05/9/15

My Say: Proposed Breeder Code of Practice SA

(This is post two in a series of four blog posts on proposed changes to dog laws in South Australia. Post One: Summary. Post Three: D&CMA. Post Four: Mandatory Desexing.)

Submissions on the Government’s proposed changes are due by the 29th of May 2015.

In making a submission, you can follow the online form through the YourSay website, or by:

Emailing: dogandcatreforms@sa.gov.au

Snail mailing:

Dog and Cat Reforms
Conservation and Land Management Branch
Department of Environment, Water and Natural Resources
GPO Box 1046
Adelaide 5001

The YourSay website provides a copy of the proposed Breeder Code of Practice and also a FAQ document. I have uploaded both of these documents to this blog, for historical purposes.

First, let’s consider the online survey. This online survey asks for your feedback on a number of questions, and then a field for further comments. Below, I have listed each question and the response I provided. You are welcome to use my responses in their entirety or in part. You may find it useful to consider these questions in advance and save your responses to a Word document or similar, to avoid the risk of losing them in case of website error.

 

 Survey Question One

· Are the definitions used in the draft Breeding Code clear?

· Do you agree with having standards that set the minimum requirements and are legally enforceable?

· Do you agree with having guidelines that are above the minimum requirements (standards) and are not legally enforceable?

6. Do you support the proposed interpretation and definitions?

While the definitions of the Breeding Code are clear, I do not agree with the notion of a Breeding Code of Practice in the first instance. If the standards outlined in this document are genuinely in the best interest of animal welfare, then they should be applicable to all animals, not just those used for breeding.

Further, I do not agree with having guidelines that are not legally enforceable, as they are superfluous to the goals of the document. That is, it is illogical to introduce guidelines that are known to be not legally enforceable and an optional extra.

Additionally, even if the proposed Breeding Code was to ‘go ahead’, there are many proposed standards that are inappropriate. For example:

*In general, the standards require excessive record keeping.  For example, it is incredibly burdensome to expect a small hobby breeder to have all the details listed, written and stored for 5 years, for every dog ever in their care. Additionally, the requirement for breeders to have an isolation area is inappropriate and burdensome to small hobby breeders.

*Standard 5.1.1.3 is vague and subjective, requiring animal housing to be designed in a way that facilitates ‘good health’ and ‘minimises risk of disease transmission’.

*Minimum sizes for dog housing prevent the use of crates as crates are below the minimal standards specified. Crates should not be banned as they help train appropriate toiletting, help animals learn to cope with transport (e.g. they learn to be crated prior to transport), and are often spaces that dogs enjoy and seek out.

*Standard 6.1.1.4 requires animals to be isolated from others in a number of circumstances that have no scientific basis. For example, bitches in season have to be isolated from other animals. There is no need for this to occur. Additionally, many bitches will co-parent litters (e.g. two bitches lactating for one litter), and this standard removes the ability for breeders to be allow bitches to co-parent in this way.

*Standard 6.3.1.6 requires bedding to be disinfected weekly. This is well beyond the normal practices of pet owners, and may actually cause resistant-bacteria to formulate in the animal’s environment.

*Standards that vary for droving or animals used for stock control weaken this legislation. If this is ‘best practice’, then it is best practice for all dogs, not just those used in pet settings.

*Standard 7.3.1.1 requires (uses the word “must”) animals to be euthanised if a vet suggests it, and includes behavioural reasons as a suitable reason for euthanasia.

*Standard 8.1.1.1 requires animals are not sold before 7 weeks, yet many breeders have waiting lists where puppies are sold before they are even conceived, born, and most times before 7 weeks. This acts as insurance for both breeder and puppy buyer.

*Standard 8.1.1.4 requires animals that have health issues are not sold – effectively requiring breeders to keep the animal, kill the animal, or give it away. Instead the section should, at the very least, be changed to “No animal suspected of suffering a significant illness, injury or disease (including congenital disease) must be sold without full disclosure of this condition to the purchaser.”.

*Standard 9.1.1.1 requires bitches are not bred on their first season. There is no scientific basis behind this claim. Bitches are normally fitter and more able to naturally whelp at a young age than an older age. It assumes that all bitches will have their first cycle before 12 months, which is not the case.

*Standard 9.1.1.6/7 requires bedding is changed daily for newborn animals, which could be unnecessarily stressful for a mother and litter.

*Standard 9.1.1.12 requires bitches be able to escape their young. This has obviously been written by an individual who has not whelped an animal that does not want to mother their offspring. If this was a requirement, puppies would die due to maternal neglect. Breeders should be able to manage dams and pups as they best see fit.

*Standard 9.1.1.13 means that puppies can’t begin socialisation/habituation outside the house before 7 weeks unless their mothers accompanies them. This is counter-intuitive to the psychological development of pups.

 

Survey Question Two

The draft Breeding Code proposes legally enforceable standards relating to the responsibilities and competency of staff. These include:

· the person in charge is responsible for compliance with the standards

· the person in charge attends the establishment with sufficient frequency to meet the requirements of the code

· the person in charge must be knowledgeable and competent to provide for the care of animals

· trainees and volunteers are supervised by experienced staff and adequately trained

· facilities are sufficiently staffed to meet the standards

7. Do you support the proposed standards for the responsibilities and competency of staff?

Requirements on what is ‘adequate training’ are vague. However, if there was required learning (e.g. a particular certificate) this would be unnecessarily financially burdensome for small hobby breeders and rescue facilities. The workings of this whole section need to be reconsidered.

 

Survey Question Three

The draft Breeding Code proposes legally enforceable standards for quality management systems. These include:

· a requirement to record information about each animal housed at the facility

· records must be retained for five years after the death or disposal of an animal

· staff must be able to access and present records for inspection

· documented program for the control of insects, external parasites and vertebrate pests at the facility

· documented procedure for swift removal of animals in the case of an emergency

8. Do you support the proposed standards for quality management systems?

These requirements are excessive for a small hobby breeder. To require a breeder to have this information recorded on paper will create a lot of work for breeders for little or no gain in terms of animal welfare. A visual is all that’s required to determine whether an animal is healthy or not, and paperwork is only useful to show a process for animals that are unhealthy.

 

Survey Question Four

The draft Breeding Code proposes legally enforceable standards for animal housing that include:

· requirements for shade, light, ventilation and security

· standards for animals that need to be kept in isolation

· minimum sizes for dog housing and cat housing

9. Do you support the proposed standards for animal housing?

The current proposed requirements practically ban the use of crates. Breeders need to be able to use crates to transport dogs and for assisting in toilet training. Crates are also used for animals after undergoing surgeries. The best way to allow an animal to become habituated to a crate is to use them in ‘everyday life’. Crates need to be legal.

 

Survey Question Five

The draft Breeding Code proposes legally enforceable standards for animal management that include:

· a daily 30 minutes minimum exercise requirement

· a requirement for environmental enrichment

· a requirement to provide a balanced and complete diet

· cleaning and disinfection standards

· transport standards

10. Do you support the disability dog regulation proposal?

I’m not sure that this question marries with the dot pointed list above. However, I mostly support the proposed standards around exercise and environmental enrichment. The proposed standards seems to use disinfectant excessively and some uses of disinfectant should perhaps be switched to guidelines instead of standards, or removed all together.

 

Survey Question Six

The draft Breeding Code proposes legally enforceable standards for animal health that include:

· require daily inspection of animals

· appropriate veterinary treatment must be provided for sick or injured animals

· euthanasia standard

11. Do you support the proposed standards for animal health?

Euthanasia should not be an option for dogs that are ‘impractical’ to train. Instead, owners should attempt to rehome the animal. Attempts to rehome animals should be part of the standards, not guidelines. Remove the use of the word ‘must’ in regard to veterinarian recommendations of euthanasia. Currently, the standards are written in a way that makes euthanasia permissive.

 

Survey Question Seven

The draft Breeding Code proposes legally enforceable standards for the transfer of ownership that include:

· puppies and kittens must not to be sold before they are seven weeks of age

· animals must be vaccinated prior to sale

· free information on the care of animals must be provided at the time of purchase

12. Do you support the proposed standards for transfer of ownership?

Support vaccinations of animals before sale and provision of free information. The information suggested in the guidelines is excessive and, if provided, is likely to not be read by the purchaser. Puppies and kittens should be able to be sold prior to 7 weeks, but shouldn’t leave to their new homes until 8 weeks. This would give consumers confidence (e.g. they are definitely getting an animal), and buyers reassurance (e.g. there is a home for their puppy/kitten at 8 weeks).

 

Survey Questions Eight

The draft Breeding Code proposes legally enforceable standards for the breeding and rearing that include:

· males and females must be physically and mentally fit, healthy and free of disease at the time of mating

· no intentional mating during the first oestrous cycle

· bitches must not have more than two litters in any 18 month period, unless approved in writing by a veterinarian

· queens must not have more than three litters in any two year period, unless approved in writing by a veterinarian

· a requirement to provide additional food and water in certain circumstances

13. Do you support the proposed standards for breeding and rearing?

Support all but ‘no intentional mating during the first oestrous cycle’. There is no scientific reason that bitches cannot be mated during the first season.

 

The second manner in which to respond to this draft code is by email submission. My own is written below, however, if you prefer, you can also download the PDF version.

To whom it may concern,

Re: Dog and Cat Reforms

I am writing in response to the Draft Code of Practice for the Welfare of Dogs and Cats in Breeding Facilities. Including in this response is a table, responding to each individual standard outlined in the proposed Code, the changes that are necessary, and the rationale for suggesting such a change.

It concerns me that this Code at times replicates legislation already seen in The Animal Welfare Act and The Dog and Cat Management Act (or its proposed changes). This complicates animal management in the state, for both those responsible for animals and those authorised persons responsible for upholding the legislation. Many of my recommendations are based on removing this duplication of legislation.

My other suggestions for changes are chiefly based upon removing undue burden for small hobby breeders, standards with no scientific basis, and the ease this document allows animals to be euthanised.

While I have responded to the Draft Code of Practice, it is important to note that the proposal of a breeder registration scheme problematic in itself. There is no evidence that breeder registration results in greater consumer confidence or satisfaction. There are risks that such legislation would cause a decline in ethical breeders (as they may be priced out of the scheme) while unethical breeders who produce many puppies for profit will be most suited to respond to the standards. Further, considering the authorised persons already inadequately enforce The Animal Welfare Act and The Dog and Cat Management Act, I have little faith that any new legislation will be adequately enforced.

Considering this, it would be best for no breeder registration scheme to be implemented. However, failing that, the standards at least need to be heavily reviewed in order to address the issues of duplication, impact on small breeders, lack of scientific rationale, and simplistic euthanasia procedures. Because of the number of problematic standards in this draft code, a second review process needs to be undertaken at the very least.

Regards,

Tegan Whalan

 

Current Proposed Standard Proposed Change Rationale
3.1.1 The person in charge of the facility is responsible for compliance with all Standards within this Code. - -
3.1.2 The person in charge of the facility must be aware of their responsibilities towards the animals in their care. Each day, a person must be in attendance with sufficient frequency to meet the requirements of this Code, and must be knowledgeable and competent to: • provide for the animals’ care and welfare • provide for the feeding and watering of the animals • take reasonable steps to protect animals from distress or injury caused by other animals or interference by people • clean and ensure proper hygiene in the facility • identify signs of common diseases of the animals kept. - -
3.1.3 Where trainees and volunteers are engaged by the facility they must work under the supervision of trained and experienced staff. - -
3.1.4 Facilities must engage sufficient staff to meet these Standards and ensure the welfare of the animals being kept. Remove section. Unnecessary. 3.1.1 states that the person in charge of the facility is responsible for complying with the code. Obviously, this involves employing staff to meet the requirements of the code.
4.1.1 The following information must be recorded for each animal that is housed at the facility: • a description which includes: » name » microchip number (if microchipped) » sex (including whether desexed) » breed » colour » the pedigree registration number (for purebred animals) of owned and leased animals » distinguishing features » any special medical and dietary requirements • the history of the animal which includes: » date of birth » the date of acquisition/arrival » vaccination status » details of preventative and veterinary treatment, for example routine husbandry procedures such as worming or parasite control » details of medical history » any genetic or other health testing undertaken • method of disposal of the animal which includes: » the date and details of the sale or give away » if animals are euthanised the date, reason and method for euthanasia » if the animal died, the date of death, whether or not a necropsy was performed and the cause of death (if known) • if the animal is leased: » the name, address and telephone number of the owner or lessee » the name and contact telephone number of the veterinary practitioner who normally attends the animal. Remove section. Record keeping outlined here is extensive and burdensome for a hobby breeder.
4.1.2 Information which details each litter bred must be recorded and must include: • the name and microchip number of both the dam and the sire (if microchipped) • the date of mating(s) • the date of whelping or queening • identification details for each animal within the litter including any abnormalities or deaths. - -
4.1.3 Records must be retained for no less than five years after the death or disposal of the animal and all staff must be able to produce the records at the request of an inspector under the Animal Welfare Act 1985. Remove section. Record keeping outlined here is extensive and burdensome for a hobby breeder.
4.1.4 The facility must have a documented program in place to control insects, external parasites (including fleas, lice, ticks) and vertebrate pests (for example rats or mice). This program must be kept at the facility and all staff must be able to produce or access it and must be familiar with its content. 4.1.4 The facility must have a documented program in place to control insects, external parasites (including fleas, lice, ticks) and vertebrate pests (for example rats or mice), if evidence of such parasites or pests are sighted. This program must be kept at the facility and all staff must be able to produce or access it and must be familiar with its content. Unnecessary for facilities to have a documented program of parasite and pest control if the facility has never witnessed the parasites or pests.
4.1.5 Each facility must have a documented procedure for the swift removal of animals from the facility, in the case of emergency. This procedure must be kept at the facility and all staff must be able to produce or access it and must be familiar with its content. Remove section. Record keeping outlined here is extensive and burdensome for a hobby breeder.
5.1.1.1 Vehicles, caravans, portable crates and the crawl space under any dwelling must not be used as permanent housing. Unsure. Currently unclear what ‘permanent housing’ definition is.
5.1.1.2 Breeding facilities must have a clean and adequate water supply, sufficient to meet the daily requirements of the animals. Remove section. An individual is already in violation of the Animal Welfare Act if they fail to provide an animal with water.
5.1.1.3 Breeding facilities must be designed, constructed, serviced and maintained in a way that: • provides for the good health and wellbeing of the animals • minimises the risk of the transmission of infectious disease agents • minimises the risk of escape of animals • Minimises the risk of injury to animals and humans Unsure. Section is vague, subjective, and unenforceable.
5.1.1.4 Animals must be provided with protection from rain and wind, direct sunlight or other adverse weather conditions and must be provided with clean, dry, dedicated sleeping areas. - -
5.1.1.5 If a facility houses both dogs and cats, cat housing must be sufficiently distant or otherwise isolated from dog housing to minimise the stress to cats created by the sound, sight or smell of dogs. - -
5.1.1.6 Housing must meet the minimum sizes shown in Tables 1 and 2 below. These limits do not apply to animals being temporarily housed while undergoing treatment or being transported for a disease or injury. 5.1.1.6 Housing must meet the minimum sizes shown in Tables 1 and 2 below. These limits do not apply to animals being temporarily housed. (Section: “while undergoing treatment or being transported for a disease or injury” removed.) As the code is currently written, crates have been banned. Crates are important for confining dogs for a number of purposes, and are often spaces that dogs deliberately seek out for rest. As dogs are often crated during medical treatment or transport, a familiarity with crates is important to minimize stress at these times. Crates need to be permitted and the only way to do this is to make changes to the housing sizes shown.
5.1.1.7 Animals: • must be provided with sleeping areas that have clean, hygienic, dry bedding, appropriate to the species and breed, sufficient for the number of animals held, and sufficient to insulate them from the floor • must not be in extended contact with wet floors • must not be kept exclusively on wire flooring. - -
5.1.1.8 Cats must be provided: • with a suitable box each in which to hide or sleep • a litter tray that is at least 1.2 times the length of the cat and that contains a sufficient depth of material such as commercial cat litter, sawdust, shavings, sand or shredded paper. - -
5.1.1.9 An area must either be available at the facility or at a veterinary hospital where animals can be kept in isolation. There must be documented and demonstrable biosecurity measures in place prior to use. Remove section. Excessive demands of small hobby breeders to have an isolation area, and it is excessive to require vets to provide written documentation of their availability of their facilities for isolation.
5.1.1.10 Animals known or suspected to be suffering from a significant infectious disease or severe injury must be taken directly to where they can be kept in isolation unless it is in the animal’s welfare to be housed with other animals and does not put the other animals at risk. - -
5.1.1.11 A cat isolation facility must be a sufficient distance or otherwise isolated from dog housing to minimise the stress created by the sound, sight or smell of dogs. - -
5.2.1.1 Housing must have a shaded area to escape direct exposure from the sun. Remove section. Already covered in 5.1.1.4.
5.2.1.2 Animals must be protected from extremes of temperature. Remove section. Already covered in 5.1.1.4.
5.2.1.3 The duration and intensity of artificial lighting, if used, must be as close as possible to natural conditions, sufficient to allow thorough inspection and observation of animals and must mimic the prevailing natural light cycles. Animals must be protected from excessive light that is generated from an external source. - -
5.2.1.4 Housing areas must sufficiently ventilated to maintain the health of the animals, while minimising undue draughts, odours and moisture condensation. Unsure. Section is vague, subjective, and unenforceable.
5.2.1.5 Air ventilation devices, if used, must have an air change rate sufficient to distribute fresh air evenly to all of the animal holding areas ; and must have a back-up system in case the system becomes inoperable. - -
5.3.1.1 The facility must be able to be reasonably secured to prevent access by unauthorised people. - -
5.3.1.2 Housing must be fitted with a secure closing device that cannot be opened by the animals held. Remove section. Covered by section 5.3.1.4.
5.3.1.3 Animals must not be able to escape except in circumstances that cannot reasonably be foreseen and guarded against. - -
5.3.1.4 Unauthorised people must not have access to animal holding areas unless under the supervision of a staff member. - -
5.3.1.5 All potential poisons and harmful substances, whether in storage or in use, must be kept out of reach of animals. - -
6.1.1.1 Each animal must be individually identified. Remove section. Covered by proposed changes to the Dog and Cat Management Act that requires all animals to be microchipped.
6.1.1.2 Appropriate measures must be implemented to minimise the risk of distress or injury caused by other animals. This includes supervising animals sharing an exercise area unless they are known to be compatible. - -
6.1.1.3 Animals must be protected from distress or injury caused by interference by people. - -
6.1.1.4 Animals that must be kept in isolation must be kept in a quiet, warm and dry area. In most instances, the following categories of animals must be isolated : • animals with dependent young • animals about to give birth • animals in season, where it is not the intention to breed • sick or injured animals. Remove section. Animals due to give birth should not be kept in isolation, but supervised by someone experienced in whelping/queening. Animals with dependent young may choose to co-parent litters, but requiring them to be in isolation prevents the benefits of co-parenting by effectively making the practice illegal. Dogs are social animals and should not be isolated from others of their species for 2-3 weeks because they are in season. There is no logical reason for these isolation requirements.
6.1.1.5 Animals that may be distressed by the presence of other dogs or cats, or another species (eg. sheep or cattle) must be housed in a manner that prevents visual contact and minimises or reduces their ability to smell the other animals. - -
6.1.1. Long haired animals must be groomed by brushing or clipping at a frequency which ensures that their health and comfort is maintained. - -
6.1.1.7 Adult animals must have the opportunity to exercise for at least 30 minutes daily, unless being treated for significant illness or injury. For dogs, this can be provided through training or work activities, or allowing the animal access to an exercise area to run freely, or by walking them on a lead. Unsure. It is unclear on how an exercise area differs from an area that the animal permanently resides.
6.1.1.8 Dogs must not be exercised in any way which may pose the risk of serious injury, for example attached to a motor vehicle, or unsupervised on a treadmill. - -
6.1.1.9 Animals must receive environmental enrichment, recognising the physiological status and special needs of differing ages and species, to ensure good psychological health. Remove section. Section is vague, subjective, and unenforceable.
6.1.1.10 Animals that are unable to feed themselves must only be kept if there are adequate facilities and expertise is available for artificial rearing. Remove section. Owners are already required to provide animals with “appropriate and adequate” food as per the Animal Welfare Act. Unnecessary to include it in this code.
6.2.1.1 Adequate cool, clean, palatable water to meet the physiological needs of the animal must be available at all times. Remove section. An individual is already in violation of the Animal Welfare Act if they fail to provide an animal with water.
6.2.1.2 Animals must receive a balanced and complete diet which allows them to maintain good health and growth. Food must be palatable and in a form appropriate to the age and medical condition of the animal. Remove section. Owners are already required to provide animals with “appropriate and adequate” food as per the Animal Welfare Act. Unnecessary to include it in this code.
6.2.1.3 Puppies and kittens under four months of age must be offered a sufficient quantity of a balanced and complete diet at least twice daily, unless receiving adequate maternal nutrition. Remove section. Owners are already required to provide animals with “appropriate and adequate” food as per the Animal Welfare Act. Unnecessary to include it in this code.
6.2.1.4 Animals that are co-housed with other animals must be monitored during feeding to ensure they all eat their own share. Remove section. Owners are already required to provide animals with “appropriate and adequate” food as per the Animal Welfare Act. Unnecessary to include it in this code.
6.2.1.5 Spoiled or stale food must be removed and disposed of promptly. - -
6.2.1.6 Food and water containers must be removed, cleaned and replaced immediately if noticed to be contaminated by urine, faeces, vomitus and the like. Remove section. Unenforceable, as an individually can simply claim that the reciprocal ‘wasn’t noticed’ to be contaiminated.
6.2.1.7 Food must be stored to prevent its deterioration or contamination - -
6.3.1.1 Areas housing animals within a facility must be cleaned at least once daily. Unsure. Section is vague. What does ‘clean’ extend to? Poop scooping, hosing, disinfectant, or others? How does this apply to home hobby-breeders who have dogs that run on porous surfaces?
6.3.1.2 Exercise areas must be maintained in a clean and healthy state and cleaned before new dogs are introduced to the area. Unsure. Section is vague. What does ‘clean’ extend to? Poop scooping, hosing, disinfectant, or others? How does this apply to home hobby-breeders who have dogs that run on porous surfaces?
6.3.1.3 Housing must be disinfected regularly. Remove section. Disinfecting regularly is likely to cause the development of resilient bacteria, and have no true purpose in maintaining cleanliness of a facility.
6.3.1.4 Housing, including exercise yards and bedding, which has housed an animal afflicted by an infectious disease must be disinfected and decontaminated with an appropriate product before a new animal is introduced (or the bedding discarded and replaced entirely). - -
6.3.1.5 Housing must be cleaned and disinfected before new animals are introduced or before whelping or kittening. Remove section. Disinfecting regularly is likely to cause the development of resilient bacteria, and have no true purpose in maintaining cleanliness of a facility.
6.3.1.6 Bedding must be cleaned or changed at least once daily if soiled, and disinfected at least weekly. 6.3.1.6 Bedding must be cleaned or changed at least once daily if soiled. (Removed section”, and disinfected at least weekly”.) Disinfecting regularly is likely to cause the development of resilient bacteria, and have no true purpose in maintaining cleanliness of a facility.
6.3.1.7 Food preparation and storage areas, food and water containers and utensils and equipment used in the preparation and provision of food must be maintained in a hygienic state. - -
6.3.1.8 Collection drains must be cleaned daily. Unsure. If no collection drains are present at the facility, how may the owner of the facility meet this element of the code?
6.3.1.9 Litter trays must be checked, scooped and replenished daily - -
6.3.1.10 Litter trays must be changed, washed and disinfected before being allocated to a new cat. - -
6.3.1.11 Litter trays that are saturated with urine must be changed immediately. - -
6.4.1.1 All animals must be transported in a manner appropriate for their species, size and age. Incompatible animals must be physically separated during transport to prevent injury, harm or distress. - -
6.4.1.2 Animals must not be transported in the boot of a car. - -
6.4.1.3 Vehicles must have adequate ventilation and shade, sufficient to maintain good health and to avoid distress. - -
6.4.1.4 All vehicles used extensively for the purpose of transporting animals must be thoroughly cleaned and disinfected after use to minimise the possibility of transmission of infectious disease agents between consignments of animals. This does not apply to a vehicle used to transport a dog that is being used in the droving or tending of stock or is going to, or returning from, a place where it will be, or has been, so used. Remove section. Disinfecting regularly is likely to cause the development of resilient bacteria, and have no true purpose in maintaining cleanliness of a facility. Further, many vehicles are difficult to adequately clean/disinfect due to the upholstery. Additionally, dogs used for stock use should not be exempt from this section of the code.
6.4.1.5 The minimum exercise requirement of this Code (6.1.1.7) applies to transported dogs and cats. - -
7.1.1.1 All dogs and cats must be inspected at least once daily to monitor their health and wellbeing. The person who is inspecting must note all adverse observations, for example if an animal is: • not eating • not drinking (in the case of kittens/puppies drinking milk) • not defecating • not urinating • behaving abnormally • unable to move about freely • displaying an abnormal coat • showing any obvious signs of pain, injury, illness or distress • suffering any unexpected or rapid weight loss. - -
7.1.1.2 Any changes in health status must be promptly reported to the person in charge of the facility for appropriate action. 7.1.1.2 Any changes in health status must be promptly reported to the person in charge of the facility and action taken. Changed from passive (‘appropriate action’) to assertive (‘and action taken’).
7.1.1.3 If there is evidence that whelping or kittening has commenced (e.g. straining or contracting) and there is no progress within two hours, the bitch or queen must be examined by a veterinary practitioner or other appropriate remedial action taken. - -
7.2.1.1 The person in charge of the facility must establish liaison with a veterinary practitioner who is able to attend to their animals and advise on disease prevention measures. - -
7.2.1.2 The contact details for the veterinary practitioner must be posted in a location which enables staff and visitors to see them. - -
7.2.1.3 Appropriate veterinary treatment must be provided for sick or injured animals. - -
7.2.1.4 Permission in writing must be obtained from the owner (or nominee if the animal is leased at the time of acceptance for breeding) authorising the provision of necessary veterinary treatment. - -
7.2.1.5 Dogs and puppies must be vaccinated against distemper, hepatitis and parvovirus in accordance with the manufacturer’s recommendations unless there is written advice from a veterinary practitioner not to do so. Remove section. There is significant debate regarding vaccination protocols in dogs. In particularly, The Australian Veterinary Association recommends tri-annual vaccination, yet many veterinarians current practice against the AVA’s recommendations. Due to the discrepancies between the AVA, practitioners, and the manufacturers, it seems folly to legislate one particular approach.
7.2.1.6 Cats and kittens must be vaccinated against feline infectious enteritis and feline respiratory disease in accordance with the manufacturer’s recommendations unless there is written advice from a veterinary practitioner not to do so. Remove section. There is significant debate regarding vaccination protocols in dogs. In particularly, The Australian Veterinary Association recommends tri-annual vaccination, yet many veterinarians current practice against the AVA’s recommendations. Due to the discrepancies between the AVA, practitioners, and the manufacturers, it seems folly to legislate one particular approach.
7.2.1.7 Animals known or suspected to be suffering from a significant infectious disease must not be used for breeding or be accepted for breeding under lease unless under written approval from a veterinary practitioner. - -
7.2.1.8 Internal and external parasites including fleas, lice, ticks, gastrointestinal worms and heartworm must be controlled through routine and preventative treatment as appropriate. Remove section. Already covered by 4.1.4.
7.3.1.1 If treatment to restore the physical and mental health of an animal while in the facility is impractical or unsuccessful, or if euthanasia is recommended by a veterinary practitioner, the animal must be euthanised. 7.3.1.1 If treatment to restore the physical and mental health of an animal while in the facility is impractical or unsuccessful, the animal should be moved to a facility where attendance to its physical and mental needs is attainable. Owners should not be obligated to euthanise animals (“the animal must be euthanised”), nor should this approach be legitimized in the code.
7.3.1.2 Euthanasia must be conducted in an area that is separated from animal accommodation at the facility and must not be carried out in view of any other animals. - -
8.1.1.1 Puppies and kittens must not be sold before they are 7 weeks of age. Unsure. Animals are frequently sold before 7 weeks, but do not permanently vacate the premises before this time. Selling animals prior to 7 weeks means that both the buyer and seller has certainty about the puppy’s future, and this fore-planning should be encouraged, not out-lawed.
8.1.1.2 No animal must be sold unless vaccinated in compliance with the requirements of Section 7.2 of this Code. 8.1.1.2 No animal must be sold unless vaccinated. (Removed section: “in compliance with the requirements of Section 7.2 of this Code.”) There is significant debate regarding vaccination protocols in dogs. In particularly, The Australian Veterinary Association recommends tri-annual vaccination, yet many veterinarians current practice against the AVA’s recommendations. Due to the discrepancies between the AVA, practitioners, and the manufacturers, it seems folly to legislate one particular approach.
8.1.1.3 All animals must be treated for internal and external parasites prior to sale. - -
8.1.1.4 No animal suspected of suffering a significant illness, injury or disease (including congenital diseases) must be sold. 8.1.1.4 No animal suspected of suffering a significant illness, injury or disease (including congenital diseases) must be sold unless the purchaser is provided with written details of its condition prior to sale. As it is currently written, breeders are required to either keep or euthanise animals with illness, injury or disease. Steps should be made that reduce euthanasia, not increase it.
8.1.1.5 At the time of purchase, clients must be offered accurate written information at no charge that concerns the care of animals purchased. - -
9.1.1.1 Bitches and queens must not be intentionally mated during their first oestrous cycle. Remove section. There is no scientific evidence, anywhere, that suggests that breeding bitches on their first cycle is hazardous to the well being of their pups or the dam.
9.1.1.2 Males and females must be physically and mentally fit, healthy and free of disease at the time of mating. - -
9.1.1.3 During mating, breeding pairs must be isolated from other animals, and monitored by the person in charge or a competent member of staff. - -
9.1.1.4 Bitches and queens in the latter stages of pregnancy must be provided with additional food and water, at frequent intervals. - -
9.1.1.5 During birthing bitches and queens must be isolated from other animals and monitored by the person in charge or a competent member of staff on a regular basis to ensure that the birth proceeds in a normal manner. - -
9.1.1.6 Whelping bitches must be provided with a suitable whelping box, lined with clean bedding, which is changed daily. 9.1.1.6 Whelping bitches must be provided with a suitable whelping box, lined with clean bedding. (Section removed: “, which is changed daily.”) Changing bedding daily can be stressful to a bitch and her pups.
9.1.1.7 Kittening queens must be provided with a covered kittening box, lined with clean bedding, which is changed daily. Unsure. Perhaps changing bedding daily is stressful for queens and her kittens, too.
9.1.1.8 Animals that are isolated must be provided with additional attention and socialisation to animal carers. - -
9.1.1.9 Bitches must not have more than two litters in any eighteen month period, unless with the written approval of a veterinary practitioner. Remove section. There is no scientific evidence that suggests that having more than two litters from a bitch in an eighteen month period is hazardous to the health of the bitch or to her pups.
9.1.1.10 Queens must not have more than three litters in any two year period, unless with the written approval of a veterinary practitioner Unsure. Perhaps there is no scientific evidence that multiple litters is hazardous to the health of queens and kits, either.
9.1.1.11 Lactating bitches and queens must be provided with additional food and water. Remove section. Already covered by 6.2.1.1 and
9.1.1.12 Lactating bitches and queens must be housed in such a manner that they are able to escape their young. Remove section. Some bitches (and presumably queens) are ‘bad mothers’ and may inadequately feed their young. If they are allowed an avenue to escape, they may not feed their young, and their young would perish. Breeders should be allowed to make choices based on the welfare of an individual bitch and her young.
9.1.1.13 Kittens or puppies must not be separated from their litter or their lactating mother until they are seven weeks of age, unless it is in the best interests of the puppy or kitten, or their mother. Remove section. It is always in the best interest for puppies to be extensively socialised from 4 weeks old, and independently to their mother and other pups. It is in a puppy’s best interest to be weaned well prior to 8 weeks, when they go to a new home.
9.1.1.14 Puppies and kittens must be monitored when first offered solid food to ensure that the food is acceptable and palatable. Remove section. Owners are already required to provide animals with “appropriate and adequate” food as per the Animal Welfare Act. Unnecessary to include it in this code.
9.1.1.15 Puppies and kittens must be observed to ensure they achieve a steady weight gain every week. Remove section. Owners are already required to provide animals with “appropriate and adequate” food as per the Animal Welfare Act. Unnecessary to include it in this code.

Please feel free to utilise my own submission in whatever way you feel just in preparing your own. I can only hope that this time the powers-that-be heed the submissions and make changes that are based on science and evidence, instead of public outcry.

Dogs SA’s response to the breeder code can be seen here.

Voluntary credit to Tableizer who made creating that massive table a whole lot easier.

05/2/15

My Say: South Australian Dog and Cat Reforms

It’s been brewing for a while. In January 2013 that I urged readers to make a submission to the Select Committee. They were looking for suggestions to ‘improve animal welfare’ and ‘reduce euthanasia in shelters’. It was July 2013 that they ignored all evidence-based suggestions and instead went with simply replicating faulty legislation as seen in other states.

Then it all went quiet, and I was optimistic that the whole stupidity had disappeared.

But in September last year, there were indications that legislation was in the works. A few news articles that gave glimpses of a story.

And then… 

Last month, April 2015, we were given another opportunity to respond. This time, the legislation is written down, and they’re wanting feedback on the actual words. It’s great that they’re inviting feed back, but some of the choices are a bit concerning.

Each area will have its own blog post, but this blog post serves as a summary of the major points.

Submissions can be made through the Your Say website through the section on South Australia’s Dog and Cat Reforms.

There are two proposed areas for change:

Further, there is a Citzens’ Jury on mandatory desexing.

 

A new Breeder Code of Practice (COP)

While this could’ve been disastrous, the COP proposed here is milder than that in other states (like Victoria). So breeders can take a much needed breath – at least for now.

The ‘good thing’ about this COP is that it does not discriminate on breeders based on arbitrary measures. It simply requires that anyone who breeds dogs or cats ‘for sale’ is required to register as a breeder. However, this is a little bit muddy. Do I have to register as a breeder if I sell a litter? If I have a litter that is born? If I have a bitch in whelp? When I attempt a mating? When I own an entire animal? This area is unclear.

Myrtle and Clover both lactated and mothered Myrtle's litter of puppies.

Myrtle and Clover both lactated and mothered Myrtle’s litter of puppies.

The main issues are:

    • A lot of the standards and guidelines are incredibly burdensome for a small hobby breeder. This includes excessive record keeping.
    • The code practically prohibits the use of crates by breeders. Crates have many purposes. The way the COP is written, crates are smaller than the minimal size area that dogs can be kept in.
    • The COP requires animals to be isolated from each other, in situations that are excessive. For example, a bitch cannot raise a litter with another bitch (i.e. co-parent), as they must be isolated from other animals when with pups. Also, bitches who are in season must be separated from other animals – which is a 3 week period where a social animal is required to be by themselves.
    • Standards sometimes do not apply for people with droving or stock-working dogs. If these standards are necessary for best practice, then they must be true for all dogs. Suggesting that the physical and psychological needs of working dogs varies weakens this legislation.
    • A standard specifies that animals “must” (quote!) be euthanised on the recommendation of a vet.

For more details, see the complete blog post.

 

Changes to the Dog and Cat Management Act (D&CMA)

I was surprised to find I had more objections with these changes than the breeder code! They are:

  • Facilities are not required to check for a microchip in lost animals! While I support the general idea that all animals should be microchipped, I am alarmed that the changes to the Act do not necessitate an authorised person and a facility to scan for a microchip on all animals impounded, and animals that are received deceased (e.g. road kill animals). This section urgently needs attention to ensure that facilities carefully check animals for microchip, seek this microchip number on available databases, and action the contact details linked on the database. This section of the Act urgently needs to be reviewed.
  • They can desex your lost pet! I am incredibly troubled by the proposed inclusion that allows a holding facility to desex and microchip an animal in their care. It is unclear why this section of the legislation has been included. It does not specify a time limit from seizure to surgery – hence, a person with a dog roaming at large for several hours could have their dog seized and desexed before being returned. This is a huge violation of the rights of the owner to keep their dog entire if they see fit. This section must be amended to at least specify that desexing can only occur 72 hours after impoundment.
  • Requiring all animals to be microchipped. If a pet owner has a pet that is not microchipped, they will have to have it microchipped. The cost of doing so could be prohibitive and people may be forced to choose to relinquish their pets or live as criminals under the D&CMA. A grace period of two years may help to alleviate this problem.
  • The requirement of breeders to be registered. I’ve always maintained that breeder registration will not achieve the welfare aims many activists believe. That is, breeder registration is bollocks.

More details on these changes in this blog post.

 

I hope this gives you a basis to begin your submission, and hope to provide you more specific inclusions for your submissions in the coming days.

02/1/15

Breeder Registration is Bollocks

It doesn’t take long for those involved in animal welfare circles to hear arguments for the implementation of breeder registration. Many advocates of breeder registration argue that such a scheme would cause some breeders to ‘reconsider’ breeding, and one less breeder is seemingly desirable to these animal advocates.

There seems to be a lot of faith and enthusiasm for such a scheme, despite breeder legislation never having been shown to achieve anything, that if affects ‘good’ and ‘bad’ breeders equally, impacts on rescues, and is difficult to police. Further, it seems to be targetting the mythical ‘overpopulation problem’, and not the actual issue of pound poor-performance.

So let’s address all the reasons why breeder registration is not the holy grail of animal welfare legislation.

 

No Evidence

There is no research that indicates that breeder registration reduces impounds/euthanasia, or improves the welfare of dogs in breeding establishments. For example, the Gold Coast Breeder Scheme is widely considered to be a flop, and has been discontinued. If there is no evidence that breeder legislation works, why would we be invest funds in establishing a scheme? Breeder legislation is a poorly qualified solution to animal impoundment, as much as BSL is a poor solution to dog bites.

It’s been tried before, and failed before, so why repeat the same mistakes?

 

Australian Shepherd puppies playing in a ball pit.

Decline in Ethical Breeders

The hallmark of most breeder registration schemes is a breeder having to pay in order to be ‘registered’.

The problem is that ethical breeders are (largely) not making money from their breeding, and therefore may not be in a financial position to pay for registration. Ethical breeders may choose to cease breeding due to expense. How do we ensure that responsible, ethical breeders are not discouraged from producing wonderful pets?

As most of these schemes require breeders to pay in order to be registered, what breeder registration effectively does is limit (legal) breeding to those who are making money from the practice. What I mean is: breeders who don’t make money are are probably the ‘ethical ones’, and are probably less likely to be able to afford registration. Are these the individuals we want to perturb from breeding?

Furthermore, there is those that breed dogs in working fields, like guide dogs, customs, and so forth. Any restriction on breeders would also cause more expense and process for those producing animals for these roles.

 

Unethical Breeders Unaffected

On the flip side of this, those who are most likely to be able to afford registration is puppy farmers themselves. Those running a business, profiting from the sale of puppies, are going to be able to afford registration, and continue breeding puppies.

If a breeder is raising puppies in conditions that are undesirable and outside of welfare codes, they are going to avoid registration, and simply remain unnoticed and unpoliced.

Or, alternatively, a breeder may pass all the codes as they meet physical levels of care, but they neglect the psychological well being of their dogs and puppies.

Basically: Unethical breeders are not going to be deterred by a breeder registration scheme.

 

Association with Code of Practice

Whenever breeder legislation is suggested, it tends to appear alongside a Code of Practice. A Code of Practice attempts to specify the way animals should be maintained. The biggest problem is that it effectively obligates breeders to keep their dogs in a kennel situation, which many would argue is in contradiction to the best interest of dogs. I discussed these problems in my article called Clean and Kennelled.

Basically, if you have a breeder registration scheme, it goes hand-in-hand with a prescribed approach to animal management and handling, which is counter intuitive to animal welfare goals.

 

Mandatory Desexing Overtones

Any breeder registration scheme has overtones of compulsory desexing for dogs. Not only are there legitimate reasons to keep dogs entire, mandatory desexing also has negative social factors. For example, mandatory desexing is often associated with increased surrenders (e.g. “I can’t afford to desex my dog, so I need to surrender it instead so I don’t become a law breaker”).

The Saving Pets blog does a good job of describing how mandatory desexing has never worked. Furthermore, I’ve blogged before about how mandatory desexing is hard to define (unless we desex everything and eradicate the species). Mandatory desexing is also often associated with early age desexing, which has its own welfare implications. And there’s evidence that making desexing mandatory increases surrenders, as people aren’t able to pay for the surgery and so are left with no other choice. And, on top of that, desexing is a medical procedure, which should be implemented by medical professionals based on the individual animal at hand – not policy makers.

Further, mandatory desexing seeks to categorise people who have an entire dog as ‘breeders’, when this may not be the case. That is, non-breeders may be forced to become breeders according to legislation in order to comply with the law.

 

Exclusions

Mandatory breeder registration often excludes key groups: ‘backyard breeders’, ‘working dog breeders’, and greyhound breeders. These breeders produce a lot of dogs and dogs that are, seemingly, more likely to end up in the pound system.

A dog is a dog. We can’t argue that breeder registration is for the welfare of dogs owned by a particular group of people. Legislation needs to apply to all dogs, or none at all.

And, when you make this breeder registration compulsory, you need to consider the impact on rescues.  As rescues occasionally take in pregnant dogs, they may be deemed as breeders, and may have to pay breeder registration too. The last thing we need is for rescues to be further out of pocket due to the introduction of unfounded legislation. I could list twenty things that rescue could be better suited to spend their funds on.

 

No Policing

I’ve blogged before about how many dog-related policies are not policed.  In South Australia, we have the Animal Welfare Act and the Dog and Cat Management Act. I see constant violations of both these acts as it currently stands. So what are we doing bringing in new legislation, when our existing legislation is under enforced?

Without enforcement, legislation is just tokensitic. Arguably, if our existing legislation was enforced, we wouldn’t need further legislation. Our existing legislation is pretty good legislation. If it’s not enforced, then puppy farms can flourish.

 

Poor Focus

My biggest rejection of this is that there isn’t a population problem. We don’t need to reduce the number of dogs in the world. Shelters need to market and promote animals in their care better. Breeder registration doesn’t have anything to do with shelter euthanasia rates.

While we’re busy spending all our time going after breeders, we will still be watching shelters killing a great number of dogs. While you might take issue with people breeding their dogs, I take bigger issue with shelters killing dogs in their community. What’s the greater problem here?

 

Further reading:

Just Stop Breeding Until the Pounds are Empty

Why I Don’t Want Oscar’s Law

The Fallacy of Mandatory Desexing

What is the answer? (To puppy farms)

Rescue Vs Breeders

05/4/14

How to choose a rescue or shelter to adopt from

Purchasing a dog or puppy: What to look for in a rescue or shelter

 

Congratulations on choosing to add a new dog or puppy to your family.

It is great that you are considering adopting a pet from a rescue or shelter. However, not all rescues/shelters are created equal – indeed, some facilities are merely posing as rescues and are more like an animal-broker than an animal-rescue.

It’s not a ‘black and white’ matter, but here are some suggestions that will hopefully help you when you’re looking at adopting a pet.

 

Green traffic lightNecessities

Do not purchase a dog from a shelter unless the facility:

  • Shows concern and regard to the physical health of their dogs and puppies
     
  • Shows concern and regard to the psychological well being of their dogs and puppies – either in providing enrichment on site, by frequently taking their dogs ‘out and about’, by using Dunbar’s methods of raising puppies (with toilet area, kongs, socialisation), and by providing training to dogs with behavioural problems
     
  • Is willing to provide life-long support to you as a purchaser, and is willing to take their dog or puppy back if things don’t work out. (There should be a trial period of anywhere from 1-12 weeks where a refund is provided.)
     
  • You feel comfortable approaching the rescue or shelter for advice, and feel they would be supportive and give you clear advise you can understand.
     
  • Sells all dogs and puppies microchipped, vaccinated and sterilised (or on contracts to have these procedures performed at a latter date, or with a medical certificate exempting them from these procedures)
     
  • Gives you some time to ‘think about’ adding the dog/puppy to your household
     

 

Niceities

It’s ‘nice’ if a shelter/rescue does these following things, but not a deal breaker.

  • The rescue/shelter asks you lots of questions about your household and what you’re looking for
     
  • There is a sales contract
     
  • The rescue/shelter seems to have a great deal of knowledge about dogs
     
  • The rescue/shelter uses foster carers so they know what the dog is like in a house (instead of just living in a kennel)
     
  • The rescue/shelter has had the dog in care for at least 10 days, to serve as a quarantine period
     
  • Friends, family, or other shelters and rescues have heard of this rescue and have positive things to say
     
  • Identifies as ‘no kill’ or ‘out the front door’ or as ‘saving 90%’
     

 

Red Flags

Have some concern about the shelter or rescue if any of these events take place.

  • The rescue/shelter seems overly concerned about the purchase price
     
  • The rescue/shelter puts the hard sell on – “I might sell her next week if you don’t take her today”, or “I’ll give you 10% off if you buy her now.”
     
  • The rescue/shelter sells puppies together to the same pet family
     
  • The rescue/shetler is willing to sell a puppy/dog to you without you even meeting the dog/puppy to assess it for yourself
     

 

Do Not Buys

If the shelter or rescue does any of the following things, then walk away and source a dog from an alternative source.

  • You cannot meet the dog or puppy before sale
     
  • Dogs/puppies are not microchipped – in most states of Australia, this is a legal requirement
     
  • The dogs or puppies seem unhealthy or in poor condition (dirty, matted, skinny, fat)
     
  • There seems to be no plan to improve the socialability/behaviour of dogs that have problematic temperaments
     
  • The rescue/shelter is not willing to show you all the dogs in their care
     

 

Is there anything you would add to the list?

 

Further reading: See How to Find a Good Dog Breeder

04/6/14

How to find a good dog breeder

Purchasing a Dog or Puppy: What to look for in a breeder

 

So you have made a decision to add a dog or puppy to your family. Congratulations!

But how do you make sure you’re getting a puppy from an ethical source?

It’s not a ‘black or white’ matter. There is no definitive issue that makes a breeder ‘good’ or ‘bad’.

Instead, here’s a guide which talks about necessities, niceties, and red flags.

 

Necessities

If your breeder doesn’t do this then walk away…

  • Breeder shows concern and regard to the health of dogs and puppies – either in health testing or in the studs used (e.g. choosing old studs that show they’re healthy, using DNA testing, using x-rays, and other relvant tests)
     
  • Breeder shows concern and regard to the psychological well being of their dogs and puppies – either in providing enrichment on site, by frequently taking their dogs ‘out and about’, by using Dunbar’s methods of raising puppies (with toilet area, kongs, socialisation), and preferably a combination of these methods.
     
  • The breeder has a clear purpose in their breeding program that goes beyond ‘breeding pet puppies’ – they may enter their dogs in dog shows, participate in agility or obedience with their dogs, or have dogs that compete in working dog trials
     
  • The breeder’s dogs approach you in a friendly and sociable way. You are able to interact with and handle all dogs on the property. The mother should be available and should show exceptionable sociable behaviour.
     
  • The breeder is willing to provide life-long support to you as a puppy buyer – including taking back the dog at any point things ‘don’t work out’
     
  • The breeder happily shows you all the dogs in their care
     

 

Niceties

It’s nice for the breeder to do any of these things, but don’t be concerned if it doesn’t happen.

  • The stud dog is on site
     
  • The breeder asks you lots of questions about your household and what you’re looking for
     
  • There is a sales contract that goes beyond simple money exchange
     
  • The breeder can show registration or affiliation to an organisation with a code of conduct/ethics
     
  • The breeder can recite pedigrees and seems to be oozing with knowledge about the breed
     

 

Red Flags

If any of these items take place, you may want to reconsider purchasing an animal from this breeder.

  • The puppies are not vaccinated
     
  • The breeder seems overly concerned about the purchase price
     
  • Not all adult dogs are sociable and friendly
     
  • Part of the breeder’s sales pitch is ‘lots of colours available’ or ‘will grow up big’ or ‘will stay tiny’ or ‘rare!’
     
  • The breeder asks for deposits before a bitch is mated
     
  • The breeder sells puppies together to the same pet family
     
  • The puppies are crossbreeds which seem to have no real purpose (ask, how do they fit into the clear purpose of their breeding program?)
     
  • The puppies are crossbreeds and are given a fancy name like ‘labradoodle’ or ‘spanador’.
     
  • The breeder does seem to be putting the hard sell on you – they’re saying “if you put a deposit down today, I’ll take $100 off the asking price” or “If you don’t buy him now, I have someone coming at 2 o’clock who will buy him”.
     
  • The breeder breeds more than 3 different breeds of dogs
     

stop sign

 

Do Not Buys!

If a breeder performs any of the following points, then do not purchase a puppy and look elsewhere.

  • You cannot meet the mother or father in any circumstances (e.g. ethical breeders, even if the stud dog owner is interstate that should be able to say ‘you can meet them if you really want to go interstate’)
     
  • Puppies are not microchipped – in most states of Australia, this is a legal requirement
     
  • The dogs or puppies seem unhealthy or in poor condition (dirty, matted, skinny, fat)
     
  • The adult dogs are not sociable and friendly, especially if many of the adult dogs are not friendly
     
  • The breeder is unwilling to show you all the dogs at their home
     

 

Is there anything you would add to this list?

 

Further reading:

Red Flags: Warning signs when dealing with a breeder

How to tell if your dog breeder is responsible

A puppy ‘with papers’ from a ‘registered breeder’

Select, select, select

Dog Breeders: Don’t produce lemon puppies