Pawlicy priorities for Scotland - Dogs Trust
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Pawlicy priorities for Scotland Dogs Trust 1
Contents Our pawlicy priorities for Scotland 1 Aversive training devices 2 Dog breeding and sale 4 Advertising 6 Dog boarding, walking and grooming 7 Enforcement of companion animal welfare legislation 8 Puppy smuggling 10 Fireworks 12 Livestock worrying 14 Hope Project 16 Our rehoming centres 18
Our pawlicy priorities for Scotland We are the UK’s largest dog welfare charity and normally we care for around 14,000 dogs each year across our network of 20 UK rehoming centres and one in Dublin. In Scotland we have two rehoming centres, in Glasgow and West Calder. On average, we rehome around 700 dogs a year in Scotland and have over 430,000 supporters across the country. Since Dogs Trust (formerly National Canine Defence League) was founded in 1891, we have campaigned on dog welfare issues. We invest substantial resources in information services, community outreach programmes, and education on responsible dog ownership. Our work extends to cover a variety of different activities, including providing responsible dog ownership initiatives and education workshops for children – in 2019, we taught more than 29,000 children across Scotland by delivering around 800 school workshops. Although this work has been significantly impacted by the pandemic, in 2020 we taught 8,750 children by delivering 255 workshops in school and online. Our Freedom Project runs across the whole of Scotland – this project is a free fostering service for dogs belonging to those fleeing domestic abuse. In 2020, we placed 31 new dogs on the project, helping 21 dog owners flee abuse and reunited 32 dogs with their owners. Our Hope Project Veterinary scheme covers the cost of veterinary treatment for any dog whose owner is homeless or in housing crisis. The scheme runs in 10 towns and cities across Scotland, and last year, we helped 347 dogs across the UK by registering them on our vet scheme enabling them to access free vet treatment. The health and happiness of every dog is at the heart of all our work, which is why we never put a healthy dog down. Dogs Trust 1
Aversive training devices
We believe that the use of electronic shock collars as well as
other aversive training devices, such as sonic and spray collars, is
detrimental to the welfare of dogs.
This type of device is not only painful for a dog, but it can also have
a serious negative impact on their mental and physical wellbeing.
As well as distress at the time of use, dogs can develop anxiety and
other problem behaviours as a longer-term consequence.
The results of research1 on dog training methods found:
- There are consistent links between positive punishment or
negative reinforcement methods and problematic behaviours
such as aggression and poor learning ability
- Aversive training devices do not deal with the root cause of
barking or other undesirable behaviours
- Shocks from e-collars during training cause distress-related
behavioural reactions and are painful and physically stressful for
dogs
Under no circumstances do we condone the use of equipment
or techniques that use pain or fear to train a dog. We care for
approximately 14,000 dogs each year using reward-based training
methods only. For these reasons we have been calling for a full ban
on the use and sale of aversive training devices.
We are disappointed that despite previously committing to effectively
ban the use of electronic and other aversive training devices, the
Scottish Government only issued guidance about their use under
the Animal Health and Welfare (Scotland) Act 2006. This means that
Scotland’s pets are not adequately protected from the negative
impacts of using these cruel devices.
Whilst the use of electronic shock collars is banned in Wales, and
Westminster has confirmed it will introduce a ban on the use of
these cruel devices in England, the Scottish Government has only
committed to reviewing the guidance.
1 https://www.dogstrust.org.uk/news-events/news/the%20welfare%20impact%20
%20and%20efficacy%20of%20%20canine%20training%20methods_v4.pdf
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We call on the Scottish Government to implement a ban via secondary legislation on the use of electric pulse, sonic and spray collars, and to hold discussions with Defra about banning the sale of these devices. Dogs Trust 3
Dog breeding and sale
We welcome The Animal Welfare (Licensing of Activities Involving
Animals) (Scotland) Regulations 2021. From introducing a ban on the
third-party sales of puppies to updating the licensing system for dog
breeding, the updated Regulations mark the start of a significant
improvement for dog welfare. However, there is still more to be done.
As of September 2021, the new Regulations lower the licensing
threshold for breeders from five litters a year to three, bringing more
breeders within scope of licensing. However, we would like to see the
Regulations go further so that anyone breeding, selling or transferring
the ownership of a litter, regardless of any financial transaction or
gain, should be required to be registered. There should be a link-
up between individuals and their address so that it is possible to
identify situations where multiple individuals are evading licensing by
individually registering to breed or sell animals on the same premises.
It should then be a mandatory requirement for any advert to include
the individual’s unique registration or licence number. This would
ensure total traceability and only through the implementation of this
system will it be possible for enforcement authorities to proactively
and adequately tackle unscrupulous breeders and dealers that evade
the current licensing system.
We urge the Scottish Government to strengthen the minimum
legal requirements for dog breeding and sale to include a robust
system of licensing and registration.
We would like to see the Regulations go
further so that anyone breeding, selling
or transferring the ownership of a litter,
regardless of any financial transaction or
gain, should be required to be registered.
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Advertising We chair the Pet Advertising Advisory Group (PAAG), which was created in 2001 to combat growing concerns regarding the irresponsible advertising of pets for sale, rehoming, and exchange. Since its formation, PAAG has witnessed a significant increase in the number of pets and animals advertised for sale online. PAAG’s work has been endorsed by the Scottish Government, as well as Defra, DAERA in Northern Ireland and the Welsh Government. PAAG has created a set of Minimum Standards for the advertising of pets on online classified advertising websites, which are voluntarily applied by thirteen websites in the UK. Unfortunately, whilst the standards are voluntary, they remain limited in their impact as not all websites are willing to adopt them. We are calling on the Scottish Government to make the Minimum Standards a legal requirement, so they are applicable to all websites advertising pets for sale. We are pleased that The Animal Welfare (Licensing of Activities Involving Animals) (Scotland) Regulations 2021 make it a legal requirement, as of September 2021, for licensed sellers in Scotland to display their licence number on all adverts, along with some details about the pet being sold including a photograph and its age. However, due to our serious concerns around the sale of dogs, we believe that all forms of advertising, including online, should be verifiable. By introducing the aforementioned robust registration and licensing system, as well as creating a centralised, publicly accessible list of all registered and licenced breeders and sellers, buyers would then be able to check the legitimacy of breeders or sellers. This would allow a simplified system that would be easily accessible for purchasers to verify where they are buying a dog from in an increasingly online, nationwide marketplace. We urge the Scottish Government to introduce PAAG’s Minimum Standards as a legal requirement for all adverts offering pets for sale, in conjunction with the development of a centralised, publicly accessible list of registered and licensed breeders and sellers. Dogs Trust 6
Dog boarding, walking and grooming We believe that the Animal Welfare (Licensing of Activities Involving Animals) (Scotland) Regulations 2021 should be extended to cover dog boarding, including day care, as well as dog walking and grooming, as these activities all have the potential to seriously impact dog welfare. The Animal Boarding Establishments Act 1963 predates the Animal Health and Welfare Act 2006 and there have been significant advances in the understanding of dog behaviour and welfare in recent decades. There is also a loophole in the interpretation of the Act which states that: ‘a person shall not be deemed to keep a boarding establishment for animals by reason only of his providing accommodation for other people’s animals in connection with a business of which the provision of such accommodation is not the main activity’. We would like this loophole to be closed so that it is not possible for individuals to set themselves up primarily as a business which is outside of the scope of licensing and to then also offer boarding without the need to be licensed. Currently, this loophole means that dog walkers and dog groomers which board dogs as an extra service, do not need to be licensed and we strongly believe this loophole should be closed. We would also like the Regulations to explicitly include dog day care businesses, as well as dog walkers and groomers which are currently completely unregulated activities. We urge the Scottish Government to extend the Animal Welfare (Licensing of Activities Involving Animals) (Scotland) Regulations 2021 to cover dog boarding, including day care, as well as dog walking and grooming. Dogs Trust 7
Enforcement of companion
animal welfare legislation
We have serious concerns that inspections of animal establishments,
such as breeding premises and dog boarding facilities, are currently
often conducted by Local Authority officials with limited knowledge
of animal welfare. We strongly believe that anyone inspecting animal
establishments should be appropriately qualified in animal welfare.
We therefore recommend that the Scottish Government develops
a central unit of suitably trained inspectors which can be utilised
by any/all Local Authorities to carry out inspections of animal
establishments. This inspectorate would have to have no profit-
making commercial interests in order to ensure that the goal is not
on profit, but on animal welfare. Licence fees should be set by Local
Authorities to allow full cost recovery for this.
In the absence of this, the Scottish Government should provide vital
training and support for Local Authority inspectors to enforce the
right breeding standards.
We call on the Scottish Government to introduce a central
unit of appropriately trained inspectors which can be utilised
by Local Authorities to carry out inspections of animal
establishments.
We recommend that the Scottish
Government develops a central unit of
suitably trained inspectors which can be
utilised by any/all Local Authorities to carry
out inspections of animal establishments.
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Puppy smuggling
We have long highlighted the failures of the Pet Travel Scheme
(PETS). Our investigative work in this field has found evidence of:
- Breeders and dealers in Central and Eastern Europe using PETS
for the illegal importation of puppies into Great Britain for sale
- Unscrupulous vets falsifying data on pet passports
- Vets in Serbia (a third county) providing pre-filled Hungarian and
Bulgarian passports and microchips for underage puppies, pass-
ing them off as EU-bred animals
- Vets in Lithuania offering to sedate puppies to allow them to be
smuggled into the UK
- A growing trend of heavily pregnant bitches being illegally brought
into the UK to allow dealers to dupe buyers into buying ‘UK bred’
puppies
- Ineffective border controls and enforcement of PETS at UK ports
- Lack of sufficient penalties to deter the illegal trade
Dogs Trust 10We urge the Scottish Government to work with
Defra and the Welsh Government to develop
an action plan to address the abuse of the Pet
Travel Scheme and the number of dogs illegally
entering Great Britain every day.
In 2016, the Scottish Government, Defra and the Welsh Government
consulted on the Non-Commercial Movement of Pet Animals Order
2011, which previously implemented EU legislation on pet travel into
domestic legislation. However, the governments have not put forward
any clear proposals. Now the UK has exited the EU, the Governments
have more powers to strengthen the legislation and end the suffering
of puppies caught up in the cruel smuggling trade.
We urge the Scottish Government to work with Defra and the Welsh
Government to develop an action plan to address the abuse of the
Pet Travel Scheme and the number of dogs illegally entering Great
Britain every day. This should include the following actions:
- Raise the minimum age for puppies to be imported into the UK
to six months to help make them less desirable. We support
reintroducing a requirement for a rabies blood (titre) test before
entry into the UK, together with a wait period post vaccination
which is in line with the incubation period of rabies. This means
that the age at which puppies could legally enter the UK would be
increased to six months.
- Bring in tougher penalties for smuggling pups to deter deceitful
sellers. Only a handful of puppy smuggling cases have ever been
prosecuted and you can get a longer sentence for smuggling
cigarettes than you can for smuggling puppies.
We call for an immediate action plan to address the abuse of
PETS and the number of dogs illegally entering Great Britain
every day.
Dogs Trust 11Fireworks Dogs generally feel safe and more secure when they can predict and control their environment, so fireworks, which are inherently loud, bright, unpredictable and difficult to escape from, can cause dogs immense stress which has a negative impact on their welfare, irrespective of whether they are used in a way deemed responsible or safe. Easy access to fireworks and few restrictions on when or where they can be used means it is impossible for dog owners to predict or prepare their dogs in advance of fireworks being set off. It can also be challenging for owners to introduce short term measures to manage their dogs’ behavioural responses if they cannot predict when fireworks will be set off, particularly if they are not at home with the dog when it happens. For these reasons it is a constant waiting game for owners or rehoming centre staff who are caring for dogs that suffer from noise fear. We were pleased when the Scottish Government consulted on the use of fireworks in 2019 and subsequently announced a Fireworks Action Plan. We proposed that there should be restrictions around the use and sale of fireworks, limiting them to licensed, public occasions at certain times of the year and organised events. We also recommended the introduction of a licensing system whereby fireworks can be sold to licensed venues only. Local Authorities should take the location of public displays into consideration when granting them a licence and require that they are well publicised in the surrounding area. For this to be enforceable, and as the sale of fireworks is a reserved issue, we urged the Scottish Government to continue discussions with the UK Government, with a view to banning the sale of fireworks to the public. As a result of the consultation and work by the Fireworks Review Group, the Scottish Government introduced the Fireworks (Scotland) Amendment Regulations 2021, amending the times that fireworks can be used and sold, and amending the quantity of fireworks that can be sold by retailers to individuals. We do not expect these changes to reduce the significant negative impact of fireworks on dog welfare and we strongly urge the Scottish Government to take forward our recommendations outlined above. We call on the Scottish Government to introduce restrictions around the use and sale of fireworks, limiting them to licensed, public occasions at certain times of the year and organised events. Dogs Trust 12
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Livestock worrying It is an offence for a dog to “worry” livestock i.e. (a) chase livestock, or (b) attack livestock, or (c) not be on a lead or otherwise under close control in a field or enclosure in which there are livestock. By law, farmers are permitted to destroy a dog that injures or worries their animals, so prevention is key to ensure all animals remain safe. Livestock worrying has a significant negative impact on the livestock involved and the farming community. We are therefore pleased to see that The Dogs (Protection of Livestock) (Amendment) (Scotland) Bill has passed. Once this Bill comes into force, it will extend the maximum penalties for those who carry out livestock worrying offences while also extending the legal definition of livestock. The Bill will also provide the police with additional powers to better investigate and enforce these offences. We welcome these changes but are also calling for the introduction of mandatory reporting and standardised data gathering to help build a better understanding of the prevalence and circumstances of incidents and what interventions might work to prevent attacks, recognising that these may vary between areas. We also continue to actively advise owners of measures they can take to prevent incidents when enjoying the countryside with their dog. We believe that dog owners have a responsibility to keep their dog under control around livestock. Training is crucial, particularly basic recall techniques and we would urge dog owners to visit our Dog School website for more information on appropriate training techniques: dogstrustdogschool.org.uk/training We also offer specific advice for dog owners walking in the countryside to minimise the risk to both dogs and livestock: dogstrust.org.uk/news-events/news/dogs-and-livestock We call on the Scottish Government to introduce mandatory reporting and standardised data collection as a means of helping to identify and evaluate proactive measures to prevent incidents of livestock worrying and attack before they occur. Dogs Trust 14
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Hope Project Our Hope Project provides free veterinary treatment for any dog whose owner is experiencing homelessness or housing crisis. Dogs that are part of our Hope Project Veterinary Scheme are entitled to free preventive treatments, such as flea and worming treatments, vaccinations, neutering and microchipping as well as most other essential and emergency treatments that a dog may need. The scheme runs in 10 towns and cities across Scotland and is available to any dog owner who is rough sleeping or living in temporary accommodation, such as a hostel or night shelter. Hope can also help dog owners who are living in other unsecure accommodation, such as sofa surfing and living in squats, as well as those living out of tents and vehicles. Dog owners can apply to our scheme through any participating homelessness organisation or by applying to us directly for support. Hope Project also works with temporary housing providers to help them become dog-friendly via Hope Project’s Welcoming Dogs scheme. We offer a range of resources and advice on accepting and managing dogs, including support developing a dog policy and addressing other areas such as health and safety, hygiene and behaviour. As part of our service in this area, we also offer onsite consultations to assist service staff in taking the practical and easy steps to welcoming clients with dogs. We are delighted to have launched a dedicated 1-year project in Scotland to strengthen this work. Through this project our Pets and Housing Development and Engagement Officer is working jointly with leading homelessness provider, Simon Community Scotland, to safely welcome and manage dogs in their accommodation services and improve dog-friendly provision across central Scotland. For more information visit: moretodogstrust.org.uk/hope-project- parent-our-work-in-scotland/our-work-in-scotland We would like to see more temporary and permanent housing providers across Scotland welcoming owners in housing crisis and their pets by adopting positive pet policies. Dogs Trust 16
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Our rehoming centres
Contact us to visit
our Scottish centres
Glasgow West Calder
= Scottish Rehoming Centre
= Rehoming Centre
If you are interested in visiting your local rehoming centre or would
like more information about the work that we do, please contact our
Public Affairs team:
E: publicaffairs@dogstrust.org.uk
T: 020 7833 5114
@DT_Pawlitical
www.dogstrust.org.uk/publicaffairs
Registered Charity Numbers: 227523 & SC037843 © Dogs Trust 2021
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