05/9/13

Breeding and Rearing Code in Victoria – Online Submission

Commenting on the Victorian Breeding and Rearing Code was an exhausting process! Indeed, I am still in the process of writing a response to email to the DPI. (There email is animal.welfare@dpi.vic.gov.au (open in email client) if you’re looking to do the same.)

I wrote about the problems with the proposed code yesterday.

Making an online submission is a very intensive process, but I am very concerned that others may be ‘put off’ from placing a submission because of the process! Please don’t! Below I have included my submission which may help you form your own.  Each response is limited to 1000 characters (due to the nature of the online form). You are welcome to use the entirety or bits of this response in your own.

 

1. Introduction

I believe that all Options, A-E, are unlikely to meet the objectives outlined in the RIS.

The welfare of breeding dogs and cats (and their offspring) is governed by the Prevention of Cruelty to Animals Act. If the welfare of animals in breeding establishments is of concern, then the act should cover relevant penalties for these welfare breeches, or an Animal Welfare Act introduced.

The proposed code does not offer sufficient consumer protection from “poorly socialised puppies”. While the code makes some attempts to describe socialisation experiences, they are no where near adequate for developing ‘well socialised’ puppies during the critical socialisation period of 4 weeks to 16 weeks.

While I believe the cost of $14.75 is not unreasonable for consumers to absorb, it is unrealistic to say that paying such a cost would ‘ensure’ better practice. Any practice compromising the welfare of breeding animals should be dealt with under existing or new Acts.

 

1. Background

This proposed Code has come to fruition due to concerns about animal welfare. If this is the case, then why is the Code only focussed on the welfare of a very small group of fertile animals? Particularly, why does this proposed Code not apply to greyhound breeders? If the practices defined in the Code are best practice, then they should apply to all animals and not just a select few meeting the narrow scope of a ‘breeding establishment’.

The ‘microchip in advertisements’ amendment has simply seen animal-sellers list any microchip number in their advertisements instead of the microchip of the animal actually for sale.  Authorised officers are inefficient in enforcing microchip listings in advertisements, and also the permanent identification of animals before sale (as seen in the Domestic Animals Act), then I am pessimistic regarding authorised officers’ ability to enforce the complexities of this proposed Code.

 

2. The problem and the policy objective

Case Example 1 shows how Victorian animals are suffering due to a non-existent Animal Welfare Act.  Animals need an Act to ensure their welfare, and not simply prevent them from suffering cruelty.

However, the POCTAA does allow for individuals to be prosecuted in veterinary problems are not sought. Therefore, the common veterinary problems, as listed here, occur in violation of the Act and should be prosecuted as such.

This proposed Code is well advised to amend the process for selling unhealthy animals (i.e. they can be sold with a veterinary certificate), to make attempts to ensure the socialisation and handling of young animals, and become inclusive of small scale breeders with dogs living in home environments. (Though, in regard to the latter, the Code is still lacking in some ways.)

 

3. Identification of viable options

Considering the only reference regarding breeding animal health used in justifying the code is that written by Kustritz, I presume that by “scientific research” you are referring only to the work of Kustritz. If this is the case, the conclusions reached from the her review are hugely flawed.

Kustritz paper is not ‘scientific research’, it is a review of evidence, and it is not peer reviewed (i.e. it has no quality control measures undertaken before it was published). The paper explicitly states, “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.”  The author themselves does not recommend that the review be used in guiding legislation. Using this paper to substantiate this code is a clear perversion of the conclusions made within the paper itself.

 

4. Assessment of costs and benefits

The costs and benefits of each option are only relevant if they are going to be sufficiently enforced.  The perceived benefits listed are optimistic, at best, of enforcement and compliance with the proposed Code.

 

6. Evaluation Strategy

This evaluation strategy uses indicators that apply to animals sourced from all breeders, including those exempt from the code.  This means that backyard breeders’, small scale ANKC breeders, and greyhound breeders all still able to produce and own unhealthy animals, and there will be consistent detection of ‘poor animal health’ and consistent consumer complaints.

 

7. References

There is shockingly little research described in this list of references, and very little on breeding dogs. Indeed, there is as many references on breeding dogs as there are papers published by a pig journal.  Furthermore, there is no reference listed for cats and their welfare.  For a Code that will have such significant and far reaching implications, it is important that it is substantiated by scientific evidence. Currently, it seems that the Code is more opinion than science based, which is hugely concerning for companion animals in the state.

 

2 (10). Euthanasia

This section is titled euthanasia, which is the destruction of animals that are injured or diseased. It concerns me that, at the end of this segment, there is a clause regarding rehoming animals, which seems to imply that euthanasia of surplus animals is permitted in the Code. This certainly does not seem to be in the best interest of animal welfare. Indeed, if a facility is producing animals that are ‘unsuitable’ to rehoming, then they are clearly housing, socialising and managing animals in a way that is not synonymous with their welfare.

 

3. Records

The record keeping process described within this section is excessive and burdensome for small businesses with few animals.

 

3 (3) c. Individual animal identification

This segment is irrelevant to small businesses who have animals in their house and yard, and not penned or caged.

 

4. Sale of animals

The requirement for animals to be sold with a complete health check signed by a veterinarian is perhaps the best element of this entire code. It should be a requirement for all animals sold, and not just those being sold with individuals who fall under this code.

The segment saying “Animals must not be sold before 8 weeks of age” should be “Animals must not permanently leave the business premises before 8 weeks of age, except upon veterinary advice”.

 

5 (1) Nutrition

These nutrition guidelines require dogs to be fed from a food receptacle, which does not seem to be in the best interest of animals considering the enrichment activities that animals could engage in if fed in alternative ways.  For example, if all meals were provided in enrichment activities such as being provided in “Kongs”, from boxes, with food hidden in their pens and exercise yards, then this would be more desirable in terms of animal welfare.  Indeed, I suggest that feeding simply from a food bowl is poor practice.

Though there is a risk of hydatids in offal, an internal parasite treatment regime close to eliminates this risk..

 

5 (2)(b) Dogs over 3 months of age

I strongly object to the proposal that a vet will be required to sign off on the behaviour/temperament of a dog to determine its suitability for breeding.  Performing assessments on behaviour is a highly controversial area as it is difficult to get an accurate picture of a dog’s behaviour in a limited window of time.  While a vet may be best in determining the health of an animal for breeding, the temperament and behaviour is best assessed by an owner who spends long periods of time with their animal and sees them on a daily basis and in a number of settings.

 

5 (3)(a) Heritable defects

Breeding healthy animals is important, but it is possible for animals affected by particular genetic disorders to not pass this condition on to their offspring, depending on the inheritance of that condition. For example, dogs affected with CEA can be bred to dogs clear of CEA (as shown by DNA tests), and produce dogs that are not symptomatic of CEA.  There are several conditions in dogs that are inherited in this way, and so dogs who have the disorder can produce healthy animals with careful mate selection.

Considering this phenomena, it is unclear why this Code requires affected animals to not be bred from. Animals should only not be bred from if they have an heritable defect that will be passed on to their children, and this can be controlled by mate selection, and so an affected animal can produce non-affected children.

 

5 (3)(b) Males

The requirement for stud dogs to not be used for more than 6 years at stud is one of the most heinous suggestions in this entire Code. This Code attempts to protect consumers from unhealthy animals, and part of this is having animals that stay healthy for a great number of years. The best resource for breeders in producing animals that are healthy is to use stud dogs that are healthy into their senior years. For this reason, many breeders use stud dogs who are 7 years old or older, hoping to be produce puppies with genes for longevity. Like human men, male dogs stay fertile for a great number of years and suffer no ill effects from copulating as a senior. There is no logical welfare reason to prohibit the use of older stud dogs and, indeed, to do so actually seems contradictory to the goals of the Code.

 

5 (3)(c) Females

These restrictions on breeding bitches, especially for large breed bitches, makes it very difficult for breeders to produce puppies. If you consider large breeds do not mature before 2 years, and may only cycle ever 1 year, then breeders are restricted to a maximum of 3 litters per bitch. This is further complicated by Dogs Victoria guidelines that restrict a bitch from being bred every season.  If the bitch in question is particularly desirable to parent, in terms of her health scores, or the genetic diversity she offers, this restrictive breeding code is even more heinous.

I think it is again important to note that the Code of Practice for the Operation of Greyhound Establishments put none of these restrictions on the breeding of greyhound bitches.  If these guidelines are in the interests of animal welfare, why do they not apply to all breeding bitches? Alternatively, if they are not in the interests of animal welfare, then why have they been included in the code at all?

 

5 (3)(d) Retirement

There are numerous negative health implications associated with desexing, and it should be no means be made mandatory for all retired breeding animals.

There should be no option for the euthanasia of animals that have been retired from breeding.  Business owners must be obligated to rehome any animals they no longer wish to have on their premises.

 

5 (3)(f) Whelping

Bitches that are pregnant are not sick and do not need to be isolated from other animals due to their pregnancy. Indeed, bitches, who are social creatures, may be stressed by being removed from their companions.

 

5 (4) (a) Exercise and enrichment

This table is a great starting point for the type of experience puppies and dogs should be receiving.  However, it should also include a requirement for puppies from 4-16 weeks of age to be taken off the premises and be exposed to many sights, sounds, and smells in ‘the real world’.  This could include things like exposure to traffic, to many different types of people, to noisy environments like busy shopping environments, and ‘day to day’ things like riding in a car.

 

5 (4) (b) Socialisation and handling

This table is a great starting point for the type of experiences puppies and dogs should be receiving.  However, puppies should be removed from littermates for short periods from 4 weeks of age to learn to be independent. From 4-16 weeks of age, puppies must interact with compatible adult dogs, not just ‘where practical’.

 

5 (5) (a) Disinfectant and hygiene

The use of disinfectant in this code is excessive for small or home breeders who have dogs living in their home.

 

5 (5) (c) Tethering

Considering that tethering of dogs is known to increase aggression, it should not be permitted in order to improve public safety.

 

5 (5) (d) Small businesses

While I like that this code acknowledges that dogs sleep inside in small businesses, steam cleaning of carpets every 6 months seems excessive and militant.

In regarding to whelping and lactating areas, some of the requirements are over prescriptive given the individual nature of bitches and the methods they choose to parent.

It should be up to the owner to determine if bitches should have space to remove herself from the puppies, as some bitches will choose to abandon their puppies if given too much space.

Furthermore, some bitches choose to co-parent litters, which reduces strain on each individual bitch and can aid in preventing some problems like milk fever. The Code in its current form would prevent such an event from occurring.

Additionally, providing a heat source should be on a case by case basis and dependent on the weather at the time.

 

5 (5) (e) Large businesses

Entire male and female dogs should be allowed to be housed and exercised together. Indeed, the most complimentary temperament pairings are normally mix sexes.

In regarding to whelping and lactating areas, some of the requirements are over prescriptive given the individual nature of bitches and the methods they choose to parent.

It should be up to the owner to determine if bitches should have space to remove herself from the puppies, as some bitches will choose to abandon their puppies if given too much space.

Furthermore, some bitches choose to co-parent litters, which reduces strain on each individual bitch and can aid in preventing some problems like milk fever. The Code in its current form would prevent such an event from occurring.

Additionally, providing a heat source should be on a case by case basis and dependent on the weather at the time.

Please take the time to submit your own comment. It is important this Code does not get through in its current format, and it will be dependent on public comment.

05/7/13

Breeding and Rearing Code Review in Victoria

It will soon be easier to be a gun dealer in Australia than a registered breeder. (source)

Just one of the comments made regarding the DPI’s current Breeding and Rearing Code Review, currently up for public comment.

Like other codes, this one has a big emphasis on running dogs in kennel environments, puts arbitury numerical values to determine animal welfare, and has elements of mandatory desexing. In other words: Legitimising big breeders at the expense of small breeders.

Screenshot of the DPI Victoria's website.

 

Missing the Problem

Code is for anyone with 3+ fertile bitches or queens if they’re not “registered members of an Applicable Organisation” or reigstered breeders with 10 or more fertile female dogs or cats. As a ‘registered member of an Applicable Organisation’, in some ways, I am grateful for the exemptions, but in other ways, they don’t really go far enough. Greyhound breeders and backyard breeders are exempt and, debatably, these are the breeders with the biggest ethical problems associated with them (read “Incentives to breed more greyhounds?!“).  Thousands of greys are killed each year for not making the grade, and then backyard breeders are untraceable and arguably contribute to the impounds of pounds (considering the abundance of staffy type dogs in pounds).

Further, this is complicated by the lose terminology. What do I have to do to have 3+ or 10 fertile bitches? Do they have to live with me? Or do I just have to own them? How is ‘fertile’ defined? Is it a bitch that is not desexed? Or a bitch who has had at least one heat cycle? Or a bitch that is less than 12 years old?

On one hand, it’s ‘good’ that the code only applies to certain groups.  But that then poses the question: If this code is really in the best interest of animal welfare, why doesn’t it apply to all breeders?

 

Getting Sexy with Vets

I don’t know who wrote this draft, but I’m pretty sure they must have a vested interest in vet profits! Vets need to sign off on everything in this review – from diet, vaccinations, and parasite control, to whether the dog is appropriate to be bred from, to a ‘health management plan’ and a retirement plan for the dog. What the! Surely the best person to make decisions for a dog is the owner of the dog.

Furthermore, for those who choose a more holistic method for raising dogs (raw diet, limited vaccination protocals, etc), then they will have close to no chance to raise dogs through the methods they choose, as close to no vets advocate raw diets or 7 yearly vaccination protocols. (Indeed, the code says dogs cannot be fed offal, fullstop.)

While vets might be initially excited about how this might translate into income, surely they are not the best judge for my dog’s temperament. For example, most vets indicate a dry/kibble diet, but my current litter have soft stools on dry, so they’ve been eating a raw diet with better stools. I had a puppy with a vaccination reaction at 7 weeks so I decided (against vet advice) to only give her one vaccination at 18 weeks instead of a series of puppy shots. Here I am making individual decisions based on my experience, and sometimes against vet advice, for the welfare interests of my dogs.

I spend hours every day with my dogs, so I am going to bet that my evaluations are a little more informed than the 15 minutes that a vet can spend with my animals during a consult.

 

Reeks of Mandatory Desexing

Like other schemes, this one has elements of mandatory desexing, saying things like: “All retired breeding animals must be desexed”. I’ve already talked about the fallacy of mandatory desexing and the fallout of mandatory desexing schemes.

 

You’re Running a Business

This is more a terminology issue, but I very much reject the use of the term ‘business’ to describe all dog breeding.  The term ‘business’ implies profits, and many ethical breeders do not make profits and so are not really a ‘business’.

Furthermore, this code defines ‘large’ or ‘small’ business based on how many ‘fertile’ animals you own. Shouldn’t a business’s size be determined by its profit, not its capital?

 

Restrictions on Breeding Ages

This code puts a limit on the maximum breeding age of a dog, and bitches can only have 5 litters or less in their lifetime. Both these decisions are hugely prohibitive.

Firstly, using old stud dogs is good! We need to breed healthy dogs with longevity, and there’s no better way to know if a dog is healthy and long lived that waiting for him to live a long time. In fact, I deliberately look for old dogs to use at stud for that very reason (read an old puppy announcement).

Additionally, if we have a bitch that is exceptional, particularly in health, then having 5 or more litters may be a good thing. For example, if we had a bitch with 0/0 elbows and 0/0 hips, then I’d love her to produce as many offspring as possible, especially if the breed average is 6/6 or 8/8. However, the maximum breeding ages listed are hugely prohibitive for large breed dogs, with 5 years being the maximum. Large breeds often don’t reach maturity until 3 years, and so, with this code, bitches are limited to only 2 ‘breedable years’, or 2 litters. As I mentioned, for an exceptional bitch, this is not many litters, and doesn’t leave much room for error – if she is mated and she misses, you then have 18 months to get all the puppies you can out of her.

 

Good: Some Interest in Socialisation

One of the good things about this code is that it is trying to mandate some socialisation and habituation with puppies, as seen in “Table 3” and “Table 4” in the document. Of course, it’s close to impossible to enforce this, but it’s nice to think someone is thinking about it.

The only downfalls is that puppies “must remain with mother & other litter mates until 6 weeks of age”. For those of you who read my ‘Puppies 2012 Series‘, you will know that my puppies get out and about (without their mother and litter mates) from 4 weeks of age, as that is when the critical socialisation window starts. Why would you legislate against this? Furthermore, the socialisation table describe doesn’t allow puppies to socialise with other dogs until they are 8 weeks old – again, meaning that a big chunk of their socialisation window is missed.

It’s nice to see some attention given to socialisation in this document, but it is still somewhat misguided, and pretty much impossible to enforce the good bits, even if we wanted to.

 

Lack of Privacy

Like other codes, ‘business’ must be recorded keeping nazis.  The concerning things is, this records must be available to authorised offices upon request, and must be given to council if the ‘business’ ceases.  This means that Joe-Blow the puppy buyer’s details will be available to certain parties on request and when the business ceases.  Where is the privacy in purchasing decisions? Why does the council, or even the authorised officers, need to know this kind of stuff?

 

Dogs in Clean Kennels Again

Okay, so there’s a good thing about the ‘small business’ and ‘large business’ thing: Large business is required to have pens or yards, while small business doesn’t have to. This is good – better than a lot of similiar legislation that requires pens full stop. Another good thing is this code mentions dogs that sleep inside the house, showing that it is possible for dogs to live in ways other than clean and kennelled.

But then there’s all the normal stuff which is keen on disinfectants and hand washing, even with visitors obligated to wash hands. Not too bad in a kennel environment but if my dogs are just hanging out in my yard, it’s not possible for me to disinfect the lawn.

 

Separate the Dogs, Again

At least! This code allows dogs to run together – an important psychological role for dogs, especially living in kennel environments.

And there are some common-sense regulation in this code: You can’t run dogs together that fight, and you can’t run different sexes together in there is a bitch coming in or in season.

Okay, maybe that’s about it. They ask for bitches to be separated from other dogs two weeks prior to whelping. Presumably, the logic is that the bitch may like ‘peace and quiet’ during this time.  In reality, bitches used to running with a group of dogs are likely to be more stressed by their segregation than anything else. Then, once she has puppies, she has to be able to ‘escape’ them if she chooses to. Theoretically, a nice idea, unless you have a bitch disinterested in mothering and her pups perish when she chooses to ‘escape’ them on a permanent basis.

If you are a ‘large business’, you can only exercise up to 4 compatible dogs together, and they must be in single sex groups. I’m not sure who wrote this code, but they obviously have had very little to do with dogs in the real world – mix sexes are generally more compatible, temperament wise, than single sex groups.

 

Policing?

A lot of the standards in this code are very hard to enforce. If you walk into a facility and the puppies aren’t having their socialisation, then they must’ve had their socialisation earlier that day (says the business proprietor). You walk into a facility and see that there is lamb fry in the fridge, and the proprietor says that’s for his dinner. How can you prove otherwise?

You walk into business and see dogs with red irritated paws from walking on a hard disinfected surface. The dog is receiving vet treatment, but can’t be moved to a different surface because of regulations required concrete and disinfectant. So the dog is obligated to spend a life of irritation due to regulation. But ‘the police’ can do nothing because all boxes are being checked.

(And, quietly, I’d say that ANKC registered breeders who have good records in terms of pedigrees, date of births, and so forth, and so are most likely to be ‘caught out’ if they do breedings out of line.)

 

Why Rescue Groups Should Care

When you have fertile animals come into your care, you will become a breeding establishment. You just need three or more fertile animals to become a ‘business’.  This means that rescues would have to have a vet sign off on everything too, you have to be record keeping nazis, dogs have to be kept in concreted kennels, and you can’t run animals of different sexes together (if you have more than 6). Being a rescue is not currently an exemption in this code. While arguing for exemption may be possible, I would still ask:  If this code is really in the best interest of animal welfare, why doesn’t it apply to all breeders?

 

Other Bits

Once I had a dream that I walked into the backyard and my stud dog, Chip, was mating two of my bitches at the same time. A very funny dream, which I thought was quite mythical – until this code came out saying “Male dogs must not mate with more than 1 female dog at a time”. Is there dogs out there that have a magical double-headed penis for performing two matings at the same tie? Is there so many out there that we need to legislate against their impressive copulation style?

The DPI has a pretty nifty idea with their own breeding training being recommended every 3 years. And by ‘nifty’ I mean good for fundraising.

The code requires, “Animals must not be sold before 8 weeks of age”. I’m guessing the code actually wants to say something like, “Animals must not permanently leave their place of whelping and rearing prior to 8 weeks of age”. A bit of an oversight, as many breeders take deposits and so ‘sell animals’ before 8 weeks of age.

The code specifies, “A heat source must be provided for puppies in/over their bedding”. The code doesn’t specify that, if the weather is 40C or higher, that this would be unnecessary.

 

What can you do?

Right now this legislation is only ‘okay’ because registered breeders are exempt (unless they have more than 10 dogs). But this exemption is very easy to remove. Indeed, I would suggest that the ‘animal righters’ are probably putting in proposals as we speak to have the exemptions removed.

I hope to make a more detailed post before the May 13th deadline, but in the meantime, you can click here to submit comments online.

If you need further inspiration when making a submission:

Read this page on Campaspe Working Dogs (for perspectives from working breeders)

Read this thread on DogzOnline (for perspectives from ‘show breeders’)

04/22/13

Clean and Kennelled: The Future of Dog Breeding

Many animal welfare groups call for legislation that defines what ‘best practice’ is for breeders.  They state that their goals are to eradicate any suffering of animals used for breeding. While I, too, am concerned about the wellbeing of animals, this concern extends to all dogs, and not only those used for breeding practices.  Because of this, I advocate for animal welfare legislation to be upheld nation-wide.  While I certainly want to discourage individuals motivated solely by profit and romantic ideals from breeding dogs, I do not want to see committed, knowledgable and ethical breeders removed from their hobby.

However, this is exactly what dog breeding legislation seems to be doing in Australia.

Puppies, on grass, with two adult dogs: Sin! According to Australian breeders legislation.

Puppies, on grass, with two adult dogs: Sin! According to Australian breeders legislation.

Nationally, here are two significant pieces of legislation regarding dog breeding, though both are only applicable to certain areas.  There is the Gold Coast’s “Breeder Code of Practice” which targets anyone with entire dogs, and, in NSW, there is the “Breeding Dogs and Cats – Code of Practice“, which targets anyone breeding animals.  These codes seem to have been developed in consultation with one another, because they are very similar in a lot of ways. Significantly, both codes have ‘standards’, which are enforceable, and ‘guidelines’, which are just recommendations on breeding animal husbandry.

 

Commercial Breeding Establishments Only

Both the Gold Coast and NSW document is written in a way that obligates people to keep their animals in kennels and concrete enclosures. They define breeding establishments as being purpose built (NSW), the floor as being ‘non-porous’ (GC), that needs to be disinfected weekly (NSW & GC), and run off into a sewage system (NSW).

I know what this is trying to do – it’s trying to stop people with a large number of dogs running in muddy and faeces-laden runs. However, this legislation targets anyone who breeds dogs (NSW) and anyone with an entire dog (GC). This means that people who keep and raise dogs and puppies in their home are effectively illegal.

For example, my puppies are raised in the dining room – an excellent place for puppies to socialise to general household ruckus. However, my dining room was not purpose built for puppy rearing, it is not disinfected weekly (though it is cleaned daily when housing puppies), and it doesn’t have a drain, let alone a drain to a sewage system. This means I wouldn’t, legally, be able to raise puppies in a home environment while in NSW or the Gold Coast. To follow legislation, my puppies would have to be raised in a purpose built enclosure outside or in a shed, something I think is hugely undesirable and indeed detrimental to the psychological development of puppies (it would produce what Ian Dunbar calls ‘Lemon Puppies‘).

Effectively, both these pieces of legislation have made-illegal the practice of raising puppies in a home environment. The alternative is raising puppies in a kennel environment, and that just doesn’t make sense considering what we know on the importance of puppy socialisation. However, considering the NSW legislation also says that puppies “must not be separated from their mother until 7 weeks”, it seems that the legislation has zero interest in producing amicable, sociable, independent, and well-rounded puppies.

 

Dogs Can No Longer Be Crated

Both schemes specify minimum sizes for animal enclosures.  The Gold Coast calls for the dog to be able to move away from its bed to urinate and defecate. This legislation pretty much means that crates cannot be used, as they are smaller than the minimum enclosure sizes specified. Considering the benefits of crate training, why would legislation be introduced to delegalise it?

The minimum enclosure sizes increase for the number of puppies, which makes sense, except it doesn’t define an age. This means they require a bitch with puppies to be housed in a minimum area of 3.5 metre square area (NSW). I often lock a bitch in a 1 metre square area with their puppies during the first week or two, because otherwise I find bitches neglectful of their puppies. It, of course, depends on the individual bitch, but with legislation such as this in force, I can’t make decisions based on these individuals. I am serious when I say that not locking Clover in with her puppies would almost undoubtly have resulted in puppy death – but this would be contravening the legislation in NSW that requires bitches to be able to escape their young. How is that in the best interest of animal welfare?

 

Co-Habitation of Animals is Foggy

Both pieces of legislation are a bit unclear, but seem to suggest that animals should be isolated from one another.  The Gold Coast Scheme asks for enclosures to be “disinfected between animals”, which implies that two animals may not share a run.  The NSW legislation requires bitches in season to be “isolated from other animals”, a truly bizarre request. I wonder if the writers of the legislation realise that bitches require an entire and fertile male dog to get pregnant, so can run with any dog that doesn’t fit that description and avoid pregnancy?

In kennel situations, having a dog companion is important to enriching the day-to-day life of that dog. Furthermore, for young puppies, having dog-dog play is important for developing bite inhibition. And, again, for the hobby breeder at home, running dogs together is a natural part of dog ownership. It doesn’t make sense that people with two or more pet dogs can run them together, but having two or more breeding animals means that this is no longer an option.

 

Elements of Mandatory Desexing

I have already discussed the implications of mandatory desexing schemes, and both these schemes stink of mandatory desexing.  The Gold Coast scheme even says “A permit condition may require the holder of the permit to desex an entire female animal which the holder of the animal has retired from breeding”. Yuck! This comes back to considering the well being of individual animals (is desexing really in their best interest?).

 

Arbitrary Limits for Animal Welfare

Both schemes have, with no real basis, decided that numbers determine bitch welfare. For example, in the Gold Coast, a bitch is clearly compromised if she has more than 4 litters, and if she is older than 6 years old.  In NSW, a bitch can’t be mated on their first cycle, regardless of their age.  Of course, I wouldn’t advocate breeding a bitch at 6 months, but many bitches don’t come in until they’re 18 months or older. What hazard does pregnancy in a bitch’s first cycle cause?  While these strange numerical scales are probably good guides in general, they are by no means indicative of animal welfare.

 

Double Standards

I find it ironic that the Gold Coast scheme says that “Euthanasia of cats and dogs is only acceptable for the relief of incurable illness, chronic pain, and suffering”, yet the RSPCA of QLD euthanises 30% of dogs and puppies that come into their care and 44% of cats and kittens (according to their 2011/2012 annual report).  Why are breeders, whose ‘job’ is to breed animals, held to a higher standard than shelters, who’s job it is to shelter and protect them?  Furthermore, the scheme calls for secure enclosures, yet the RSPCA QLD admits to having 15 dogs escape throughout the course of the year (again in the 2011/2012 annual report). Can you say “what the”?

 

Weird Inclusions

Some parts of the scheme are just plain weird. In the Gold Coast you are allowed to tether animals (known to increase aggression in dogs), but you can’t microchip them before 8 weeks of age…

In NSW, breeders need to record keep everything, have emergency procedures for evacuation documented, and have functioning fire righting equipment. All very excessive for a home, hobby breeder.

 

Puppy on grass! Legislation wants this banned!

Puppy on grass! Legislation wants this banned!

 

So what does this mean?

While animal welfare groups who push for breeder standards have good intentions, so far, no legislation has been produced that does anything other than legitimise the practice of kennelling dogs and raising puppies in kennel environments. While I would not argue that all kennel environments are ‘bad’ for dogs, they certainly fall short of socialisation that can be achieved in a home environment, and so fall short of producing the best puppies that they can.

Breeders have a responsibility to care for the wellbeing of their animals – but disinfectant, concrete floors, and isolated animals isn’t necessarily indicative of animal welfare.  Dog welfare is as much as the psychological aspects of keeping and raising good dogs: Selecting appropriate parents with good temperaments, providing enriching environments, socialisation and toilet training of puppies, and monitoring their dogs for life.

If socialisation was mandated, I would be all for it. If breeders were responsible for their animals for life, that would be awesome.

Making breeders keep their animals in kennels instead of houses is just backwards to everything we know about dog welfare.

 

Further Reading:

Can Breeders Breed Better?

The Sin of Breeding Dogs

The Fallacy of Mandatory Desexing

What is the answer (to puppy farms)?

 

 

01/12/13

DO SOMETHING! Make a submission!

Currently, the South Australian government is seeking submissions on companion animal welfare (specifically dogs and cats).  That is, they want to know what legislation could be introduced to improve animal welfare and reduce euthanasia in shelters.

You need to act before the 16th of January 2013.

You can find more details on the submission process on the Parliament of SA website.

Below, I am providing both a summary of my submission, and the body of my submission, too. Though I welcome individuals to write a submission and use mine for inspiration, I hope that you add your own personal touches to the submission, and don’t just take mine ‘word for word’. (Though I personally don’t have a problem if you do – it’s just less powerful if you do!)

If you’d like to download the submission, you easily can: download selectcommittee.pdf

Update as of 16th January: This is the submission I actually made: In Response to the Terms of Reference

Otherwise, below is the document practically copied and pasted into this blog entry: Continue reading

12/3/11

National BSL? Say no!

Photos © Ruthless Photos

Here I go again!  If you have not sent letters to Brendan O’Connor or John Rau rejecting national BSL, click here to see past letter proformas.

If you have, good, now I’ve got another letter for you to send.

This letter I have tailored to be sent to Jay Weatherhill (SA Premier) and Paul Caica (minister for sustainability, environment, and conservation).  I also sent it to my local member.

It is (loosely) based on CommunityK9’s letter, which I also suggest you look at and consider sending. (If you’re not in SA, they have some recommendations on who you should be contacting. I’m a bit of a politics failure, so their suggested recipient list is a great help.)

You might even want to use bits of mine and bits of their’s.  I don’t mind. As long as you send a letter, I’m happy!

So, without further adieu, here’s the letter to be sent to Jay Weatherill (via vaughan.julienne@dpc.sa.gov.au) and Paul Caica (minister.caica@sa.gov.au). Continue reading