N.W.T.F. RESPONSE TO DEFRA'S PROPOSED CODE OF PRACTICE FOR THE WELFARE OF DOGS.
NATIONAL WORKING TERRIER FEDERATION SUBMISSION
IN RESPONSE TO
THE D.E.F.R.A. CONSULTATION DOCUMENT
"A PROPOSED CODE OF PRACTICE FOR THE WELFARE OF DOGS."
The National Working Terrier Federation (N.W.T.F.).
The N.W.T.F. was formed in 1984, when all of the major working terrier clubs in England, Scotland and Wales joined together to form a single umbrella organisation Their main aim being to promote and advance the most humane and efficient practices associated with working terriers. It now consists of some 26 member clubs, representing over 4,000 individual members, plus other affiliated organisations.
Through its Codes of Conduct and Accredited Membership scheme, the N.W.T.F. has singly promoted best standards of welfare and accountability in terrier work both nationally and internationally.
Its membership is primarily involved with the breeding and working of terriers for the purpose of controlling pests. It is an indication of their, and previous generations, skill, dedication and concern regarding the future well being of the breed, that the true modern day working terrier displays none of the hereditary faults which are so commonplace in so many other breeds today.
The N.W.T.F. has in the past provided both written and oral evidence on terrier work and working terriers at Westminster and to the Scottish Parliament, and similar written evidence to the National Assembly for Wales.
The N.W.T.F. is most grateful for the opportunity to contribute towards this consultation process and would welcome the opportunity to be included in any future debate or consultations.
2. N.W.T.F. Response.
We appreciate the Code is primarily aimed at those owners of dogs which are kept as pets or companion animals. Rather than the owners of working terriers, gun dogs, sight hounds, and other working dogs which have a more varied and natural lifestyle and one which enables them to more fully engage with their natural instincts.
Nevertheless, the Code as drafted applies to all dogs and while many of the recommendations it contains may be considered appropriate in respect of certain dogs kept merely as pets, they are not necessarily either desirable or practical in respect of working dogs, especially during their normal working activities.
We are also concerned that the Code itself is a lengthy document and unlikely to be read, understood and followed by every dog owner, and that the likelihood of different Codes in England, Scotland and Wales will further confuse matters for those many thousands of dog owners who regularly travel “cross border”.
SECTION 1 – ENVIRONMENT
1.6. "The kennel should be large enough for you dog to lie comfortably both in and beside its bed and it should be provided with clean, comfortable bedding."
Some purpose built kennels layouts are designed so they are ‘all bed' and have no room “beside the bed”. Nevertheless, they do provide excellent accommodation in which to rest and sleep, and have much to commend them when compared to other alternatives.
1.8. “You should ensure that there is sufficient room for all dogs to be alone when necessary”
The term “when necessary” needs further clarification. Consideration needs to be given to the fact that some dogs not only live in a pack/group environment, but also prefer doing so.
1.10. “It is good hygiene practice to clean up after your dog at home using a plastic bag or a ‘pooper scooper' and to dispose of any faeces in the waste bin."
Whilst this might be considered good hygiene practice in a small urban garden, the Code is intended to provide the Courts with advice on animal welfare matters, rather than attempt to deal with environmental issues. It also may not be quite so applicable or even feasible on large country properties and farms, particularly where dogs are dogs are exercising or working in cover and over large areas of private land.
1.12. “You should ensure that your dog is not able to move freely….”.
Working dogs will often be transported short distances across private land, at low speed, in a variety of different types of vehicles and without any adverse welfare implications. Is this something for which it is intended the owners should be prosecuted unless the dogs are restrained in some manner?
1.13. “Dogs should not be left unattended in a car or other vehicle in warm weather.”
There is nothing wrong in leaving a dog in a vehicle so long as this does not cause distress or in any way compromise the animal’s welfare. Working dogs, along with companion dogs, may at times quite justifiably need to be left in a vehicle. The real issue is whether by doing so the owner undermines the animal’s welfare.
This issue needs to be reworded from an animal welfare perspective and in such a manner as to ensure that the animal is left in a comfortable and stress free environment; one which pays due regard to extremes of heat and cold, and does not in any way compromise its welfare.
SECTION 2 – DIET.
2.2. “Your dog must always have access to fresh clean water from a clean bowl…”
The words “must always” raise a number of practical issues. We agree that where dogs are housed they must have access to fresh clean water and that appropriate provisions should also be made on long journeys and during a working day. However, it is inevitable that there will be periods of time during which when dogs are for example being worked, or companion dogs are simply being walked and exercised, that they will not “always have access to fresh clean water from a clean bowl…”.
2.10. "Generally it is better to feed an adult dog twice a day rather than the traditional once."
What evidence is there to support this statement? In the wild animals don’t eat each day, let alone twice daily. In reality they gorge themselves on a kill and then lie up. Including this statement means that someone who feeds their dog once a day could find them self accused of compromising its welfare.
2.12. “If you have more than one dog it is important to give each animal the opportunity to eat in privacy”.
Clearly it is an owner’s responsibility to ensure that every dog in its care is given proper access to food, water etc. This requirement applies equally to those who own a single dog or a number of dogs, regardless of whether they are housed and fed singly, or as a group.
In certain circumstances this may require some individual dogs to be supervised separately. However it is impractical and unnecessary to suggest that “each animal” should be given the opportunity to eat in privacy.
SECTION 3 - BEHAVIOUR.
3.14. “It is advisable to keep your dog on a lead …near livestock….”
Dogs are required to work off the lead and this may often be near, and sometimes in close contact with livestock. This fact needs to be acknowledged and appropriate allowances made in the Code.
3.15. “…avoid walking your dog during the hottest part of the day”
Every day will have a “hottest part”, regardless of whether it is during the height of summer, or the middle of winter. This needs rewording and further clarification.
3.20. “A dog owner…has a legal responsibility to clean up after it…when in a public place…”
As in 1.10 above, this would be impractical and impossible to apply in rural areas where dogs are being worked in cover and/or over large areas of private land.
It is unclear what is meant by “a public place” and it should be made clear that such a recommendation does not apply on private land or when dogs are undertaking a working activity, as opposed to being walked in streets, parks etc.
SECTION 4 – COMPANY.
4.7. "Dogs should not be routinely left on their own for more than a few hours during the day as they are likely to become bored."
The terms “routinely left” and “few hours” need further clarification. However, there is no reason why a dog cannot be left on its own for long periods providing adequate provisions are made for its comfort and wellbeing. Many working dogs live outdoors in purpose built accommodation; they respond well to such an environment and display no signs of boredom or distress. In fact quite the reverse, they are clearly contented and normally very quiet unless disturbed.
SECTION 5 – HEALTH AND WELFARE.
The summary on page 6 (veterinary treatment).
This states that if injured or ill you must ensure the dog is treated by a vet, however the main section on Health and Welfare is less prescriptive. As with humans, there are many minor injuries which dogs can and will sustain which are appropriately treated at home and it is disproportionate to state that if injured they “must” be seen by a vet.
5.6. "A long haired dog... will need grooming once a day"
This is bad advice for an outdoor dog, particularly during winter months. Excessive grooming will strip its coat, remove the physical protection it offers from briars, thorns etc, and also leave it more vulnerable to feeling the effects of cold and hyperthermia. Possibly “will need grooming to ensure its coat does not become badly tangled or matted” might be a more appropriate statement.
5.9 “your dog must wear a collar and identity tag when in a public place…”
There are genuine welfare and safety reasons why dogs should not wear collars while being worked below ground, or above ground in dense cover.
This section requires amending to make it clear that a dog may be collarless while being used for work and/or sporting purposes, and also to ensure there is a clearer definition of what is regarded as a “public place”.