Consultation Response FROM THE RSPCA IN WALES Draft Code of Practice for the Welfare of Dogs January 2018 The RSPCA is delighted to respond to the consultation on a new draft of the Code of Practice for the Welfare of Dogs. The Code is an extremely important document which may be used by those with responsibility for dogs to help them understand how to care for them. The RSPCA uses the Code in our everyday duties both to work with owners to improve the welfare of their animals and also in more extreme circumstances of a prosecution where it is used to demonstrate what is required of an owner/keeper, to meet the needs of their dog, under the Animal Welfare Act 2006. Since the Code was introduced in 2008 the RSPCA has continued to print and distribute copies throughout Wales as an essential tool in our ongoing work to improve animal welfare and prevent suffering, as such we welcome this process to update and refresh the content. We hope the following document will be of assistance. As applicable, this document refers to, and cites, current guidance from dog behaviour and welfare experts as well as details of relevant legislation. Some general dog behaviour and welfare points considered helpful are also included. General comments : Cross Reference Information: It might be helpful to signpost important website links, as well as the Appendices, within the main body/text of the Code. 1 Code Promotion: Evidence suggests that awareness of the Codes amongst the animal owning population is generally limited, despite its online availability. Hardcopies are not easily available. We would therefore welcome a discussion - perhaps with our partner organisations on the Animal Welfare Network Wales - on how best to make the Codes more accessible. The RSPCA would recommend a user-friendly online format of the Code which is also fit for purpose for all platforms (such as mobiles). Specific comments on the Code of Practice for the Welfare of Dogs Introduction In paragraph 3, we believe it would be helpful to emphasise that every animal is different and an individual with its own personality. In the final paragraph, it is stated that there is a responsibility to read the Code of Practice. We would recommend that it is explicitly stated that they have a responsibility to care for their dog as described by the Code. 1 Only 13 percent of people in Wales Cymru poll, were aware about the existence of these guides on how their pets should be legally taken care of.these figures are from YouGov Plc. Total sample size was 1,103 adults. Fieldwork was undertaken between 10 13 January 2017. The survey was carried out online. The figures have been weighted and are representative (politically) of all Welsh adults (aged 18+). www.rspca.cymru www.politicalanimal.wales PAGE 1 externalaffairscymru@rspca.org.uk 0300 123 8910
SECTION 1: ENVIRONMENT Section 1 is predominantly focused on dogs living outside and doesn t take into account the large numbers of dogs who live indoors or sufficiently acknowledge that providing for a dog s welfare needs when living outdoors is very difficult. This can be addressed by providing additional wording as suggested in comments regarding 1.1. We have also suggested a statement about outside living in the summary of the Code. The RSPCA is increasingly seeing unneutered dogs, those with behaviour problems and in multi dog households kept in crates, often for extended periods of time. As this may reflect an emerging trend in dog care, and is one which can detrimentally affect welfare, we suggest that there is a section on crating within this section to ensure that the dog s welfare needs are provided for. Suggested wording is as follows: Crating 1. A crate should never be used as a place in which your dog spends all of its time or as a form of punishment. If you use a crate to confine your dog it is important that the crate is a place where your dog is happy to be and feels safe and relaxed and it shouldn t be in there unattended for any period of time that is likely to cause distress. 2. It is important that the crate is the right size for your dog and not used for more than one dog. As a minimum, the crate must provide enough space for your dog to able to sit and stand at full height, turn around, stretch out and lie down in a natural position. Your dog will probably outgrow the crate it had as a puppy. As your dog grows you must replace their crate with one of a suitable size. 3. The crate needs to be in an area of the house which is quiet and away from things that frighten or worry them and away from draughts, sources of heat or direct sunlight but needs a good air flow. The crate needs a source of fresh clean drinking water, bedding and toys or other items to prevent your dog from becoming bored. Regular opportunities for playing with other dogs and people, exercise and toileting need to be provided. 4. Many welfare organisations offer advice and information on the use of crates for dogs. 1.1 This section needs to include guidance which is applicable regardless of where the dog is living as currently it seems most relevant to a dog who lives outside. For example the point there should be enough space to allow for exercise and toileting is more relevant to a kennel than a home as it refers to space rather than access or opportunities for both. We would recommend removing this point and instead revising and expanding the guidance so that it refers to the need for an environment, whether living inside or outdoors, which is clean; safe, secure and free from hazards; has somewhere to avoid things that are frightening; a suitable resting area; effective ventilation and temperature control and the ability to move around to prevent the dog from becoming too hot or too cold. The environment should also provide adequate opportunities and/or access for toileting and exercise and dogs should not be left unattended in situations or for any length of time which is likely to cause distress. Sleeping and Resting 1.2 Within the four bullet points there are three different terms used to describe the dog s bed: comfortable space, bedding and resting area. We would suggest using the word bed as in the original version of the Code for clarity and consistency. We have also made additional revisions in bold. For example, we are unsure if most owners would know that retire meant withdraw to, and so we have replaced it with go to which is simpler. Dogs need: Their own comfortable space bed with bedding, to which they can retire go to, rest and sleep and which should be in a quiet place. Their bedding bed to be in a dry, draught free but adequately ventilated area Their bedding to be regularly cleaned, washed or removed and replaced. A resting area bed free from such things as sharp edges and splinters that can cause injury. 2
Outside space For clarity and to accurately represent the purpose of the section, we would suggest changing the subtitle of Outside space to Keeping your dog outside. We would expect outside space to cover the back garden where the dog would be taken to go to the toilet or for exercise but this section also covers kennelling of dogs. We would also suggest moving this section to the end of Section 1 so that it is clearer that sleeping and resting, hygiene and hazards and travel are applicable to all dogs regardless of where they live and that this section is specific to dogs living outside. 1.4 Suggest replace The environment that your dog is kept in in first sentence with the area that your dog is kept in. 1.5 We suggest cross referencing this section to Appendix I and the Animal Welfare (Electronic Collars) (Wales) Regulations 2010 as invisible fences that emit a shock via a collar are prohibited but some may consider using them to contain their dog. 1.7 To ensure it is clear that it is outside housing which is being referred to change any area at the start of the first sentence to any area of the outside housing. 1.7 There are additional behaviours which outside housing should allow and which need to be included: sitting and standing upright. 1.7 Enclosure, as used in the second sentence, is a term most associated with wild animals. We suggest replacing this with accommodation or housing. 1.8 Suggest adding barking to the behaviours which may be seen when dogs are socially isolated as this is commonly seen. Hygiene 1.10 Rather that state it is good practice to clean up after your dog, we suggest it would be better to strengthen that sentence and state that is is necessary to clean up after your dog and to dispose of any faeces. Hazards 1.11 Dogs, and especially inquisitive puppies, will explore and eat things that are poisonous and dangerous to them so suggest adding explore to this sentence. 1.11 There are other hazards in the environment in addition to those listed e.g. open windows and balconies. We suggest that these are included so that attention can be drawn to the possible hazard of falling. 1.11 The final sentence of 1.11 states that you should always consult your vet if you are concerned that your dog has eaten or come into contact with anything that could be harmful. We suggest adding immediately to this sentence because the time when advice is sought is as important as the frequency. Travel 1.12 We suggest that for ease of reading and clarity the second sentence is revised to read You should make sure that your dog is restrained when being transported. 1.12 When being transported a dog also needs to be comfortable so we suggest adding a point to this effect. 1.14 It is stated that dogs should never be left unattended in a car.. Is the should not a must or could this be reworded as It is very important that you do not leave your dog unattended in a car... SECTION 2: DIET 2.1 Sentence one refers to a clean bowl or trough. This is very specific, suggest replacing with a suitable container. 2.1 It is also important to take clean, fresh drinking water with you when away from home in case there isn t any available so suggest this is added. 2.1 Suggest adding further wording to the end of the 4th sentence which refers to changes in the amount of water your dog drinks: It is therefore important to be aware of your dog s normal drinking habits. 3
2.2 To save confusion as to what early means we suggest replacing from early in a dog s life to at all stages of your dog s life 2.3 As the amounts recommended by manufacturers are considered guidance, and the amount for an individual dog could be greater or less than stated, we suggest that rather than stating follow the food manufacturer s instructions closely, replace with When feeding prepared food, you should read and be guided by the food manufacturer s instructions. Monitor your dog s weight and body condition closely adjusting the amount of food as necessary. 2.3 & 2.4 We have sought advice from a vet with expertise in nutrition and general consensus within the veterinary sector is that it is very difficult to provide a balanced diet through homemade foodstuffs and most vets lack the specialist knowledge required to help formulate a balanced diet. This needs to be made very clear in these sections. As it is so difficult to ensure a nutritionally balanced diet this way we do not believe that it is appropriate or accurate to say a diet containing protein, fat, carbohydrate, vitamins and minerals can be given in the form of homemade meals and that feeding homemade diets is an alternative to feeding prepared dog food. It has to be explicit in both sections that achieving a nutritionally balanced diet is problematic and if owners choose to provide such a diet they need to seek advice from a nutrition expert to ensure the diet is adequate and appropriate for their individual dog. 2.5 Breed is included as a factor to take into account when considering what diet to provide a dog. There is huge individual variation within a breed and other factors like activity, health and lifestyle are much more important than breed. We suggest that this is removed. 2.6 As this point relates to feeding the diet in the correct portions, would it not fit better under feeding regimes? Healthy weight 2.8 For consistency with the point raised under 2.3, we suggest revising the second sentence so that it states: The feeding instructions on dog food packaging are a good guide or you can also seek.. 2.8 Obesity is also a significant welfare issue with large numbers of pet dogs affected. Including this point may be helpful. 2.9 We would suggest leaving the point about underweight dogs being unwell in this section but creating a new one about knowing your dog s weight, maintaining an ideal body condition and changes in the way a dog eats or drinks. These points are relevant to any dog not just one which is underweight. We would suggest the following: You should regularly monitor your dog s weight and body condition score, adjusting their diet as required. Changes to the way your dog eats or drinks may be a sign of ill health. Observe your dog s drinking and feeding habits and seek advice from your vet if they change. Body condition 2.10 As there is huge individual variation within a breed, we suggest removing the point about knowing what is normal for the breed and instead state know what is the ideal body condition score for your dog. Monitor it regularly and change their diet accordingly to maintain an ideal condition. 2.10 There is no reference for the body condition score system provided and so it it is difficult to determine whether the system has been validated. This system, unusually, has 3 scores whereas others more commonly used within the animal care and veterinary sector have between 5 and 9. We would suggest including a system which is validated and widely used by the sector and one which has illustrations. Feeding regime 2.11 We would suggest adding a point about seeking help from your vet to advise on frequency of feeding. 2.13 It is most important that a dog is undisturbed when feeding and this isn t completely clear from the current statement. We suggest revising so that it states.to eat undisturbed. 2.14 It is unclear what a persistent reduction in appetite means and doesn t appear very lay friendly. We are assuming that it refers to a dog which has stopped eating and believe it would be better phrased as if your dog has stopped eating, advice from your vet should be sought although this point is covered in Section 2 already. 4
Other dietary needs 2.16 Not feeding your dog immediately before travel is open to misinterpretation and so we would suggest revising the wording about feeding before travel so that it is consistent with that around feeding before exercise and states a recommended time period. SECTION 3: BEHAVIOUR 3.1 It is stated that this section focuses on puppies however much of the information is for puppies and adult dogs and so we would suggest removing the second sentence. 3.2 Socialisation is not defined and so suggest revising the first sentence to Puppies learn most readily about other dogs, people and animals when they are very young. It is important that puppies are provided with positive experiences from three to 14 weeks of age so that they have the best chance of developing into well adjusted and happy dogs. 3.2 & 3.3 Both sections focus on the early experiences of puppies. However, it is important that these socialisation and habituation continue throughout adult life and we would suggest including a point to cover this. 3.4 As written it could be interpreted that a dog shouldn t be woken or asleep and shouldn t also be allowed to wake up of its own accord. Suggest revising so that it is clearer. Training Whilst all sections refer to the use of rewards to train dogs there is nothing about the use of punitive or aversive techniques, equipment and methods. These abound training and behaviour modification and can seriously compromise dog welfare as well the relationship between dog and owner. In some cases, they can make behaviour problems worse or cause new behaviour problems to develop. We would really like to see information covering these points included in the Code and reference to equipment not to be used including, but not exhaustive of, choke chains, prong/pinch collars, anti-bark collars, smacking, shouting, hitting. A lack of information is this area would be a real missed opportunity for dog welfare. 3.6 We suggest adding a point about why training is important for dogs e.g. it helps dogs learn how to behave appropriately and allows us to keep them under control. 3.7 Suggest revising and adding to the end of this section Take every opportunity to praise your dog for behaviour you want. Your dog is less likely to perform unwanted behaviours if they are ignored. Exercise 3.9 There is significant individual variation within a breed and so using this as a guide for the amount of exercise a dog needs could be very misleading. 3.11 It is stated not to exercise a puppy outside until it is fully vaccinated and protected. However, this is likely to impact on the owner s ability to adequately and appropriately socialise their puppy. We suggest revising to say that Puppies are not fully protected from disease when first vaccinated. It is important for your dog not to go to places where they are likely to encounter other unvaccinated dogs. Speak to your vet about the best way to exercise and socialise your puppy until they are fully protected. 3.12 It is not clear what unless exempt means and so we would suggest that this is removed and instead it is stated that there are exemptions to these requirements and more detail can be found in Appendix 1. 3.12 We would suggest adding a point about the need for a dog to immediately and reliably return to their owner when called. 3.13 There are other times when care needs to be taken when walking your dog e.g. during extremes of weather and the firework season. We suggest these are added. 3.16 Changes in behaviour are often the first signs of illness as well as unhappiness and we suggest this is added to the third sentence of this paragraph. 3.16 The fourth bullet states barking (unless there is good reason). It isn t entirely clear what this means. Does it mean unless it is in response to something specific e.g. someone knocking on the door or a person entering a property? 3.16 Many welfare organisations provide illustrations which show the signals use to tell us how they are feeling. We would suggest making reference to this at this point in the Code. 5
3.18 Although vet s are extremely knowledgeable in the physical health of dogs this is not necessarily the case for behaviour and mental health. To ensure that behaviour problems are diagnosed and treated appropriately a vet should refer cases like uncharacteristic aggression or sudden fearful or aggressive responses to a behaviour expert. We suggest the following wording: Your vet may refer you to a dog behaviour expert. It is important that they have a combination of appropriate qualifications, knowledge, skills and experience. They should work in ways which protect dog welfare. 3.20 There are two sections labelled as 3.20. 3.20 Toilet training. For clarity, we suggest removing punish from the third sentence and revising as follows: Do not tell your dog off or use any other form of punishment when it makes a mistake... 3.20 Removing faeces. Unless exempt is also used here. We suggest using more lay friendly language or explaining in a way which is more likely to be understood by all readers. SECTION 4: COMPANY Unlike other sections, there is very little information which helps put this section into context and why the advice and guidance is important. We suggest the following: Dogs learn how to behave appropriately and in social situations through careful introduction to lots of different people, other animals and friendly dogs. Dogs who have had bad experiences might not react well in social situations. You should be aware of how your dog responds to unfamiliar people, other dogs and animals and act accordingly. Relationships with other Dogs, Other Animals and People 4.1 The RSPCA is very pleased to see this key safety information included in the Code. However, as the aim of the boxed section is to prevent children from being bitten, we suggest that the wording is revised to state this: Any dog has the potential to bite. Never leave your dog unsupervised around children or other animals. We also suggest adding a point about materials to keep children and people safe around dogs which are available from many welfare organisations. When away from home 4.5 In the final sentence we would suggest that this should read.and you need to ensure that they understand. rather than. and you should.. 4.6 Dogs may suffer when alone not only through lack of company but also due to boredom. Suggest the second sentence is revised as follows: Some dogs can become bored and others, which haven t been taught to cope when left alone.. 4.6 We believe that the last sentence relating to roaming needs to be a standalone point? Number of dogs 4.8 In addition to the factors listed it is important for owners to think carefully about the lifespan of dogs as this directly affects the financial and time implications of having a dog. SECTION 5: HEALTH Health care 5.2 Your vet can also advise on the frequency of health checks which are an important part of maintaining good health so suggest this added to the text. 5.3 The fifth bullet point covers the need to take prompt action if the dog becomes ill etc but this point should also cover the need for owners to monitor their dog daily as this will allow them to take prompt action. We are unsure as to why dental hygiene is specifically mentioned here. Considering the dog s coat, eyes and ears are also important but not mentioned specifically. Illness 5.3 As well as being aware of the signs of illness in their dog, it is also important that owners monitor and check their dog daily for signs of illness. 5.3 We suggest adding constipation and difficulty passing urine to sickness and diarrhoea. 5.3 We suggest revising lack of appetite so that it states lack of, or a change in, appetite. 5.3 We suggest adding a point about onset of fearful behaviour or dog being uncharacteristically aggressive. 6
Getting a dog 5.4 We would suggest replacing the different options available with the different types of dogs available. 5.5 The current wording states that the future health and welfare of your dog may be affected by the circumstances under which it was bred. This needs to be made stronger and should say it is affected by the circumstances under which it was bred. 5.5. The current wording suggests that it is the circumstances under which it was bred or the previous environment in which it was kept when it is actually both so we suggest replacing or with and. 5.6 This section is focused on genetic health but there are also issues relating to conformation which could be inherited by the puppy and affect its health and wellbeing. We suggest adding: Check if either parent has had any surgical procedures to correct features that could be inherited by the puppy, such as eyelids which rubbed on the eye. To ensure owners have a full understanding of what the results mean from health screening tests we suggest revising 5.6 so that it reads You should check, as far as is possible, that the dog s parents have been appropriately screened for inherited problems in the breed, taking advice from your vet as to what the results mean. It should also be made clear that breeders who have not done appropriate tests or who won t provide the results need to be avoided. 5.6 The final sentence states that dogs with inherited birth problems will require special care. This needs to be clearer as to what special care means and so we suggest replacing this with dogs with inherited birth problems may need expensive veterinary treatment. 5.7 We suggest adding the following to this section: A puppy that has lived in a domestic environment, particularly in a part of the home where people come and go, is more likely to be prepared for life in a home. As well as the checks listed we would also suggest adding that you if you are buying a puppy from a breeder you need to see it in the place it was born and raised and you need to see the mother more than once. If you can t do these things then not do not buy the puppy. There are two bullet points labelled as 5.7 The address for the puppy contract is incorrect. Please revise as: www.puppycontract.org.uk 5.8 The breeding premises needs to be licensed by the Local Authority so we suggest adding this and the need for the buyer to ask to see it. 5.8 As well as stating that all puppies must be microchipped by the age of eight weeks we would suggest adding and by the breeder before they go to their new home. 5.9 It is stated that the new dog or puppy should go to their vet within a couple of days. We would suggest allowing the dog or puppy to settle into the new home first before taking somewhere which could be an additional source of stress, unless the dog is ill or injured. Grooming 5.10 It is more accurate to state that certain coat types will need more attention than others as some shorter hair dogs can require more grooming than longer haired ones. 5.10 We suggest adding a point about advice on how best to groom your dog can be sought from a pet care specialist. Breeding and neutering 5.11 The second sentence states that if a decision to breed is made then the health and welfare should be considered. Revise this to must be considered. 5.11 Where appropriate socialisation is stated in the fourth sentence, we suggest adding adequate as both quantity and quality of experience is important. 5.12 The age at which a dog is neutered is also important and so we suggest adding a point about this and the need to discuss this with their vet to ensure it is best for their individual dog. Identification 5.15 It is important that as well as fitting correctly, the collar also needs to be secure and comfortable. 7
Specific comments on the Summary of the Code of Practice for the Welfare of Dogs SECTION 1 - ENVIRONMENT We suggest adding this applies to dogs who live indoors or outside to Your dog should have a suitable environment to live in. We suggest adding a point to state that it is difficult to provide for the welfare needs of a dog which lives outside. You will need to make sure that they are comfortable, in an area large enough to perform normal behaviour with enough to do to prevent boredom and regular company. Failure to provide for their welfare needs is likely to cause behaviour problems. Sleeping and resting We suggest adding with bedding to the resting area and a point about it being free from hazards. Hazards We suggest adding a point about ensuring that the dog s living area is free from hazards as well as keeping your dog away from anything hazardous. Travel Instead of stating that dogs should not be left unattended in vehicles, we suggest making this stronger and stating do not leave dogs unattended in vehicles. SECTION 2 - DIET Add drinking to the sentence your dog must have access to fresh clean water at all times. SECTION 3 - BEHAVIOUR We suggest adding a section on play and interactions with the need to have regular opportunities for playing and interacting with toys, other people and dogs. Reward based training As per our comments on the full version of the Code, we would like to see reference in the summary to aversive and punitive training methods and their impact on dog welfare. Exercise Add the need to exercise at least once a day. Behaviour We suggest revising this so that it states: Monitor your dog s behaviour daily and seek advice from your vet if you see changes in behaviour or signs of fear, anxiety and stress. Socialisation Include a point so that the need to habituate dogs to a range of noises, objects and activities in the environment is also included. Add to the end of the paragraph and experiences should continue throughout life. SECTION 4 - COMPANY We would suggest adding the point about dogs and children to the summary as this is a key piece of information for dog owners. For consistency with the fuller version, revise sub title: social interaction with relationships with dogs, other people and animals. For consistency, add people and other dogs to the second paragraph which states you should be aware of how your dog responds to other animals. SECTION 5 - HEALTH Identification Add with your name and address to the point about the need to wear a correctly fitted collar and identity tag. Breeding and neutering We suggest removing neutering from this paragraph so that it refers to breeding only and then adding a separate point about neutering which states: Neutering can prevent unwanted pregnancies and can also have some health benefits. Speak to your vet about neutering your dog. 8