THE KENNEL Club has responded to the new report by the Associate Parliamentary Group for Animal Welfare (APGAW) saying it is disappointed that the report has not differentiated ‘adequately’ between those who register their dogs with the club and those who do not.
And it had missed the ‘central point’ – the need for a level playing field for all breeders, it said.
The Government, local authorities, vets, breed clubs and others had an equal part to play in improving health and welfare, the KC maintains, and all breeders, whether KC-registered or not, should share responsibility.
As reported last week, the APGAW report ‘A healthier future for pedigree dogs’, has called for breeders of three or more litters a year to be licensed instead of the present five. An APGAW questionnaire revealed that its stakeholders want the Assured Breeder Scheme (ABS) to be independent, health screening to be made obligatory for its members, and unannounced, regular spot checks made. Most respondents to the questionnaire wanted health checks to take place ‘in the primary rounds of showing or even before so that dogs not clear of hereditary disease or overly-enhanced characteristics do not even enter the show ring’.
The reports also said APGAW wants the KC to endorse the British Veterinary Association (BVA)/RSPCA puppy contract by the time it is reviewed in 12 months’ time, and the Dog Advisory Council (DAC) to become an independent regulatory body and to receive long-term funding from DEFRA.
The KC said it disagreed with APGAW’s recommendation that the five-litter trigger be reduced to three.
"The motive for such a change is to deal with puppy farmers, who are widely considered to be higher volume breeders,” it said in its reply. "Reducing the number of litters from five to three is disproportionate and will serve no useful purpose in this regard.
"Furthermore, a reduction would risk wasting limited local authority resources inspecting small scale breeders and delaying the time it takes to get to the disreputable, large, commercial, breeding establishments – puppy farms. The proposals could lead to poor risk assessment at local authority level and potentially give the wrong target for enforcement officers, leading to the unnecessary penalisation of people. In our view those who breed up to five litters per year can be dealt with with more proportionate and appropriate measures.”
The KC said it would encourage APGAW to consider how effective enforcement can be assured without the danger of local authorities adopting a ‘low hanging fruit’ approach by conducting inspections on breeders whose licence fee is easy to obtain ‘as opposed to dealing with the more difficult, unscrupulous breeders who may require more time and resources’.
APGAW’s recommendation that dogs should be health checked before being shown would be unworkable, it said, and the proposal that the licence trigger should be reduced to three litters would serve no useful purpose.
However, it welcomed the report, saying it was ‘a useful part of the ongoing analysis of the progress stakeholders feel has been made in relation to the important issue of canine health’. The KC said it ‘particularly applauded’ the sentiment that stakeholders should speak with one voice and issue one message.
"Some consider more should have been done to improve the welfare issues of dog breeding and we would stress that significant improvement to genetic health will take generations to fully come to fruition,” the KC said in its reply. "However, even though significant steps continue to be made to ensure that KC-registered breeders breed with health and welfare as their first priority, this will not be sufficient unless action is taken to prevent irresponsible, commercial breeding of dogs.”
The KC believes that the Government, local authorities, veterinary and animal welfare bodies and breed clubs have an equal part to play in improving canine health and welfare.
Although it is lobbying for the standards of its Assured Breeder Scheme (ABS) to be made mandatory to anyone breeding dogs, it also recognises that education via vets and animal welfare groups play a significant role in getting important messages to the puppy-buying public.
"Breeders of all dogs, no matter whether KC registered or not, also share this responsibility and must lead by example,” the reply stated. "We urge endorsement of the ABS by stakeholders… By publicly backing mandatory application of the scheme’s principles, the stakeholders would send a clear message to everyone who breeds dogs.
"This would be far more effective than the recommendation of an increased number of reward and punishment schemes to encourage good breeding and to help inform the public.”
The KC’s reply continued: "The AGPAW report misses the central point, which is the need for a level playing field for all those who breed dogs. A single, enforced standard for all future puppy buyers to look for when obtaining a puppy would have positive results.”
The KC is concerned about APGAW’s comments on breed Standards, which APGAW wants to be kept under review. But, the KC said, it should be remembered that a breed Standard influences only those who breed pedigree dogs under the KC’s umbrella, and therefore changes to the Standards would have no impact on those who breed irresponsibly ‘as they have no relevance to this sector of the dog breeding community’.
It also said that APGAW’s recommendations that dogs are health checked before they show would be unworkable.
"Most importantly this recommendation entirely misses the point on dog health,” the reply stated. "Dogs not registered with the KC are not tested for inherited conditions, formally assessed for conformational defects or subjected to any assessment by a judge as seen with dogs exhibited in the show ring. Irresponsible breeders do not abide by codes of practice and are not assured breeders.
"It is important to understand the difference between conformational issues which can be seen by a judge and/or vet on inspection in the show ring and inherited conditions causing internal health problems which are not as obvious without either a detailed clinical examination or genetic testing.
"Such health tests would be dealt with by the KC in its code of practice for breeders or as assured breeder requirements. Within these it is stated that no mating should take place if test results indicate that it would be inadvisable in the sense that it is likely to produce health or welfare problems in the offspring. To this end, dogs who have health problems should not be bred from, regardless of whether they compete in showing or no – less than two per cent of KC-registered dogs go on to be exhibited. Thus health testing is of most value in breeding programmes and will have little impact if employed in the show ring.”
The proposals made by APGAW offered little improvement on what is already in place, the KC said, and the focus should be on equivalent health measures to dogs bred outside of the KC’s registration system.
Regarding the issue of outcrossing and crossbreed programmes, of which APGAW approves, the KC said it will consider any outcrossing plans which are ‘genuinely beneficial’ to the health and welfare of a breed.
"The report requested further clarification on the point at which the KC would register offspring from crossbred dogs involved in outcrossing programmes – which is straightforward, since offspring are registered immediately but registrations are marked accordingly using the asterisk system,” it said. "We would not support the suggested limit on the number of matings permitted for each sire to allow registration, as we maintain there is no reason why sires who have been health checked and can produce disease free offspring should be restricted from breeding.”
The KC said it had concerns regarding the ‘legal strength’ of the BVA/RSPCA puppy contract and said it could not support it at present. But it will be submitting ‘points for consideration’ at its next review. The puppy information pack linked to the contract was ‘needlessly complex’, the KC believes, and was ‘likely to dissuade participation in a voluntary scheme’.
"We do, however, recognise that as with promoting one breeding standard such as the ABS, it would be of great benefit to the public to have a single puppy contract, and hopes that in the future one standard and one form of contract can be supported by all the stakeholders.”
The KC’s response concluded: "We welcome many points made within the APGAW report and we see it as a positive step forward in keeping the issue in the public and political consciousness. We look forward to increased levels of collaborative working with other APGAW members and stakeholders to secure and enhance the health and wellbeing of all dogs now and in the future.”
I conceed the point of breeders having 2 breeds, i maybe should have said three or more my point was only we need to address the" Farms" by other means, and restricting breeders to three litters without licence does nothing as most puppy farms would be licenced anyway.
I cannot agree with the previous post I know lots of breeders with two breeds.
Does't make them puppy farmers.
Personally I found the heading of this topic amusing if it was not so sad KC and level playing field do not belong in the same sentence, Especially if you are one of the chosen 15.
I think reducing litter size to 3 without concil licence would not go anywhere towards a reduction in puppy farms, instead we should target the breeders that breed more than 1 breed of dog these are much more likely to be "FARMS".