We are writing on behalf of Bide Awhile Animal Shelter Society to express our thoughts
on the Draft Standards of Care for Cats and Dogs, dated February 27, 2014. Those
writing this statement are Bide Awhile Board of Directors members, including its
President and the Executive Director of Bide Awhile. We speak on behalf of the entire
Board, and more importantly, we speak on behalf of those who cannot speak for
themselves - the abused, neglected, homeless and abandoned domestic animals of this
province.
We applaud the Minister of Agriculture for bringing public awareness to the issue of
cruelty against and abandonment of cats and dogs, and for taking much-needed steps to
improve the situation of domestic animals in Nova Scotia. We feel, however, that until
the issues outlined below are addressed, these contemplated changes fall short of their
goal.
It is commendable that cats have been included in the definition of ‘animal’ within the
draft standards, and we feel this is long overdue. We would, however, recommend the
definition of ‘animal’ for the purposes of these standards be broadened to include all
companion animals. We suggest the definition of ‘animal’ be widened so as to take
account of “domestic companion animals, including, but not limited to, cats and dogs.”
In order for standards of care to be effective and enforceable, they must be specific and
quantifiable. Ambiguities in wording must be minimized where possible, and examples
of key concepts provided, in order to guide the interpretation and enforcement of the
standards, and the prosecution of offenders. We feel a number of key concepts within the
draft standards of care are lacking the specificity required to meet these objectives,
including:
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section 3, bullet 5: “prompt and adequate veterinary care”
section 3, last line: “An animal must not be abandoned or left on its own in
hazardous conditions that cause distress.”
Section 4, first line: “…such that the animal is adequately protected from the
weather conditions to which it is exposed.”
While there are several other such examples contained in the draft standards of care, we
feel that these statements best exemplify areas where interpretations of clauses could vary
widely. The meaning of these phrases is unclear, and as such they do not provide enough
guidance to animal owners or enforcement officials in making determinations relating to
the ‘minimum standards’ referred to in the draft.
Widening the definition of ‘animal’ to include all companion animals, and increasing the
clarity of concepts and minimum requirements within the standards of care, could greatly
improve the usability of same. However, we feel that until the province of Nova Scotia
places a stronger emphasis on enforcement of animal protection laws, any attempts at
reformulating the legislation will fail to have an impact. Without strong, consistent
enforcement of animal protection laws – and subsequently, prosecution and punishment
of offenders – the changes contemplated in the draft standards of care will be
ineffectual. The Animal Protection Act (2008) is already in place with the goal of
protecting animals in this province; however, enforcement of the Act is inadequate.
Further to this point, there are no procedures in place through which owners who
abandon their companion animals can be identified or shown to in fact be responsible for
the abandoned/neglected animal. A system, such as mandatory micro-chipping, through
which animals can be identified and linked to the persons responsible for them would
greatly improve the ability of enforcement officials to perform the duties necessary to
bring these people to task for animal abandonment and cruelty.
Until such time as sufficient resources to monitor and ensure compliance with animal
protection legislation are provided, we feel that changes to the wording in the Act and
related regulations and standards, while significant, do not fully address the problem at
hand.
We do thank you for expanding the definition of ‘animal’ within the draft standards, to
include cats and encourage you to consider widening the definition further to provide
protection to all companion animals.
Bide Awhile remains committed to helping abandoned and neglected animals in any way
we can, and as part of this commitment, we wish to express our willingness to participate
in any consultative process relating to these standards and related legislation, and the
strengthening of protections for animals in Nova Scotia in general. We appreciate your
consideration of our thoughts and look forward to the implementation of stronger animal
protection laws and enforcement in Nova Scotia.