Environment, Food and Rural Affairs Committee Written evidence submitted by the British Veterinary Association and the British Small Animal Veterinary Association

1. The BVA (British Veterinary Association) and BSAVA (British Small Animal Veterinary Association) welcome the opportunity to respond to the EFRA Committee inquiry on Dog Control and Welfare.

2. The BVA is the national representative body for the veterinary profession in the United Kingdom and has over 13,000 members. Its primary aim is to protect and promote the interests of the veterinary profession in this country. The BSAVA is the largest specialist division of the BVA and of the veterinary profession. It represents approximately 7,500 members, the majority of whom are in general practice and have an interest in the health and welfare of small animals, namely cats and dogs.

3. Our specific responses to the Committee’s questions are outlined in brief below but we have also attached a number of our responses (see Appendix A) to recent Government consultations on these topics which include more detailed background information.

Dog Control

Is there a need for a more fundamental overhaul of dog legislation, and its enforcement, including that relating to dog attacks on people, livestock and pets?

4. Yes. We strongly believe that the current dog legislation should be overhauled. While we support the individual proposals put forward in the most recent consultation on tackling irresponsible ownership we do see the package as a missed opportunity.

5. The current legislation is flawed and ineffective and the new proposals do very little to prevent future dog attacks. We believe that to solve all of the problems associated with dog control and dog welfare, repeal and replacement of the Dangerous Dogs Act with dedicated and consolidated legislation is necessary.

6. We do not support breed-specific legislation. Evidence from hospital bite injury reports or surveys of bite victims indicates that a wide variety of breeds are involved in these incidents.1 Breed-specific legislation faces problems because of the difficulty in proving the breed of a dog and may engender a false perception that aggression is a problem in certain breeds and that therefore the legislation does not apply to the majority of dogs and their owners.

7. The manner in which a dog behaves is partly as a result of its inherited characteristics, but more importantly is a result of the rearing and training provided by its owner and the environment in which the dog is kept. We therefore favour a preventive approach to the problem of dog control, which includes not only measures to educate the public about responsible ownership, but also measures (such as control notices, acceptable behaviour contracts, etc) to address the early signs of aggression in all dogs and tackle irresponsible ownership before it becomes a problem.

8. It is also our view that legislation should be extended to cover attacks on protected animals.2 The recent Guide Dogs for the Blind Association report highlighted an increase in attacks on guide dogs, with more that eight guide dogs a month being attacked by other dogs.

Is sufficient action being taken on pets raised as status dogs to ensure their welfare and reduce their impact on communities?

9. The issue of status dogs and those animals kept for the purposes of intimidating others should be considered separately from the wider issue of dog control. The former is a specific situation arising from the behaviour of individual people who expose their dogs to environments and situations deliberately to create an uninhibited and aggressive response. The behaviour of these individuals should be addressed with public order or antisocial behaviour legislation.

10. As well as causing problems for the police, because of public order offences, there are welfare problems for the dogs themselves through their involvement in dog fighting and abandonment. Status dogs are often referred to as “dangerous dogs”, although this is not necessarily the case as many of these “status dogs” are Staffordshire Bull Terriers or their crosses (breeds not covered specifically by the Dangerous Dogs Act).

11. We agreed in principle with the proposals put forward by the Home Office in May 2011 to tackle the social causes of the problems caused by dangerous and “status” dogs. We believe that more action needs to be taken to deal with the issues that lead people to acquire “status dogs”, and that significantly more education is needed so that people understand the responsibilities of dog ownership before acquiring a dog.

Will compulsory microchipping of puppies improve dog welfare and help prevent dog attacks at an affordable cost to dog owners? Should a dog licensing scheme also be considered?

12. We support a policy of compulsory microchipping and are in favour of the Government’s proposal to introduce compulsory microchipping for all dogs within a year of the legislation coming into effect (option d). However microchipping alone has limited benefit and must be combined with a requirement for the owner/registered keeper of the dog to register and keep registration details up to date.

13. The principal objective of microchipping is to enable lost, stolen or stray dogs to be reunited with their owners. This in itself can help to improve dog welfare by reducing the amount of time that dogs are kennelled before being reunited with their owners or re-homed. Microchipping can also help promote responsible ownership as owners can be readily identified, and it can facilitate the reporting of hereditary health problems and surgical procedures resulting in conformation alteration in pedigree dogs.

14. However, microchipping is not the solution to the problem of irresponsible ownership and dangerous dogs. Instead, compulsory microchipping must work in tandem with a package of other measures aimed at reinforcing responsible ownership through education and the use of initiatives such as control notices and acceptable behaviour contracts.

15. The cost of microchipping is not prohibitive, especially in the context of the cost of lifetime ownership of a dog.3 The cost of microchipping ranges between £10 and £30, although many charities offer discounted or free microchipping services and veterinary practices may include discounted microchipping as part of a package of wider healthcare measures.

16. The issue of dog licensing is controversial, as although the idea of dog licensing can be linked to responsible dog ownership and has the potential to raise revenue, experience suggests that it is difficult to enforce. We feel that dog licensing would potentially create unnecessary bureaucracy and expense for local authorities and could act as a barrier to dog ownership for vulnerable groups. Although it has been suggested that money from a licensing scheme could be ring-fenced to provide for dog welfare initiatives, we are yet to be convinced that this could be adequately achieved. As a result, we believe that compulsory microchipping and registration is currently the preferred alternative to a dog licensing scheme.

Should the Dangerous Dogs Act 1991 be extended to include offences committed on private property?

17. Evidence suggests that most incidences of human directed aggression in dogs occur within the home environment and towards family members or those known to the dog. We therefore support the extension of the Dangerous Dogs Act to private property alongside a programme to educate owners about responsible ownership. However there must be clear guidelines for owners about their responsibilities and the circumstances under which they may or may not expect to be prosecuted should their dog attack an intruder.

Are Defra’s proposals for wider community and educational approaches to support responsible dog ownership sufficiently ambitious?

18. No. While the £50,000 earmarked for education is welcome and we support the idea of disseminating good practice, we consider that significantly more money will need to be spent on education in order to promote responsible pet ownership.

19. There should be wider engagement with the general public on this issue, with a nationwide public campaign to raise awareness, to encourage responsible ownership and to promote safe interaction between people and dogs. There are already a number of initiatives which could be used as resources upon which to base any such campaign, including the Blue Dog Programme, the Kennel Club’s Safe and Sound scheme and the AWF/RSPCA Puppy Contract and Puppy Information Pack.

20. As we have stated above, dog control notices and acceptable behaviour contracts, should also form a key part of a community approach to supporting responsible ownership.

Do local authorities, the police and animal welfare charities have the right roles in managing stray dogs under the current legislative regime?

21. Currently the responsibility for stray dogs rests with the local authority while the police are responsible for dangerous dogs. It is correct for the police to have responsibility for dangerous dogs where an offence has been committed. As local authorities do not have a requirement, or in many cases the resources, to collect dogs outside normal working hours this can create problems, not least of all for the welfare of the dogs concerned. While animal charities may be in a position to accept stray dogs directly, many stray dogs are initially presented at veterinary surgeries. Compulsory microchipping and registration would enable rapid re-unification of those dogs which have temporarily become separated from their owners.

Dog Welfare

In respect to concerns expressed in Professor Bateson’s report over poor welfare that has arisen in the course of breeding dogs:

Has the response by dog breeders and the veterinary profession been effective?

22. Issues surrounding dog breeding still present significant problems to animal welfare and we feel this remains a priority concern. Although progress has been made on dog breeding, we feel that more could have been done by now to tackle the problem.

23. Since Professor Bateson’s report, a large number of initiatives have been created to address the problems associated with dog breeding. However, a more strategic approach is needed to co-ordinate these initiatives so that progress can be measured more accurately against a single set of objectives.

24. The setting up of the Advisory Council on the Welfare Issues of Dog Breeding in 2010 has been a positive step in this regard and we feel that the Council is on the right track. We believe that the Council can act as a collaborative body, pulling together stakeholders to achieve a more co-ordinated approach. Outputs from the Council are due to be published soon and we will be working with the Council to take these forward. The lack of funding for the Advisory Council is an issue and we recommend that Defra look to providing some funding so that the Council can work properly.

25. Because of the disproportionate influence of show dogs on the desired phenotype and genotype of a breed, there should be greater pressure for those showing and breeding dogs to improve the health and welfare of their dogs.

(a)The health and welfare of individual dogs must be put before the protection of the breed.

(b)Breed standards should be reviewed to ensure that the emphasis is on health and welfare and not aesthetics,

(c)There needs to be better data gathering to identify individuals with heritable diseases or exaggerated characteristics, and this information must be made available to those seeking to breed from or buy progeny from these animals.

(d)Identifying problems in dogs before breeding is of paramount importance and we welcome the research largely funded by the Kennel Club, being undertaken for DNA testing at the Animal Health Trust to identify those genes carrying inherited diseases. It is vital that the breeders and breed clubs make the most of this information when selecting dogs for breeding.

(e)Steps should be taken to maintain and increase the gene pool by:

(i)allowing outbreeding where necessary to counter inherited disease;

(ii)limiting the use of popular sires so that they do not have a disproportionate influence on the gene pool of a breed; and

(iii)prohibiting registration of puppies where the co-efficient of inbreeding is greater than 12.5%.

(f)Dog shows should be encouraged to place greater emphasis on health, welfare and fitness for function.

(i)We welcome the “vet checks” on the Best of Breed winners at all championship dog shows to ensure that only healthy dogs are awarded prizes and in due course this should be extended to cover some other breeds.

(ii)Where health schemes or genetic tests exist for a breed the dogs must be tested and the results published before the dog can be awarded “champion” status.

What actions should Government take to address these Issues?

26. There need to be stricter controls over dog breeding covering the conditions in which dogs are bred; the welfare of the breeding animals and future generations, through the appropriate selection of breeding stock in order to reduce the incidence of hereditary disease and conformational exaggeration; and the socialisation requirements of puppies particularly those destined to become family pets.

27. We have called on the Government to conduct a broad review of breeding legislation to ensure that it is fit for purpose and can respond to the problems of puppy farming and irresponsible breeding. Both the Welsh Government and the Department of Agriculture and Rural Development in Northern Ireland have recently consulted on proposals to amend their dog breeding legislation; the English Government should follow this example.

28. The introduction of compulsory microchipping before puppies leave a breeder will enable puppies to be traced and allow for more breeder accountability, both in the case of hereditary disease and health and welfare problems arising from puppy farming.

Are further controls required on dog breeders, including puppy farms, and those selling or importing dogs to ensure the welfare of bitches and puppies?

29. Yes, controls should adopt the Breeding Standard developed by the Advisory Council on the Welfare Issues of Dog Breeding (http://dogadvisorycouncil.org.uk/the-reports/) and should cover:

(a)The registration of all breeders, other than those breeding an occasional litter from a family pet.

(b)Minimum requirements for the premises in which the animals are kept with reference to disease control and animal welfare—with particular emphasis on environmental enrichment for those animals which are kept in “puppy farming” environments.

(c)The staffing ratio required to provide for the welfare of all animals on the premises allowing for the greater needs of pregnant and lactating bitches and socialisation of puppies.

(d)Socialisation programmes appropriate to the destination of the puppy with particular emphasis on those animals likely to become family pets.

(e)Microchipping and registration.

(f)Puppy contract detailing breeders and future owners responsibilities to ensure the welfare of the dog.

June 2012

1 For more information please see our response to the Consultation on Dangerous Dogs of June 2010, question 4 (Appendix A).

2 As defined by section 2 of the Animal Welfare Act, ie if (a) it is of a kind which is commonly domesticated in the British Islands, (b)it is under the control of man whether on a permanent or temporary basis, or (c)it is not living in a wild state.

3 The PDSA Wellbeing Report 2011 estimated the lifetime costs of owning a dog to be between £16,000 and £31,000.

Prepared 14th February 2013