Memorandum submitted by the British Veterinary
Association
INTRODUCTION
1. The British Veterinary Association (BVA)
is the national representative body for the veterinary profession
in the United Kingdom and represents circa 10,000 members. Our
chief interest is to protect and promote the interests of the
veterinary profession in this country and we therefore take a
keen interest in all issues affecting the veterinary profession,
be they animal health, animal welfare, public health or employment
concerns.
2. The BVA welcomes the opportunity to contribute
evidence for the EFRACom evidence session with the Minister and
have the following points to bring to the Committee's attention.
DIFFERENCES BETWEEN
THE ANIMAL
WELFARE BILL
AND THE
ANIMAL HEALTH
AND WELFARE
(SCOTLAND) BILL
3. A major concern of the Association is
that the Animal Welfare Bill and the Animal Health and Welfare
(Scotland) Bill have some marked differences. The act of abandonment
for example is covered in Scotland but not in England. It is felt
that this may cause significant problems for those enforcing the
powers set out in the Bills. BVA entirely supports the Committee's
view that abandonment should continue to be a specific offence
for the reasons the Committee stated. We have not changed our
view and urge the Committee to press the government on this matter.
SPECIFIC COMMENTS
ON THE
ANIMAL WELFARE
BILL
4. BVA are disappointed that Defra have
not seen fit to include a provision for statutory improvement
notices which would have been a useful adjunct to enforcement
and are disappointed that the Government have chosen not to include
the facility in the Bill. In particular we view improvement notices
as particularly useful when implementation of secondary legislation
on sanctuaries takes place because we consider it less likely
that some will close. Closure of a significant number of sanctuaries
would inevitably result in animals being killed because no place
can be found for them.
5. The restraints following animal ownership
disqualification are also felt to be incomplete.
6. BVA is concerned about the powers of
entry into private dwellings where there is an animal welfare
emergency and would like to recommend that this be looked at in
more detail.
7. Mental suffering: BVA notes that the
Government have failed to take up the Committee's recommendation
that there should be specific reference to mental suffering in
Section 4 of the Bill. We strongly support the Committee's recommendation
and wish to see the words "physically and mentally"
inserted in appropriate places in this section.
8. Mutilations: BVA is content with the
definition of mutilation in the Bill and welcomes the ban on mutilations.
However the Association remains concerned that the explanatory
notes and RIA refer to permitting tail docking in certain types
of dogs. The Minister has verbally referred to Parliament taking
a free vote on this issue which is a relaxation of his previous
line that cosmetic docking would be banned. Both cosmetic docking
and non-therapeutic or prophylactic docking should be completely
banned, as outlined in the RCVS' Guide to Professional Conduct
(Annex A). This is a mutilation that the majority (over 90%) of
veterinary surgeons find abhorrent. In fact most veterinary students
are no longer taught to dock tails.
9. Fighting: The Bill is significantly watered
down from the draft Bill as the range of offences is smaller.
BVA cannot conceive why this universally condemned activity is
not the subject of an offence whatever the connection. We suggest
that the making, sale or possession of any recording of a fight
should also be an offence (similar to child pornography) and would
urge you to act to ensure that this barbaric practice is forever
prevented.
10. Sale of pets to minors and pets as prizes:
The section, as currently drafted, is muddled and shows no clear
thought process. These are two separate issues and should remain
so, as they were in the draft Bill.
11. Delegated powers: We support the wide
powers available, which will allow legislation to be kept up to
date with current science and best practice and we agree with
the Committee that the sole purpose of the legislation being delegated
is to achieve that. However, we suggest that the language of these
sections could be improved.
12. Pet fairs: should be made illegal because
it is almost impossible to protect the welfare of the animals
involved. Certainly cats and dogs should not be allowed to be
bought or sold at such events but there is grave concern over
the transport and display of other exotic animal species, such
as birds and reptiles.
13. Inspection intervals: we are extremely
disappointed to see that licences are to be issued for between
three and five years. We fail to see any animal welfare benefit
in such proposals and consider that adverse effects are almost
inevitable. While we could accept a risk based approach to inspection
we consider that the minimum should remain an annual licence.
14. Greyhounds: We welcome the fact that
the proposed regulation is to be brought forwards.
15. Dog breeding: Puppy farms are of huge
concern given that many see them as a source of income and have
little regard for the welfare of the animals. Regulation of dog
breeding must be tightened to ensure that all breeding dogs are
carefully regulated.
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