{"id":2972,"date":"2013-05-12T23:39:39","date_gmt":"2013-05-12T13:09:39","guid":{"rendered":"http:\/\/leemakennels.com\/blog\/?p=2972"},"modified":"2021-08-02T17:40:23","modified_gmt":"2021-08-02T07:10:23","slug":"breeding-and-rearing-code-in-victoria-email-submission","status":"publish","type":"post","link":"http:\/\/leemakennels.com\/blog\/dogs-and-politics\/breeding-and-rearing-code-in-victoria-email-submission\/","title":{"rendered":"Breeding and Rearing Code in Victoria – Email Submission"},"content":{"rendered":"

Less than 12 hours to go to get your online submissions and email submissions in!\u00a0Commenting online<\/a>\u00a0or\u00a0email animal.welfare@dpi.vic.gov.au\u00a0(open in email client)<\/a>\u00a0if you’re looking to do the same) with your feedback on the proposed code.<\/p>\n

To Whom It May Concern,<\/p>\n

 <\/p>\n

Re: Breeding and Rearing Code Review and Public Content<\/b><\/p>\n

\u00a0<\/b><\/p>\n

Whilst I understand that the proposed Breeding and Rearing Code has come about due to public concern regarding the welfare of breeding animals in large breeding establishments, and I support motions to improve the welfare of all animals, I am deeply worried by the unscientific nature of this proposed Code.\u00a0 Significantly,<\/p>\n

1)\u00a0\u00a0 The Code includes only 18 references.
\n<\/b>
\nA Code such as that proposed should be far more thoroughly researched before reaching a consultation stage.\u00a0 Instead, this Code uses 16 papers on a variety of companion animal topics, some which are not even peer reviewed, to reach a conclusion.\u00a0 There needs to be far greater review of the available literature to reach recommendations on further regulation.\u00a0 This review should include articles covering the welfare of breeding animals in a number of contexts, in a variety of breeds and species, while also considering the success of regulation in achieving welfare outcomes in similar circumstances.\u00a0 None of these areas are covered in any of the references currently included for the Regulatory Impact Statement (RIS).\u00a0 Without more research, the proposed Code may be ill positioned to improve animal welfare in Victoria.<\/p>\n

2)\u00a0\u00a0 <\/b>The significance of the paper by Kustritz (2012) is exaggerated, and its interpretation is erroneous.<\/b><\/p>\n

The review paper written by Kustritz (2012) seems to be the basis of many of the conditions surrounding breeding animals in the proposed Code. \u00a0However, this is only a review paper.\u00a0 This means that this paper reviews other literature, and is not research in itself.\u00a0 Therefore, calling it \u2018scientific research\u2019 (as claimed in the RIS) is erroneous.\u00a0 Furthermore, this review paper has not been peer reviewed (and therefore has no quality control measures) and this paper also has only ever been published in Canine Theriogenology<\/i>, which is owned by Ms Kustritz herself.\u00a0 In addition, this paper warns against regulation, saying \u201cThere 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\u201d.\u00a0 That is, Kustritz recommends against the very actions that have been undertaken when writing the proposed Code.\u00a0 Whilst the paper by Kustritz is a starting point when considering the welfare of breeding dogs, it is not scientific, it is not peer reviewed, it is not independently published, and it recommends in its own text that it not be used in creating regulation.\u00a0 Considering this, it should not be used as the crux of the proposed Code, as it currently is.<\/p>\n

Additionally, the paper is often erroneously quoted within the RIS.\u00a0 This raises huge concerns about the validity of the research process undertaken in formulating the Code.\u00a0 For example, the RIS claims that the critical age recommended is for the general health of the bitch.\u00a0 However, the Kustritz paper makes no claims of this nature.\u00a0 Critical age is based solely on bitch productivity and not the welfare of the bitch.\u00a0\u00a0 Similarly, the RIS claims \u201cScientific Research [sic] recommends that\u2026 bitches should not produce more than five litters\u201d.\u00a0 But the Kustritz paper does not say this at all, instead uses two articles on two breeds of dogs to indicate that productivity decreases after five litters.\u00a0 That is, scientific research shows that productivity decreases after five litters, but not that bitches should not be bred after five litters, and certainly does not make claims on bitch welfare.\u00a0 In these two instances, the RIS is misleading.<\/p>\n

However, there are also claims in the RIS that are completely false, such as \u201cthe research recommends male dogs are not bred\u2026 beyond critical age\u201d, when in reality, Kustritz (and others) do not recommend a critical age for stud dog use at all.\u00a0 Another false claim made in the RIS is \u201cThe justification behind these recommendations includes\u2026 the general health of the bitch and the increased risk to both bitch and male dog of reproductive failure and diseases such as cancers of the reproductive tract, urethra and bladder.\u201d\u00a0 Nowhere in the Kustritz paper does she link breeding of animals to cancer formation.\u00a0 That is, dogs that are bred are not more likely to develop cancer.\u00a0 Many of the claims in the RIS are erroneous, misleading, and should be immediately rectified, and these changes should then be reflected in the Code to show breeding standards that are actually<\/i> recommended in scientific research.<\/p>\n

3)\u00a0\u00a0 The paper references nothing on cats.
\n<\/b>
\nThere is a huge paucity in the literature referenced regarding cats and their welfare.\u00a0 Indeed, the term \u2018cat\u2019 and \u2018feline\u2019 does not appear in any of the reference paper titles.\u00a0 In fact, there are more papers referenced from a pig journal than there are articles on cats. \u00a0It is inconceivable that the proposed Code could ever make recommendations on cat welfare without using references actually pertaining to cats.\u00a0 This is a huge oversight and it reflects the lacking process in developing the proposed Code, especially in regard to the recommendations made on breeding cat welfare.<\/p>\n

Due to these clear inaccuracies in the RIS\u2019s interpretation of the limited references, I argue that the proposed Code is not significantly informed to accomplish the desirable welfare goals.\u00a0 Potentially, this Code could therefore be a huge waste of government resources.\u00a0 Thus, I do not support this Code until it can be more comprehensively supported by academic literature.\u00a0 I argue that relevant literature needs to be comprehensively reviewed in order to create an informed code that accurately reflects current animal welfare understandings, including its regulation.\u00a0 To do any less is to potentially compromise the credibility and impact of significant animal welfare legislation.<\/p>\n

 <\/p>\n

Sincerely,<\/p><\/blockquote>\n

Get your submission in NOW! Less than 12 hours to go! And if you’re looking for another submission to formulate some ideas, here is what Victoria Dog Rescue had to say<\/a>.<\/p>\n

Go go go! Do something!<\/p>\n","protected":false},"excerpt":{"rendered":"

A template for an email submission on the Breeding and Rearing Code under review in Victoria. Do not delay! Submit today! <\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[54],"tags":[38,12,233,11,59,230,562],"class_list":["post-2972","post","type-post","status-publish","format-standard","hentry","category-dogs-and-politics","tag-breeding","tag-dog","tag-dog-breeding-2","tag-dogs","tag-legislation","tag-politics","tag-submission"],"aioseo_notices":[],"_links":{"self":[{"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/posts\/2972"}],"collection":[{"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/comments?post=2972"}],"version-history":[{"count":5,"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/posts\/2972\/revisions"}],"predecessor-version":[{"id":5023,"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/posts\/2972\/revisions\/5023"}],"wp:attachment":[{"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/media?parent=2972"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/categories?post=2972"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/leemakennels.com\/blog\/wp-json\/wp\/v2\/tags?post=2972"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}