Response 762496496

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Questions

1. The Scottish Government proposes that animal sanctuaries and rehoming centres should be regulated. Do you agree?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
Although there may be concerns over financial implications for very small/poorly funded rescues, as a veterinary surgeon I have often seen the consequences of well-meaning individuals who open unregulated rescue operations. This mainly results in individuals taking on too many animals than are appropriate for them to take care of, resulting in poor nutrition, healthcare and management of the animals in their care. In order to ensure that basic needs are met for rescued animals I believe that regulation and proper enforcement of standards are essential to avoid welfare crises that may inadvertently be created by well-intentioned individuals. In addition, I believe that basic needs must be enforced in order to preserve the psychological health of animals in order for more successful rehoming and re-integration with a domestic environment. Poor or non-regulation of numbers of animals and husbandry may result in poor behavioural management and result in anxiety and future behavioural issues when rehomed.
Considering that the ultimate aim of rescue and rehoming centres is to preserve animal welfare and support their ongoing quality of life, I believe that the need for regulation is of top priority.

2. Do you agree with the principle that registration is appropriate for those with fewer animals and that licensing is appropriate for those with more animals?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Please explain your answer.
I believe that licensing is appropriate in all cases, as regardless of the number of animals it needs to be made clear about acceptable standards of animal husbandry/keeping. Plus, small organisations always have the potential to grow. How often would checks be done on the number of animals in possession of a rescuer? I am aware of several cases (seen in veterinary practice) where individuals have started with small numbers of animals, and then quickly escalated despite lack of resources. These situations are where I have seen fairly pressing animal welfare issues (occurs quite commonly in rabbit rescue in my experience).

3. Do you have any comments on the thresholds that should apply? Should these be different for separate species?

3. Do you have any comments on the thresholds that should apply? Should these be different for separate species?
I think that thresholds should be the same for all species, although if there is the potential for resources to be evaluated at time of registration/licensing, this could possibly factor into such decisions. For example, if there was demonstrable evidence of good facilities, financial stability, and the potential to keep a larger volume of animals well, but the rescue had a small number of animals, this could perhaps factor into the decision.

4. Larger organisations and charities that may have a network of homes and smaller branches in different local authority areas should be able to apply centrally for the relevant licensing. Do you agree?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
It is important for large organisations to have a coordinated approach across all of their smaller centres, and these groups tend to have well established standards of care across their network.

5. The Scottish Government believes that all premises must be inspected before licensing (but not registration). We propose that, as well as local authorities, expert independent bodies, such as Scottish SPCA, should be able to carry out inspections. Do you agree?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please give reasons for your answer.
I think it would be good for expert bodies with experience of rescue/rehoming, but outwith of the field itself ie expert veterinary surgeons to carry out inspections. I think that for truly objective evaluation in line with appropriate welfare standards, independent inspectors should not be involved in organisations which have their own rehoming centres.

I do think that expert knowledge in the field of animal care is required as animal welfare is a complicated field. Local authorities likely to not have this knowledge level to ensure that premises are appropriate, other than basic hygeine/safety etc.

6. Do you agree that individuals with unspent convictions for animal welfare offences or other criminal convictions (e.g. fraud) should not be allowed to register or hold a licence for an animal sanctuary or rehoming activity?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please give reasons for your answer.
An individual with the capability of committing such crimes, especially animal welfare offences, is not appropriate to register for an animal sanctuary.
The problem would be monitoring such individuals, as if they were indeed allowed to run such premises, great care would need to be taken to ensure that they did not repeat similar animal welfare offences or that they did not commit financial crimes depriving rescues of resources. This level of monitoring may not be feasible without financial input which could be better diverted elsewhere.

7. Are there other requirements, apart from criminal, that should be part of a ‘fit and proper person’ test for those running animal sanctuaries or rehoming activities?

7. Are there other requirements, apart from criminal, that should be part of a ‘fit and proper person’ test for those running animal sanctuaries or rehoming activities?
I believe that individuals should have to demonstrate thorough knowledge of animal welfare acts, appropriate standards for care, species knowledge etc. I am in favour of formal assessment of this knowledge as I have seen, as a veterinary surgeon, many animal welfare issues resulting from lack of awareness of the above. The general public are expected to provide basic duty of care for their animals, so I believe individuals operating on a more formal basis of animal keeping need to adhere to the appropriate standards in a formally assessed way.

8. The Scottish Government proposes that reasonable costs of inspections should be charged to recover costs to inspectors approved by Scottish Ministers or local authorities. Do you agree with that proposal?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
I agree that inspectors/expert bodies should be remunerated for their time and input. I also think that each inspection should be charged, and premises with welfare shortcomings should be subject to more frequent visits. This may incentivise the maintenance of higher standards in rescue centres. I also think that there should be a degree of flexibility in payment, especially for smaller rescues which may have poorer standards and may be subject to the above situation.

9. Should licence fees be set by the authorised inspectors, local authorities or by the Scottish Government? Do you have any comments on what cost is reasonable and what should be included in this?

9. Should licence fees be set by the authorised inspectors, local authorities or by the Scottish Government? Do you have any comments on what cost is reasonable and what should be included in this?
Scottish government should set standard fees. A uniform approach should be made in this situation. Considerations could be made for deprived or poorly affluent areas?

A reasonable cost would include mileage, time and a low-moderate hourly rate for time spent at the premises.

10. The Scottish Government considers that licences lasting more or less than one year may be issued on the basis of a welfare risk assessment. Do you agree?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
I agree, but would be inclined to suggest that licences do not last more than two years, as rescue situations can change fairly quickly depending on available finances and resources.

11. Do you consider that the relevant Local Authority should have a duty to enforce the regulations on animal sanctuaries and rehoming activities in Scotland?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
I am unsure about this point - unsure about the level of knowledge of animal welfare of local authority staff, although I appreciate standards would likely be set by those with expert knowledge. Ideally there would be a high level of relevant knowledge in any staff dealing with regulation and enforcement.

12. Do you consider that the Scottish SPCA should be able to act on behalf of the relevant Local Authority using the powers contained in Animal Health and Welfare (Scotland) Act 2006 to enforce proposed regulations on animal sanctuaries and rehoming activities in Scotland?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
I believe that SSPCA staff have the level of knowledge and experience for enforcement of these principles.

13. Do you think that a national list of licensed premises and activities should be kept?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
It would be good to provide case examples of licensed facilities to the public in case individuals want to set up small rescue operations, in order to give individuals an idea of what standards need to be kept for licensing purposes (in order to avoid wastage of resources/finances when these standards can't be met by the individual).
I think recording of licensed premises should be kept in order to aid monitoring, re-licensing and enforcement.

14. Do you have any comments on who should be able to access information from the list, and if a charge should be made for information?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
I think a charge should be made for information to the general public, but they should be made aware of its existence.

15. The Scottish Government believes that enforcement agencies should be able to suspend, vary or revoke registrations and licences or issue improvement notices for minor irregularities. Do you agree with this proposal?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Please explain your answer.
Unsure - it depends what is meant by minor irregularities. Suspension is probably the best of these options as it gives the rescue a chance to remedy any shortcomings in duty of care without having licenses revoked, which may require a big financial input to resolve.

16. The Scottish Government proposes to adopt welfare standards based on those published by the Association of Dog and Cat Homes that all licensed animal sanctuaries and rehoming organisations should follow for the species they hold. Do you agree that this should be a condition of licensing?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
If you are aware of any other relevant standards please comment.
I think that welfare scientists and veterinary bodies should be consulted to review these standards in the context of licensing rescue/rehoming organisations. Welfare knowledge is continually changing and expanded upon, as is knowledge of shelter medicine.

17. Do you agree that appropriate fixed penalties should apply for minor non-compliance with the legislation?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
I think charges should be on an appropriate scale in line with the severity of non-compliance as it applies to the welfare of the animals.

About the consultation

1. Are there any other measures you consider should be included in legislation for animal sanctuaries and rehoming activities in Scotland?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
Particularly in the case of rehoming organisations, I think that outcome measures ie success of rehoming, rate of return to rehoming center, etc should be measured. If there is evidence of consistent behavioural problems in rehomed animals, it is worth considering evaluation of psychological effects of the premises.

I think that behavioural needs are important to emphasise with regards to regulation and legislation, but easily overlooked.

2. Do you consider that that consultation explained the key issues sufficiently to properly consider your responses?

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Radio button: Ticked Yes
Radio button: Unticked No

3. Do you consider that you had sufficient time to respond to the consultation?

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Radio button: Ticked Yes
Radio button: Unticked No

About you

Are you responding as an individual or an organisation?

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(Required)
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