Notes of Meeting March 3 2016

Present: 
Dan O’Neill (DON), Sheila Crispin (SC), Chris Laurence (CL), Stephen Charlton (SC), Julia Charlton (JC), Julia Carr, Tania Ledger (TL), Margaret Carter (MC), Carol Fowler (CF), Charlotte Mackaness (CM), Natalie Plowman (NP), Vicki Betton (VB)
 
Apologies:
Marisa Heath, David Grimsell, Clare Rusbridge, Gudrun Ravetz

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1. Matters Arising

• BVA/KC Eye Scheme:  SC informed us about the re-writing and updating of the Scheme. SC explained that Schedule A of the Scheme represented the known inherited eye diseases based on prevalence and published scientific literature. CF has updated the DogBreedHealth website to include whether litter screening or annual testing is required and to use consistent and correct naming of the various eye diseases. Breeds reported to have eye disease(s) remain on the DBH website even if they are not listed on Schedule A of the Scheme. Available DNA tests have also been included in the updated Scheme and DBH website.  SC intends to continue her work into other breed-related anomalies and abnormalities of the eye and adnexa (tissues surrounding the eyes).
• DogBreedHealth website: we agreed that breed club input into the DBH website breed pages would improve the information by ranking the ‘Other diseases reported’ in order of priority and possibly removing some diseases which had low welfare impact or low incidence. LF offered to speak to breed club associates about their involvement.
• CF has written to Claire Horton regarding her CSFG Puppy Group but so far has not received a reply. At the meeting with Defra Minister, George Eustice, in January, it was suggested Geoffrey Clifton-Brown, MP and CF meet again with Claire. We have not yet heard back from Defra about this meeting.
• Use of ‘CIEH Model Conditions’ by all local authorities. It is very much hoped that as a result of the Defra Consultation on Licensing, local authorities will be required to apply the ‘CIEH Model Conditions’ rather than simply encouraged to do so.
• Indemnity insurance for DBRG: CL will go ahead with this.
• Agreement within the group: CF explained the problem of getting agreement on matters dealt with by email. In the main this is due to the heavy workloads of members. It was agreed that CF will give a date by which a response is needed. No response means no objection.
• Position papers: it was agreed that we need to have an agreed position on matters related to dog breeding and these will be displayed on the DBRG website. Ideas are invited by email. For example, DBRG’s position on how best to represent all dogs; how we interpret the ‘five freedoms’ of the Animal Welfare Act; how best to represent dog owners, etc. A list will be compiled by CF and an order of priority agreed. The task of writing papers will be shared amongst group members according to their areas of expertise.

2. National Dog Breeding Inspection Scheme (JC)

The Scheme would draw on documents already available, such as the CIEH Model Conditions, DAC Breeding Standard, EMRA document (emotional and enrichment needs of dogs). There was an excellent response to the idea of a Standard for Breeding Dogs from members of the public at dog events last year. It is noted that other welfare groups are thinking along the same lines and there might be opportunities for collaboration. It was felt that UKAS accreditation was not necessary as the bar is set too low. The purpose of such a scheme would be as a tool to guide the public in their choice of breeder and to reward the breeders with the highest standards. The Scheme could include a scale of competence and trained inspectors would be able to help breeders to improve. The Scheme could be reviewed and evolve over time as long as breeders were given ample notice that a review would be taking place. CL pointed out that the Standard must be specific (which the KC ABS is not). An easily recognisable symbol such as the Red Tractor could be used to help purchasers.  A database of breeders would be kept and any negative feedback from members of the public would be investigated by the Scheme Inspectors. A breeder could also be supported if they felt an owner was unreasonable.

It was agreed that FC, DG, CL, JC would meet as a group to prepare outline proposals to be discussed at the next full meeting. LF offered to run the outline proposals past a group of breeders for their feedback. It should be offered to a group of dog owners/potential puppy purchasers as well.

3. DBRG New Leaflet

Much work has gone into producing a second leaflet aimed at providing more information about DBRG and our aims/objectives. The general feeling was that the leaflet contained too much information, particularly the list of links on one page which should be removed. The importance of visual information was stressed as was the need to engage members of the public. Cute pictures of dogs/puppies will attract attention and be more likely to engage dog owners.  LF questioned the purpose of leaflets when a website can contain all of the information. However, after discussion it was agreed that leaflets do serve a useful purpose particularly in face to face situations and we probably need several versions. TL pointed out that Cavalier Matters charity has produced many leaflets on specific aspects of Cavalier health and welfare, including advice for owners of dogs with breed-related problems.  JC said that there had been a good reaction to the first DBRG leaflet at dog events around the country last year and that the pseudo quiz worked well. JC suggested that the leaflet does go to print and that we should consider a third. CF will work on further ‘trimming’ to make room for more illustrations before leaflet 2 is printed.

4. DogWellNet/International Partnership for Dogs (DON)

The Partnership was founded to support ‘co-operation, collaboration and sharing of information and resources across the global dog community to enhance the health, wellbeing and welfare of pedigree dogs and all dogs.’
 
IPFD and DogWellNet, created by Brenda Bonnet, are linked to the DogHealthWorkshop which is held bi-annually in Europe. The next is on April 2017 in Paris. We discussed whether DBRG should apply to join as a group and attend the next Dog Health Workshop. We agreed that it was important for us to be involved given our focus on dog breeding and breed related health issues.  It would also be a way of representing dog owners at an event that was chiefly attended by kennel clubs’ representatives and scientists. We would welcome the opportunity to explain what DBRG was about and engage with the governing bodies of pedigree dogs. However, we agreed that as a new organisation we needed more time to agree on our policies and have position papers in place. We expect to be ready in 2019 and CF will write a formal response to Brenda Bonnet.

5. Canine Action UK Update (Julia Carr)

Julia outlined her newly completed research, ‘Analysis of Licensed Pet Shops in Great Britain.’ This involved issuing Freedom of Information (FOI) requests in November 2015 to all 379 local authorities in England, Wales and Scotland, asking for information relating to pet shops that were licensed to sell puppies. There was a 99% response rate and for the first time there is data which gives a clear picture of what is going on. There are three types of premises which have pet shop licences: retail pet shops; dealers (who may be selling from domestic premises); hybrid sellers (these breed and sell their own puppies and puppies bred by other breeders). 60% of puppies sold are not from retail premises. There are inherent risks in selling dogs in this way: transport regulations are not enforced; it allows imported puppies to be sold; vet inspections are not carried out; 2013 Model Licence Conditions are ineffective or not used at all; enforcement issues are commonplace and prosecutions for poor animal welfare are rare; puppy buyers rarely complain to local councils; the Kennel Club continue to register puppies which are bred and sold in this way; the accountability of breeders relies on their own record keeping; ineptitude of inspections; no qualifications are needed to breed or sell dogs in this way. There is a lack of transparency and accountability.

SC suggested creating a website listing all pet shop licences and complaints received. However it is difficult to persuade local authorities to provide the information. In some ways local authorities are shielding these breeders and sellers. JC will check the legality of publishing a list of pet shop licences.

VB commented that dogs are a high risk group but are given low priority.  She suggested that other welfare groups would like to have this data.

Julia is to be congratulated for the hundreds of hours of work that went into producing her report which will be immensely valuable to all those concerned with dog welfare.

The Executive Summary of the Report is included as an Appendix to these Notes.

6. DEFRA Consultation on Licensing

Our response is almost complete. We discussed the question of reducing the threshold for local authority licensing to above two litters. It was felt by the majority of the group that there shouldn’t be a threshold at all and that all breeders (even those who only breed one litter) should be registered with the local authority and provided with a registration number. We should make this clear in our response.

7. EFRA Inquiry on Animal Welfare

Our response would need to be shared according to individual expertise and was now urgent. CF will complete the final document which will focus primarily on dog breeding issues.

8. Description of members for DBRG website

CF requested short biographies (100 words) from all members to be placed on the DBRG website. Biographies should be accompanied by a portrait photo.

9. Charitable status and fundraising

Natalie Plowman (founder of the Leeds University Animal Welfare Society) was welcomed as a new member and as our official fund raiser. Natalie will begin by writing to those animal welfare charities which help other, smaller charities to start up. Other fund raising ideas welcome. Note that we are able to adopt the title, ‘charitable trust’, even though we have not reached the minimum financial requirement of £5,000 for registration with the Charity Commission. Funding now stands at £365.50.

10. Press release/communication

A sample press release provided by CF was discussed briefly and rejected. We agreed that the purpose of such communication would be to raise our profile a little and respond to dog related events such as Crufts. CM and VB will work together in future to produce appropriate releases which balances our viewpoint with an awareness of the dog welfare political landscape.

11. Public Canine Events 2016

Events, dates and venues will be sent to members when available.

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Date of next meeting

Next meeting on 9 June 2016 at the British Veterinary Association
Notes compiled by CF

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Appendix

ANALYSIS OF LICENSED PET SHOPS IN GREAT BRITAIN

Julia Carr March 2016

In November 2015, we issued Freedom of Information requests to all 379 Local Authorities in England, Wales and Scotland, asking for information relating to pet shops that were licensed to sell puppies.
We have had a 99% response rate to our enquiry (three local authorities have not responded) and this has enabled us to build a very detailed picture of licensed third party puppy vending in Great Britain during the last three years.
We wanted to primarily identify all premises selling puppies which hold pet shop licences and establish whether these were retail or non -retail premises. We also wanted to:

• Ascertain the scale of the licensed third party puppy trade in Great Britain.
• Examine the inspection processes that justify the issuing of the licenses.
• Look at the supply chain, including where puppies are being sourced from and transportation links.

 
Executive Summary

This Freedom of Information survey has revealed a detailed picture of the licensed third party trade of puppies in Great Britain. Key findings are:

• 61 (16%) of Local Authorities licence pet shops to sell puppies under the criteria of the Pet Animals Act 1951.
• 14 (4%) of Local Authorities have more than one pet shop licensed to sell puppies.
• Only 38% of pet shop licences are issued to retail premises. 21% of pet shop licences are held by dealers (selling bought in puppies from non-retail premises) but 41% are granted to hybrid sellers/vendors (licensed breeders selling bought in puppies alongside those bred on site).
• The sale of puppies through non-retail licensed pet shops is a growing problem. Nine new licences permitting the sale of puppies have been granted in the last three years - five to dealers and four to hybrid sellers.
• As many as 80,000 puppies may be sold each year through licensed pet shops in Great Britain.
• Non-retail pet shops are on average permitted to stock more than twice the number of puppies permitted in retail pet shops.
• Almost a quarter of pet shop licences place no restriction on the number of puppies that may be stocked. This includes licences for large scale hybrid sellers/vendors and puppy ‘supermarkets’.
• It is estimated that fewer than 12% of pet shops are importing puppies from outside the UK.
• Almost 70% of local authorities did not know where the pet shops were obtaining puppies from.
• About two thirds of local authorities are not inspecting premises against the latest (2013) model conditions, including those licensing some of the largest puppy vendors in the UK.
• Licensed establishments involved in the breeding and sale of dogs are unlikely to be assessed by officers with a specialist knowledge of the species.
• More than half of the licensees did not hold any formal qualification in animal care and even where the licence conditions required new applicants to obtain a qualification, some authorities deemed this unnecessary as only one species was being sold.
• Vendors are not obliged to maintain a level of continuous professional development.
• 40% of premises do not have full inspection reports on file and almost 20% have no written record of inspection assessments.
• 31% of the full inspection reports had fields left blank – presumably to avoid recording a negative response. This was also frequently observed on breeding establishment inspection reports.
• Breaches of licence conditions were noted on 14% of inspection reports.
• Where the number of breeding bitches on the premises exceeded the number permitted in hybrid sellers’ breeding licences, this seemed to be overlooked.
• Issues with record keeping were noted on 19% of inspection reports, in some cases on successive visits.
• Acclimatisation periods for puppies varied between 48 hours and 10 days, but the most common were either 48 hours or 7 days. Puppy ‘brokers’ who bought in puppies and sold them on to other pet shops were generally only required to hold puppies for 48 hours.
• Acclimatisation, though necessary for third party vending, will inevitably have some negative consequences that would not have arisen with a puppy sold directly from the breeder. The process of acclimatisation itself is therefore ‘harmful’.
• The websites of hybrid sellers/vendors partially or completely conceal the pet shop side of the business in almost all cases, leading consumers to believe they are buying directly from the breeder.
• More than half of pet shops had complaints relating to the sale of puppies made against them and 41% of premises had multiple complaints recorded.
• 29% of vendors had complaints relating to sick puppies recorded – including puppies that had died soon after purchase, and 26% of vendors had complaints relating to the welfare of puppies recorded.
• Where diseases such as parvo virus have been reported, the usual action recorded was to visit the premises and make a visual assessment of the health of puppies on sale. Physical examinations of puppies do not seem to take place and no laboratory testing to confirm the presence or absence of disease was ever reported.
• No centralised database exists to record complaints or problems with vendors. Owners may complain to different organisations or just to the vendor. Therefore, complaints reported to local authorities are only likely to be the tip of the iceberg and should be regarded as an indication rather than the extent of problems.
• Local authorities have no statutory duty to enforce the Animal Welfare Act 2006 so it is rarely mentioned in licence conditions/inspections. Where it has been included, it appears that only ‘lip service’ has been made to the requirements. 
• Although retail outlets on average sell fewer puppies than non-retail outlets, they have particular issues, including puppies being left unattended for long periods when the shop is closed and stress relating to overstimulation and disturbance.
• 68% of local authorities were unable to say if the licence holder held an Authorised Transporter certificate, even though the local authority is the body responsible for enforcing the Welfare of Animals (Transport) (England) Order 2006.
• The average fee charged for licensing a pet shop selling puppies was £155.33. This is unlikely to cover the cost of multiple visits where required or further formal enforcement action. Even the highest licence fee (£499) would be unlikely to offset the cost of a prosecution.
• While most local authorities were efficient at providing the requested information, some authorities initially refused to release details, even though these establishments are operating as businesses.
• Where puppies are sold through third parties in particular and on a commercial scale in general, issues may arise both from encouraging impulse purchasing/not refusing sales to unsuitable homes and with unsold puppies. There is no duty to ensure that puppies are bred and sold responsibly.
• Breeding establishments supplying pet shops tend to have more breeding bitches than those selling directly to the public and there is a correlation between the number of breeding bitches and welfare standards.
• There is a reluctance for breeders to identify puppies sold via third party vendors.
• The location of a breeding establishment does not appear to be a barrier to private sales.

 
Licensing is regarded as a tool to protect animal welfare and consumers by ensuring that basic minimum standards are complied with. However, our study has shown that it is ineffective on both counts. The regulation itself is inadequate, it also has tremendous variation in application and enforcement. There is almost no deterrent for non-compliance and once granted, a licence may even serve to protect the licensee. We do not believe that the licensing system as it currently functions is fit for purpose. Rather than amending the basic parameters, a radical rethink of the entire process is required towards a system which incentivises the highest standards and will ensure that puppies are bred and reared to meet the expectations of those purchasing them.
 
Puppy buyers want to be able to confidently buy a puppy that has the best possible chance of being a happy and healthy companion. Businesses that sell puppies as family companions should have a legal duty to ensure as far as possible that the animals they are producing are fit for that purpose.
 
Selling puppies through licensed pet shops cannot meet this objective, because selling puppies from premises other than where they were born has an inherently negative impact on their welfare that cannot be neutralised.