Multi Agency Report Sent to DAFM for Animal Welfare Act Review

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Review of the Animal Welfare Act, including Dog Breeding and Trade legislation.

A contribution from the public. The following is a report that we hope will be considered as public participation, as requested, for the forum to inform the re-writing of the animal welfare act. It comprises of views of other agencies involved in welfare, including vets and farmers, the gardai, shelter managers, councilors, fishermen, rehoming and fostering services and conservation projects for non-native species traded in Ireland.

There is widespread concern for the welfare of animals in Ireland, including those shipped in for experimentation and those bred here and shipped out, such as puppies and calves under 30 days old, for veal.

Enforcement

I believe that the main section under review is the dog breeding and trading legislation but, common to all aspects of the Act, legislation is not being enforced. 

Following extensive consultations with many parties, the main concern is that the laws are there but there is no one to enforce them. There are 8 ISPCA inspectors for all 26 counties, one of them is the Chief Inspector. We need more ‘authorized officers’. In addition to the ISPCA’s 8, the gardai are authorized officers but have other things to do. Even the dog wardens are not technically ‘authorized officers’. A considerable amount of authorized officers could be recruited by the ISPCA, for suitability, but paid directly by the government. The cost of this would recouped through the charges they successfully bring to court of the worst offenders.

At the moment, even when the ISPCA do get a case to court, they do not have the support of the judiciary. A case that has cost maybe several thousand to bring to court might be met with a €300 fine to the prosecuted, if that and not necessarily the withdrawal of their license or a ban on keeping animals. There is no recuperation of fines from the biggest offenders – such as non compliant laboratories, unregistered puppy farmers, meat factories and other big companies, where the violence is inherent but the unnecessary cruelty could be monitored and reduced.

At present, the ISPCA have been coerced by the current structures into not pressing charges in various scenarios. For example, the laboratories and the seizing of a multitude of puppies at Dublin Airport. The ISPCA are not even authorized to seize them, as they are somebody’s produce or property. They can take the puppies and re-home them only on condition that they do not press charges. It is a real issue of this legislation, or its lack of enforcement, that it only protects people or industries that profit from the use of animals, regardless of their welfare. For example, the microchip, licensing and vaccination of puppies, for export, is only affecting adoption services and not touching the puppy farmers so far.

The Cork vet conference described how the 243 breeding establishments, including (inappropriately) rescue services and hunt kennels housing more than 6 females, ‘are inspected by Department Vets’. This is not actually the case. It is in the dog wardens’ remit to inspect breeding facilities in the county. The wardens repeatedly ‘approve’ establishments that are later exposed as perpetuating horrendous living conditions, far more bitches than they have licenses for and severe neglect and illness. I allude to Myshall, Carlow and Cavan for example.

The number of puppy farms is also hugely underestimated. A local vet in Kilkenny said that, if they were to agree to inspect puppy farms, they would be on the road 7 days a week, that there are several hundred of them in a network between Carlow and Gorey to start with. However, rather than wardens, it should be vets and dog behaviour experts who regulate the farms. The former would have the authority to write a report that could be used to prosecute non compliance and the latter would be able to measure the dog’s level of socialization and care. Whoever carries out inspections will need to be made ‘authorized officers’ in order to implement any changes to outcomes. The following dog breeding establishment issues came up at the vet conference:

It was unanimously felt that we should call for a ban on puppy farming altogether, on the following grounds:

1.     Horrific living conditions – Ireland has been exposed as running shameful operations, with intolerable conditions.

2.     Unhealthy – There is an inevitable spread of zoonotic diseases and lack of basic ventilation, warmth and nutrition lead to the production of unhealthy puppies.

3.     Genetic defects – Defects occur due to inbreeding, in unmanaged establishments with no individual records of dogs. They often cause painful conditions to be inherited.

4.     Future problems are not spotted as there is a lack of screening.

5.     It is nearly impossible to socialize a puppy from a puppy farm. They are notoriously difficult to house train as they have been born in a crate and inadvertently ‘taught’ to defecate right there in the bed as the only option, which puppies in a better environment would naturally avoid.

6.     The people who set up as puppy farmers are the least appropriate keepers of animals. I quote our local puppy farmer “Dogs don’t need eyes to pump out puppies”. It is going to be very difficult to regulate an industry dominated by individuals with no regard for animals.

7.     It will need to be made illegal to advertise on line as that is where the majority of puppies are sold and specific penalties applied.

8.     In other countries, it is illegal to buy a dog unless the shelters are empty. We have approximately 11 dogs arriving at the local pound daily and putting them to sleep, selling them on to research and shipping them out to make fertilizer is not a long term strategy.

9.     Abandonment – Being allowed to breed and sell dogs contributes to the problem of abandonment. People impulse buy and then regret their decision.

10. Although there is a limit of 8 litters per bitch, it is considered nearly impossible to determine how many bitches people are keeping, let alone how often they are putting them in pup again.

Education

Education is considered a long-term strategy that can be put in place right away. This year, 2017, there is a new wellness programme being added to the curriculum of schools. This is to stop the depression, isolation and antisocial behavior that children are expressing. It is an ideal opportunity to develop people’s natural affinity with animals through responsible pet ownership classes, teaching the physiological needs of various animals and to teach kindness. If the next generation is taught how to care for animals and given an awareness and respect for them, we will see many fewer being abused.

Because regard for animals is so low in Ireland, people believe that it is okay to mistreat an animal, abandon it, abuse it and torture it for entertainment. The internet is full of photos of young men and women holding up dogs and cats in Ireland that they have nailed to the floor, buried alive, chopped off its ears etc. Welfare, care, responsibilities, justice and compassion must be included in the new ‘Wellbeing’ modules in secondary schools. In return, animals will give the young the emotional comfort and support they need, the friendship and the playfulness to wake them up to a sense of nature and where they fit in to it.

There is evidence for a direct correlation between animal cruelty and domestic violence. We have an opportunity with the review of this legislation to set a new balance here; where kindness is rewarded and exploitation is penalized. People feel that would be a good basis for welfare legislation.

Dogs Trust have said that they would happily fulfill this educational role and expand their current education programme to all school years.

Dog Fighting

In the meantime, a central problem is animals being stolen as bait for fighting dogs or to sell on.

These groups must also operate on line (no doubt, Donedeal.ie again). There could be a project to crack down on dog fighting rings.

Beyond making it illegal, the guardai’s role must be clarified and clear penalties applied, as a deterent.

Welfare of Farm Animals

Live Export Ban

Most farmers would like to sell their animals in Ireland but the five big meat and offal producers keep limiting the amount of animals that farmers may bring to the factories and offering much reduced prices for their animals. This means that they are forced to sell the animals abroad to get a fair price for them. It is one of the same big players who collects all the offal from the factories and also has a monopoly on this in the UK. It serves him and others in the supply chain for there to be more and more animals reared in Ireland. They can then refuse to take the offal after a certain point and factories must turn farmers away or offer them next to nothing for their animals.

During live export there are supposed to be vets to oversee welfare and regulations, around how long animals may be transported without food, water or being unloaded and loaded again. None of these regulations are enforced and that is without even considering the welfare practices of the countries where animals are sent. Any merciful human being would make sure it is stopped and investigate how to regulate the meat and dairy producers, rather than penalize the farmers more.

Farmers are being offered very low interest rates on loans and bits and pieces of subsidies to lure them into further debt. I am in contact with several farmers who have not yet been able to pay for last winter’s feed, let alone this one. That is a welfare concern as well, if animals can’t be fed. Farmers have no idea what they will get for their cattle having kept them for their two years, their sheep for one.

Cows

People want a change from intensification to Organic Keep standards. This guarantees better quality, better value, better health and better welfare all at the same time. There are a massive amount of antibiotics being fed to calves to keep them alive in their first few months. It would help if they could be born outside, away from the closed-in environment of sheds, which harbour and spread disease. The sucklers are not as ‘at risk’ welfare–wise as dairy cows. Farmers aim for sucklers to be born in August or September when it is still warm outside and then they stay with the cow for seven months. For dairy cows, they are usually inside when they give birth. It is planned for the calves to be born in January or February, as that is when the new grass is starting to shoot. It does not matter if the calves of dairy cows live or not, as it is the milk that the farmers want. Those calves are usually sold cheap. Within days of being born they are transported to Holland and Belgium mainly and confined to make veal. These must be under 31 days old to be accepted abroad. The ones that are bought by Irish farmers are raised intensively in sheds on milk powder, with antibiotics regularly needed to tackle pneumonia and coughs. Most of them are tormented by ring worm for their whole life, as they grow and must exist in closer and closer proximity to each other and the fencing where it is also spread.

The legislation for organic standards are to give more bedding, a more ventilated environment, less cows per square metre, non genetically modified or sprayed feed etc etc. It might not suit the fertilizer, chemical and pharmaceutical companies but the meat end result would suit public health and it would improve the welfare standards of the farm animals too, to move towards these standards. It can be corrected that farmers meeting better standards pay a great price for the labeling of their efforts and intensive farmers, totally reliant on chemical fertilizer, pharmaceuticals, pesticides and GM or sprayed feeds do not have to identify that on their labels.

In non organic farms, which is 98% of Ireland’s farms, the vets are cashing in on the endless regulations for farmers - €5.75 just to sign their name on a bit of paper. Sometimes that might be just to confirm the weight of a cow or to report that an ear tag has been lost. The TB testing is an industry in itself. Every year they must be tested and sometimes more. Over €800 the vet charges for less than 5 hours work. The farmers believe that it is improbable that any of the cases of TB are actually definite. It just suits the industry to keep that myth alive and now to line the pockets of the pharmaceutical companies further by suggesting the vaccination of badgers. The TB link to badgers is tenuous, the presence of TB at all is tenuous but it is an incredible earner.

In regard to TB and legislation, it is most important to understand what happens to cows that are tested positive for it. They must be taken to the factory and destroyed. The farmer has to pay for that but the factory may cook the meat and then include it in their meat products and sell it at full value. This might be also a public health issue. If it can be cured and is no risk to humans, then why should the farmer not hold on to the cow, treat it, let it recover and retain the value?

Pigs

Pigs desperately need welfare legislation enforcement, as the laws are there. There is little sign of the five freedoms that should be afforded to pigs. It was more economical for the farmer to let a thousand pigs burn alive in Bagenalstown, Co. Carlow last year than to let them out of the burning building. The guidelines say that they should not be on slatted floors unless it is more economical for the farmer. It must be considered that only people who intend to make money become pig farmers and so the risks of putting economy before welfare are very high.

The guidelines also state that there should be bedding and rooting material. Pigs should not be tethered. However, 99% of pigs kept in Ireland are still in crates, with no room to move or nurse their piglets. The piglets are castrated, tails cut off and teeth pulled out without any anaesthetic. This is not acceptable to the groups I have consulted with.

Human Health. Again, there is so much illness amongst pigs, that the antibiotics and vaccinations pigs are given must pose a threat to human health as well, as they are carried along the food chain. Legislation could promote a move to less intensive breeding. If there were a move towards less numbers, organically reared and free-range it would improve the welfare of pigs and the quality of food produced from them.

Legislation could simultaneously stop live export and also ban the import of (even less well cared for) pigs from other countries that force Irish farmers to cut corners further, in welfare and feed. 

Sheep

20 million euro was given by the state last autumn for sheep welfare. Within a few days, 2 million was given to every other animal’s welfare collectively. This might be another contradiction in the welfare system. Sheep farmers confirmed that that 20 million was mainly a way to give a further subsidy to sheep farmers (but only to big sheep farmers as smaller ones were not eligible to apply, which is significant). The money was distributed under the sections Fly Strike, Hoof Rot, feed for ewes before giving birth and minerals for both before mating and before giving birth. It amounted to €10 per head and farmers had to prove that the money was spent on whichever section they had applied through. Although foot rot is the most pressing issue for sheep, the chemical dips are not a longterm strategy.

Even though farmers can get foot rot out of the land, the chemical treatments mask the individual sheep and breeds of sheep that have a natural immunity to the problem. These are the sheep that we need to be breeding, instead of dosing up in greater and greater amounts and affecting soil balance and wildlife at the same time. A further problem is that the factories also heard about this subsidy going to sheep farmers and now literally deduct that ten euro, from what they will offer for a lamb.

CCTV Welfare in factories and Meat Producers

Although animals are at the end of their life here, it is a place where unnecessary violence is routinely exposed. One farmer said put it that there should be ‘dignity in life, dignity in death’. However, being kicked, stabbed and skinned alive, in full view of each other, are all accepted in abbatoirs. We would ask for monitoring by CCTV cameras.

There is also a supreme public health risk that could be monitored this way too. The risk of cross contamination. It is generally understood by farmers that their care and keep are regulated excessively, while once the animal hits the factory floor there is no enforcement. We have all heard of the DNA samples from meat producers showing traces of up to 5 species in one batch of beef.

Chickens

There are 3 million chickens sold every week in Ireland. Welfare and public health concerns are tied together in this industry too. It is speculated that 98% of chickens have muscle disorders now and carry 250% the fat they should, following intensive farming and cramped unhealthy living conditions. The chicken now has white stripes in it that confirms these disorders and there has been considerable footage circulated of chicken unable to carry their own weight and worse, in the broiler industry. There is also a very loose criterion for calling a product free range or corn fed, including possible access to daylight through a small grate shared by thousands of others and non-organic corn. It was required by the EU that the space, a caged chicken gets, be increased by 50cm squared. This is not very much but the EU gave member countries 12 years to implement it and as that period came to a close, 9 countries wrote and apologized saying that they were not going to make the deadline.

This slow pace of implementation is one of the main concerns in Ireland. There is a misplaced assumption that companies want to offer better welfare and generally better practice to preserve their reputation and that of the wider animal agriculture industry. However, the main motivating force is to ‘get away with as much non compliance as possible’. It is literally considered an art form and the casualties are the consumers and the animals’ welfare beforehand. In this I refer to intensive farming practices, transporters, slaughter houses and meat processing plants.

A ban is requested on grinding up one day old male chicks alive. These are considered a by product of the egg industry and are therefore not considered valuable. Another process is to fill bin bags up with the living chicks to suffocate over time. Another process is dropping them on to a conveyer belt to be deposited in boiling water. Can we not do better than this? There is obviously a way that male chicks could be raised to produce meat. There might also be an overproduction of laying hens and eggs in general.

Chickens are highly sensitive birds with a complex social structure of their own which is rendered untenable with over a 100 birds, leaving greater numbers in a state of permanent stress. Pigs as well have the intellect of a three year old human and should be accommodated accordingly. More importantly they have the exact same heart as a human heart. I have heard from several people who have received successful complete heart transplants – not just valves – from pigs. They feel it is inappropriate to overlook these likenesses and characteristics.

Sale of retired greyhounds

A ban is requested on sending greyhounds to China or other dog-eating countries.

Welfare of Greyhounds and Hares in Hare Coursing

The majority of the population is behind the Irish Council against Blood Sports in calling for a ban on hare coursing. The cruelty, the declining numbers of wild hares, the precedent that it is banned everywhere else, the fact that it is subsidized by over a €100,000 public money annually, the unnecessary suffering of a wild, non predatory animal being trapped and then made to run for its life, for entertainment and income for the gambling industry. Whether it is tossed and beaten to death or not, the welfare of the hares is markedly overlooked, in this sport.

The least decent people travel to Ireland to watch the coursing, in the same way that research companies choose Ireland for our lax welfare laws. Similarly, we are producing meat beyond our capacity in Ireland and causing environmental damage through carbon emissions, which also suits other European countries. Also similarly, Ireland has let the resources of gas and turf continue to be used, when your legislation could protect, monitor and regulate what damage is done, rather than just let it happen. Just because it is allowed does not mean it should be continued. Just because something is a tradition does not mean it is justified. Just because an industry or sport makes a bit of money or provides a few jobs should not put those industries outside the constraints of the welfare legislation. We need a big move in policy to be exemplary in preserving life and the quality of life for all affected. There will need to be inspectors but there are many willing and qualified to monitor and advocate on behalf of domestic and wild animals, for marine life and healthy food, they just need the information chain to be coordinated, in order to feed back to authorized officers.

Some are aware of the services of the Agriculture, Food and Marine Animal Welfare helpline. It is still not widely known what happens to information delivered on this line and how reports are responded to.

Include legislation that requires a regular donation to retirement welfare

Coursing dogs, when they are finished with, are put in rescue schemes or put down. Racing greyhounds end up in rescues too. There is a Retired Greyhound Trust. In the UK, book makers must, by law, give a donation to the Retired Greyhound Trust. Not so here. The welfare law could incorporate some responsibilities to industries that benefit so specifically from the use of animals. They could be required to provide for them, during their working life, through welfare and sponsor their keep, in retirement, for good service. This obviously goes for the Horse Welfare Trust and other rescues as well.

Traveler Education

There also needs to be horse and dog care projects for travelers. In a local Wetlands haulting site, 66 dogs were found. None of these had licenses and all were neglected and suffering from mild to severe mange and other health difficulties. The wardens said they could go in and seize them but where would they take them, there is nowhere for them to go. If there were dedicated inspectors to each county, frequenting the different operations and traveler activities, welfare would improve under that supervision.

Stray and Traveler Horses and a Sulki Road-Racing Ban

It is widely considered that horses are at the most risk at the moment. If Four Seasons Promotions, trading as ACS (an animal carcass collection company) are deemed an inappropriate choice to manage the Dog Shelters then the department should consider withdrawing the public contracts they already hold for the collection, impounding and disposal of horses.  To this end, please find to follow two alternative proposals. They would deliver an animal welfare response to dealing with stray or abused horses. At the same time, it would be possible to make a sulki road-racing ban a reality. It would be welcomed by all sides, including the travellers:

Current horse contractors collect and immediately dispose of horses for €980

A rescue network would collect, hold, recover condition of, microchip, passport, geld if necessary and break-in horses for the €980. Local authorities could make an income on the sale of the animals to home-checked new owners. This would range from €50 for a companion animal, through to €2,000 for a safe riding horse, with scope for further training.

In this model the figure of €980 and therefore the spending of public money could be broken down and monitored with complete transparency.

€15 per hour driving

Diesel charged on the basis of €25 miles per gallon (Half the cost of diesel go towards the use of the box)

€120 For vet             – microchip €75

-       registry of passport €45

€600 Keep and training/care 

There could be an arrangement with vets to take horses to the practice, so key passporting and initial condition checks would be done en route to the foster home. 99% of stray horses are travellers horses.

The establishment of a ban on sulky racing, would be possible if off-road facilities were provided. The travellers themselves would run them and pay for it themselves, under strict animal welfare supervision. Consultation with the travellers themselves confirms that if a track was provided, they would use it and participate in any courses offered.

In America there is a successful model, consisting of a circular all-weather track and furthermore all the horses are stabled there. In Ireland as well, the travellers have plenty of money. They would pay for such a facility on a regular basis and it could be scaled on the level of care they provide for their own horses, like a livery yard, necessary micro-chipping and passports initially and then how much they intended to use the track, for training and race days.  These facilities would not need to be close to towns, there is plenty of out of the way land that might already be public property, where such tracks could be provided. Sulky racing in England is also popular and in North Wales there are proven groups implementing animal welfare, design of the tracks and supervision of such facilities. Attitudes and habits can be changed but bans and facilitative projects must be mediated respectfully. Again, there are already people and groups that combine this equine and social inclusion work successfully. The travellers have the money for hay, feed, water, training, competitions and grazing. What they do not yet have is a culture of animal care or a set-up to provide these basics.

The Managed Resale of Stray Horses

For the purposes of this review, we would like it to be considered that selling a good horse to a good owner (background and home-checked), would contribute to stopping the further deflation of the horse market. This is instead of only offering horses and ponies on loan, after rescue which is common practice. It has been identified that this deflation is one of the main reasons there are so many unwanted horses. In addition, letting people really own a horse retains the idea of investment.

At the moment, the horses are the worst provided for, in terms of government policy and welfare. Security and disposal have been prioritized with even recent government policy explicitly preferring that horses are put down rather than even impounded. There is a series of unresolved connections between the meat industry, the horse collection services and research facilities that are putting horses and public health at risk. Please do not leave these groups outside the law as the amounts of money that can be claimed means that there is even an incentive to collect horses. There have been reports that several have been seized that were not even straying. For example, there were the 29 seized – a mixture of pregnant mares, stallions and ponies all loaded together under department veterinary supervision, guardai and the ACS wearing balaclavas. The horses were micro-chipped and in good condition but they were all transported together,  against regulations. In that instance a judge stated that the owners must be let in to the pound to check the condition of the horses but they were refused and it turned out that all the animals had been put down, rather than impounded.

Conflicts between the existing parts of legislation

Greyhound Welfare

Bord na gCon were asked to use the welfare of greyhounds act to address a case of a hoarder of 120 greyhounds in Offaly, in recent weeks. All of the dogs were severely neglected. It was recommended that the offender get each dog DNA tested and then sell them. This didn’t address the neglect, the non compliance, the interbreeding in the first place, lack of monitoring of who was mating with who. Also it was not realistic that, at €80 per DNA test, the offender would take that follow up action. A welfare stipulation of actually feeding the dogs should have been first and foremost or seizing them and setting a fine that would cover the treatment and rehoming costs.

All dog breeds’ welfare

Please remove the contradictions in the legislation around pet adoption. Rescues are not allowed to rehome a stray animal for one year and a day. This is particularly if there is no micro-chip. On the other hand, the government is (as of autumn 2016) withholding state payments to rescues who do not sign an agreement to put animals to sleep and not keep them long. This means they cannot keep them or rehome them.

Dog Welfare and Dog Control

Then there is the conflict with the Department of Environment’s Dog Control Act.  With that, stray dogs must be kept in a pound for 5 days to be reclaimed. They cannot be rehomed during that time and it is preferred that they are put to sleep after that time. This is rife for exploitation by animal collection services. They are protected, by law, in getting rid of healthy animals. This is by any means and doing no rehoming, adoption work or education. In addition to the public pound contracts, the collection companies benefit when they dispose of the carcasses and for the collection of dogs and for the sale of seized or surrendered dogs on to research or to the animal body parts factory in Riga, Latvia, where the ACS are actually registered (with no physical office in Ireland).

Contradictions in the distribution of public money

Animal-related public tenders for the dog and horse pounds are all going to private for-profit firms. There is no welfare, these private firms are just prepared to ‘get rid’ of the unwanted animals and make it a further economy. They have made, illegally, some of the pounds ‘closed’ pounds, so people may not enter and see if their dog or horse is there. Dogs surrendered to the pound can be put down immediately without the 5 days’ grace. There is state facilitation of all the wrong groups. Could legislation be changed so that shelters can tender for the county pounds, without losing their ‘not for profit’ status? The benefit of having an animal welfare organization group is that they have managed shelters already, know how to assess animals and rehome them. They are motivated to monitor puppy farms and provide education and training for dogs and owners. This willingness to do the work and experience of how to make a network work to improve welfare will be key to enforcing legislation.

Request to waive the passport and vaccination legislation for rescues

There are groups like Blue Cross in England ready to take some of our unwanted dogs and willing to vaccinate, spay and neuter, passport etc. Ireland’s shelters are overflowing with unwanted dogs and the new legislation adds 6 weeks to the rehoming time. We would be very grateful if the microchipping, license and rabies legislation was waived for rescue groups.

At the moment, even if the Blue Cross or Dogs Trust or anyone can rehome dogs to England, the 6 week process places a considerable additional financial strain on the rescue centre. It all benefits the vets, the pharmaceutical companies and the license revenue and none of it enhances the welfare or future outcome for the dog or dogs in general. The rescue centres already spend a lot of money on emergency care and rehabilitation.

What could happen instead is that free, or at least subsidized, ‘Spay and Neuter’ programmes be made available. If possible, make rescues exempt from the passport and vaccination unnecessary expenses and use that legislation as a tool to hold the puppy farmers and other traffickers to account instead.

Cats are treated like vermin in Ireland

Please look to a country like Finland or others who know how to revere an animal and keep them responsibly. Spay and neuter programmes again would be a helpful welfare strategy to subsidize and reduce the problem of strays.

Blood Sports Bans

Ban on use of Terriers for ‘Dig Out’ of foxes

Although we would like a ban on fox hunting, can it first be considered to ban the process of digging out foxes, using terriers. This fight happens underground and both animals are savaged. Perhaps it would be fair instead to stipulate that the fox can go to ground and escape. If only drag hunting was allowed, it would make for a guaranteed good day out, where the route and pace could be set, far fewer accidents, welfare incidents with horses and hounds and less damage to land.

Ban on Pet Shops Doubling as Zoos

Please address the problem of unlicensed ‘mobile zoos’. The welfare aspects are several. The zoo legislation states that exotic pets should have permanent housing but they are living on the road, with no location registered. They are operating like circuses, with boas, pythons, crocodilians as well as the more common rabbits and hamsters. There are no logs with details of each animal – the dietary, housing, care or behavioural needs noted. No registered owner, let alone requirement for that person to be qualified to handle these animals. When they die or are sold, there is no record. This is particularly problematic as these mobile zoos are often attached to pet shops, where there is the priority of selling and showing these animals for profit. This is the opposite of a licensed zoo that has conservation and educational priorities and prioritizes the monitoring of their residents’ welfare.

There is also a public safety risk as the animals are handled, at shows, by the public. The stress could change their normal behavior too. For example the same animal may be used four or five days in a row and kept in a box in a van in between times. The roadshow itself might be two hours plus. The law says that an animal must have a permanent residence, a log of dietary and veterinary care and the organization must have a zoo license. Are these mobile zoos saying that the pet shop itself is their permanent residence? The zoos are not licensed to them as far as can be established, they advertise on line. Perhaps they are registered to an owner’s or staff member’s house. But, again, roadshows are booked on line with no establishment or physical address associated with the web address.

This also means there is no way to oversee the welfare. There is nowhere registered for inspection. They don’t seem to be insured, they are non compliant with the housing welfare legislation, they have no zoo license and no logs.

The solution to this would be having authorized officers – with a relevant background to inspect and help operations achieve welfare compliance. 

Ban on Fur Farming and Re-Wilding of Mink

We ask for the legislation to at last deem fur farming illegal in Ireland. It would be possible to work with the wildlife department to re-wild the mink. Mink would usually have a kilometre of riverbank to live, per family. In the fur farms they are kept in darkness packed into small dirty cages. When it comes to killing them, they are gassed en masse and many of them are still alive when they are skinned. The only arguments for fur farming are vanity and greed. Therefore, the people who manage such farms are inevitably unfit and unmotivated to keep animals to any welfare standards. Inspectors will have to monitor the fur farms and oversee their closure. The merits of re-wilding are an interesting concept being explored by Monbiot at the moment. It is the very opposite of the semi-tame deer in Killarney National Park for instance, who are now being porned off to trophy hunters. People consider it unjust to shoot deer that have seen people on a daily basis for years and had no previous need to fear them. That makes them the very definition of ‘an easy target’ and therefore we would appreciate welfare legislation extending to protect them too.

Animal Testing

The owners of Charles River Laboratory were charged with four of the worst non compliances of welfare ever exposed. Ireland has become the animal testing capital of Europe (the people of Ireland do not want this). This can only be because Irish legislation facilitates and protects companies offering as little welfare as they want, to make the most money and completely unmonitored or inspected. Even further than that, a freedom of information request was refused to disclose exactly what tests are being done on animals, as they would be deemed so cruel that it might invoke attacks on the staff. That says more about what is being tolerated than about what will not be tolerated.

Possible Welfare in Laboratories

What we do know is that the laboratories offer a ‘continuum’ of testing to companies and 80% of it is commercial product testing and not even for scientific or medical research. This re-write of the legislation is an opportunity to fully replace the use of animals with the computer models that Ireland has been exploring and funding. At the moment we are not ‘reducing’ (the number of animals used) ‘refining’ (using experiments that cause less pain or stress of the animal, or ‘replacing’ (with computer models, biochemical alternatives or replacing more sentient animals with less sentient animals). All animals suffer. It is considered unfair, to the majority of people, to test toxic ingredients and substances repeatedly on animals, including chemicals and nicotine etc which all animals, except humans, naturally avoid.

Please navigate a way to make computer modeling not prohibitively expensive.

Research from the Hadwen Trust who do not use animals in their testing are a useful resource and it was said recently that the only factor stopping the switch to computer model testing was financial. Please as part of the welfare policy make it affordable and make it compulsory. It is widely understood that animals are not even remotely parallel to humans so many of the test results are irrelevant. It is also well documented that the stress of the experiments means that the animal’s own physiological response cannot be relied upon to be representative of anything either. As with all research, please do not allow policy to assume that the research is rigorous and unbiased: Ireland has invited Merck  in to Ireland, heralded as bringing jobs, even though they have 800 ongoing lawsuits against them for just one of their vaccines. Experiments over one or two years will never demonstrate the accumulative affect of a chemical or medicine or later impacts it might have on the human body. Therefore, there is a real argument for banning animal testing as insufficient and irrelevant and an avoidance of real accountability.

Please refuse licenses for research companies to breed puppies and regulate how they acquire other dogs and cats, for testing

Companies should not be allowed to breed puppies for their laboratories or be facilitated in taking our stray dogs, with a small payment to our animal collection firms, to torture with impunity. It is widely known that the dogs and cats of non specific number that were released from the laboratory in Mayo, were put up for adoption in the UK for a number of significant reasons. One might have been their condition but also the fact that they may be recognized as lost family pets if they were advertised for rehoming here. At very least, laboratories should pay a penalty for non compliance and cover the costs of vet and rehoming for the animals released.

Marine Life

We call for a ban on super trawlers in Irish Waters

Fish are facing complete depletion. Inspectors on super trawlers spend the same time on them, as on local boats, even though they can carry 7000 tonnes of fish. In addition, these boats are often fishing where they should not be and are not asked to leave. The super trawlers have been exposed, by their own crews, as catching up to 12,000 tonnes and throwing 5000 tonnes of the smaller fish back dead, so as to only declare their allowance. Inspectors can’t be expected to really work out what is going on in a freezer factory of that scale and to compare logs to check on quota, all within a one or two hours inspection. In parallel to the freezers in meat processing companies, it is impossible to see what is there and what should be detained. Those slightly smaller fish would have provided major catches for Irish fishermen along the coast.

No Take Zones

Stocks of fish cannot replenish themselves, 1) if they are taken in such numbers and 2) if they are thrown back dead.

Around the UK, they have identified 27 dead zones where there is no marine life and have designated ‘no take zones’ where fish can breed and multiply again without being found by radar and shoals being caught, in their entirety, in the super trawler nets that are twice the size of football pitches.

Perhaps it would make sense to not make the ‘no take zones’ around the coast as that will only further penalize Irish coastal communities. Instead, it might be possible to propose to Europe to declare Irish Waters totally a no take zone for five years so that it can recover. This would be much easier to police as all boats could be asked to leave, without inspecting the finer details of their practice, their catch, their logs or their permits. The 1km area from shore could remain open for fishing for small boats. This would only require the discernment of the fishing community, the sale of the fish within Ireland and then their exemption from the ban need not be formally accounted for to Europe, if that was a concern.

Seismic blasting

It is common knowledge that Shell are making 17million euro a day from the Corrib gas line. It is not clear how destructive the operations continue to be to sea life. The welfare of marine life depends on there being an end to Seismic blasting, to map the seabed and prospect for more fuels. Please confirm that that has stopped. Please also monitor the level of noise that the drilling, drawing or transporting of gas and other by products continues to produce and what effects they are having on the surrounding area. Leaks are also a problem, as there are flares above sea level and no doubt contamination below. It is one thing to allow money and resources to be used but this welfare legislation could rein in the ecocide that is happening under the radar.

Contamination

Please don’t allow the cull of otters on the rivers, as if they are causing the shortage of salmon. Everybody knows that the sea has been stripped to nearly a dead zone and the few salmon that make it back to the rivers at all are representative of the few there are left. Also the computer companies, Coca Cola, increasing untreated animal agriculture run off, the chemical producers and unchecked levels of plastics and toxic waste in the sea and rivers are also having an impact. As the department of animal agriculture, food and marine, welfare education and regulations could be put in place around these topics. It might also be possible to secure a commitment from the companies themselves, under their Corporate Social Responsibility programmes, to lessen their impact on nearby water sources.

Boiling lobsters etc alive in restaurants

Please ban this as they clearly demonstrate their suffering with the sound they make. Also ban foie gras and veal while you can. This shift in policy to eliminate extreme practices from the food chain will have a knock on effect, alerting ordinary people to consider such factors when sourcing food and products.

Circuses

The welfare of animals in entertainment is difficult to manage, partly because they are on the road a lot. Nonetheless, there are people who do monitor circuses that use animals and they could be utilized, to contact an authorized officer to intervene in cases of cruelty or neglect. The most recent case of the three elephants routinely hit with bull hooks at Belly Wein Circus, ended badly as those working for the welfare and good practice could not use the law. Advocates were invited into the circus grounds on the pretext that the circus staff offered to prove that the animals were well looked after. When they were inside, they themselves were battered with bull hooks, both men and women. When the guardai arrived, it was the advocates who were taken away. Instead, the network of motivated animal advocates could provide shelter for the animals, should they need to be seized. The alternative is that the circuses just move along to a town where they are not met with criticism or they decide to stop using the animals and leave them uncared for, as no longer earning their keep. Neither offer improved welfare but there is the offer and the ability here of rehoming abused circus animals, should you want to enforce a ban on circuses using animals in Ireland.

Conclusion

We would appreciate this review of the Act to demonstrate effort and vision being put into a new welfare strategy, that acknowledges the value of animals, beyond the economic exploitation of their body parts.

Please could it also reverse the present situation that every socially motivated service or good practice is funded by donations and managed by charitable voluntary organizations and then the State subsidizes all the for-profit industries? This goes for provision for both people and animals.

Please can this review seek to engender empathy with an enforceable bit of legislation that incentivizes good practice and enlists a full capacity number of authorized officers, to implement and enforce the legislation. New authorized officers can be people already working in and proven in the welfare laws and therefore reduce the need for new salaries, just payments for the additional remit they are recruited to monitor. Fees and fines that would be recouped from offenders would quickly recover the extra inspectors employment costs.

Many thanks for your interest,

Frances Micklem