Dear Mr Cavill,
Response to David Cavill, Our Dogs Newspaper, Speakers Corner, May 19th 2015.
We read with interest your response to our open letter to the Pet Industry Federation published in the Huffington Post on 25th March 2015, and would like to reply to some of the points you raise.
It's very disappointing you feel the PupAid petition was never up for serious consideration, especially given the turnout of MPs for the debate. Certainly a ban on the sale of puppies and kittens through pet shops is feasible, manageable, and enforceable - much more so than endless attempts to bring in stricter controls that require costly and more difficult enforcement.
The lack of immediate activity from the Government is likely due to priority focus on the impending election and a general reluctance to amend legislation if it can possibly be avoided, but that is not to say it won't act.
You describe the Pet Industry Federation as a trade body representing the interests of the pet industry and go on to say it was not set up to protect its members but the welfare of pet animals. This is encouraging as it would suggest the focus is in the right area, even if representing the industry implies protecting members' interests against external intervention.
Educating the public through its charity is also a wholly commendable objective and certainly we can agree that the Animal Welfare Act 2006 would be a powerful tool indeed if it had a statutory duty of enforcement.
You rightly highlight the contribution from the Pet Industry Federation in developing the latest CIEH Model Conditions for Pet Vending Licensing, which have to be considered an improvement on the minimal provisions of the Pet Animals Act 1951, although they are not intended as a substitute for secondary legislation. It is necessary to mention however, that less than 28% of local authorities were using the 2013 version in 2014.
Apparently Pet Industry Federation now has eight members that are selling puppies, rather than the five mentioned by its CEO Nigel Baker in October. It appears that in the intervening five months, Pet Industry Federation has gained more new members than have been relinquished because they did not meet the criteria of the new Audit.
Hopefully the Pet Industry Federation will now proudly disclose the names of the commendable outlets that are so committed to doing the right thing they have joined Pet Industry Federation to support the scheme.
It would be very peculiar if, having publicised this measure and awarded businesses an approved status, Pet Industry Federation does not decide to reveal who these members are, so buyers can make an informed choice without extensive investigations. (Although if they are prepared to go to those lengths then what on earth are they thinking of buying a puppy though a pet shop anyway?)
You assure us that Pet Industry Federation has long stated it would prefer that puppies and kittens are not sold in pet shops, but sadly we have not been able to find any evidence of this. Rather to the contrary there is the very recent assertion from Mr Baker that "the sale of puppies in pet shops is acceptable if it is done well."
Far from disapproving of the practice and reluctantly issuing guidance, Pet Industry Federation appears to come out strongly in favour of the trade continuing and confers its approval on premises by awarding a stamp of 'Quality Assurance'.
It is this continued insistence that there is nothing wrong with removing puppies from the place of their birth, transporting them usually over long distances and selling them through third party outlets that has singled out Pet Industry Federation for condemnation.
None of the organisations you mention have 'demanded' pet shops do anything other than the law requires but they are in agreement that the law is desperately outdated and in need of revision to recognise this method of selling dogs is no longer appropriate. It is not even a question of doing it 'our way'.
The basic advice to always see a puppy interacting with its mother is both longstanding and widespread, shared and promoted by every responsible animal welfare organisation in the UK - even DEFRA's own guidelines recommend this simple rule to make sure prospective puppy buyers make the best, informed choice.
Why should the onus be placed on the public to follow best practice and discriminate with limited knowledge between the profusion of puppy sellers? Should they try to do the right thing they can still be mislead and deceived, even and particularly by outlets which are supposedly 'licensed and regulated' and therefore perceived to be trustworthy?
Why should 'bad' options that are well recognised as such be permitted to persist and remain as pitfalls and traps for the unwary? This is not a game. The lives of animals are at stake and the distress of those families who unwittingly purchase a sick puppy from a seller they put faith in should be more than compelling enough to see that owners need protection as much as puppies and breeding dogs.
A ban on the highest risk sellers, resulting in impulse purchases (likely influencing rising levels of abandonment and therefore increasing numbers of rescue dogs) would be simple and cheap to enforce and immediately improve welfare.
"Marc ends his open letter by saying that Pet Industry Federation is simply demonstrating 'an ongoing refusal to accept that it is possible to improve the sale of puppies in pet shops to a point where it becomes acceptable'. I do not agree." We wondered if this mis-quote was in fact deliberate?!
The accurate quote is of course that "it is impossible to improve the sale of puppies in pet shops to a point where it becomes acceptable." If only Pet Industry Federation were refusing to accept that it was possible to improve third party trade in puppies - it would be a much bigger step forward than their Quality Audit.
Freedom to trade is certainly the issue at stake and there are endless examples of bans on the sales of certain goods or goods sold in a certain way to refute your pessimistic view that legislation on the trade in dogs will not change.
Regional administrations in America and Australia are setting an inspiring precedent by restricting and prohibiting the third party trade in puppies, so a ban in the UK is certainly a realistic and achievable prospect.
It would progress even faster if Pet Industry Federation were to actually stand by their supposed aim of 'promoting excellence' and join us in calling for a ban, because 'excellence' and the continued sale of puppies through pet shops will forever be mutually exclusive.
You continue by stating there are not enough responsibly bred puppies to meet demand. This is a very questionable point. The 'demand' for puppies - the perceived right to buy a dog immediately without planning or preparation - results in the deaths of hundreds of dogs each year in the UK, largely because they are unwanted or have been so badly abused they are not re-homeable.
Perhaps if puppies were harder to obtain then more thought would go into a) the process and we would not have such a problem, and b) more rescue dogs would be considered for adoption? Your statement suggests that there are only a finite number of responsibly bred puppies to go around and this raises the unhappy question of tiers of dog ownership.
Should there be a recognition that some buyers cannot have the 'Finest' range of puppy (due to limited availability) and these unfortunate souls should resign themselves to a lesser quality 'value range' puppy?
These kind of distinctions are fine for groceries but we shudder to apply them to pet dogs. Surely it is not a puppy buyer's right to have a huge range of available puppies, but instead to expect that any puppy they can buy has been bred responsibly and sold honestly, even if this does not mean instant gratification?
David the crux of the matter is simple. Can pet shops sell puppies well, meaning to at least the same standard as puppies sold directly from the breeder's home, and with no detrimental impact to their welfare? No they cannot. Unequivocally they cannot. Possibly and hypothetically it could be done to significantly minimise the negative implications, but such measures would be so onerous that it would be implausible for a business.
It matters not how scrupulously clean the premises are, or how big the pens or how meticulous the record keeping. Puppies sold through third parties are not well-reared, balanced potential family pets. They are simply livestock. No decent breeder is going to invest time, effort, and money into breeding and rearing healthy, well-adjusted puppies only to pass off all responsibility for their future welfare and sell them for a fraction of their worth to a third party.
The façade of the pet shop (in whatever context) serves only to conceal the unpalatable practices of those irresponsible breeders who care nothing for either their puppies, their puppies parents, or the people who buy them.
Marc Abraham BVM&S MRCVS, Founder PupAid
Julia Carr BSc (Hons), Founder Canine Action UK