THE BLOG
16/10/2015 12:14 BST | Updated 15/10/2016 06:12 BST

Why Does the Pet Industry Federation (PIF) Continue to Withhold Public Information?

When an organisation publicly and specifically encourages constructive engagement, then continues to ignore polite and reasonable requests for information, it demonstrates a distinct unwillingness to cooperate.

We were therefore relieved when Pet Industry Federation (PIF), the only organisation resisting a ban on the sale of puppies in pet shops, finally broke their silence, responding with their own open letter to our Huff Post blog.

However relief turned quickly to disappointment when we realised that within four pages of their reply, PIF still withheld public information we and many others had asked for - namely the criteria for their Quality Audit and identity of members that have successfully passed.

In fact PIF's letter did nothing more than criticise the manner in which the subject had been publicly broached and restate the same points PIF previously made. No explanation was forthcoming as to why PIF were not releasing the same details for their Puppy Vendor Audit as are freely available for their comparable, and well respected, Groomers' scheme.

Faced with this stolid and somewhat condescending reply, the question still on everyone's minds is how can an 'industry' that appears to be responsible for inflicting such cruelty and misery on dogs possibly continue to be regarded as legitimate?

With no statutory duty on councils to enforce the Animal Welfare Act 2006, even when clear breaches are apparent, exposing and closing down all breeders and sellers operating with poor standards is sadly easier said than done.

And it's because our laws are so weak it's often impossible to get action taken, which is why we're also relentlessly campaigning for change in legislation and encourage PIF to give us their support.

As a matter of courtesy we gave PIF ample opportunity for honest, transparent dialogue about their Quality Audit, but as this was not taken up, we believe it entirely appropriate that this important subject is debated openly and in full view of the public.

Apart from dogs, the biggest stakeholders in this situation are puppy buyers. They have the right to expect that the puppy they purchase is responsibly bred and fit for purpose as a family pet; and our intention is always to raise awareness so that prospective owners are able to make informed choices.

This is also clearly a matter of significant public concern, as evidenced by the level of discussion on social media with this issue gathering momentum by the hour through reasoned, clear presentation of the facts; facts that PIF seem unable to refute.

Attack seems to be PIF's preferred method of defence rather than answering questions. In his reply, Nigel Baker, PIF's CEO continues to insist PupAid's campaign has changed tack, that selling puppies without their mothers being present is a separate issue from banning the sale of puppies in pet shops.

Any circumstance where puppies are legally sold away from their mother and place of birth is almost certainly going to be through a pet shop; the focus of PupAid's campaign has not altered. Frankly it is becoming rather tedious to keep pointing this out as Mr Baker has yet to clarify why he perceives there to be a difference.

Additionally his suggestion that a ban would increase potential of rabies outbreak is entirely unfounded. We have patiently reminded PIF (on numerous occasions), that as the only legitimate outlet for commercially imported puppies is through a licensed pet shop, a ban would significantly reduce if not almost eliminate flow of puppies entering the UK from Eastern Europe.

It is important to clarify at this point that the term 'pet shop' is highly misleading as our research shows most premises selling puppies are actually private rather than traditional retail premises. The Pet Animals Act 1951 defines a pet shop very specifically: "The carrying on at premises of any nature (including a private dwelling) of a business of selling animals as pets".

The fact that farms, riding stables, and residential homes can all be licensed as 'pet shops' means identifying 3rd party vendors becomes all but impossible for consumers. Mr Baker makes frequent reference to pet shop regulation but attempting to regulate the immense variety of premises that now sell puppies using the same basic parameters that apply to pet superstores and aquatic centres is never going to be effective.

Even the most recent CIEH Model Guidelines for Pet Vendors (2013) does not have sufficient scope to encompass all of these situations and the outcome is that puppies' needs - especially in terms of emotional development - can't ever be met.

This is of considerable concern as no other pet animal has such particular requirements for appropriate socialisation and failure in this area poses risk to dogs, future owners, and society in general.

Regulation also doesn't even hint at ensuring animals have been bred and reared to appropriate standards. Like PIF, the most recent version of Model Guidelines continues to perpetuate the myth that animals mysteriously appear in pet shops and the aspect of sourcing 'stock' is conspicuously absent.

We've repeatedly asked PIF to explain how pet shops might obtain puppies from responsible breeders but of course PIF has not even attempted a response, as by definition this is impossible; pet shops do not obtain their puppies from responsible breeders.

Decent, ethical breeders that have reared puppies well, care about the lives they've created and would never contemplate selling through a 3rd party agent e.g. pet shop.

Mr Baker also claims that PIF "are and have always been against puppy farms and commercial breeding where welfare, as set out in the Animal Welfare Act 2006, is compromised."

The huge pet shop demand for puppies sustains establishments that breed puppies in large quantities with minimal costs. Inevitably this results in low standards of welfare and is the generally accepted definition of a 'puppy farm.'

These establishments must produce and sell large numbers of puppies to survive but do not have a sufficient customer base due to poor conditions and geographical location. As a result they depend on selling to pet shops.

The baseline is that pet shops and intensive, low welfare breeding establishments are intrinsically linked as they need and support each other. Banning the sale of puppies in pet shops would greatly reduce, if not almost eliminate, the need for 'puppy farms' to exist.

It may not mean that all puppies are bred responsibly but it will mean that there is no legally sanctioned market for puppies bred in circumstances which have the highest risk of poor welfare.

Forcing breeders to sell directly to owners would improve transparency and traceability, therefore a ban on pet shop puppy sales is the most effective solution to improving welfare..

It is unnecessary to set out precise parameters defining a 'puppy farm' in order to tackle the problem. Mr Baker seems particularly worried that eradicating the pet shop supply might result in insufficient puppies being bred to meet the demand. To this we say surely no one's need for a pet dog is so great that it justifies compromised welfare in the commercial dog breeding industry and necessitates large scale intensive establishments.

Sacrifice immediate availability and unlimited choice, and ensure that every puppy from a licensed breeding establishment has been bred responsibly (and encourage owners to consider rehoming a dog instead).

Yes owners should have the right to buy responsibly bred puppies, but not necessarily the right to (impulse) purchase a puppy immediately so it is certainly not essential that supply of puppies must meet or as is currently the case (with almost 5,000 healthy 'surplus' dogs destroyed last year), exceed demand.

If it's possible to make a commercial success of breeding dogs responsibly, this can only be achieved by selling directly to consumer and investing in the dogs rather than the chain of middlemen siphoning off as much income as possible.

Almost certainly there'll be a limit to the scale of any establishment, beyond which welfare becomes compromised; it's impossible to breed pet dogs intensively and responsibly and the aim must be to ensure that quality is prioritised over (and at the expense of) quantity for all breeders.

Perhaps one of the more disturbing tactics PIF have adopted is to follow the example set by their US counterparts trying to redirect the debate against rescue centres, maybe they view animal shelters as serious competition?

Mr Baker's reasoning is, once again, flawed because genuine rescue centres don't operate as profit making businesses; any rehoming charges are simply to cover overheads, usually dependent upon additional donations.

Too often animal shelters deal with the results of impulse purchases, overbreeding, bad breeding and rearing; heavily reliant upon volunteers and goodwill. Many operate as charities, additionally governed by the rules of the Charity Commission, so not unregulated.

There may be an argument for formal regulation of rescues but the motivation behind rehoming the nation's unwanted animals is so very different from the profit-driven world of pet retail that guidance in the form of a non-statutory code of practice would likely be sufficient control.

It seems apparent Mr Baker believes the aspect of regulation is of paramount importance - but is it? The necessity for and extent of regulation should correlate to the degree of risk posed; it is a waste of resources to try and regulate situations where there is a low risk of causing harm to people/animals/environment etc.

The very reason Pet Animals Act and the Breeding of Dogs Acts exist is because it was recognised that animals in these establishments required official protection. Mr Baker also suggests that non-commercial breeders and rescue centres present a risk to welfare because they are unregulated; however the absence of regulation simply reflects that it is deemed unnecessary because the risk is in fact minimal.

Regrettably regulation of the puppy 'industry' appears to protect businesses of licence holders rather than welfare of the dogs or the interests of those who purchase them. The fact is that regulation in practice means nothing; and the central pillar of PIF's opposition to a ban begins to crumble once again.

PIF is the primary (and essentially only) opposition to massive public appetite calling for a ban on the sale of puppies through pet shops yet Mr Baker is adamant that his organisation does not represent the wider industry.

Mr Baker claims that PIF only represents its (two) puppy-selling pet shop members, but intentionally or not PIF's stance defends the entire industry and whole supply chain from breeders to the point of sale, which is why we we're so persistent in challenging its position.

The only worthwhile piece of information in PIF's four page letter reveals only two of PIF's member pet shops even sell puppies - they also both breed even more dogs; therefore are not solely dependent upon selling bought-in puppies.

On the website, PIF states its combined membership numbers around 1,900 businesses. As less than 0.01% of PIF members would be impacted by a ban on puppy sales we are curious as to why PIF remains so prepared to continue contesting it, even at the risk of losing a growing number of non-puppy selling members strongly disagreeing with PIF's position?

While Industry bodies do exist to represent the interests of their members, surely this tiny faction of two does not merit the effort PIF is expounding to keep the UK's puppy trade legal?

PIF is so inexplicably determined to keep the pet shop trade in puppies going that it has (presumably) devoted time and money to creating a 'Quality Audit' to "outline how puppies could be sold 'well' in a retail environment."(Politics and Puppies).

We were correct in our assumption that the take up on this had been embarrassingly low as it appears that PIF has lost several members who were unprepared to commit to their scheme.

This reflects the general attitude of an industry which seems to prefer to cut corners and lower standards where possible rather than strive for improvement. To be fair there is little incentive for businesses to jump through Audit hoops because far from promoting the remaining two members as examples of their idea of good practice, PIF have consistently avoided revealing their identity - and still do!

This is completely illogical and surely demonstrates developing PIF's Audit was a pointless exercise from both a business and customer relations perspective. Furthermore, PIF's ongoing determination to withhold details of the Audit and names of the accepted member pet shops only serves to reinforce our assumption that PIF is not sufficiently confident to expose criteria or scheme members to public scrutiny; presumably also doing a disservice to those two members by keeping their identity a secret - hardly good for their businesses is it Mr Baker?

It's astonishing that Mr Baker still asks for support in promoting something which his organisation continues to refuse to reveal full details of, insisting his scheme has defined and measurable criteria but how has this been developed - and by whom? What qualifications and experience will the auditors have? Retail? Veterinary? Behavioural?

PIF may be satisfied the audit means their unidentified members are operating above the required standard - without access to that information we are not. Instead of feeling victimised, PIF should welcome this level of interest in the Quality Audit scheme and see it as a positive opportunity to publicly demonstrate improvements they claim to have made rather than fueling suspicions that they've 'something to hide'.

If animal welfare and education is at the forefront of PIF, it must now recognise and incorporate the latest scientific evidence into its ethos, even where this conflicts with established trading models.

Unless PIF is prepared to drop its opposition to a ban, prove publicly it's really against puppy farming, and reveal it's puppy selling members, then there is little point in meeting in private to discuss differences of opinion.

But as campaigners, we are greatly encouraged that Mr Baker now agrees legislation needs updating and finally concedes that our cause is just. We ask PIF to join with us, calling for an urgent review of areas where welfare is most compromised and bring pet retail into a new era.

Marc Abraham BVM&S MRCVS, Founder PupAid

Julia Carr BSc (Hons), Founder Canine Action UK