Environment, Food and Rural Affairs Committee Written evidence submitted by Care and Respect Includes All Dogs Campaign (C.A.R.I.A.D)

1. Summary

Puppy farms occur widely. Welfare conditions on such farms are most often poor with dogs kept in barren conditions, with minimal exercise, socialisation or health care. Such conditions lead to health and behaviour problems of breeding dogs and puppies. Later problems of dogs bought as puppies lead to increased risk of abandonment and contribute to the stray dog problem. Extant regulations have failed to address this issue. Local authorities are inconsistent in their application. Public information on breeders is inadequate. New regulations specifying high welfare standards are needed along with mechanisms for scrutiny of standards.

2. C.A.R.I.A.D. (Care and Respect Includes All Dogs)

Is a voluntary organisation set up in September, 2011, in Wales, to campaign for the ending of puppy farming, and for improvements to the welfare of dogs involved in breeding. C.A.R.I.A.D. comprises a coalition of 29 dog rescue and animal welfare organisations in Wales.

Details of C.A.R.I.A.D. can be found at http://cariadcampaign.co.uk

3. Evidence

3.1 The nature of puppy farming

3.1.1 The puppy farming environment is characterised by:

failure to provide veterinary care;

failure to carry out preventative treatments, such as vaccination;

keeping of breeding parents in barren, kennel accommodation;

failure to provide even minimal levels of exercise or stimulation for dogs;

failure to provide socialisation activities for puppies;

repeated breeding of bitches to exhaustion; and

disposal of unwanted breeding animals.

3.1.2 Evidence for such breeding operations comes from visits to unlicensed or licensed premises by local authority officers, periodic exposure of animal cruelty on such premises by the RSPCA, observations of those collecting dogs for rescue and other visitors, the observations of veterinary surgeons and rescue organisations in dealing with ex-puppy farm dogs, and under-cover investigations.

3.2 The effects of puppy farming

3.2.1 Dog rescue organisations regularly take in dogs previously kept in a “puppy farm” environment, most commonly ex-breeding bitches. Commonly, such dogs exhibit a wide range of signs of neglect. These include untreated ear infections, tooth and gum infections, skin complaints, eye infections and more severe problems such as untreated tumours.

3.2.2 Most often, ex-puppy farm dogs taken on by rescue organisations exhibit a range of behavioural problems. These often include initial high levels of fearfulness and withdrawal. Such dogs may be unfamiliar with going outside, standing on grass or other such basic experiences. Adopters frequently report that rehabilitation takes a great length of time and that dogs may continue to show fear reactions over many years.

3.2.3 The observations of rescue organisations gain strong support from a recent study, in which a comparison was made between adult dogs brought up in a domestic environment with dogs of equivalent breed, age and other characteristics previously kept as breeding animals in puppy farm situations (n=664). Dogs previously kept in a puppy farm situation were found to be 42% more likely to experience physical health problems. They were significantly more likely to show fear in a range of situations. Such dogs were also more passive showing low levels of excitability and energy.

3.2.4 Negative consequences of puppy farm conditions of breeding are likely to extend to the behaviour and health of puppies reared in them. A “socialisation period”, after puppies leave the whelping box and up to around 12–14 weeks, is viewed as particularly important for the formation of social relationships which are likely to have long-term impacts on adult behaviour. Veterinary surgeons, canine behaviourists and welfare organisations all recommend exposure, over this period, to a wide range of stimuli with extensive social contact. In the puppy farm environment, this will seldom occur.

3.2.5 Puppies deprived of appropriate experience during sensitive periods show less friendliness and responsiveness to people, often higher levels of fear-based aggression, and generally lower trainability. In addition, puppies separated from their dams during this period show poorer health. Unfortunately, this is likely to lead to greater risk of being relinquished by owners, and to contribute to dog abandonment and the stray dog problem.

3.2.6 Puppy farmers most often lack commitment to avoiding health problems associated with in-breeding, failure to undertake genetic tests or inappropriate crossing. They are major contributors to the current epidemic of genetically-driven health problems.

3.2.7 The experience of breeding dogs in puppy farms will often be poor. There is strong evidence of poor welfare of dogs kept in a kenneled environment in terms of physiological measures of stress and abnormal behaviours. Lack of stimulation, exercise and of control over the environment have each been shown to have negative welfare consequences. Again, these are characteristic features of this environment. Much research indicates that dogs are likely to show particular responsiveness to human contact, and that welfare can be significantly enhanced by increased interaction with humans. Yet puppy farm environments are impoverished in this respect.

3.2.8 A comparison of the key welfare criteria that underpin the Animal Welfare Act, 2006, the “five freedoms”, in the light of the above evidence, suggests that where dogs are reared in puppy farms they will most often fail to have key welfare needs met. This is particularly the case with respect to the freedom to express natural behaviour, freedom from fear and stress, and freedom from disease and injury. Moreover, many dogs will not experience freedom from discomfort either, as provision for bedding, warmth and other environmental features will often be inadequate.

3.3 How puppy farming works

3.3.1 Puppy farms are most often run in rural areas associated with farm operations. Outbuildings, such as barns, are converted to kennels. However, there are many which operate from domestic premises with rooms used to house dogs, often confined to crates.

3.3.2 Puppy farms operate both illegally, in the sense that no local authority license is held, and “legally”, where the conditions correspond to most or all of those described above, yet a license has been awarded by the authority. The prevalence of such operations, particularly concentrated in some areas, is high. In Carmarthenshire and Ceredigion, where most breeding operations occur in Wales, there were 159 licensed premises in late 2011. While not all of these would be described as puppy farms, many are characterised by such conditions. For example, in Carmarthenshire a dog breeding operation with 196 breeding dogs has been continuously licensed for many years, yet a recent planning application states that there are only 1.5 full-time equivalent staff to look after these dogs.

3.3.3 It has been evident in Wales that “behind the scenes” there are likely to be a large number of unlicensed premises. Again in Carmarthenshire, an unlicensed breeding operation with 123 breeding dogs came to light early in 2012.

3.3.4 Puppy farms often sell puppies via the Internet. In some cases puppies are sold through classified advertisements, cards in shop windows and “road-side” mobile numbers. Very often puppies are also sold through dealers who sell on either directly to pet shops, or via a network of intermediaries.

3.3.5 Those operating puppy farms seldom allow purchasers to come on-site. Often buyers will obtain their puppy from a dealer, or will be required to meet the seller away from the farm or puppies may be delivered. Advice from all reputable quarters (eg the RSPCA) is that anyone purchasing a puppy should see the puppy where it has been bred, and see at least the mother, and ideally both parents. A recent study showed that risk of subsequent behavioural problems is approximately twice as great if only one parent has been seen, and approximately four times as great if neither parent has been seen.

3.4 Limitations of the current legislative framework

3.4.1 The Breeding of Dogs Act, 1973, requires that those with more than four breeding bitches have a license and specifies conditions for this. These conditions are both limited and overly broadly defined, and no statutory guidance is provided for their interpretation. Local authorities most often draft their own “licensing conditions” based on the regulation, but operate inconsistently in applying the legal framework. Some, if not most, place emphasis on basic hygiene and structural aspects using “tick box” guidelines, but fail to adequately appraise the behavioural requirements of dogs eg with respect to needs for exercise, human contact etc. While guidance for local authorities was produced (the “CIEH Guidance”), this has widely been ignored on the grounds that “it is not statutory”.

3.4.2 The Breeding and Sale of Dogs (Welfare) Act, 1999, sought to prevent sale of puppies by breeders to individuals who “sell on” ie dealers. However, it has totally failed in this. The regulation allows for sale to those with a “pet shop license”. However, many have easily obtained pet shop licenses (they don’t even need to have a pet shop. Moreover, many puppy farms sell to dealers who do not have such licenses, yet almost never has action been taken against them. For example, there have been only three convictions under the Act between 1999 and 2012 (Home Office data). Observational evidence is that puppies are often kept in poor conditions while awaiting sale in pet shops. They will most often have been transported there during the sensitive socialisation period, and not receive necessary stimulation. It would be better if sale to anyone “selling on”, and the sale of puppies from pet shops, was prohibited. Regulation of sale via the Internet is also now essential.

3.4.3 Routinely dog breeders in Wales are provided with licenses when it is evident that the conditions do not meet the minimum requirements of the Animal Welfare Act, 2006. This appears to reflect difficulty in applying requirements relating to expression of natural behaviour and the experience of fear and stress. A further problem is that currently some authorities are choosing not to take on the responsibility to apply the Animal Welfare Act.

3.4.4 Most licensing officials do not have the training to appraise the welfare needs of dogs. A specific qualification concerning dog welfare should be developed to support practice.

3.4.5 There is a need for a level of independent scrutiny of local authority practice. This might be in the form of a “Commissioner for Dogs” funded from a proportion of license fees, who may conduct inspections of local authority licensing procedures. Alternatively, it may be that regional licensing units could be set up to include purpose-trained staff, taking this responsibility away from local authorities.

3.4.6 A primary purpose of the current licensing framework is protection of the public as consumers. However, many authorities do no make information on licensed breeders public. A requirement that local authorities make available details of who is licensed, and of relevant licensing reports, on their web-sites would be a cost efficient way of doing this.

3.4.7 In Wales, there have been steps to address some of the limitations of extant dog breeding regulations with consultation on new draft regulations recently completed. The regulations are associated with statutory guidance related to the requirements of the Animal Welfare Act. However, there are limitations in the proposals, including the allowing of low staff to dog ratios. Moreover, these proposals do not address issues of sale. However, the new proposals are a step in the right direction, and may help inform development of regulations elsewhere across the United Kingdom.

4. Recommendations

A. New regulations should be introduced across the United Kingdom which specify clearly defined minimum welfare conditions for the breeding of dogs. These should place a strong emphasis on exercise, opportunities to express natural behaviour, appropriate socialisation of puppies and health care. The regulations should be associated with statutory guidance.

B. An independent body or Commissioner should be established to ensure scrutiny of licensing standards applied by local authorities.

C. A qualification for licensing officers focusing on assessment of canine welfare should be developed.

D. All authorities should be required to make public details of licensed breeders on their web-sites.

E. Sale of dogs from pet shops should be prohibited.

F. It should be an offence for a breeder to knowingly sell puppies to someone who sells on.

G. There should be regulation of sale of companion animals on the Internet.

For Gracie and Hattie—two ex-breeding bitches with multiple, chronic health problems.

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June 2012