Consultation Draft
Dear DEPI,
I have read the draft Code of Practice for the Operation of Breeding and Rearing Businesses,
Revision 1, July 2013 and have the following concerns:
Page 1:
“The code is mandatory for all breeders with 3 or more fertile female dogs or cats that are not
currently registered members of an Applicable Organisation”
This exception from the code includes backyard breeders which cause a lot of damage and
overproduce cats and dogs. Please amend the code to include ALL breeders regardless of size or
affiliation with an organisation.
“Greyhound (boarding, training and breeding) businesses are exempt from this code; but must abide
by the Code of Practice for the operation Greyhound Business.”
Please include in this code the greyhound industry- it is a self-regulated industry and has its own
code however it is does not protect the animals enough.
Page 2:
Definition of Beds:
‘the major component must not be made of concrete or metal’
Please amend to state that no concrete or metal must be used in animal beds
Page 6:
2) Staffing
2 (1) Proprietor responsibilities
Please add that the proprietor is also responsible for the re-homing of all healthy animals once
he/she is finished making good money out of them.
2 (2) Operations Manager responsibilities
Please define ‘removal’ of animals from the breeding/ rearing operation that have been deemed not
fit for the breeding purposes. If removal means euthanasia, please change this. An unfertile animal
still makes a wonderful pet and can be re-homed. Euthanasia must not be taken lightly.
Page 7:
2 (3) Veterinary Practitioner
Please include in this section that the vet is responsible for deeming an animal fit for sale. If this is
left to the owner of the business, too many sick and unsuitable animals enter the market. It should
be the duty of a vet to determine the suitability not just for breeding and rearing but also the
suitability to be sold.
Page 9:
2 (6)
The staffing ratio is too large-how is one expected to look after 25 animals at the same time? Please
increase staff during business hours and night time to attend to the animals correctly.
Page 11:
2 (10) Euthanasia
“The preferred method of euthanasia is barbiturate overdose, which must be carried out by a
veterinary practitioner. “
Please amend so that the ONLY method of euthanasia is barbiturate overdose. Otherwise the
shooting, drowning, clubbing etc. of puppies, kittens, adult dogs and cats will continue. Please also
put appropriate checks in place to ensure the breeders obey this requirement.
Page 19:
5 (3) Breeding
“Second degree matings (for example, grandfather and granddaughter) are not recommended
without appropriate prior expert advice.”
Please make it illegal to breed with such closely related animals.
Page 20:
5 (3) (c) Breeding Females
“Female dogs must be at least 12 months of age prior to their first mating.”
Please also include an age limit to the life of a breeding animal, i.e. no female over the age of 6
should be allowed to be bred with,
“A female dog must have no more than 6 litters in her lifetime”
Please decrease the litter size to 4
Page 26:
5 (5) (c) Tethering
“Dogs must be tethered in accordance with the Prevention of Cruelty to Animals Act (1986)”
No tethering must be allowed- working dog or not, it is not appropriate to tether a dog even if in line
with the Prevention of Cruelty to Animals Act (1986). The Act states that you can tether a dog for 22
hours at a time provided you allow it to be untethered for 2 hours. This is unacceptable!
Page 28:
Table 5 and 6: Minimum pen sizes
The pen sizes are too small and need to be doubled.
Page 29:
“The entire pen floor must not be constructed of wire, allowed to remain muddy or sufficiently dusty
that the dogs are likely to or are suffering from respiratory or eye conditions. “
Please do not allow wire pen floors! If you have to allow them, please specify how much floor space
can have wire- e.g. 20%
Page 30:
“The pens and flooring of the pens must be of a design that will not cause injury to the animal.”
Wire flooring does not cause injury? As per the comment above, it must not be allowed.
Page 32:
“Exercise areas must be physically separated from housing pens except where the housing pens are
at least as large as the minimum pen size plus 20 sq m for each dog housed in the pen.”
No exceptions. The housing and exercise area must be separate at all times to allow sufficient
stimulation and exercise for the dogs.
Page 33:
Same concerns as above for working and guardian dogs
The code also needs to be enforced with sufficient human resources in place to inspect puppy farms
regularly. Otherwise this code means nothing.
Kind regards,
Name:
Postcode:
Date: