-->
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
