Dear Pet Industry Federation (PIF),
Your recent report in Pet Trade Xtra and Ideas 4 Pet Retail (12 March 2015) gives only a brief overview of the requirements of PIF's new Quality Assurance Standard for the Sale of Puppies in Pet Shops.
You will hopefully be releasing the full criteria for scrutiny, especially as you are anticipating that "other stakeholder groups will be encouraged by this initiative."
However, solely on the basis of the statements made in the report, this Standard is not going to make any radical demands on third party vendors, and sadly seems unlikely to improve animal welfare standards either.
Furthermore it seems to reflect PIF's complete failure to grasp that the outdated practice of selling puppies in pet shops is inconsistent with the unanimous basic advice for buyers (from RSPCA, Dogs Trust, Battersea Dogs & Cats Home, The Kennel Club, PDSA, DEFRA, etc) to always see the puppy interacting with its mother.
You claim this Quality Assurance measure will ensure the "highest standards" are reached by pet shops but you do not appear to recognise that these ought to apply to the entire supply chain rather than just the sale premises - which rarely provide for the young puppy's emotional and developmental needs.
The primary areas of concern relating to the sale of puppies through pet shops are:
- Puppies bred in high volume, low welfare commercial breeding establishments, e.g. puppy farms
- Puppies separated from their mothers at too early an age (improperly weaned/socialised)
- Buyers having no opportunity to see puppies with their mother
- Puppies being transported over long distances in unsuitable conditions
- Risk of disease and health problems through poor breeding practices; conditions at the breeding establishment; stress resulting in compromised immune systems; inadequate biosecurity both in transit and on sale premises
- Lack of socialisation and habituation (throughout supply chain) necessary to ensure puppies are fit for purpose as family pets
- Conditions on premises unsuited to meeting welfare needs of puppies as outlined in Animal Welfare Act 2006
- Impulse purchasing
- Unsold puppies
Sadly your 'Quality Assurance Standard' does not seem to satisfactorily address any of these concerns.
The main precautions are stated as "systematic checking and cross-checking of paperwork, premises and puppies." Surely PIF is aware this is already a licensing condition for most local authorities?
The report goes on to briefly mention puppies will be:
- At least eight weeks old or over - is this when they leave their breeding establishment or at point of sale? If the latter then you'll be aware this is no improvement on current practices.
- Only sourced from licensed UK-only breeders - this is far from sufficient to ensure puppies are sourced responsibly. Some licensed breeders have standards that barely meet the licensing criteria and fall well short of the requirements of the Animal Welfare Act 2006.
The pet shop demand for puppies sustains establishments that breed puppies in large quantities with minimal costs which inevitably results in low standards of welfare. This is the generally accepted definition of a 'puppy farm', and the welfare risks associated with high volume, low budget establishments exist irrespective of whether the establishment is licensed or not.
How therefore can your 'Quality Standard' ensure that breeders supplying pet shops prioritise quality over quantity? By definition, responsible breeders spend time, effort and money rearing their puppies. They are concerned about the future wellbeing of their puppies, will always personally interview prospective owners, and will not supply pet shops.
Additionally the CIEH Model License Conditions (2014) for licensed dog breeders advises "extreme caution" when selling to third parties, e.g. pet shops.
- "UK-only breeders" would of course exclude sourcing puppies bred in the Republic of Ireland.
- Apparently a "respected veterinarian" was consulted during the construction of the audit. As the advice of the veterinary profession is not to purchase a puppy unless it can be seen with its mother, it is hard to understand how any veterinary surgeon could assist in developing a quality standard for a process which is clearly a polar opposite of this guidance.
- "Microchipped, vaccinated, flea-ed and wormed" - Microchipping by the vendor is now becoming the normal process. The single dose Parvovirus vaccination is currently used by most third party vendors so would your Standard now require the full course of vaccination? Flea and worm treatment is also already standard practice with most vendors and is basic care rather than welfare.
- "Welfare" means providing for behavioural and emotional needs, but nothing in your report indicates the Standard covers these.
Of the other "welfare requirements" listed:
- Imposing a "three day wait between viewing a puppy and its purchase" - this is probably the only meaningful improvement that your Quality Standard might bring and potentially may prevent some very spur of the moment or ill-thought out purchases. Out of interest would the three days be inclusive of the viewing and purchasing days?
- "Interviewing the new owner" - a proactive move but only if the sale would be refused if the circumstances are unsatisfactory! If this is the case, what criteria will be used to determine client suitability and will this be decided by PIF, the vendor, or the sales person? In particular, it would be interesting to hear how pet shops might be persuaded to lose money by declining sales and holding onto growing puppies until the right home comes along, which responsible breeders and rescue centres have no hesitation in doing.
- "Puppy Sale Contract" - most third party vendors already issue some form of contract but this is mostly a disclaimer with numerous 'get out clauses'. The only appropriate contract would be the BVA Puppy Contract.
- "Pet Store Management qualification" - Most local authorities already require the qualification for new licence applications. It does not however ensure the vendor has appropriate knowledge of the care of dogs in general or of the specific requirements and traits of individual breeds or cross-breeds offered for sale. This also makes no provision for ensuring all staff members are trained to an acceptable standard and have a sufficient depth of knowledge on puppy care, which is very important if they are involved in sales.
- Your CEO Mr Baker stated in October 2014 that five PIF members were selling puppies and the report reveals that some have left PIF rather than comply with the audit requirements. It is concerning rather than unfortunate that these businesses are not prepared to sign up to even these minimalistic demands and it would be interesting to know how many pet shops have been forced to leave PIF membership. If their reluctance to improve reflects the attitude of the whole industry, then the Audit is less "enormous step" than shuffling limp and any positive impact is going to be minuscule. Has this supposed move towards 'highest standards' gained any new members for PIF?
In respect of illegal importation of puppies, PIF will surely be aware that the only legal outlet for puppies imported into the UK, complete with "increased rabies risk", is in fact through a licensed pet shop. The most efficient means of reducing imports is to remove the legal outlet thereby instantly reducing the scale of the problem, disease risk to humans and other animals, and making illegal imports easier to identify, so action can be taken.
The final comment in your report appropriately relates to enforcement - although it isn't at all clear where you feel this is needed. This Standard doesn't impose draconian restrictions and with potentially fewer than five remaining members, it shouldn't require any onerous inspection burden, but you have been decidedly taciturn about the enforcement measures that you intend to use to ensure adherence.
The only conclusion that can be drawn from this latest PIF development is that far from being an "enormous step forward in the debate about puppy sales" you are simply demonstrating an ongoing refusal to accept that it is impossible to improve the sale of puppies in pet shops to a point where it becomes acceptable and does not negatively impact on animal, or indeed human, welfare.
Marc Abraham BVM&S MRCVS, Founder PupAid
Julia Carr BSc (Hons), Founder Canine Action UK.