from reaching young blind and partially sighted
people through the guide dog service. At the very least, we would
like to seek an exemption for the "sale" of guide dogs
to young people under 16 years old, and for this purpose supply
the following definition of a guide dog used by our organisation:
"A guide dog is a dog trained to provide
mobility assistance to a blind or partially sighted person. In
the UK the guide dog is trained, assessed and accredited by The
Guide Dogs for the Blind Association. Outside the UK a guide dog
is a dog trained by an individual or organisation that is accepted
by and affiliated to the International Guide Dog Federation."
CLAUSE 6—REGULATIONS
TO PROMOTE
WELFARE
We note that the draft Bill makes provisions
for regulations to be made with respect to the accommodation of
animals. We would request that when the time comes, a rigorous
regulatory and economic impact assessment be carried out, which
takes into account the financial limitations of charities and
other caring organisations to be able to carry out modifications
to existing facilities. We would also like to advise that specifications
be animal specific and take into account the role of the animal,
and that there must be wide consultation on drawing up such specifications.
Guide Dogs would be very happy to share its expertise on specifications
for the accommodation of dogs.
24 August 2004
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