Memorandum submitted by the Ornamental
Aquatic Trade Association Ltd (Vet 09)
OATA represents the interests of some 750 businesses.
Among our members are importers, consolidators, breeders, wholesalers
and retailers of ornamental fish and invertebrates. The species
traded vary from the coldwater goldfish and koi carp, through
freshwater tropical species to coral reef fish and invertebrates.
Many of these species have been in trade for many decades, some
for more than a century. Thus the industry has build up an immense
wealth of information on the care, husbandry and welfare of the
2,000 species of ornamental fish in trade.
In addition to businesses selling live fish,
many other members manufacture and distribute dry goods such as
pumps, fish treatments, aquariums, filters and other ancillary
equipment which helps ensure the welfare needs of ornamental aquatics
specimens can be readily met.
Advice on both the live animals, and the equipment,
required to ensure their welfare has always been readily available
from retailers or relevant manufacturers.
OATA members have a code of conduct. We have
developed and made available to the industry two levels of distance
learning material. A range of point of sale information to help
inform customers and further enhance the welfare of specimens
in trade has been printed and distributed.
OATA was one of four organisations that helped
develop the Local Government Associations "Model standards
pet shop licence conditions". OATA is also recognised as
an "organisation to consult in the case of specialist or
unusual species" in the guidance notes to the Protection
of Animals (Amendment) Act 2000.
THE FISH
KEEPING HOBBY
Fish are the third most popular pet group, after
cats and dogs, being kept in over four million (approximately
15% of the total) households in the UK. Surveys by OATA canvassing
some 4,000 customers visiting members retail premises indicated
that there are between 100 and 150 million pet fish in the UK,
making them by far the most populous pet group.
Fish are usually purchased from retailers and
may cost, depending on species or characteristics, from as little
as a couple of £s through to many £000s for rare high
quality koi carp.
WELFARE OF
FISH: COST
AND OMNICOMPETENCE
OF VETS
Should any proposals be implemented they must
enhance and protect the health and welfare of animals.
To ensure the welfare of ornamental fish, kept
in either aquaria or ponds, or indeed any other animal, care and
advice must be both professionally competent and accessible. Those
providing care or advice must be familiar with the animals concerned.
Their services must be affordable. Economic constraints to owners
seeking advice and providing the care needed to ensure the welfare
of animals in their care, must be minimized as far as is reasonably
possible. Care and advice should be available within a reasonable
distance.
Currently ornamental fish keepers obtain most
advice on husbandry matters from their local aquatic retailers
for free. Further advice is available from fish biologists working
either as consultants or within government agencies eg the CEFAS
Fish Health Inspectorate. Some vets apparently refer their clients
to aquatic retailers for detailed advice that they are currently
unable to provide. This reflects a lack of confidence, on the
part of some vets, that they are able to provide professional
advice with regard to fish.
Some concerns that the 1966 Act apparently excluded
fish from its purview have been expressed. However, in the interim
little training specifically concerning fish biology and welfare
has been developed and made available during under-graduate veterinary
courses and few, geographically disparate, vets have any specialist
post graduate training. An exception to this general comment being
those vet who train specifically and then join the Fish Veterinary
Surgeons. In that same period importers, retailers and fish specialists
have continued to train and amass even greater practical experience
and knowledge of the husbandry needs of fish and the mini ecosystem
in which they are maintained using a range of equipment systems.
OATA's distance learning training courses have played a part in
the continuing professional development within the sector.
Fish welfare would, in our view, suffer, if
any proposals to revise the Veterinary Surgeons Act denied owners
full access to the wealth of information and experience available
in the trade and from specialised fish biologists, there being
no similar bank of information and experience within the veterinary
profession. Vets with experience of fish are widely spread geographically,
and particularly given the difficulties in transporting fish,
are far less accessible, irrespective of cost, than are ornamental
fish retail outlets.
OATA would support the maintenance, under
the act, of the status quo as far as fish are concerned.
Maintenance or improvement in fish welfare, rather than protection
of the interests of the veterinary profession, must be demonstrable
practical outcomes of any revisions to the legislation.
THE ALTERNATIVES
If the status quo is altered and fish
are specifically covered by any proposals to revise the Act, then
in the interests of welfare, provision must be made to permit
owners access to care and advice from ornamental retailers, product
and food manufacturers and other non-veterinary fish specialists.
If a supplementary list of competent lay people
who could provide advice to fish keepers was created, then OATA
could play a leading part, in its organisation or indeed administer
its own register. Any list would have to allow "grandfathering"
to ensure experience and knowledge of fish welfare is not unnecessarily
lost. The role of the RCVS in any supplementary lists would of
necessity need to be open, transparent and administration kept
simple and the least burdensome necessary, so as not to reduce
standards of fish welfare.
LIMITATIONS
We believe, however, there should be limitations
to activities of lay persons in the area of active surgical intervention.
Routine minor procedures such as taking skin and gill scrapes,
removing damaged scales, fin clipping (usually used in fisheries
management but also may be used to collect samples for disease
identification) and tagging and the like should be available to
lay persons if they are carried out within the limits established
by recent animal welfare legislation concerning mutilations.
Invasive surgery, particularly where the body
cavity is opened, should not be available to anyone other than
appropriately trained veterinary surgeons.
August 2007
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