The suggested code for the running of breeding establishments is unsatisfactory.
Here are a few of the problematic parts of the code, quoted from a RSPCA discussion:
- ‘Any method’ of euthanasia as long as it is humane. Humane is not defined and ‘any method’ could include shooting or blunt trauma, causing incredible suffering.
- Breeding and rearing establishments are not required to have agreements with, and 24-hour access to, veterinary services.
- Breeders will be able to declare an animal fit for sale – not vets.
- Raised pens with wire floors are permitted for the housing of working dogs - wire is an unacceptable floor surface.
And in more detail, here:
Business hours and animal: staff ratios
- Under the revisions, staffed ‘business hours’ for breeding and rearing establishments have reduced from 12 to eight hours a day. This means that animals – often in vulnerable stages of pregnancy or birth - are left for 16 hours overnight (when they are most likely to give birth) with minimal staff present. During business hours, the ratio of staff to animals is 1:25, but outside of these hours, the ratio of carers to animals is proposed as 1:100 (formerly 1:50).
- The revised code also deems a mother with her litter, and litters under four months as equivalent to one animal over four months old. That could mean a breeder could have 80 mothers with litters under four months, another 10 breeding mothers without litters and 10 adult males and provide only one staff member for almost 500 animals, during non-business hours.
- The requirement for vet checks at various stages of an animal’s life has reduced and vet checks to ensure animals are fit for breeding are no longer required before animals are bred from.
- Under the proposed revisions, breeders will be able to declare an animal fit for sale – rather than vets. Not only may breeders lack the appropriate qualifications to do this, but it may also mean that the animal and purchaser are not protected from post-sale welfare or return issues.
- Under the recommendations, a purchaser will not be able to return an animal for behavioural reasons more than three days after purchase – unscrupulous breeders and rearers will have little incentive to ensure their animals are behaviourally sound, before selling them.
- The recommendations allow for ‘any method’ of euthanasia as long as it is humane. Humane is not defined and ‘any method’ could, in theory, include shooting or blunt trauma, causing incredible suffering.
- Euthanasia via barbiturate overdose carried out by a vet is only ‘preferred’, not required.
- The proposed legislation does not adequately ensure that breeding and rearing establishments have sufficient agreements with, and 24-hour access to, veterinary services, to be able to provide animals with prompt veterinary care, if required.
- Breeding between second-generation related animals would be acceptable.
- There would be no maximum breeding age or period that an animal could be bred from, meaning these animals can potentially spend their entire lifetime confined to breeding establishments.
- Maximums litters numbers for females would be increased while males would have no maximum number.
- An individual animal with a heritable defect can continue to be bred from.
- Under the recommendations, some categories of puppies must not be left without food for more than 12 hours. But compliance with this recommendation will be extremely difficult during the 16 overnight hours, with staff ratios at 1:100, given all their other responsibilities as well.
- The feeding of raw offal is now permitted in conjunction with a complete worming program. While this recommendation might be more financially appealing to many breeders, it does not take into account the welfare issues associated with this diet.
- Standards and guidelines for retirement of animals have been weakened.
- Tethering is permitted (except for some categories of breeding females). RSPCA Victoria does not support tethering and advises against it.
- Provision for temperature regulation has been removed.
- Cats need only be fed once daily. We recommend that cats should be fed twice daily.
Working and guardian dogs (‘working dogs’)
- Working dog breeders have their own section and are exempt from many of the minimum standards and guidelines for non-working dogs in the current version.
- Raised pens with wire floors are permitted for the housing of working dogs. Wire is an unacceptable floor surface and there are poor welfare outcomes associated with it. The required dimensions of these pens are also too small.
- If working dogs are regarded as different to other animals under this code, the government needs to ensure that working dog codes of practice are developed which have these animals’ welfare as the key priority.
You can read the draft legislation here: