Environment, Food and Rural Affairs Committee Written evidence submitted by Carol Fowler, Dog Health Campaigner

“We also want to find out whether enough is being done to improve the health and welfare of dogs bred for sale.”

I have been campaigning on the welfare issues of dog breeding since 2006. My particular interest is genetic welfare issues which I feel is a much neglected area of animal welfare. It is a huge problem affecting many thousands of dogs and their owners. I entirely agree with the RSPCA’s “Born to Suffer” campaign message and its stance that a large proportion of dogs, particularly purebred dogs, face a life of needless suffering as a result of breed related genetic diseases and exaggerated conformational traits. Reports written by CAWC, RSPCA, APGAW and Sir Patrick Bateson have confirmed this.

I would like to see the welfare issues associated with poor breeding practices dealt with separately from dog control and irresponsible ownership issues. I would like Defra to appreciate that these are two quite separate issues involving dogs. In lumping them together, there is a danger that none of them will be dealt with adequately or that undue emphasis will be put on dog control and irresponsible ownership because of the tabloid interest it generates.

I will limit my response to breeding issues.

Dogs are sentient beings: they feel fear and they feel pain (as well as joy). They give their owners love, loyalty and companionship (and much more if they are working dogs). They are entirely dependent on their human breeders and owners for the quality of their lives. Unlike animals in the wild they are not free to choose their mates. These are selected for them by their human owners and the dogs pay the price, in the form of genetic diseases, from so much inbreeding (sometimes called line breeding).

The Animal Welfare Act 2006 identifies five needs that a dog has:

(a)Its need for a suitable environment.

(b)Its need for a suitable diet.

(c)Its need to be able to exhibit normal behavioural patterns.

(d)Any need it has to be housed with or apart from, other animals.

(e)Its need to be protected from pain, suffering, injury and disease.

Dog Breeding

This may be divided into two parts:

1. Issues of welfare associated with large scale breeding for commercial purposes (“puppy farms”)

2. Genetic welfare issues associated mainly with purebred dogs where closed gene pools give rise to a disproportionately large number of breed related diseases (caused by the loss of genetic diversity within the gene pool). The emphasis of breeding to achieve a certain “look” or conformation (the Kennel Club breed standard and its interpretation by show judges). This has the effect of further reducing the gene pool because certain dogs are favoured over others for breeding. Also, traits regarded as desirable become ever more exaggerated (such as short legs, wrinkly skin, excessive hair, short noses, curly tail, etc)

Large Scale Commercial Breeding (Puppy Farms)

Not all large scale breeding establishments compromise dog welfare but for many obvious reasons they often do.

Commercial breeding establishments should be licensed by the local authority but many are not. Those that are licensed are not inspected often enough and standards required are far too low and do not conform to the 5 principles of the Animal Welfare Act 2006. The law on commercial dog breeding (Breeding of Dogs Acts 1973 and 1991 and the “Breeding and Sale of Dogs (Welfare) Act 1999) needs to be updated so that requirements include more than the basic needs for water, food and shelter. Local authority inspectors should be trained properly for this job and local authorities adequately funded to carry out regular inspections. Large scale Kennel Club Assured Breeders should not be exempted from local authority control and inspection. The Welsh Assembly government have drawn up proposals to end the poor welfare practices of puppy farms and I’d like to see their detailed proposals adopted by the national government. I find it astonishing that the national government has not taken the lead on this but leaves it to the devolved assemblies to act first.

Small Scale or so called “Hobby Breeders”

These are either breeders who breed to show and sell their puppies (or charge stud fees), and are usually members of breed clubs, and those who breed an occasional litter from the family pet. It is worth pointing out that three litters bred a year (four in a litter) would earn a breeder a minimum of £6000. Pedigree breeds and “designer cross breeds” can cost anything between £500 and £1000 per puppy. So it is incorrect to say that small scale breeders do not benefit commercially from what they do. Stud dog fees can range from £500 to £1000 and with many cash transactions it is very easy to avoid paying income tax from these activities. To screen or test breeding dogs for genetic diseases incurs financial costs for the breeder and for that reason many are not willing to carry out such screening tests. For show breeders the aim is to produce dogs which are prefect examples of the “breed standard” and which will win prizes. Prizes are awarded purely on the basis of the outward appearance of the dog, not whether it is free from the genetic diseases associated with that breed.

Why a Self—Regulatory System will never result in the Improved Genetic Health of Dogs

There is a conflict of interest for breeders as their commercial profit and show winning success would be affected if they pursue rigorous health testing and ethical breeding practices.

There is a conflict of interest for the Kennel Club as it would lose commercial profits from its registration services if breeders are alienated or registration refused due to lack of health screening. A fee of £15 is charged to the breeder for every puppy registered and a further £15 is charged when the puppy changes to a new owner. The single most important thing the Kennel Club could do to improve the genetic health of dogs would be to refuse to register puppies from parents which have not undergone health screening and found fit to breed. The KC refuses to do this because it would impact on its commercial profits (although other reasons are usually given). For the same reason it will not limit the number of times a stud dog may be used—a measure which would slow down the depletion of a breed gene pool and maintain sufficient genetic diversity.

Why Measures taken so far will have little Impact on the Genetic Welfare of Dogs

The Kennel Club has introduced some changes to improve the genetic health of dogs, such as minor changes in the breed standards of some breeds (to avoid extremes). However, these changes do not go far enough. It is also funding research by the Animal Health Trust which will result in more DNA tests becoming available. However, the production of DNA tests can never keep up with the emergence of new genetic diseases. Eliminating affected dogs from the gene pool will have the effect of reducing genetic diversity even further. DNA testing needs to occur in conjunction with introducing new genetic material. Currently the Kennel Club pays lip service to this idea when it should be normal practice to regularly open up the gene pools of all breeds. The introduction of new official BVA/KC health screening schemes is urgent, in order to tackle more complex diseases, but in 4 years since “Pedigree Dogs Exposed” only one new scheme has been introduced (Chiari malformation/Syringomyelia CMSM) making four in total. A promised new scheme for Heart Disease is not yet ready after four years due in the main to a lack of will and sense of urgency by the Kennel Club. There needs to be a speeding up of the process of introducing new schemes to tackle the huge number of breed related health and welfare problems.

The much trumpeted Estimated Breeding Values (EBV) scheme for dog breeds is underway but faces enormous practical difficulties. In theory breed related diseases can be tackled by using health data to show the relative risk of a proposed mating of producing offspring who will suffer from a genetic disease. However, collecting the health data is proving to be an insurmountable problem as it relies on breeders submitting accurate health data. An example is that an EBV project to tackle Chiari malformation/Syringomyelia (CMSM) in Cavalier King Charles Spaniels is floundering due to lack of data. Data collection for one disease in one dog breed started in February 2008 and is still not sufficient to provide robust EBVs. Breeders have been reluctant to MRI scan and submit health data in case it impacts on their breeding activities.

What the Kennel Club could do to make Speedier Progress but has refused to do.

The biggest contribution the Kennel Club could make in order to improve the genetic health of dogs is to refuse to register puppies from parents which have not been health tested and proved to be fit to breed.

It should also put a blanket limit on the number of times any one stud dog can be used for breeding so that the effective population size can be maintained above a critical level for all breeds.

It should require a clean bill of health for any dog entered into one of its shows. Breed clubs should be responsible for this. The emphasis on dog showing should be on health and vitality rather than the aesthetic qualities of a dog.

It should make the Assured Breeders Scheme more robust and then apply its rules to all breeders registering with the Kennel Club. Currently only 14% of breeders registering with the KC are Assured Breeders. Of those, only 19% have been visited by advisors.

However, as stated before, the conflict of interest on the part of breeders, breed clubs and the Kennel Club mean that the current system of self-regulation will not improve the health and welfare of dogs. Also, the Kennel Club has a long history of resentment towards and rejection of any outside “interference” in its affairs.

The Advisory Council for the Welfare Issues of Dog Breeding should be given the power to enforce change rather than just have an advisory role. The problem is urgent, the task enormous, dogs and their owners are suffering. The issue has been highlighted on several occasions over many decades and successive governments have failed to take effective action. Time and time again the Kennel Club has shown that it is not capable or willing to put its own house in order. Let’s not wait more decades for the Kennel Club to remain untouchable and for the proliferation of genetic diseases to grow at a much faster rate than the small changes for the better.

The UK Government Lags behind other Countries in its Animal Welfare Laws

Countries such as Sweden, Norway, Denmark, Germany, Switzerland, Holland, Australia and others are tackling genetic welfare issues in a serious way. It seems incredible that the UK (supposedly a nation of animal lovers) lags so far behind. In failing to tackle genetic diseases in an effective way we are failing in our duty under the Animal Welfare Act to fulfil a dog’s “need to be protected from pain, suffering, injury and disease.”

I urge the EFRA Select Committee to require DEFRA to take a more proactive role in this issue instead of sitting back and waiting for the Dog Advisory Council, with its very limited scope, to do all the work. For how much longer will this scale of suffering be allowed to continue in this nation of animal lovers?

June 2012

Prepared 14th February 2013