The Scottish Government has published its analysis of the responses received to the recent consultation on proposals to regulate animal sanctuaries and rehoming centres in Scotland.
The consultation received a total of 185 responses, of which 73% (135) were from members of the public. A further 34 responses (18.3%) were from animal welfare charities, animal sanctuaries and rehoming centres, vets and other professionals, and 16 (8.7%) from local authorities in Scotland.
Like most respondents (98.3% of those who gave a view), OneKind agrees that there is a good case for bringing all animal sanctuaries and rehoming centres in Scotland – other than very small or temporary operations – into a licensing or registration scheme. We know that the vast majority of animal sanctuaries and rehoming centres are set up with the best of intentions and have the care of animals in need as their main focus. Without sanctuaries, many animals would suffer as a consequence of being lost, abandoned, unwanted, old, injured, orphaned or diseased.
But welfare issues can arise when operators become overwhelmed by growing numbers of animals or by lack of knowledge and resources for veterinary care, food and bedding. Regrettably, we know that some people set out to turn the rehoming of animals into a money-making business. And when things go wrong, the consequences for the animals can be severe and can affect a large number of animals. One notable case, some years ago, resulted in 100 cats having to be euthanased on removal from a two-bedroom council house; while the recent shocking case of the Ayrshire Ark involved the appalling suffering and death of a number of dogs whose owners gave them up for rehoming. Some long-established sanctuaries, such as Mossburn Community Farm, said they often had to repair the damage done by badly run establishments.
Respondents were split in their responses to the Scottish Government’s proposal for a ‘tiered’ approach involving licensing for larger establishments and a simpler registration scheme for smaller ones, with 56.8% supportive of the approach and 43.2% of respondents against. Many, including OneKind, felt that it was important not to impose bureaucratic burdens that would discourage small sanctuaries from offering care, but a number of respondents felt that the risks to animals in care were so high that all establishments should have to be licensed.
Assuming that the tiered approach will be favoured, the key issue is where the threshold should lie. The Scottish Government intends that operations caring for 6 – 10 animals at a time/per year should be registered, while operations with more than 11 animals at a time/per year should be subject to a full licensing regime. Smaller operations would be exempt. OneKind and others have pointed out, however, that these thresholds need to be species- (or at least grouping-) specific to be meaningful and appropriate. As South Lanarkshire Council put it, “5 rabbits would be on a different scale to keeping 5 horses for rehoming.”
OneKind also drew attention to the difference between caring for 10 cats or dogs in the course of a year and caring for 10 cats or dogs at any one time, and asked for the question of ‘throughput’ to be reconsidered.
Responses also varied on the proposal for licensed premises to be inspected by expert independent bodies, such as the Scottish SPCA, in addition to local authorities.
Of the 169 respondents who answered this question, 64.5% favoured the Scottish Government’s proposals but a surprisingly large 35.5% did not. Many incorrectly assumed that the Scottish SPCA would be expected to ‘police’ their own locations. The Scottish Government has now clarified that it does not intend the Scottish SPCA to be responsible for inspecting its own premises – this duty would be carried out by other independent experts and local authorities. The Scottish SPCA agrees with this approach, stating in its response, “…obviously the Scottish SPCA could not inspect or license our own premises.”
Similarly, on a question about enforcement by Scottish SPCA Inspectors, there were differences of opinion and – so it seems to OneKind – a degree of misunderstanding. Some respondents appeared to think this question was also about licensing inspections, and indeed some local authorities were concerned about being ‘undermined’ by the use of non-council staff to carry out regulatory functions. In fact, the Scottish SPCA already has enforcement powers under the Animal Health and Welfare (Scotland) Act 2006 (the Act under which the new regulations will be made) and it seems sensible that they should be harnessed in this way, rather than adding an additional burden to already-stretched councils.
Another area of concern to respondents was the narrow focus of the consultation, which appears to concentrate on dogs and cats with little consideration of other pets, livestock and wildlife. A proposal to base animal welfare standards on those published by the Association of Dog and Cat Homes drew a good many comments about the need to provide more specialist standards for other types of animals. Despite this the report concludes, perhaps slightly simplistically, that ‘a sizeable majority’ have agreed with the basic proposal.
OneKind looks forward to seeing how the Scottish Government will resolve a number of the questions that remain after this consultation exercise. Detailed work is required to establish different numerical thresholds for registration and licensing, as well as welfare standards appropriate for the wide range of needy animals in Scotland. Regulating sanctuaries and rehoming for dogs and cats may appear relatively straightforward – but for other species, different approaches still need to be explored and more discussion will be required.