Environment, Food and Rural Affairs Committee Supplementary written evidence submitted by the Advisory council on the Welfare issues of Dog Breeding

COMPULSORY PERMANENT IDENTIFICATION OF DOGS (ENGLAND)

Preamble

In Defra’s Consultation on Dangerous dogs (Defra 2010) 84% of respondents (1,875 responses) answered “yes” to the question: Do you think that all dogs should be microchipped? This provides an effective mandate for government to introduce PI and, if irresponsible and illegal activities are to be managed effectively, it must be compulsory;

The changes to the pet passport scheme bring a certain urgency to this debate as there is greater potential for fake documentation than previously [examples include dogs with fraudulent documents being imported from abroad ‘after hours’ and sold close to points of entry from the back of vans];

Insertion of a microchip is the most reliable form of permanent identification (PI) currently available and should therefore be regarded as the default position, but it is important to ensure that future research and development does not preclude the use of other forms of PI as new technologies emerge;

The insertion of a microchip has been shown to be a robust means of identification in a number of animal species [it is probably the most tamper-proof system available, although this is not 100% reliable—some ‘criminals’ will remove them ‘surgically’ for example];

The reliability of the database that records the unique identifiers is crucial, as is its ease of interrogation [room for improvement here; there is probably no appetite in Defra for a central database that they would administer, but it would be sensible to ensure that all the existing databases can share information, ideally that a well respected organisation or organisations has/have ‘ownership’ of the database that any potential privacy issues are resolved. In addition, there must be 24 hour access to the database, this is not so at present];

Good publicity and free, or reasonably priced, microchipping will be important aspects of encouraging uptake, especially initially;

A lead in period of at least 12 months with an amnesty arrangement for unidentified dogs would be desirable.

Aims

Traceability, linking the dog with the original breeder and subsequent owner(s) [this is a key element of tackling irresponsible breeding, including the worst aspects of puppy farming. Anyone who decides to produce a litter of puppies from their dog is a breeder. Whether it is one accidental litter, one planned litter from a much loved family pet, or an established kennel breeding, all these people are breeders and so must be included];

Puppies to be microchipped by eight weeks of age and before they leave their dam—all paperwork to be in place before point of sale [Important to ensure that puppies do not leave their mother prematurely, so suggest that puppies remain with their mother until at least eight weeks of age and this also makes it much less likely that potential owners will not then see the mother];

It is much more difficult to breed irresponsibly and to fail in the duty of care required by the Animal Welfare Act if PI is universally adopted;

Comprehensive database assists the reuniting of owners and dogs if the dog is lost or stolen [provides owners with a certain peace of mind];

The fact that that there is a comprehensive database assists those involved in tackling irresponsible breeding by ensuring that all puppies produced by breeders are recorded via a unique identification number [as are cattle, sheep, pedigree rabbits, most horses and some cats];

The cost of microchipping is borne by the breeder, so is self-funding with no cost to government [ideally it should apply to large breeders and single breeders of all dogs whether pedigree, crossbred, mongrel, registered or non-registered];

PI aids identification of those involved in breeding illegally, eg dangerous dogs—ensures that unidentified dangerous dogs can be removed from the population. There are considerable costs (physical, mental and economic) attached to the damage inflicted by various types ‘dangerous’ dog. For example, the number of hospital admissions (ie those requiring an overnight stay) for dog bites continues to increase; NHS records for England show that there were 2915 hospital admissions in 1997–1998 and 4699 in 2007–2008 and the costs exceeded £2 million per year;

Reducing the stray dog population. Dogs Trust has been researching the stray dog problem for the last 10 years, carrying out a survey with Local Authorities. Taking the number of stray instances, the numbers that are put to sleep, the number of nights that the Local Authorities have to board dogs, the savings, at a minimum would be £2.9 million per year. RSPCA estimated costs were similar at about £2.8 million per year;

It makes it much more difficult for people to falsify the results of health screening tests, including DNA sampling [note that PI is compulsory under existing Canine Health Schemes in the UK];

Improves individual identification and disease surveillance [it would seem illogical to regard PI as an essential feature of disease tracing and control in farm animals and not to extend the same logic to dogs];

Future developments will increase the capacity of microchips to hold a considerable amount of information which is linked to the individual animal and much less susceptible to tampering than paper records.

Summary of Benefits

Identification, traceability, accountability and transparency;

The benefits should exceed the costs—available data in support require collation;

Irresponsible breeding can be tackled at source. Puppies are individually identified and linked with the breeder;

All dogs would be identifiable and if a unique identifier is part of each microchip, it is easier to ensure that the breeder is accountable;

Dog welfare would be improved;

The stray dog population would decrease;

Dangerous dogs would be linked with the breeder/owner;

In the event of a disease outbreak, such as rabies, reliable PI will be absolutely crucial.

Other Questions to Consider (assuming that not all will agree with the summary of benefits)

Will this be cost effective?

Will this be sufficiently robust (microchip failure, human error, database problems etc)?

Will this reduce irresponsible breeding and make breeders truly accountable?

Will crime rates be reduced?

Will the number of weapon dogs/dangerous dogs/attacks by dogs etc, be reduced?

Will this increase or decrease owner responsibility?

Will it make it easier to trace and control exotic notifiable diseases?

Why not a licence/other system—or simply retain the status quo?

The Advisory Council’s Proprosed Breeding Standard

EFRA Commitee Possible questions for the Minister

The Advisory Council is waiting for a response from Defra with regard to meeting the new Minister to discuss, inter alia, the Standard for Breeding Dogs (hereafter the Standard).

Chris Laurence and I have both had informal contact with Rebecca Garcia at DEFRA to clarify minor points about the Breeding Standard.

For Chris: That the Standard is good practice not legal minimum.

For me: That the Standard is a document to be used as the basis for further discussion with the specific aim of producing a single document and standard for all types of dog. The covering letter to Lord Taylor, the then minister, said that the AC Standard would be used as a basis for a unified approach. Prof Bateson will chair a working party charged with producing a common Standard.

Other specific issues related to the Standard which Defra needs to address are as follows:

Permanent Identification: If permanent identification is considered so crucial for farm animals, should this approach not also be extended to dogs where more can be achieved, not least the potential for restoring lost and stolen dogs to their owners?

Would permanent identification of individual dogs (linked to a central 24 hour database) and registration of individual breeders using, in simplest form, a breeder registration number be the best way of making a start on the issues of irresponsible breeding?

Whether the minister considers a parallel to the Racing Greyhounds (England) Regulations whereby allowing a breeder to be inspected by a UKAS accredited body would exempt them from local authority inspection and licensing? And if so, does he consider the Standard would be appropriate for such an accredited body?

[For information: The Welfare of Racing Greyhounds (England) Regulations 2010 introduced under the Animal Welfare Act 2006 set out the legal minimum requirements to protect racing greyhounds’ welfare. In doing so the Regulation requires an annual inspection of the racetrack by the local authority similar to that required by local authorities for premises under the Breeding and Sale of Dogs (Welfare) Act 1999. However a significant section of the greyhound racing industry is already regulated by the Greyhound Board of Great Britain (GBGB). Their primary role is to ensure the integrity of racing to support the gambling industry and the welfare of the dogs is secondary. The Regulation accepts that dual regulation is unnecessary as long as the GBGB regulates to a standard approved by the United Kingdom Accreditation Service (UKAS). The Regulations therefore exempt greyhound tracks from local authority inspection if they are regulated by GBGB. There is the potential for an analogous situation with dog breeding, if there was a body accredited by UKAS that was inspecting to a standard approved by government. The Advisory Council Standard could form the basis of such a process if government accepted it as complying with all current legislation.]

It is likely that the existing breeding legislation would need to be repealed and replaced with a new Regulation under the Animal Welfare Act similar to the greyhound legislation.

October 2012

Prepared 14th February 2013