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To Whom It May Concern,
Re: Breeding and Rearing Code Review and Public Content
Whilst I understand that the proposed Breeding and Rearing Code has come about due to public concern regarding the welfare of breeding animals in large breeding establishments, and I support motions to improve the welfare of all animals, I am deeply worried by the unscientific nature of this proposed Code. Significantly,
1) The Code includes only 18 references.
A Code such as that proposed should be far more thoroughly researched before reaching a consultation stage. Instead, this Code uses 16 papers on a variety of companion animal topics, some which are not even peer reviewed, to reach a conclusion. There needs to be far greater review of the available literature to reach recommendations on further regulation. This review should include articles covering the welfare of breeding animals in a number of contexts, in a variety of breeds and species, while also considering the success of regulation in achieving welfare outcomes in similar circumstances. None of these areas are covered in any of the references currently included for the Regulatory Impact Statement (RIS). Without more research, the proposed Code may be ill positioned to improve animal welfare in Victoria.
2) The significance of the paper by Kustritz (2012) is exaggerated, and its interpretation is erroneous.
The review paper written by Kustritz (2012) seems to be the basis of many of the conditions surrounding breeding animals in the proposed Code. However, this is only a review paper. This means that this paper reviews other literature, and is not research in itself. Therefore, calling it ‘scientific research’ (as claimed in the RIS) is erroneous. Furthermore, this review paper has not been peer reviewed (and therefore has no quality control measures) and this paper also has only ever been published in Canine Theriogenology, which is owned by Ms Kustritz herself. In addition, this paper warns against regulation, saying “There is little literature to support many of the recommendations made by veterinarians regarding management of breeding dogs. This limits our ability to guide legislators uniformly and may result in inappropriate legislation or legal findings”. That is, Kustritz recommends against the very actions that have been undertaken when writing the proposed Code. Whilst the paper by Kustritz is a starting point when considering the welfare of breeding dogs, it is not scientific, it is not peer reviewed, it is not independently published, and it recommends in its own text that it not be used in creating regulation. Considering this, it should not be used as the crux of the proposed Code, as it currently is.
Additionally, the paper is often erroneously quoted within the RIS. This raises huge concerns about the validity of the research process undertaken in formulating the Code. For example, the RIS claims that the critical age recommended is for the general health of the bitch. However, the Kustritz paper makes no claims of this nature. Critical age is based solely on bitch productivity and not the welfare of the bitch. Similarly, the RIS claims “Scientific Research [sic] recommends that… bitches should not produce more than five litters”. But the Kustritz paper does not say this at all, instead uses two articles on two breeds of dogs to indicate that productivity decreases after five litters. That is, scientific research shows that productivity decreases after five litters, but not that bitches should not be bred after five litters, and certainly does not make claims on bitch welfare. In these two instances, the RIS is misleading.
However, there are also claims in the RIS that are completely false, such as “the research recommends male dogs are not bred… beyond critical age”, when in reality, Kustritz (and others) do not recommend a critical age for stud dog use at all. Another false claim made in the RIS is “The justification behind these recommendations includes… the general health of the bitch and the increased risk to both bitch and male dog of reproductive failure and diseases such as cancers of the reproductive tract, urethra and bladder.” Nowhere in the Kustritz paper does she link breeding of animals to cancer formation. That is, dogs that are bred are not more likely to develop cancer. Many of the claims in the RIS are erroneous, misleading, and should be immediately rectified, and these changes should then be reflected in the Code to show breeding standards that are actually recommended in scientific research.
3) The paper references nothing on cats.
There is a huge paucity in the literature referenced regarding cats and their welfare. Indeed, the term ‘cat’ and ‘feline’ does not appear in any of the reference paper titles. In fact, there are more papers referenced from a pig journal than there are articles on cats. It is inconceivable that the proposed Code could ever make recommendations on cat welfare without using references actually pertaining to cats. This is a huge oversight and it reflects the lacking process in developing the proposed Code, especially in regard to the recommendations made on breeding cat welfare.
Due to these clear inaccuracies in the RIS’s interpretation of the limited references, I argue that the proposed Code is not significantly informed to accomplish the desirable welfare goals. Potentially, this Code could therefore be a huge waste of government resources. Thus, I do not support this Code until it can be more comprehensively supported by academic literature. I argue that relevant literature needs to be comprehensively reviewed in order to create an informed code that accurately reflects current animal welfare understandings, including its regulation. To do any less is to potentially compromise the credibility and impact of significant animal welfare legislation.
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