The government’s Department for the Environment, Food and Rural Affairs (Defra) has just finished a consultation exercise on proposed changes to the rules relating to ‘animal establishments’ – primarily breeders and sellers of companion animals. This is a massive animal protection issue affecting the wellbeing of some 65 million individuals.
The CASJ’s unique approach is based on the understanding that genuine protection of animals’ interests can only be secured through coherent law and policy, effectively enforced by the state. Without robust policies to safeguard them, animals will continue to suffer on a colossal scale. This is true across the board for all animal use, including policy on companion animals.
In our submission to the consultation, we have told Defra that we are deeply concerned that their overarching approach appears to be dominated by a desire to further weaken the-already feeble regulatory system (or ‘cut red tape’ as they euphemistically describe it) with no serious consideration for animal welfare impacts. This is clearly in severe conflict with the public’s desire for effective protection of animal welfare.
Defra claim that ‘the current licensing system has served its purpose for several decades’. This is clearly not the case and seems to be an attempt at false reassurance. As the RSPCA concluded in their comprehensive ‘Sold a Pup?’ report exposing puppy breeding:
‘Welfare problems are evident at every stage of the trade including the choice and husbandry of breeding stock, the breeding and rearing of the puppies, transport to the markets and the eventual sale of these animals. This can also result in poor health and increased susceptibility to fear or avoidance-related behaviour in the puppies and in the breeding stock. Animals can be left with severe and chronic health and behaviour problems.’
Defra has a few ideas that could benefit animals, such as the suggestion of prohibiting the sale of puppies below the age of eight weeks. However, Defra’s proposals are, overall, likely to make a bad situation worse by moving to a weak system of self-regulation. Allowing businesses whose sole priority is profiteering to govern themselves will create an environment where animal harm is likely to get even worse.
In this vein, the CASJ also strongly disagrees with the proposal to use welfare rules which are unfit for purpose, particularly in respect of birds and ‘exotic animals’ such as reptiles, amphibians and fish. For example, they recommend cage sizes that would prevent some birds from being able to fully extend their wings and other guidelines that would lead to animal suffering in breach of the Animal Welfare Act. Not surpisingly, these rules reflect industry submissions and provide a disturbing insight into the likely effects of self-regulation.
As an example of a much more comprehensive and genuine attempt to make good animal welfare policy in this field, we have pointed Defra to the work of the South Australian Government which has conducted citizens’ juries to develop promising new rules for dog and cat welfare in that state. One idea to emerge there was for prospective animal guardians to take an online test to raise their awareness of animals’ needs. We’ve taken that further to suggest that if our country takes animal welfare seriously then it should be a legal requirement for people to pass a test before being allowed to keep animals or hold any form of animal establishment licence, as is practised in many other areas such as driving licences and citizenship applications.
The disastrous evolution and trajectory of animal welfare policy starkly illustrates the underlying problem that condemns millions of animals to egregious suffering – a governmental system that institutionally disregards animal welfare and public concerns. It’s this fundamental issue that is that CASJ’s unique focus.
You can read our submission to Defra’s consultation on ‘animal establishment licensing’ here.
 Known as ‘Model Conditions for Pet Vending Licensing’