Promoting responsible dog ownership in Scotiand: microchipping and other measures

Transcription

1 Promoting responsible dog ownership in Scotiand: microchipping and other measures CONSULTATION QUESTIONNAIRE I 1 C - Sector " Which of the following best describes you? (Please tick whichever option applies) A dog owner A dog breeder "''-"' An animal welfare organisation/rescue, A local authority } Other The Scotfish Countryside Alliance is a membership organisation represenfing a demograohic with significant dog ownership The Scottish Countryside Alliance (SCA) is opposed to the introduction of legislation leading to the mandatory microchipping (or other measures) of all dogs in Scotland and do not recognise any justifiable reasons for adopting such a sever measure. The Scottish Government is already leading the way in public safety through the introduction of the Control of Dogs [Scotland )Act 2010, which in tandem with the Dangerous Dogs Act 1991 affording substantial powers in relation to dangerous or out of control dogs. Current situation in Scotland 1. Are all, some or none of the dogs/puppies in your care already/roufinely microchipped? Please explain. ' (Please tick whichever option applies) All Some None Don't know N/A ^

2 2. Do you offer a microchipping service to the general public? If you do, what geographical range do you cover, how many dogs did you chip in Scofiand in 2012 and how much do you charge? Please explain your answers. YesD No N/A E (Please tick whichever option applies) Number: Fee: 3. ff you run a rescue/rehoming centre, do you ensure that all, some or none of the dogs are microchipped prior to rehoming? How many dogs did you microchip/arrange to be microchipped in 2012? How many dogs came to you in 2012 that were already microchipped? Please explain your answers. All n Some None N/A (Please tick whichever option applies) Number microchipped in 2012: Number arriving microchipped in 2012:

3 Potential benefits of compulsory microchipping ^ Do you consider that compulsory microchipping would help to make dog owners more responsible? Please explain and provide any evidence that you may have. YesD No lel Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance does not believe that microchipping "per se" will make or help to make dog owners more responsible. We believe that the ability to carry out sanctions against an individual(s) and to remove or destroy certain dogs under current legislation a more appropriate way to punish those who breach legislation as opposed to the mass microchipping of all dogs. It is our understanding that Wales and England plan to introduce mandatory microchipping by 2015 and 2016 respectfully. However, Scotland has resisted emulating the tail docking exemption offered by England, Wales and Northern Ireland.

4 5. Do you consider that compulsory microchipping for dogs would help to deter dog theft? Please explain and provide any evidence that you may have. Yes No ^ Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance does not believe that microchipping will deter dog theft. Criminals will steal to keep, or sell dog(s) to unknowing buyers who are unlikely to have ownership ofa microchip scanner. The dog(s) may be reunited with the owner at some point in the future but this is not the same as deterring the theft. It is the understanding ofthe Scottish Countryside Alliance that scanners use radio waves to read the number encoded in a microchip by tuning into the right frequency, scanners need to be able to read the correct frequency to obtain this number. The problem is pet microchips come with different frequencies, such as 125 khz, 128 khz and khz. About 98 percent ofthe pet microchips in America use 125 khz, whereas those in Europe use khz [source: USDA]. Dogs that may be stolen in the UK can be re-chipped with a US chip and sold into the American market When scanned with the American frequency scanner the UK chip will not be recognised. The tables below show recorded crime where a dog was reported as being stolen between 01/01/2013 and 31/12/2013. Recorded crime Arrests Charged Convicted The increased use of the internet to buy and sell dogs and prices for some breeds encourages more and more buyers to turn away from traditional breeders. The low level of those charged and convicted reflects the criminal opportunity, regardless to whether the dog is chipped or not

5 6. Do you consider that compulsory microchipping for dogs would help to tackle the issue of puppy farming? Please explain and provide any evidence that you may have. Yes No Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance does not believe that the microchipping of all dogs is necessary or proportionate in relation to the control of "puppy farming. We believe that powers afforded to the Scottish government's under the Animal Health and Welfare (Scotland)Act 2006 and the most recent Code of Practice for the Welfare of Dogs more appropriate; and cite the most recent case against Charles Swan jailed for mistreating puppies and having his future assets seized under proceeds of crime legislation. 7. Do you consider that compulsory microchipping for dogs would help to address other dog welfare issues, such as abuse/mistreatment? Please explain and provide any evidence that you may have. Yes No lel Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance does not believe that the microchipping of all dogs is necessary or proportionate to help address other dog welfare issues, such as abuse or mistreatment We believe that powers afforded to the Scottish government's under the Animal Health and Welfare (Scotland) Act 2006 and the most recent Code of Practice for the Welfare of Dogs more appropriate; and cite the most recent case against Charles Swan jailed for mistreating puppies and having his future assets seized under proceeds of crime legislation as evidence of justice in the public interest when legislation is well policed.

6 8. Do you consider that compulsory microchipping for dogs would help to prevent dog attacks on people/animals, including on assistance dogs? Please explain and provide any evidence that you may have. Yes No ^ Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance does not believe that microchipping of all dogs will prevent dog attacks on people or other animals. We believe that the ability to carry out sanctions against an individual(s) and to remove or destroy certain dogs under current legislation a more appropriate way to punish those who breach legislation as opposed to the mass microchipping of all dogs. Potential challenges of compulsory microchipping 9. In the long term, the compulsory microchipping of dogs may require all owners to pay to microchip their dogs and to update their details on the commercial database that their dog is registered on. Do you think this would be an unfair burden on any particular sectors? Please explain. Yes ^ No Don't Know (Please tick whichever option applies) Rehoming/sanctuary charities Individuals in receipt of benefits Other Those who own/use dog(s) in connection with traditional field sport or pest control Many employed or participating within traditional field sports or pest control services maintain ownership of multiple dogs. Many of these dogs will have been breed specifically for certain purposes such as the flushing of gamebirds or fox's. Many gamekeeper, game shots, pickers up and beaters and pest control operatives breed/own sufficient numbers of dogs to work throughout a season and have several in training to insure consistency of service. In the case of a registered hound pack, employed in the flushing of fox's, staff may keep upwards of fifty working animals and a percentage of young animals in training. A one-off cost of about could incur a cost of 1000 or more for those keeping multiple dogs. The burden of microchipping multiples of dogs year on year and the bureaucratic nature of a registration system would cause this sector of working dogs undue pressure and financial constraint whilst offering little tangible benefit

7 10. When a microchipped animal changes ownership, the registration details on the database must be updated for microchipping to be effective. If microchipping was to be made compulsory, with whom should this responsibility lie: The seller, the buyer, or both? Please explain why and how you consider that the requirement could be enforced? Seller Buyer Both Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance (SCA) is opposed to the introduction of legislation leading to the mandatory microchipping (or other measures) of all dogs in Scotland and do not recognise any justifiable reasons for adopting such a sever measure. However, if microchipping was to be made compulsory, we believe that the onus lie with the individual selling or otherwise disposing the dog to notify the keeper of the register to the details of the new keeper. 7., "N

8 11. Are you aware of any difficulties due to different microchip companies using different technical specifications regarding scanners etc.? Please explain. Yes ^ No Don't Know,. (Please tick whichever option applies) It is the understanding of the Scottish Countryside Alliance that scanners use radio waves to read the number encoded in a microchip by tuning into the right frequency, scanners need to be able to read the correct frequency to obtain this number. The problem is pet microchips come with different frequencies, such as 125 khz, 128 khz and khz. About 98 percent of the pet microchips in America use 125 khz, whereas those in Europe use khz [source: USDA]. In 1996, the International Organization for Standardization (ISO), headquartered in Switzerland, adopted the khz frequency for pet microchips in an attempt to solve incompatibility problems. However, the United States was already largely using the 125 khz microchip, and critics pointed out that changing to the ISO standard would be difficult and expensive. Dogs that may be stolen in the UK can be re-chipped with a US chip and sold into the American market When scanned with the American frequency scanner the UK chip will not be detected. a

9 12. Do you think that any regulafion being introduced on microchipping should set minimum standards for commercial databases? Why, and if so what should they be? Yes ^ No Don't Know, (Please tick whichever option applies) The Scottish Countryside Alliance would insist that any legislation introduced on microchipping should set minimum standards. A database of this order would contain hundreds of thousands of individual dog owner details. The Scottish Countryside Alliance wish to remind the Scottish Government that as with almost anything, microchipping it's not a fool proof system. Although rare, microchips can fail and become unable to be detected by a scanner. Human error, such as improper scanning technique or incomplete scanning of an animal, can also lead to failure to detect a microchip. Human error within the database management could see confidential information placed in the hands of those with no right or authority and could infringe data protection protocol.

10 13. Presently, the dog owner, the microchip implanter, and some animal welfare organisations are able to access current database records, but only enforcement authorifies are able to see previous records. Do you think this should remain the same? Please explain. Yes ^ NoD Don't Know (Please tick whichever option applies) With exception the Scottish dog control database, the Scottish Countryside Alliance (SCA) is profoundly opposed to others outside of the microchip implanter, database registrar and the enforcement authorities having access to sensitive information in relation to the dog owner. If criminal activities are suspected Police Scotland should be the preferred enforcement authority given responsibility for sharing, if appropriate details greater to the owners contact details, dogs name breed etc. 14. Do you believe that compulsory microchipping would be easy or difficult to enforce effectively? Why? Can you suggest what approach to enforcement would be most appropriate? Easy Difficult Don't Know (Please tick whichever option applies) It is estimated that the UK dog population stood at approximately 8 million in 2012 (Pet Food survey). If dog ownership is proportional to UK population, it follows that Scotland, with 8% of the UK population, has approximately 640,000 dogs. A further 60 million dogs in Europe and a total estimate of 223 million Worldwide. (FEDIAF Facts and Figures 2012) The global market and exchange of dog(s) for breeding, showing, hunting and as companions animals presents a significant problem for any database management system, a problem only compounded through the differing registration and chip frequency/scanning systems. As with almost anything, microchipping it's not a fool proof system. Although rare, microchips can fail and become unable to be detected by a scanner. Problems with the scanners are also not uncommon. Human error, such as improper scanning technique or incomplete scanning of an animal, can also lead to failure to detect a microchip. Enforcement of a system with so many potential break points would be nigh on impossible

11 15. Do you have any concerns that microchipping could cause health problems in dogs? Please explain. Yes ^ No Don't Known (Please tick whichever option applies) The Scottish Countryside Alliance is aware that whenever a foreign body enters a dog, whether that's a microchip, a metal plate for a fracture or any other material, there's the potential for the dog's body to reject the substance. There have been documented cases in US veterinary medicine where sarcoma or fibro sarcoma, two types of soft tissue tumours, occurred at the site ofthe injection. US research shows that between 1996 and 2006, up to 10 percent of laboratory animals had some type of reaction to being microchipped, ranging from a localized inflammatory response to tumour formation at the site ofthe injection. The British Small Animal Veterinary Association (BSAVA) maintains a database of adverse reactions to microchips in the UK. Since the database was started in 1996, over 4 million animals have been microchipped with 391 adverse reactions reported. Of these reactions, migration of the microchip from its original implantation site is the most common problem reported. Other problems, such as failure of the microchip, hair loss, infection, swelling, and tumour formation, were reported in much lower numbers. Other highlighted problems inc: Cancer Links, Spinal cord injuries. Microchip Implant Migration, Damage to dogs during play Poor quality training for non-veterinary Implanters, Possible MRI incompatibility, Low frequency RFID EMF problems, ( If the Scottish Government were to introduce manadory chipping the numbers involved would see an exponential rise in the numbers of dogs with soft tissue sarcoma and associated health problems. The Scottish Countryside Alliance would like to ask at this time, who the Scottish Government would hold legally responsible when owners forced to implant their dogs fmd out an adverse reaction leading to cancer has occurred? 11

12 Business impact 16. Do you believe that compulsory microchipping would have a positive or negative financial or other impact on owners, enforcement agencies, animal welfare organisafions/rehoming charifies, dog breeders, pet shops, microchip database companies? Please Explain. Positive Negative ^ Don't Know The Scottish Countryside Alliance believes that the sheer number of dogs in Scotland, the UK, EU and Worldwide (circa 223 million) presents a significant challenge which will undoubtedly translate into financial costs for owners, enforcement agencies, animal welfare organisations, dog breeders and multiple microchip database companies. It is estimated that the UK dog population stood at approximately 8 million in 2012 (Pet Food survey). If dog ownership is proportional to UK population, it follows that Scotland, with 8% ofthe UK population, has approximately 640,000 dogs. A further 60 million dogs in Europe and a total estimate of two hundred and twenty three million Worldwide. (FEDIAF Facts and Figures 2012) Many gamekeeper, game shots, pickers up and beaters and pest control operatives breed/own sufficient numbers of dogs to work throughout a season and have several in training to insure consistency of service. In the case of a registered hound pack, employed in the flushing of fox's, staff may keep upwards of fifty working animals and a percentage of young animals in training. A one-off cost of about could incur a cost of 1000 or more for those keeping multiple dogs. The burden of microchipping multiples of dogs year on year and the bureaucratic nature of a registration system would cause this sector of working dogs undue pressure and financial constraint whilst offering little tangible benefit 12

13 Compulsory microchipping in Scotland 17. Do you believe that all dogs in Scofiand should be microchipped? Why? Yes No ^ Don't Know (Please tick whichever option applies) The Scottish Countryside Alliance support wholeheartedly the measurers afforded under the Control of Dogs (Scotland )Act 2010, the Dangerous Dogs Act 1991, the Animal Health and Welfare (Scotland) Act 2006 ; and further support the recommendations of the Code of Practice for the Welfare of Dogs, specifically the recommendation to microchip. We simply do not accept that the compulsory microchipping of dogs in Scotland will translate to increased public safety, increased owner responsibility or limit the attacks on postal workers of guide dogs. 18. Do you consider that any sectors of dog ownership (for example rehoming/sanctuary charities, police, armed services, security services, guide/helper dogs, vermin control, sheep dogs, or other sectors) merit exempfion from any requirement to microchip? Why? Yes lel No Don't know (Please tick whichever option applies) The Scottish Countryside Alliance seeks an exemption for recognised working dog breeds. The global market and exchange of dog(s) for breeding, showing, hunting and as companions animals presents a significant problem for any database management system, a problem only compounded through the differing registration and chip frequency/scanning systems. Many dogs breed for the hunting market whether terriers, retrievers or hounds are sold into the UK, EU and wider World market place. For instance the Fox Terrier, a breed of the terrier type that originated in a geographic area in England has a far greater numerical presence in Germany, Belgium and as far afield as Australia. Hunting with hounds is a popular sport in America with over 150 registered fox packs with many hounds from the UK exported to maintain historic bloodlines. The UK Game shooting sector leads the way in producing field trial and show champions within the traditional gundog sector. Thefinancialburden, increased bureaucracy and incompatibility of chips would place undue pressure on this sector. 13

14 19. Which ofthe suggested opfions for introducing any requirement for compulsory microchipping do you believe would work best? Do you have an alternative option to suggest? Please explain. (Please tick whichever option applies) 1. Status Quo ^ 2. All puppies born after a specific date should be microchipped - 3. All dogs microchipped on transfer of ownership ' 4. Two-phase approach over 2 years V 5. Microchipping of all dogs within one year of legislafion coming into effect. 6. Other lei, i., v The Scottish Countryside Alliance would advocate the status quo for all dogs in Scotland. We support the measurers afforded under the Control of Dogs (Scotland )Act 2010, the Dangerous Dogs Act 1991, the Animal Health and Welfare (Scotland) Act 2006 in relation to recognised breed associated with poor public safety records or with criminal activity and or animal cruelty; and further support the recommendations of the Code of Practice for the Welfare of Dogs, specifically the recommendation to microchip. 14

15 other possible measures to promote responsible dog ownership ^ 20. Do you think a system of dog licensing could help encourage responsible dog ownership and help make our communities safer from dangerous and out of control dogs? Do you have views on how such a dog licensing scheme might operate? ' '"> ' It is the understanding ofthe Scottish Countryside Alliance that dog licensing in the UK was abolished in Prior to this dog licences were mandatory, but the requirement was widely ignored, with only about half of owners having one. The final rate for a dog licence was 37 pence, reduced from 37y2p when the halfpenny was withdrawn in We believe that both public buy in and local authority enforcement is vitally important if any future licensing system were to be introduced. We agree with the suggestions that it is likely to be currently responsible dog owners would be the ones who would comply with the system whereas those who are not responsible dog owners will not comply with the system. We believe that the cost of a credible enforcement system would be prohibitive and unlikely to act against dog owners who failed to control their dog as effectively as the current measures available under the Control of Dogs (Scotland )Act 2010, and the Dangerous Dogs Act 1991 which are infinitively more suited than a licensing system to deal owners who fail to hold a dog licence. We are aware of licensing systems in other European countries-states and cite the German system of dog ownership which is regulated by a "dog tax" as opposed to a dog licence, with the amount due depending on the breed of the dog: dogs deemed "dangerous", such as Pit Bull Terriers, subject to higher tax. We would suggest that a dog tax levied against those with recognised problems or increased risk of public safety infringements could go some way towards the cost of local authority control. IS

16 21. Do you think muzzling of dogs while in public should be introduced? The Scottish Countryside Alliance does not believe that the muzzling of all dogs whilst in public places is a proportionate measure to improve public safety. Dogs fitted with muzzles are unable to drink, tongue or otherwise socially engage with other animals or humans. This could lead to an increased anxiety and stress on the animal leading to character changes and possible aggression, surely counterproductive. We believe that powers under current legislation to require the muzzling of dogs while they are in public, where a dog owner is issued with a dog control notice under the Control of Dogs (Scotland) Act 2010, where local authorities have the option of imposing a condition for a dog to be muzzled at all times while in public a more sensible approach and proportionate to the associated risk.. We would support the targeted muzzling of nuisance dogs, focused on those dogs that have been found to be out of control and are therefore likely to pose a bigger risk of potentially attacking a member ofthe public, postal worker, guide dog or other dogs. The Scottish Countryside wishes to remind the Scottish Government that working dogs are currently exempt from the wearing ofa collar in public under the Dog Control of Dogs Order If the Scottish Government sought to imposes the muzzling of all dogs in public the Scottish Countryside Alliance would seek assurances that the same animal welfare exemption be put in place. 2. (1) Subject to paragraph (2) below, every dog while in a highway or in a place of public resort shall wear a collar with the name and address of the owner inscribed on the collar or on a plate or badge attached to i t (2) Paragraph (1) above shall not apply to (a) any pack of hounds, (b) any dog while being used for sporting purposes, (c) any dog while being used for the capture or destruction of vermin, (d) any dog while being used for the driving or tending of cattle or sheep, (e) any dog while being used on official duties by a member of Her Majesty's Armed Forces or Her Majesty's Customs and Excise or the police force for any area, (f) any dog while being used in emergency rescue work, or (g) any dog registered with the Guide Dogs for the Blind Association. 16

17 22. The Dog Fouling (Scofiand) Act 2003, gives local authorifies the powers to deal with dog mess Are you aware that local authorities have these powers? Yes ^ No Don't know (Piease tick whichever option applies) Do you think they are being used effectively in your area? Yes No Don't know ^ (Please tick whichever option applies) Is there more you think can be done to address this issue effectively? Yes No [[H Don't know ^ (Please tick whichever option applies) No Comments 17

18 Any other comments 23. Do you have any other comments on the possible introduction of compulsory microchipping for dogs in Scofiand? The Scottish Countryside Alliance wish to remind the Scottish Government that as with almost anything, microchipping it's not a fool proof system. Although rare, microchips can fail and become unable to be detected by a scanner. Problems with the scanners are also common, but can occur. Human error, such as improper scanning technique or incomplete scanning of an animal, can also lead to failure to detect a microchip. In 1996, the International Organization for Standardization (ISO) adopted the khz frequency for pet microchips in an attempt to solve incompatibility problems. However, the United States was already largely using the 125 khz microchip, and critics pointed out that changing to the ISO standard would be difficult and expensive. Different frequencies could lead to dogs stolen in the UK being re-chipped with a US chip and sold into the American market When scanned with the American frequency scanner the UK chip will not be detected. The Scottish Countryside Alliance is aware of problems associated with foreign bodies entering dog's bodies, whether a microchip, a metal plate for a fracture or any other material, there's the potential for the dog's body to reject the substance. There have been documented cases in US veterinary medicine where sarcoma or fibro sarcoma, two types of soft tissue tumours, occurred at the site of the injection. US research shows that between 1996 and 2006, up to 10 percent of laboratory animals had some type of reaction to being microchipped, ranging from a localized inflammatory response to tumour formation at the site of the injection. The British Small Animal Veterinary Association (BSAVA) maintains a database of adverse reactions to microchips in the UK. Since the database was started in 1996, over 4 million animals have been microchipped with 391 adverse reactions reported. Of these reactions, migration of the microchip from its original implantation site is the most common problem reported. Other problems, such as failure of the microchip, hair loss, infection, swelling, and tumour formation, were reported in much lower numbers. Other highlighted problems inc: Cancer Links, Spinal cord injuries. Microchip Implant Migration, Damage to dogs during play Poor quality training for non-veterinary Implanters, Possbile MRI incompatibility. Low frequency RFID EMF problems, ( The Scottish Countryside Alliance would like to ask at this time, who the Scottish Government would hold legally responsible when owners forced to implant their dogs find out an adverse reaction leading to cancer has occurred?

19 24. Do you have any other comments on the promotion of responsible dog ownership in Scofiand to help improve the safety our communifies from dangerous and out of control dogs? The Scottish Countryside Alliance has no further comments. 25. Do you consider that the consultafion paper explained the key issues sufficiently for you to properly consider your responses? The Scottish Countryside Alliance considers that the consultafion paper explained the key issues sufficiently for us to properly consider our response. 19

20 26. Do you consider that you had sufficient time to respond to the consultafion? The Scottish Countryside Alliance considers the time given to respond to this consultation to be adequate. 27. Do you have any other comments on the way this consultafion has been conducted? No other comments